United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
(2251A)
EPA/315/B-98/Q05
November 1998
www.inece.org
MULTIMEDIA INSPECTION
PROTOCOLS: INTERNATIONAL
EXAMPLES
Capacity Building Support Document
For Environmental Compliance And
Enforcement Programs
ENVIRONMENTAL
LAW-INSTITUTE
Ministry of Housing,
Spatial Planning,
and the Environment
(VROM) The Netherlands
Environment Environnement
Canada Canada
EUROPEAN
COMMISSION
POLLUTION CONTROL DEPARTMENT
THAILAND
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Multimedia Inspection Protocols
International Examples
August, 1998
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Multimedia Inspection Protocols
TABLE OF CONTENTS
PREFACE iii
ACKNOWLEDGMENTS v
EXECUTIVE SUMMARY vii
1 INTRODUCTION 1-1
2 WHY CONDUCT MULTIMEDIA INSPECTIONS 2-1
2.1 ENHANCED COMPLIANCE/ENFORCEMENT PRESENCE 2-2
2,2 IMPROVED ENVIRONMENTAL RESULTS 2-3
2.3 POTENTIAL FOR INCREASED EFFICIENCY 2-5
2.4 ENHANCED COMMUNICATIONS WITH REGULATED
COMMUNITY 2-5
3 APPROACHES TO MULTIMEDIA INSPECTIONS 3-1
3.1 TYPES OF ASSESSMENTS CONDUCTED DURING MULTIMEDIA
INSPECTIONS 3-2
3.1.1 Compliance Assessment 3-2
3.1.2 Environmental Assessment 3-3
3.1.3 Compliance Assistance/Technical Assistance 3-4
3.2 APPROACHES TO CONDUCTING MULTIMEDIA INSPECTIONS ... 3-4
3.2.1 Multimedia Screening 3-5
3.2.2 Team Inspections 3-7
3.2.3 Consolidated Inspections 3-7
3.2.4 Process and Prevention Inspections 3-8
3.3 FACTORS TO CONSIDER IN SELECTING MULTIMEDIA
INSPECTION APPROACHES 3-9
3.3.1 Programmatic Factors 3-9
3.3.2 Resource Commitments 3-10
3.3.3 Site-Specific Circumstances 3-10
3.3.4 Use of Multimedia Inspections 3-11
4 CASE STUDIES 4-1
4.1 UNITED STATES 4-1
4.1.1 Screening Inspection Program Developed by United States
Environmental Protection Agency 4-1
4.1.2 National Enforcement Investigations Center Approach to
Multimedia Team Inspections 4-2
4.1.3 Consolidated Inspection with Compliance Assistance—City of
Santa Rosa, California 4-2
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4.1.4 Mixed Approach: Facility-Wide Inspections to Reduce the Source
of Toxics 4-3
4.2 UNITED KINGDOM INTEGRATED POLLUTION CONTROL
APPROACH 4-5
References 4-5
APPENDIX A—General Multimedia Screening Checklist (Based on United States
Environmental Protection Agency Version) A-l
APPENDIX B—Example Process Model for Process-Based Multimedia Inspections B-l
APPENDK C—Example Questions from the United States Environmental Protection
Agency and Massachusetts Department of Environment Facility-Wide
Multimedia Inspection Program C-l
APPENDIX D—Example of Multimedia Checklist for Printing Operations
Incorporating Pollution Prevention D-l
LIST OF EXHIBITS
Exhibit 2-1. Benefits Generally Associated with Single-media and Multimedia
Inspections 2-2
Exhibit 3-1. Types of Assessments Conducted during Multimedia Inspections 3-3
Exhibit 3-2. Relative Advantages Among Approaches to Multimedia Inspections 3-6
Exhibit 3-3. Focus of Multimedia Inspections 3-13
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PREFACE
This document, Multimedia Inspection Protocols, was originally prepared in 1996 as one of five
Environmental Compliance and Enforcement Technical Capacity Building and Technical Support
documents prepared to support the Fourth International Conference on Environmental Compliance
and Enforcement held in Chiang Mai, Thailand, April 22-26, 1996 and ongoing international
networking and capacity building under the auspices of the International Network for Environmental
Compliance Enforcement. It was maintained as a pre-publication draft to accommodate additional
country examples. This final version has been updated for use at the Fifth International Conference
in Monterey, California, November 16-20,1998 along with several new capacity building documents.
It includes information on one additional country program but is not substantially changed from the
version previously distributed to participants at the Fourth International Conference. These
documents are prepared as resource documents to be used by government officials and others who
have responsibility for developing or enhancing environmental compliance and enforcement programs.
The documents include:
• Financing Environmental Permit, Compliance and Enforcement Programs
• Source Self-Monitoring, Reporting, and Recordkeeping Requirements: an
International Comparison
• Multimedia Inspection Protocols: International Examples
• Communications Strategies for Enforcement Programs
• Transboundary Trade in Potentially Hazardous (Waste, Pesticides, and Ozone
Depleting) Substances
• International Inspector Training Compendium, Course and Program Comparison
• Country Progress/Self Assessment Reports on Environmental Compliance and
Enforcement
• Citizen Enforcement: Tools for effective participation
Consistent with the goals of the Executive Planning Committee for the Fourth and Fifth International
Conferences and the ongoing goals of the International Network for Environmental Compliance and
Enforcement to build capacity internationally for environmental compliance and enforcement, this
document addresses key aspects of how and why to incorporate multimedia inspections as a
component of a compliance monitoring program.
Environmental control programs are often directed at a particular environmental medium, that is
water, air or land. Consequently, it is not surprising that compliance monitoring and enforcement
programs have generally directed that compliance inspections be conducted on a media-specific (that
is, single-media) basis. In a multimedia or integrated inspection,1 the regulatory authority evaluates
a facility's overall compliance with environmental control programs, rather than assesses its
1 A multimedia or integrated inspection approach can involve assessing compliance by focusing on different
areas or issues. For example, a multimedia inspection can involve assessing compliance across all program
areas for one type of industrial operation or it may focus on one group of pollutants (for example, volatile
organic compounds).
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compliance on a media-specific basis. In addition, multimedia inspections may address environmental
performance issues, such as the evaluation of pollution prevention opportunities, that offer
environmental benefits in excess of that required by statue or regulation.
This document presents key factors that program managers should consider prior to adopting
multimedia inspections into an overall compliance monitoring program. As described within, there
have been a variety of approaches for conducting multimedia inspections. Selection of an appropriate
approach understandably depends on the regulatory program's purpose for conducting a multimedia
inspection, the size and complexity of targeted facilities, the expertise and training of the inspectors,
the time allotted for conducting the inspection, and other factors. Government officials can use the
information provided in this document as a reference for designing a multimedia inspection program
appropriate within an overall compliance monitoring framework.
Multimedia Inspection Protocols and the other documents listed above are available on the
International Network for Environmental Compliance and Enforcement's (INECE) Internet site:
http://wwwAnece.org. They also are available from the INECE Secretariat at the addresses below.
Finally, the INECE Secretariat seeks your comments as to whether these documents serve their
intended purpose and how they might be improved. Please send comments in writing to the INECE
Secretariat in care of Ms. Wasserman or Mr. Gerardu at the following addresses:
Ms. Cheryl Wasserman
Associate Director for Policy Analysis
Office of Federal Activities
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M Street MC 2251-A
Washington, D.C. 20460
FAX 1-202-564-0070
PHONE 1-202-564-7129
E-MAIL wasserman.cheryl@epa.gov
or
Mr. Jo Gerardu
Head, Strategy, Planning and Control Division
Inspectorate for the Environment
The Netherlands Ministry of Housing, Spatial Planning and the Environment
IPC680
P.O. Box 30945
2500 GX Den Haag
The Netherlands
FAX 1-31-70-339-1300
PHONE 1-31-70-339-2536.
E-MAIL gerardu@IMH-HI.dgm.minvrom.nl
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ACKNOWLEDGMENTS
This document was developed with the support of Science Applications International Corporation
under United States Environmental Protection Agency Contract 68-W2-0026, Work Assignments
39-nand39-m. Technical direction was provided by Ms. Cheryl Wasserman of U.S. Environmental
Protection Agency's Office of Enforcement and Compliance Assurance, in cooperation with
Executive Planning Committee members from The Netherlands and other countries, each of whom,
along with their governments or organizations, must be recognized for their support in reviewing and
commenting on the draft outline and early drafts of the document.
Dr. Adegoke Adegoroye, Federal Environmental Protection Agency, Nigeria
Ms. Jacqueline Alosisi de Larderel, United Nations Environment Programme
Mr. Antonio Azuela, Office of Attorney General for Environmental Protection, Mexico
Ms. Susan Becker, United Nations Development Programme
Mr. Christopher Currie, Environment Canada
Mr. William Eichbaum, World Wildlife Fund
Dr. Ossama El-Kholy, Egyptian Environmental Affairs Agency
Mr. Marius Enthoven, European Commission
Mr. J. William Futrell, Environmental Law Institute
Mrs. Vivianne Blanot, National Commission on the Environment, Chile
Mr. Marco Antonio Gonzalez Salazar, Department of Natural Resources, Energy, and
Mines, Costa Rica
Dr. Francois Hanekom, Ministry of Environmental Affairs and Tourism, South Africa
Mr. Steven A. Herman (co-chair), United States Environmental Protection Agency
Mr. Jalaluddin Ismail, Department of Environment, Malaysia
Mr. Zbigniew Kamienski, State Inspectorate for Environmental Protection, Poland
Dr. Pakit Kiravanich, Pollution Control Department, Thailand
Mr. Sun Lin, United Nations Environment Programme
Mr. Robert Reiniger, National Authority for Enforcement, Hungary
Dr. David Slater, Her Majesty's Inspectorate of Pollution, United Kingdom
Ms. Rachel A. Vasquez, Environmental Management Bureau, Philippines
Mr. Pieter J. Verkerk (co-chair), Inspectorate for the Environment, The Netherlands
Mr. Zhang Hongjun, National Environmental Protection Agency, People's Republic of
China
Finally, this document could not have been developed without the generous assistance of the
following individuals who provided the detailed information on their country programs:
• Mr. Javier Cabrera Bravo, Office of Attorney General for Environmental Protection,
Mexico,
• Mr. Christopher Currie, Environment Canada,
• Mr. Jo Gerardu and Mr. Robert Glaser, The Netherlands Ministry of Housing, Spatial
Planning and The Environment, Inspectorate for the Environment,
• Mr. Alun James, United Kingdom, Her Majesty's Inspectorate of Pollution,
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• Mr. Jens Erik Pettersen, Norway State Pollution Control Authority,
• Dr. Manfred Putz, Raumordnung & Landwirtschaft, Germany,
• Mr. Robert Reiniger, Hungary National Authority for the Environment,
• Dr. B. Sengupta, India Central Pollution Control Board,
• Mr. Rolf Svedberg and Kitty Victor, Swedish Environmental Protection Agency,
• Mr. Padraic Larkin, Irish Environmental Protection Agency, and
• Ms. Cheryl Wasserman, United States Environmental Protection Agency.
These individuals expended significant effort to gather information, complete tables, respond to
questions, provide relevant reference materials, and review draft documents. Because the information
they provided has been essential to the completion of this report, these individuals deserve special
thanks for the time, effort and patience they committed to this project.
A final note of appreciation goes to two summer interns at the U.S. Environmental Protection
Agency, Ms. Watcharee Lemanon and Mr. Johns Hopkins, who helped to incorporate new
information and update the text prior to final publication.
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EXECUTIVE SUMMARY
SYNOPSIS OF MULTI-MEDIA INSPECTION PROTOCOLS: INTERNATIONAL
EXAMPLES
Capacity Building Support Documents For Environmental Compliance and Enforcement
Programs
PURPOSE
Consistent with the goals of the Fourth International Conference on Environmental Compliance
and Enforcement, its international sponsors, and the Executive Planning Committee, this
document addresses key aspects of how and why multi-media inspections may be incorporated
as a component of a compliance monitoring program. In a multi-media integrated inspection,
the regulatory authority evaluates a facility's overall compliance with environmental control
programs rather than assesses its compliance on a media-specific basis. In addition, multi-media
inspections may address environmental performance issues, such as the evaluation of pollution
prevention opportunities, that offer environmental benefits in excess of that required by statute
or regulation.
SCOPE
Information and data on multi-media inspection approaches was solicited from various countries
throughout the world. Information provided by the following countries is contained in this
document:
Germany
Hungary
India
Ireland
Mexico
Norway
Sweden
The Netherlands
United Kingdom
United States
Examples of multi-media inspection approaches used in the United Kingdom and United States
are included in this document. In addition, examples of specific questions asked during
inspection programs are included in the Appendices.
SUBJECT AREAS
This document presents key factors that program managers could consider prior to adopting
multi-media inspections into an overall compliance monitoring program. As shown in this
document, there are a variety of approaches for conducting multi-media inspections. Selection
of an appropriate approach depends on the regulatory program's purpose for conducting a multi-
media inspection, the size and complexity of targeted facilities, the expertise and training of the
inspectors, the time allotted for conducting the inspection, and other factors. Country officials
can use the information provided in this document as a reference for designing a multi-media
inspection program appropriate within an overall compliance monitoring framework.
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1 INTRODUCTION
This document addresses the role that multimedia or integrated inspections can play in
advancing both environmental compliance and performance. In doing so, it identifies a
variety of approaches available for conducting multimedia inspections. Moreover, it presents
the factors that drive which multimedia inspection approach(es) may prove most valuable
within an environmental program's overall objectives.
Compliance monitoring is a key element of any environmental enforcement program, serving
to assure compliance, identify and document non-compliance, and provide the basis for
enforcement actions and program evaluation. It consists of several types of activities,
including: conducting inspections; requiring regulated entities to self-monitor; conducting
ambient monitoring of particular areas; and reviewing citizen complaints.
Traditionally, most environmental control programs have targeted a particular environmental
media, for example, air, land, and water. However, in the last few years, increasing
attention has been paid to the overall relationship between economic production and the
environment, and the need to explicitly consider all available opportunities to optimize
production and environmental performance hi an integrated fashion. They stress
environmental performance from a multimedia perspective.
Environmental program managers are working to integrate concepts such as cleaner
production, life cycle assessment, pollution prevention, industrial ecology, and sustainable
development principles into their pollution control programs, seeking new and better ways
for regulated facilities to achieve compliance. Their goal is to leverage resources to boost
compliance rates. Many environmental programs are investing effort into compliance
assistance programs, working cooperatively with regulated entities to meet compliance
requirements, and in so doing, seek to help them integrate compliance with specific
environmental requirements with these broader concepts. These efforts include providing
one-on-one technical assistance or more generic assistance, such as developing basic analytic
tools, and providing transfer of technical data. Additionally, countries are working to
provide more flexibility to the regulated community in meeting environmental standards.
Compliance monitoring and enforcement program managers are also evaluating how
multimedia concepts can be integrated into their inspection programs to improve
environmental compliance and performance. As noted earlier, compliance monitoring
approaches are an element of environmental enforcement programs, which, in many cases,
have been developed along single-media lines. Thus, it is no surprise that compliance
inspections have generally been conducted on a media-by-media basis.
By definition, inspections always focus on evaluating a facility's compliance status. The
main difference with multi-media inspections is that they involve evaluating a facility's
"overall environmental compliance status," rather than establishing the facility's compliance
status on a media-specific basis, as is done in single-media inspections. Although the
majority of compliance monitoring programs tend to involve single-media inspections,
multimedia inspections have been conducted either to augment or serve as the fundamental
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approach to inspections by environmental compliance and enforcement programs. As a
result, regulatory agencies have, over time, adopted a variety of approaches for conducting
multimedia inspections to meet their particular interest and circumstances.
This document discusses the relative advantages and disadvantages of multimedia inspections
under different circumstances. It also identifies different approaches for implementing
multimedia inspection programs, and provides examples illustrating programmatic
differences.
The information presented in this document was developed by requesting information
regarding conducting multimedia inspection programs from the following countries:
• Hungary,
• India,
• Ireland,
• Mexico,
• The Netherlands,
• Norway,
• Sweden,
• United Kingdom, and
• United States.
These countries were selected based on several factors, including prior contact and access to
preliminary information indicating that they have multimedia inspection programs in place, as
well as on each country's willingness to provide such information. Although a cross-section
of developing, transitional, industrial, and rapidly industrializing countries was sought from
all regions of the world, the countries included are not deemed to be representative of all
programs.
It is important to note that this document focuses only on one part of an integrated program -
- multimedia inspections. Such inspections may be the only multimedia component of a
country's environmental programs (that is, the program may be single-media based), or may
play a well-defined role within a country's overall multimedia environmental control
framework. There may not be a single approach to conducting multimedia inspections that is
best in all circumstances.
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2 WHY CONDUCT MULTIMEDIA INSPECTIONS
In designing an effective monitoring program, an environmental program manager needs to
develop the most appropriate approach for conducting compliance inspections for his/her
particular circumstances. There are various approaches for conducting inspections that range
from evaluating compliance of a facility for a single-media (for example, water) or a single
pollutant (for example, lead) to evaluating compliance for all media.
In considering whether to use a multimedia inspection approach, the environmental manager
may want to determine whether:
1) Multimedia inspections can enhance the regulatory agency's enforcement presence,
2) Multimedia inspections can yield better environmental results (for example,
reductions in cross-media transfer, identification of pollution prevention
opportunities) than a single-media inspection,
3) Multimedia inspections can provide increased resource efficiencies for the regulatory
agency, and
4) Multimedia inspections can result in increasing the plant manager's attention to
environmental protection issues.
The following sections discuss the benefits generally associated with multimedia inspections and
suggest factors to consider in determining whether the general benefits may occur in a site
specific situation.
Exhibit 2-1 summarizes the benefits generally associated with single and multimedia
inspections. As presented in this exhibit, both types of inspections can yield benefits.
Determining the most appropriate type of inspection for a compliance monitoring program is
dependent on overall programmatic goals as well as site-specific circumstances. The
remainder of this chapter provides a brief overview of the types of benefits that can be
derived from multimedia inspections. It also suggests factors which may detract from
achieving these benefits. Chapter 3 then provides descriptions of how different countries and
programs have adopted multimedia inspection approaches to maximize benefits in their
compliance monitoring programs.
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Exhibit 2-1. Benefits Generally Associated with Single-media and Multimedia
Inspections
Considerations
May achieve greater enforcement results
than multimedia inspections due to
specialization, experience, and training of
inspectors.
Enforcement presence may increase due to
multiple single-media inspections.
Single-media Inspections
Multimedia Inspections
Compliance/
Enforcement
Effectiveness
May achieve greater deterrence than single-
media inspections due to broad scope, time,
and potentially detailed level of inquiry.
Enforcement presence results from
achieving greater management attention.
Effective in enforcing against facilities with
many small violations in several programs.
Resource Needs
Requires trained inspectors for each media
program. Limited availability of trained
inspectors impacts ability to monitor
compliance.
Retention of trained inspectors important.
Potentially more efficient due to reduced
number of trips and consolidated
transportation of inspectors; may need fewer
inspections if they can be cross-trained.
Retention of cross-trained inspectors even
more important than single-media inspectors
due to greater training investment.
Type of Facilities
Suitable for most facilities. May not
effectively address multimedia releases.
Team inspections may be overwhelming for
smaller facilities. Consolidated inspections
with one or two cross-trained inspectors
may be more appropriate for small and mid-
sized facilities.
Time Required
Single-media inspections generally efficient,
but cumulative burden may be significant.
Screening inspections can be very efficient
for detecting potential violations and
referring for follow-up single-media
violations.
Comprehensive multimedia inspections can
take longer than single-media inspections.
Scope
Requires multiple inspections to achieve
comprehensive coverage.
Comprehensive coverage of facility.
Greater opportunity to address underlying
environmental issues.
Greater opportunity to review entire process
for pollution prevention opportunities.
2.1 ENHANCED COMPLIANCE/ENFORCEMENT PRESENCE
In theory, multimedia inspections have the potential to be more effective at establishing a
compliance/enforcement presence than single-media inspections because they:
• Enhance the likelihood of identifying violations across the spectrum of
environmental requirements, and
• Command the increased attention of management.
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Where an inspector or team of inspectors is conducting a multimedia inspection, few, if any,
components of a facility's environmental compliance program are beyond the scope of the
inspection. This broad scope can subject regulated facilities to greater compliance scrutiny
than is created under traditional inspections.
In addition, because multimedia inspections may be conducted by two or more inspectors
and, depending on the level of inspection, may involve a longer period of time than required
for single-media inspections, multimedia inspections offer an increased potential for
discovering violations. On the other hand, because multimedia inspections require greater
coordination with facility staff, it may be necessary to pre-notify the facility of an impending
multimedia inspection, whereas a single-media inspection could proceed unannounced. As a
result, where a multimedia inspection is planned, the facility could have sufficient time to
correct at least some existing problems. Consequently, program managers need to assess
whether the element of surprise is necessary to assure the success of an inspection.
Multimedia inspections can involve a large number of inspectors and require more time to
complete, contributing to an increased enforcement presence. These factors tend to promote
the increased attention of firm management to environmental compliance issues. The
significant presence achieved through team multimedia inspections also increases the
awareness of the regulated community of its compliance obligations and the potential of being
subject to rigorous compliance monitoring.
It is important to recognize, however, that the advantages discussed above depend greatly on
the nature of the multimedia inspection, its scope, and the training of the inspectors.
Program credibility may be lost if, in the process of conducting a multimedia inspection,
inspectors fail to detect important violations either because they lack the time, resources, or
training to cover the intended scope or follow proper inspection procedures.
2.2 IMPROVED ENVIRONMENTAL RESULTS
Multimedia inspections can often result in improved environmental performance. For
example, where a single-media inspection program typically focuses on the reduction or
management of waste in a particular environmental medium without regard to the
consequences for other media (for example, air pollution regulations that require the use of
control devices, such as scrubbers, which produce contaminated waste water discharges), a
multimedia inspection program may seek to reduce the cross media transfer through the
identification of a pollution prevention approach that results in reduced releases to both the
air and water media.
There are two basic ways to conduct an inspection: (1) beginning from the point of a specific
release or discharge and working back through the process to the entry of raw materials or
(2) beginning at the entry of raw materials and proceeding through the process to the point of
a specific release or discharge point. In this document, these inspections are called "mass
balance" inspections.
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Before going into more detail regarding mass balance approach inspections, it is important to
note that there are different levels within each single-media and multimedia inspection
currently used. Inspections that involve very limited information collection (for example,
screening inspections) are considered the lowest level, while the use of sophisticated
sampling and testing equipment is often considered the highest level. Prior to conducting an
inspection, the reason for doing so (for example, compliance or enforcement) will often
dictate which level or approach (single as compared to multimedia) is to be used.
Many inspections are done at a middle level to determine compliance with permissible
emission or release regulations, and with storage, handling and/or disposal regulations.
During inspections at this level, the only process-type inquiries involve the determination of
normal production conditions. If there are compliance issues, the level of inspection is often
increased to a process inspection, which is conducted concurrently with inspection of
emissions (or release points) and storage, handling and disposal practices. The next level
may involve the internal inspection of control devices, process reviews, sample collection
and on-site analysis. The highest level would involve all these activities with additional
personnel to perform more sophisticated sampling and analysis.
In cases where a simple compliance determination is required or when an inspector is very
familiar with the inspected facility or process, the inspection is often performed by starting at
the release or discharge point and working back through the process. In most cases, the
inspection ends at the control device or process activity being regulated. As mentioned
above, the only process information collected is on the conditions during the time of the
inspection.
Multimedia inspectors using this "mass balance" approach are in a far better position to
identify:
• Cross-media pollution,
• Process/material-related problems,
• Pollution prevention opportunities, and
• General environmental conditions.
This process line or mass balance approach toward conducting inspections is not only capable
of tracking environmental compliance across different media, but also of identifying
opportunities for improved environmental results by addressing corrective measures to limit
cross-media transfers, identify ing process- or material-related problems, enabling compliance
assistance, and examining pollution prevention opportunities.
The results of a process-line or mass balance inspection, may spur facility managers to
become more aware of the consequences of certain production practices and, as a result,
adopt production process modifications which reduce environmental control costs while, at
the same time, yield an equally good or improved product.
Multimedia inspections may also assess general environmental conditions (for example,
visible leaks, spills, odors, or physical conditions of processes), thereby providing the most
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comprehensive picture of overall environmental conditions at a facility and offering the
greatest opportunity for identifying areas of improvement.
Clearly, conducting a detailed, process-based inspection presents several challenges. Such a
program involves using highly-trained personnel, knowledgeable of specific industrial
categories (for example, iron and steel). One might consider conducting these inspections
with a single highly trained inspector or an inspection team. Additionally, such inspections
take more time than would a single-media inspection. Other factors to consider in this type
of approach are the size and complexity of the facility involved. For example, these types of
inspections may work well for small to mid-sized facilities with more limited regulatory
requirements and where it may be easier to train the inspector in that specific process(es)
(such as printing processes and vehicle repair activities).
2.3 POTENTIAL FOR INCREASED EFFICIENCY
Multimedia inspections also can promote the efficient use of compliance monitoring and
enforcement resources. Travel expenses may often represent a significant component of total
inspection cost. By consolidating inspections, these travel costs can be reduced, particularly
where a single inspector can screen multimedia compliance at a facility, or fully assess
compliance with requirements imposed under two or more environmental programs. At
larger facilities, where an inspection team may be employed, resource savings can be
realized by minimizing duplicate aspects of the inspection process. In addition, because of
the increased scope of multimedia inspections as compared to single-media inspections, as
well as their increased visibility within the regulated community, such inspections may not
need to be conducted as frequently as single-media inspections. Similarly, where multimedia
inspections directly address the problems that cause environmental violations, fewer
inspections may actually be needed.
However, multimedia inspections may impose additional resource demands on governments
that counterbalance gains in efficiency. Such demands include the tune and cost of cross-
training inspectors as to the requirements of multiple programs, and the need to assign
several inspectors (that is, a team) to a single multimedia inspection.
2.4 ENHANCED COMMUNICATIONS WITH REGULATED COMMUNITY
Multimedia inspections offer the potential to enhance communications between regulated
facilities with multimedia operations and the regulatory agencies responsible for
environmental oversight of such facilities. Under programs that use single-media
inspections, such inspections are typically conducted by a different inspector for each
environmental program area. One result of this approach is that where a facility has a
problem or question, it must be able to identify and contact the particular inspector
responsible for the relevant program area to address the problem.
In contrast, multimedia inspections are generally directed by a team leader or a single
specialized inspector or "process expert," who serves as an easily identifiable point of contact
for facilities with problems or questions related to environmental compliance. This makes it
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much simpler for those within the regulated community to initiate communication with the
regulatory agency. The facility also can be confident that the multimedia inspection leader or
specialized inspector will have a good understanding of the overall facility or operation,
based on his or her multimedia training and experience. These factors encourage
communication, which builds understanding and promotes higher rates of compliance.
Additionally, as a result of the tune associated with a multimedia inspection, and in some
cases the size of the inspection team, the inspection raises the visibility of the regulatory
agency across the industrial community. When a multimedia inspection of a facility takes
place over several days, or weeks, the word tends to spread across the regulated community.
This enhanced visibility can serve as an effective deterrent to noncompliance.
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3 APPROACHES TO MULTIMEDIA INSPECTIONS
As discussed in Chapter 2, multimedia compliance inspections can offer significant
advantages in terms of:
• Enhancing enforcement,
• Improving environmental performance,
• Reducing resource requirements, and
• Improving communications with the regulated community.
However, as also discussed in Chapter 2, in some cases multimedia inspections may prove
less beneficial than single-media inspections. This does not mean, however, that
environmental program managers should hot consider the multimedia inspection concept.
Rather, they may choose to use a multimedia inspection approach that yields the greatest
benefits in their particular compliance monitoring programs. In some cases, they may
choose to blend the best aspects of a multimedia and single-media programs, using them as
complementary elements within an overall inspection framework. There is not a single
approach or procedure for conducting multimedia inspections. As described hi this Chapter,
there are a variety of multimedia inspection approaches, each designed to meet particular
circumstances.
The remainder of this Chapter discusses the specific assessment or protocols performed as
part of multimedia inspections and how these may differ from single-media inspections.
Section 3.1 briefly summarizes three general types of assessments that are being used hi
multimedia inspections. The primary assessment type used by these programs focuses on
compliance; a second assessment type reviews overall facility environmental conditions; and
the third involves the provision of technical and compliance assistance to the regulated
facility. All of these assessment types share an interest in multimedia effects and can be
conducted separately or jointly.
Section 3.2 then identifies four separate approaches used to advance these assessment types.
These approaches differ hi scope and associated resource requirements. They do not
represent the sum total of inspection approaches available. Indeed, compliance program
managers can mix and match these inspection approaches as well as how and when they are
conducted. For example, these approaches may be used in a sequential fashion, or one could
be found to be applicable to smaller facilities, another to specific types of industrial
categories.
Section 3.3 provides a discussion of the programmatic, resource and site-specific factors that
may influence the selection of multimedia inspection programs. Finally, Section 3.4 presents
some examples of how multimedia inspection programs have been incorporated into overall
compliance monitoring programs.
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3.1 TYPES OF ASSESSMENTS CONDUCTED DURING MULTIMEDIA
INSPECTIONS
In this section, the three broad purposes hi which pollution control agencies are making use
of multimedia inspections are defined. These purposes are to evaluate:
• Compliance,
• Environmental conditions, and
• Need for compliance/technical assistance.
All of the countries that provided information for this document always addressed some level
of compliance assessment hi their multimedia inspections. In many cases, environmental
conditions and/or the need for compliance/technical assistance were also assessed as part of
such inspections. Exhibit 3-1 presents the types of assessments performed by various
countries hi their multimedia programs. Each type of assessment is described briefly below.
3.1.1 Compliance Assessment
Compliance assessment can be defined as determining a facility's compliance with the
applicable statutory, regulatory, or permit requirements. This type of assessment can involve
a range of activities, such as determining whether a release meets the applicable limits,
whether the facility is keeping the appropriate records and reporting to the regulatory agency
at the appropriate intervals, or simply determining whether a particular regulation applies to
a facility. Compliance assessments may also serve to identify facilities requiring more in-
depth follow-up inspections to completely assess compliance or the need to provide other
types of assessments, such as compliance assistance audits.
The types of questions asked during compliance assessment are based on the specific
requirements against which the facility is being assessed. Basic questions may include:
1. Does the facility discharge process wastewater into a receiving water?
2. Does the facility have a permit?
3. Is the facility operating hi compliance with the terms of its permit?
These types of questions are identical to the types of questions asked in a single-media
inspection. The main difference hi all inspections may be the level of detail of compliance-
related questions. For example, in a multimedia screening inspection, an inspector may ask
questions such as 1., 2., and 3. above. In a higher level single-media inspection (as
discussed hi Section 2.2), in addition to the above questions the inspector would probably ask
more detailed questions such as the folio whig:
1. What sampling and analysis methods are used?
2. Are the records being kept for the required period?
3. Do the self-monitoring reports contain the required information?
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Exhibit 3-1. Types of Assessments Conducted during Multimedia Inspections
Country
Germany
Hungary
India
Ireland
Mexico
The Netherlands
Norway
Sweden
United Kingdom
United States
Compliance Assessment
Determine compliance
and take enforcement
action
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Environmental
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Compliance/
Technical
Assistance
/
/
/
/
/
/
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The types of questions asked are related to the level of inspection being conducted as
discussed in Section 2.2. This applies to both multimedia and single-media inspections.
3.1.2 Environmental Assessment
An environmental assessment evaluates general environmental conditions at a facility to
determine whether they pose a potential or actual risk to the environment. This type of
assessment involves evaluating the general characteristics of facility releases as well as the
environmental conditions surrounding the facility but does not address specific compliance-
related issues. Environmental assessments can be based on visual observations or analytical
tests. Such assessments may address:
1. Does the soil outside the facility building show signs of a spill?
2. Does the stream to which the wastewater is being discharged show signs of
environmental damage (for example, fish kills, unusual odor)?
3. Are air emissions unusually dense or do they contain extreme odors?
Integrated Pollution Control program operators can be required to make an assessment of environmental
conditions.
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3.1.3 Compliance Assistance/Technical Assistance
Compliance/technical assistance involves evaluating the facility's operations and activities to
identify opportunities where the facility can potentially improve its compliance and
environmental performance. As part of this evaluation, the inspector discusses these
opportunities with the facility and provides guidance as to where the facility can find
additional information on these opportunities. For example, in the United States, multimedia
inspections may include a pollution prevention opportunity assessment. Similar compliance
assistance measures are conducted in India and the United Kingdom. These assessments
consist of asking questions and making observations during the inspection that solicit
information about source reduction measures and recycling practices that the facility has or
could possible implement. The focus is on issues such as:
• Process changes that would result hi less material used or waste generated,
• Material substitutions that replace toxic materials with less toxic materials, volatile
with less volatile substances to reduce fumes, gases, or other air emissions, and
use of materials that can be reused or recycled,
• In-process reuse,
• Recycling,
• Spill prevention, and
• Housekeeping and clean-up practices that generate less waste.
Typical questions that may be asked include:
1. Is the shop clean and orderly to prevent accidents and spills?
2. Does the facility use spigots and pumps when dispensing raw materials?
3. Does the facility use funnels for transferring wastes to storage containers?
4. Has the facility considered the use of less hazardous solvents (for example,
aqueous or semi-aqueous solvents)?
5. Does the facility reuse, recycle, or return to the manufacturer waste solvent?
•
3.2 APPROACHES TO CONDUCTING MULTIMEDIA INSPECTIONS
This section identifies four basic multimedia inspection types. It also describes the purpose
of each inspection as well as how it relates to the programmatic, resource, and site-specific
factors described above. These inspection types include:
• Multimedia Screening—One or more inspectors conducting detailed compliance
assessments with respect to media-specific requirements while simultaneously
screening for, and reporting on indicators of possible noncompliance hi other
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Multimedia Inspection Protocols
program areas. Such screening inspections may serve as precursors to more
detailed inspections, as necessary.
• Team Inspections—An team of inspectors is deployed at the facility to conduct a
comprehensive evaluation of the facility's overall compliance. Each inspector
investigates his/her own area of media-specific program expertise.
• Consolidated Inspections—Use of one or more inspectors, where each inspector
may investigate one or more media programs during a single inspection.
Inspectors that conduct consolidated inspections are often specialized or "process
expert" inspectors.
• Process and Prevention Inspection—This inspection involves examining all
aspects of industrial processes, including compliance, pollution prevention
opportunities, compliance assistance opportunities, and other issues related to
environmental performance and improved efficiency.
The first three inspection types share a common purpose, that of conducting a compliance
assessment. While they share the same purpose, they accomplish that purpose differently,
considering resource and site-specific circumstances. The fourth type, termed a process and
prevention inspection, offers a "beyond compliance" perspective as well as a compliance
evaluation. While any of the inspections can be altered to include a process and prevention
inspection, a multimedia evaluation can best be conducted within the context of a team or
consolidated inspection.
Exhibit 3-2 provides a brief review of the objectives, advantages, and disadvantage of these
four inspection approaches. It also provides a brief description of the facilities to which
inspection type might be targeted. A more complete description of each approach appears in
the following paragraphs.
3.2.1 Multimedia Screening
Multimedia screening inspections are conducted as a brief addendum to single-media
inspections. A single-media inspector conducting a multimedia screening inspection
generally uses a simplified checklist as a guide for recording observations and information
pertaining to possible multimedia violations that may require follow-up action, such as a
more comprehensive inspection.
Screening inspections by nature do not constitute a complete inspection for the non-targeted
program areas, and are designed to require a minimal expenditure of time. Using the
checklist and visual observation of environmental conditions, the inspector can identify
obvious compliance and risk problems beyond those directly related to the specific media
program
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Multimedia Inspection Protocols
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Multimedia Inspection Protocols
sponsoring the inspection. Often, glaring problems can be identified by direct observation of
environmental conditions at the site. For example, an inspector who visits a facility to
inspect compliance with air regulations would also examine the site for obvious violations of
water or waste regulations (for example, spills, improper effluent discharges, leaking or
unsafe storage).
A screening multimedia inspection does not require extensive staff training to be
accomplished successfully. Screening inspections require the least amount of time among
multimedia inspections to conduct and, most importantly, have the ability to identify major
environmental problems or issues (for example, environmental conditions that endanger
human health or the environment). At the same time, while such inspections cannot
accomplish a comprehensive evaluation of the site, they offer an effective means of targeting
additional, more comprehensive inspections.
3.2.2 Team Inspections
Team inspections involve the inspection of a facility by two or more inspectors each of
whom is trained in a single program area. Typically, a team inspection is directed by a
leader, who coordinates the inspection team activities. During a team inspection, inspectors
focus on their areas of program expertise, however, the inspection may proceed such that
some or all inspectors examine components of the facility (for example, a storage tank, a
major process, a treatment unit) simultaneously. This allows for each inspector to become
aware of problems in other program areas and to provide input, as needed, to assess such
problems.
The primary advantage of a team approach to conducting multimedia inspections is the fact
that such inspections do not require that inspectors undergo additional, specialized training.
Although this can save resources, such savings may be negated by having to mobilize
numerous inspectors, which is not always possible. Team inspectors also raise the visibility
of the inspection to the facility's management. By raising the visibility of the inspection, the
regulatory agency can raise corporate interest in investing in environmental control.
Additionally, conducting such an inspection can quickly spread program visibility throughout
the regulated community, particularly in the immediate geographic area and within the
facility's industrial section, resulting in deterrence of noncompliance.
From an enforcement perspective, conducting a team inspection enables enforcement officials
to consolidate inspection reports and take a single, unified action against the facility.
Preparing a single, unified action can build the enforcement officials' leverage in taking
actions and, perhaps, enable enforcement officials to negotiate innovative settlements.
3.2.3 Consolidated Inspections
Consolidated inspections require that inspectors be able to conduct full or partial inspections
in two or more program areas. Such inspections may employ one or two inspectors, each of
whom is cross-trained in two or more program areas. Deploying cross-trained inspectors is
most effective where:
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• A facility presents numerous programmatic issues (for example, hazardous waste,
air pollution, water pollution) of various types (for example, environmental
compliance, environmental impact),
• Inspectors can be trained to handle the requirements of particular industrial sectors
or broad areas of economic activity, or
• Multiple environmental programs have interrelated requirements that are
addressed by the training.
The advantage of consolidated multimedia inspections is that they can address cross-program
issues and issues that underlay the violations normally detected by single-media or certain
multimedia inspections. However, consolidated inspections demand cross-trained inspectors,
and can be difficult to execute, as well as be tune-consuming to conduct. On the other hand,
by deploying experienced, cross-trained inspectors, enforcement programs may find that the
up-front investments in conducting the inspection provide benefits in the extent and quality of
evidence gathered, improved evidence in work to speed the enforcement process, thus
abrogating the need to conduct additional follow-up inspections and increasing leverage with
one noncomplying facility.
3.2.4 Process and Prevention Inspections
Process and prevention inspections focus on identifying key industrial processes and their
associated waste streams and determining whether these waste streams are properly managed.
These inspections differ from traditional mid-level control device inspections in that they
focus on developing a greater understanding of the entire process, from raw material inputs,
through the process operation, to all outputs, including products, intermediates, and all
wastes (solid, liquid, and air emissions). Process and prevention inspections follow many of
the steps used during traditional inspections; however, the focus and level of detail is
generally greater during a process and prevention inspection consistent with the need to
develop an in-depth understanding of key processes and wastes. For example, during
process and prevention inspections, inspectors often develop a facility process model and add
to the model as the inspection proceeds.
The primary advantage of process and prevention inspections is that through developing an
in-depth understanding of targeted processes, inspectors can identify the key factors that
contribute to violations, as well as promote solutions that are most acceptable from both an
industry and regulatory perspective. The potential disadvantage of this approach is that it
can require additional tune, resources, and expertise to develop the knowledge of key
processes necessary to make it work.
One issue that may arise in conducting process and prevention inspections is that inspectors
may find it difficult to distinguish between their enforcement role and their compliance
assistance role. By design, diis type of inspection presents the inspector with a greater
opportunity to educate facilities about compliance and better environmental performance.
However, an inspector must continue to critically evaluate all environmental violations.
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Multimedia Inspection Protocols
Moreover, it must be clear to the inspector and the facility that the compliance assistance
function is secondary to that of enforcement, that compliance assistance information is purely
advisory in nature, and that each facility is fully responsible for it own compliance decisions
(that is, such information is meant to facilitate better decision-making by the facility, and is
not binding on the regulatory agency and does not render the agency liable for results
produced by reliance on such information).
3.3 FACTORS TO CONSIDER IN SELECTING MULTIMEDIA INSPECTION
APPROACHES
A variety of multimedia inspection approaches have been designed to further the advantages
associated with the principles of multimedia environmental control. Each of these inspection
approaches has been adapted to meet one or more of the following factors:
(1) programmatic factors,
(2) resource factors, and
(3) site-specific factors.
These factors can drive the selection of an appropriate inspection approach. However, it
should be noted that a single compliance monitoring program can include any combination of
multimedia inspection approaches. That it, using one approach does not preclude the use of
another, and more than likely each approach can be used wisely within the context of an
overall program.
3.3.1 Programmatic Factors
As noted in Chapter 1, compliance monitoring programs are but one element of the overall
environmental control program. In some cases, the inspection program may not be the best
mechanism for serving overall programmatic goals. Environmental program managers need
to seriously consider that the inspection program may not, for example, yield cooperation in
advancing pollution prevention goals within the regulated community.
Some environmental program managers have found they can advance pollution prevention
objectives within the private sector by providing hands-on technical assistance through the
inspection process, whereas others have found that advancing pollution prevention goals
within the context of a compliance inspection can be counter-productive.
Facility owners can be suspicious, and therefore non-receptive, of receiving pollution
prevention technical assistance within the context of a compliance inspection. Many facility
owners are strongly guarded about discussing production techniques with regulatory program
officials, particularly those with enforcement responsibilities. Thus, some compliance
program managers have found that comprehensive inspections involving facility-wide,
process-oriented reviews do not necessarily offer the pollution prevention opportunities
initially envisioned. Instead, these program managers find that pollution prevention
objectives can be furthered through separate compliance assistance programs, providing on-
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site technical assistance on demand, rather than within the context of the regularly-scheduled
compliance evaluation.
On the other hand, enforcement officials have found that such process-oriented inspections
are extremely valuable in identifying a comprehensive list of violations across media statutes.
A comprehensive list of violations provides enforcement officials with considerably more
leverage in an enforcement proceeding than would a smaller list of media-specific violations.
Moreover, since a long listing of violations is more than likely indicative of poor facility
management, developing a multimedia enforcement action based on a comprehensive
evaluation of facility-wide practices is more likely to spur the facility to notice and address
the cause, for example, poor management, rather than the symptom.
The question for environmental program managers is whether the cost of conducting a
comprehensive, process-oriented inspection merits the benefits derived.
3.3.2 Resource Commitments
Many environmental program managers find that the full range of regulatory programs are
simply too complex for a single inspector to master. Additionally, compliance monitoring
programs often have difficulty hi maintaining inspectors over sufficient time to enable them
to acquire a mastery of multiple programs. In addition, when senior inspectors that have
acquired such a mastery leave the employment of the regulatory agency, they are more
difficult to replace. Consequently, from a resource perspective, investing in training the
entire inspection staff hi multimedia skills may simply be too resource intensive.
On the other hand, training single-media inspectors is more easily accomplished and, when a
single-media inspector leaves the inspection corps, he or she is more easily replaced.
Consequently, the inspection program invests and loses less hi human capital. If the
compliance monitoring program experiences high turnover, the environmental program
manager may not choose to invest in highly-trained inspectors. In this case, the
environmental program manager may choose to establish a small cadre of highly-trained
inspectors, perhaps for addressing specified industrial sectors. Other inspectors may receive
more limited training hi program areas other than their area of media specialization.
3.3.3 Site-Specific Circumstances
Some programs have used senior inspectors, with training hi all programs, to conduct
multimedia inspections. Others have chosen to use inspection teams, where each inspector
concentrates on his/her specialized area.
In smaller facilities, the team approach has been found to be unworkable. Sending a team
through a small electroplater shop is too disruptive to facility operations, and can only work
to create unnecessary tensions between the regulatory agency and facility owners. On the
other hand, even if a program has developed highly skilled multimedia inspectors, expert hi
petroleum refinery operations for example, the tune required to conduct a comprehensive
inspection with a single inspector could involve days or weeks.
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Multimedia Inspection Protocols
Consequently, selecting an inspection approach is often a site-specific decision, depending on
circumstances, such as the size and complexity of the facility, its past compliance history,
and the number of environmental media affected.
3.3.4 Use of Multimedia Inspections
The previous section defined factors that may result in selecting one or more inspection
approaches. As noted in previous sections, countries elect to conduct multimedia inspections
for a variety of reasons, including the types of environmental programs they are trying to
enforce, the objectives of the compliance monitoring (that is, inspection) program, the
resources (for example, for staff, training) and known facility characteristics. To determine
when and how to use multimedia inspections, countries typically develop a strategy for
targeting such inspections.
A country may choose to implement multimedia inspections for:
• All inspections,
Facilities or industries that pose the greatest risk, and
Where such inspections achieve the greatest deterrence.
This choice generally depends on the type of multimedia inspection being conducted, the
objective to be achieved, and the design of the inspection program. Common factors used
for targeting multimedia inspections include the following:
• Industrial sector or processes—Since wastes from facilities in the same industrial
category exhibit similar characteristics, environmental regulations often include
standards that prescribe discharge or emissions limits for specific categories of
industries (for example, organic chemical manufacturers or pulp and paper mills).
Enforcement activities hi support of industry-specific regulations will usually be
organized by industry as well. India, Ireland, Norway and the United Kingdom
have programs to target specific industries or processes for multimedia
inspections.
• Geographical—Targeting multimedia inspections for geographical areas may result
from mandates, including national legislation or international agreements,
designed to improve environmental conditions in a severely impacted area. In
some cases, multimedia inspections of all potential sources hi a geographical area
may be necessary to obtain data that enables development of a comprehensive
remedial action plan for the area. Hungary, the United Kingdom, and the United
States report targeting facilities within a specific geographical area.
• Pollutant-specific—A particular pollutant or group of pollutants could be the focus
of a multimedia inspection with the intent of developing a pollutant reduction
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Multimedia Inspection Protocols
plan. Specific pollutants are the focus of multimedia inspection program in most
of the countries participating in the study.
By way of example, the United Kingdom's Inspectorate of Pollution has established a
comprehensive multimedia environmental program for all processes and wastes regulated
under its Integrated Pollution Control regulations. All facilities operating these specified
processes and generating target wastes are subject to multimedia inspections. The frequency
of the Integrated Pollution Control program site specific multimedia inspections is based on
risk and determined capability of the operator.
Other countries, such as India and Norway, conduct multimedia inspection programs for
particular aspects of their environmental enforcement programs. Selecting multimedia
inspection targets can be based on various factors. Norway, for example, targets the
following:
• Facilities that have a higher potential to impact the environment due to the amount
or types of emissions produced,
• Facilities that can have special impact on water and air quality considerations,
• Facilities that have had earlier recorded instances of noncompliance, and
• Facilities that fall within national priority areas that are required targets under
international agreements (for example, initiatives to improve environmental
conditions hi specific geographic regions or to reduce emissions of specific
pollutants).
Norway's State Pollution Control Authority has determined that facilities falling within
these categories require a more comprehensive evaluation of their compliance status.
Consequently, these facilities are targeted for multimedia inspections.
India inspects only targeted entities specified under the schedule contained in its
environmental law. This approach allows the regulatory agency to promote pollution
prevention within specific categories of industry.
The United States uses several factors to determine whether multimedia inspections are
appropriate in a specific instance. These factors include location, industrial sector, potential
for multimedia discharges, compliance history, national, regional and local initiatives,
environmental justice, and regional concerns. Initiatives may change over tune, resulting hi
one specified geographic area and/or industrial category targeted hi one year, and another
area/category targeted the next. Sequential targeting recognizes resource limitations in any
single year. In addition, regulatory program interest may be factored into the decision.
Exhibit 3-3 presents comparative information on factors used by select countries in selecting
multimedia inspection targets.
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Multimedia Inspection Protocols
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Multimedia Inspection Protocols
4 CASE STUDIES
As noted in Chapter 3, an environmental control program can incorporate a variety of
multimedia inspection approaches into its program. This chapter describes how these
approaches have been adapted into one US environmental program.
[Note: This section includes examples of case studies from the United States and a
description the United Kingdom's program. Based on the availability of additional
information addressing other countries, additional discussion can be added. The current
discussion is provided as an example of the type of information countries should provide.]
4.1 UNITED STATES
The United States Environmental Protection Agency has developed a policy to encourage its
ten Regional Offices to conduct multimedia inspections. Environmental Protection Agency
Regional Offices have the discretion to determine their own approach for designing and
conducting multimedia inspection programs, and how such inspections will fit into the
Region's overall compliance monitoring program.
4.1.1 Screening Inspection Program Developed bv United States Environmental Protection
Agency
The United States Environmental Protection Agency developed its multimedia screening
program to identify obvious, non-permitted activities and other noncompliant practices
through the use of indicators to determine noncompliance in environmental program areas.
Multimedia screening is conducted in conjunction with a single-media program inspection.
Information obtained during the screening inspection is generally referred to an
Environmental Protection Agency or State compliance program official for follow-up, as
appropriate. Follow-up can include confirmatory single-media or multimedia inspections or,
as appropriate, immediate enforcement action.
The United States Environmental Protection Agency uses the multimedia screening
information to 1) better target resources for more detailed coordinated or consolidated
inspections, 2) improve planning for and coordination of single and multimedia cases, and 3)
more effectively ensure that all significant releases to the environment are included hi any
facility-specific enforcement strategy.
A multimedia screening inspection checklist developed for this program consists of about 70
questions that cover 11 regulatory programs, as well as general environmental assessment.
Questions are organized by regulatory program area. Slightly less than half of the questions
require field observation to answer, while slightly more than half require an interview or
record review. A general screening multimedia inspection checklist modified from the
Environmental Protection Agency's checklist is included in Appendix A. Example questions
for the hazardous waste program area include the following:
1. Does the facility generate or otherwise handle hazardous waste?
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Multimedia Inspection Protocols
2. Do you see any containers of hazardous waste, land disposal units, lagoons, treatment
units? How many?
3. Was there any evidence of spills, leaks, or discharges of hazardous wastes? If so, provide
location and description.
4. If the facility is a generator of hazardous waste, was there a notification form for
hazardous waste activity?
5. What is the facility's Environmental Protection Agency identification number?
6. Is there any evidence of environmental impacts that have not been addressed (under
specific program area screening questions)? Were there situations of possible excessive
occupational exposure that should be reported to the Occupational Safety and Health
Administration?
4.1.2 National Enforcement Investigations Center's Approach to Multimedia Team Inspections
The United States Environmental Protection Agency's National Enforcement Investigations Center
employs multimedia inspection teams whereby several concurrent program-specific compliance
investigations are conducted by a team of investigators representing two or more program offices.
The team, coordinated by a team leader, conducts a detailed compliance evaluation for each of the
target programs. Such inspections, appropriate for intermediate to large facilities subject to a variety
of environmental laws, determine facility-wide environmental compliance. For example, a team
approach is used when inspecting complex facilities, both private and public, targeted by the
Environmental Protection Agency Regional Offices for multimedia inspections. Team inspections are
used because the complexity of these facilities can overwhelm the capabilities of a single inspector.
While the compliance assessment is similar to that used in a single-media inspection, the approach is
quite different. The National Enforcement Investigations Center has found that a process-oriented,
mass balance approach is extremely useful to completely evaluate the compliance status of the facility.
Understanding the facility's process is also valuable in the enforcement stage, as necessary, because
valuable information is gathered which may be used in developing innovative settlement terms, such
as implementation of pollution prevention projects. An example is included in Appendix B.
4.1.3 Consolidated Inspection with Compliance Assistance—City of Santa Rosa. California
The City of Santa Rosa, California, Utilities Department, Industrial Waste Section sponsors the
Sonoma Green Business Compliance Incentive Program, which is a compliance assistance program
aimed at improving compliance with environmental regulations by providing compliance and technical
assistance and positive incentives to business. The program was originally designed to reduce inflow
of organic solvents to Santa Rosa's wastewater reclamation plant from its largest hazardous waste-
producing industry—vehicle services.
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Multimedia Inspection Protocols
Prior to implementation of the program, inspectors for the wastewater treatment plant were
responsible for monitoring discharges and issuing citations to halt illegal discharges. This
created both confusion and frustration on the part of vehicle service owners, who believed
the regulations and requirements imposed by eight different county offices were unclear and
often conflicting. The Compliance Incentive Program was designed to reduce the frustration
and help the owners comply with the requirements by providing technical assistance,
multimedia regulatory streamlining, and public recognition and awareness. One tool that was
developed as part of the program was a consolidated inspection checklist. Prior to the
program, automotive facilities were subject to 48 pages of inspection checklists imposed by
eight different county offices. Under the program, this was reduced to an eight-page
consolidated checklist for automotive shops. This checklist asks basic questions that address
the primary areas of concern for an auto shop. Topic areas include: type of vehicle service
performed, vehicle wash, use of hot tank, hotspray machine, solvents parts cleaners,
management of waste materials, batteries, rags, solvent recycling, air conditioning service,
body shop, floor cleaning, floor drains. Example questions addressing the solvent parts
cleaners include:
1. Do you have solvent parts cleaners? How many?
2. Who services the cleaners? (Name, address, phone, Environmental Protection
Agency No.)
3. If not, how is solvent handled?
4. How often are parts cleaners serviced?
5. Are receipts/manifests for waste hauled in order?
6. Are parts cleaners double contained?
7. Are there any floor drains in the area?
In addition, when auto shops sign up for the program, they receive an information package
containing details on the program, best management practices (addressing all environmental
media) for automotive service/repair shops, vehicle service facility checklist that is a self-
inspection checklist based on the requirements of all environmental regulatory agencies,
vendor list for equipment and services that could help the facility comply, and answers to the
six most-frequently asked questions. Every facility that participates in the program receives
a sticker certifying it is a Sonoma Green Business and that it is in full compliance.
Participating shops are inspected by the city's industrial waste inspectors or inspectors from
other environmental agencies trained to make the multimedia inspection required by the
program. If the shops are in compliance, they receive the sticker. If not, depending on the
Enforcement Response Policy, a shop may be given a grace period in which to correct the
violation. Compliance by auto shops was essentially nonexistent prior to the program, but is
now significantly higher. This type of multimedia program combines a consolidated
approach with a process-based approach targeted at a problematic commercial sector.
4.1.4 Mixed Approach: Facility-Wide Inspections to Reduce the Source of Toxics
The United States Environmental Protection Agency Region I and the Massachusetts
Department of Environment developed a multimedia inspection protocol for various types of
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Multimedia Inspection Protocols
facilities called Facility-Wide Inspections to Reduce the Source of Toxics. The purpose of
this inspection is to determine compliance with a facility's hazardous waste, air quality,
wastewater, and Toxic Use Reduction Act requirements, and to gather information that can
be used to encourage the facility to practice pollution prevention.
The program includes three levels of inspections, with the content of each type of inspection
determined by the risk posed to the public health and the environment by the facility. The
three types of inspections are the following:
• Type A—A thorough evaluation of every aspect of a faculty's regulatory
compliance performance, perhaps including an audit of compliance with
recordkeeping and self-reporting requirements.
• Type B—A detailed evaluation of only those areas of noncompliance that are
likely to result in a significant risk to public health and the environment. Type B
inspections and follow-up would gather information that can be used to encourage
the facility to practice source reduction, particularly in order to correct violations.
• Type C—A cursory scan for imminent threats and significant areas of
noncompliance, including unauthorized (that is, unpermitted waste streams) and
some obvious minor infractions.
The protocol for this type of multimedia inspection includes groups of instructions/questions
that are used to evaluate various operations, activities, or waste streams at the facility being
inspected. For example, for a general facility evaluation regarding hazardous/solid waste,
the following questions are asked:
1. Is there any evidence of on-site burial of hazardous waste?
2. Does the dumpster or other solid waste disposal staging area contain evidence of
hazardous waste (or industrial waste that could have an adverse impact on the
environment) being improperly disposed of as solid waste?
Example questions regarding hazardous waste accumulation include:
1. Does the generator accumulate hazardous waste at or near a generation point
(satellite accumulation)? If yes, are containers in good condition? Are they
closed when not in use? Are they properly labeled?
2. Does the generator accumulate other hazardous waste on-site in tanks or
containers? If yes, are containers in good condition, are they closed when not in
use, are they properly labeled? If stored outside, will area contain leaks? Is there
sufficient secondary containment? Is unauthorized entry prevented?
The inspector decides which of the operations, activities, or waste streams are being
evaluated and uses the appropriate groups of evaluation questions. Select example questions
from the this protocol are hi Appendix C.
4-4
August 1998
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Multimedia Inspection Protocols
4.2 UNITED KINGDOM INTEGRATED POLLUTION CONTROL APPROACH
In the United Kingdom, all industrial processes and wastes regulated under the Integrated
Pollution Control regulations are subject to multimedia inspections, which include an
assessment of the best practical environmental option. Generally, these multimedia
inspections are conducted by one or two inspectors, with one inspector specifically trained hi
Integrated Pollution Control for the three primary media (air, land, water). The inspectors
focus on identifying the best options for the process. Multimedia inspections under the
Integrated Pollution Control include an assessment of pollution prevention options, as well as
advice on how best to comply with applicable regulatory standards. Compliance advice is
based on the Chief Inspector's Guidance to Inspectors: Process Guidance Notes, which is a
form of guidance developed for various industrial categories. The key feature of multimedia
inspections under these regulations is that the inspectors specifically examine and assess the
industrial process. Based on this assessment, inspectors recommend the best available
technique not entailing excessive cost. Given that all inspections under Integrated Pollution
Control are multimedia, targeting under this program consists of determining the frequency
of inspections. To determine frequency, the program assesses the risk posed by the process
and the ability of the operator to operate the process in an environmentally sound manner.
The United Kingdom does not conduct screening inspections for environmental requirements,
but does refer related problems (that is, health and safety risk) to the appropriate
Inspectorate.
References
Garn, W. John, Grimsrud, Martin L. and Paige, Dean C., The Compliance Incentive
Experience in Santa Rosa, California, in the Third International Conference on
Environmental Enforcement, 1994, pp. 527-549.
Training Course for Multi-Media Inspectors, developed by Environmental Protection Agency
in conjunction with Mexico SEDESOL, initial course offered in March 1992.
4-5
August 1998
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Multimedia Inspection Protocols
APPENDIX A
General Multimedia Screening Checklist
(Based on United States Environmental Protection Agency
Version)
A-l
August 1998
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GENERAL INFORMATION
1. Inspector(s) Name 2. Date
3. Facility Name/Address
4. Facility Contact(s)/Titles(s)
5. Description of Facility Operations
SIC Code
Number of Employees
Operating Schedules
Major Products/Production Capacity
-------
-------
HAZARDOUS WASTE
Observations
1. Does the facility generate or otherwise handle hazardous wastes?
2. Do you see any containers of hazardous waste, land disposal units, lagoons, or treatment
units? Approximately how many of each?
3. Were any of the units that contain or handle hazardous wastes (containers, beams, dikes,
tanks, piping, impoundments, etc.) in poor condition, unmarked, open, leaking, cracked,
corroded, or otherwise in a condition that would allow the release or potential release of
hazardous wastes? If yes, describe unit(s). Do you see any actual, releases or evidence of past
releases? If so, describe waste (i.e., liquid, sludge, etc.,) amounts(s), and location.
4. Does the facility operate a boiler or industrial furnace which burns hazardous wastes? Was
there any incineration of hazardous waste on site?
-------
HAZARDOUS WASTE (continued)
5. Was there any evidence of spills, leaks, or discharges of hazardous wastes? If so, provide
location and description.
Interview Questions/Records Reviews
1. If the facility is a generator of hazardous waste, was there a notification of hazardous waste
activity? What is the quantity (kilograms/month) of hazardous wastes produced? How are they
produced?
2. What was the basis (i.e., est, knowledge of process and waste) for determining whether the
facility produced or handled hazardous wastes? Who made the determination?
3. Does the facility have copies of shipping papers for the hazardous wastes? Obtain copies of
a month's (or other specific time frame) set of shipping papers.
-------
HAZARDOUS WASTE (continued)
4. Does the facility have a permit? What are the conditions of the permit? Is the facility in
compliance with its permits?
-------
-------
UNDERGROUND STORAGE TANK
Observations
1. Are there any underground storage tanks?
2. Approximately how many? What are the contents (Wastes, virgin petroleum, or chemicals)?
3. What type of leak detection is used? When was it last used?
4. Is there any evidence of leaks, spills, broken piping, broken fill/vent lines, or leaking pumps
joints or valves? Provide location and description.
Interview Questions/Records Review
1. If the tanks are virgin petroleum or chemicals (not wastes), are they registered with the
appropriate government agency? Date of registration? Date of tank(s) installation?
-------
SPILL PREVENTION
1. Does the facility have the capacity to store oil either in above or below ground tanks? How
many gallons?
2. What type of secondary containment is used at the facility? Were there any deficiencies in the
secondary containment (cracks, broken, dikes left open)? Is it adequate to contain the entire
contents of the largest tank?
Interview Questions/Records Reviews
1. Does the facility have a spill prevention plan prepared or certified by a professional engineer?
When was it last updated?
2. Have there been any major changes to oil storage at the facility since the last modification
of the plan?
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WETLANDS
Observations
1. Are there any wet areas near the facility with wetland-type vegetation (cattails, rushes,
sedges) that have been disturbed by waste disposal, ditching, or filling?
Interview Questions/Record Reviews
1. Does the facility have a federal, regional, or local permit authorizing the fill? What are the
conditions of the permit?
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PESTICIDES
Observations
1. Does the facility produce pesticides?
2. Is the facility applying pesticides?
3. Where are the pesticides stored?
Interview Questions/Records Review
1. If the facility produces pesticides, does the facility have the appropriate registration or
license?
2. If the facility is applying pesticides, what is the registration number of the pesticide?
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AIR
Observations
1. Is there any asbestos on site?
2. Is the facility undergoing or has the facility undergone any renovations or demolitions during
the last 18 months, which involve the removal or disturbance of asbestos-containing materials?
Approximately how much asbestos (square feet or linear feet) was removed?
3. Does the facility have any coating or printing operations? Does the facility use any paints or
organic solvents? What, if any, type of air pollution control is used? Was it operating?
4. Were there any odors? What process was the source of the odors? Describe the odors.
5. Were there any visible (opaque smoke) emissions? What process was the source? Were there
any fugitive (not from a stack) emissions? Was the air pollution control equipment, if any,
operating? Describe source.
-------
AIR (continued)
6. Were all continuous emission monitors operating? Itemize all monitors at the site, including
the type(s) (e.g., opacity, SOj).
7. Were there any out-of-ordinary operating practices or procedures, or occurrences during the
inspection?
Interview Questions/Records Reviews
1. If asbestos was removed, was notification provided to the appropriate regulatory agency?
2. If the facility has coating or printing operations, are they water-based or organic solvent-
based?
3. Does the facility handle/emit any Hazardous Air Pollutant chemicals other than asbestos
(mercury, beryllium, vinyl chloride, benzene, arsenic, or radionuclidies)? Describe process.
-------
AIR (continued)
4. Has the facility added new or expanded existing processes in the last two years? Was it
permitted?
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TOXICS - POLYCHLORINATED BIPHENYLS
1. Did the facility have or does it have any PCB electrical equipment? What equipment (type
and quantity) is on-site?
2. Does the facility have a PCB equipment storage area for disposal or reuse? Describe the
storage area (i.e., concrete pad, walls, roof, curbs).
3. Are there any labels/markings on the PCB equipment?
4. Is there any leaking PCB electrical equipment? Describe.
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TOXICS - POLYCHLORINATED BIPHENYLS
(continued)
5. Does the facility have any hydraulic systems? Are any of these systems leaking?
Interview Questions/Records Review
1. If the facility has PCB electrical equipment, was it tested? What were the test results?
2. If the facility has any hydraulic systems, when were they tested for PCBs? What were the test
results?
-------
WATER
1. Does the facility use water in its manufacturing?
If yes, does the facility discharge process wastewater, cooling-water, storm water,
or any other pollutant into the receiving stream, municipal sewer system or a
subsurface disposal system (e.g., septic tank, wall, cesspool, drywell, etc.)?
Describe each discharge:
Does the facility have a permit for each of these discharge? What are the
conditions of the permit? Is the facility in compliance with its permit(s)?
Does the facility treat its wastewater prior to the discharges? If yes, how? (What
treatment systems are employed?)
-------
WATER (continued)
2. Is the effluent from the wastewater treatment facilities clear and free of solids?
Does the equipment appear to be operating properly, clean and well maintained?
Are there any odors? (If yes describe.)
3. Does the facility have floor drains?
If yes, what materials are spilled down the floor drains?
4. Where do the floor drains discharge (treatment facility, the municipal sewer, or directly to
the receiving water or into the septic tank, cesspool, drywell)?
5. What is the disposal method for the wastewater sludges generated?
-------
DRINKING WATER - UNDERGROUND INJECTION
Observations
1. Are there any discharges other than sanitary waste (i.e., industrial wastes) into or onto
(Including drain fields) the ground? Is an on-site septic disposal system used? Describe the
discharges and the disposal systems.
Interview Questions/Records Review
1. Does the facility have any wells (dug, drilled or driven), dry wells, leachfields, or septic
systems? Do they receive commercial or industrial waste (liquids and/or solid), cooling water,
or drainage from roof drains, floor drains, or parking lots? If yes, give a description.
2. Does the facility have a permit? What are the conditions of the permit? Is the facility in
compliance with its permit?
3. What is the current status of wells (active, abandoned, water construction, repairs)?
4. If the wells are inactive, what was the date they were last used?
5. Well Location 1/4, 1/4, 1/4. Township , Range
, Section . (Written Description, Landmarks, Street intersections, or Geologic
Descriptions with Lat/Long.)
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DRINKING WATER - UNDERGROUND INJECTION
(continued)
YES NO
6. Maps of Facilities
Diagrams of Construction
Consultant Reports
Photographs
Fluid Analysis
7. Total number of Wells:
Number of Wells Inspected:
8. Date of Original Construction: , Date of Modification:
Depth
9. Waste Disposal Formation and Depth
10. Underground Source of Drinking Water (USDW) Name:
Depth:
( ) Confined ( ) Unconfined
11. Depth of Closet Water Wells:
Distance from Site:
Nearby Surface Waters Possibly Affected:
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DRINKING WATER - PUBLIC WATER SUPPLY
Interview Questions/Record Reviews
1. What is the facility's source of drinking water? Does the facility have a private well? How
many people does it serve?
2. Is the water sampled and analyzed for contaminants? Are the results reported to the
appropriate regulatory agency?
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AWARENESS AND PREPAREDNESS FOR
EMERGENCY AT THE LOCAL LEVEL
Emergency Preparedness
1. Have you used, produced, manufactured, or stored any Extremely Hazardous Substances in
quantities greater than the threshold planning quantities for the calendar years designated below?
(Current year and one year prior)
2. If yes, has you facility notified the appropriate
agencies that it meets reporting requirements and has
named an emergency coordinator.
Accidental Release Notification
3. Is your facility aware of the accidental release
notification requirements?
4. Has the facility had any accidental releases of
designated hazardous materials above the reportable
quantities in the years?
(Current year and one year prior)
YEAR
YES NO
YEAR
YES NO
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AWARENESS AND PREPAREDNESS FOR
EMERGENCY AT THE LOCAL LEVEL
(continued)
5. Provide the following information for each release:
DATE TIME CHEMICAL QUANTITY
6. If the facility did experience accidental releases of designated hazardous materials above the
reportable quantities, did the facility supply a written follow-up report to the appropriate local
agency for each and every release?
Provide the dates the follow-up reports were submitted for each and every release.
DATE OF RELEASE DATE OF FOLLOW-UP
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AWARENESS AND PREPAREDNESS FOR
EMERGENCY AT THE LOCAL LEVEL
(continued)
Hazardous Chemical Reporting
YEAR
YES NO
7. Is your facility required to possess
Material Safety Data Sheets for hazardous
chemicals?
8. Do you, or did you, store any hazardous
material(s) greater than the threshold
quantities designated for each hazardous
material, at any time during:
(Current year and one year prior)?
9. For each hazardous material stored above the threshold planning quantity identified in #7
above, has your facility submitted a copy of the Material Safety Data Sheet for the hazardous
material to the appropriate authorities?
10. Has your facility submitted Emergency Hazardous Chemical Inventory Forms to the
appropriate authorities for the following years?
YES NO
For calendar year
For calendar year
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ENVIRONMENTAL ASSESSMENT
1. Is there any evidence of environmental impacts that haven't been addressed? Possible
examples include:
additional evidence of spills, leaks
vegetation damage in the surrounding area
odors in the surrounding neighborhood
neighborhood covered with "dusts"
poor water quality in streams near the facility.
2. Were there situations of possible excessive occupational exposures that should be referred to
the appropriate regulatory agency?
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Multimedia Inspection Protocols
APPENDIX B
Example Process Model for Process-Based
Multimedia Inspections
B-l
August 1998
-------
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FIGURE 1
PROCESS-BASED INSPECTION
FOCUS AREAS
RAW
MATERIALS
AIR EMISSIONS
AND CONTROLS
PROCESS
OPERATIONS
PRODUCTS OR
INTERMEDIATES
PROCESS WASTE
SOLIDS
PROCESS WASTE
LIQUIDS
DISPOSITION
DISPOSmON
-------
C/3
1
C
LU
en
o
OL
CO
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Multimedia Inspection Protocols
APPENDIX C
Example Questions from the United States Environmental
Protection Agency and Massachusetts Department of
Environment Facility-Wide Multimedia Inspection Program
c-i
August 1998
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Proposed Type B Protocol for
Facility-wide Inspections to Reduce
the Source of Toxics (FIRST)
Final Recommendation of the
DEP/EPA Region ! .FIRST Inspection
Protocol Workgroup
May 16, 1994
-------
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* TYPE E FIRST INSPECTION PROTOCOL *
TABLE OF • CONTENTS
1. Preface
2. Introduction
3. Procedural Outline
4. Inspection Guidance:
• General Facility Evaluation - Inspection Guidance #1.
• Water Waste Stream Evaluation - Inspection Guidance #2.
• Air Waste Stream: Air Quality Process Inspection
Guidance:
Approved (Permitted) Process Evaluation -
Inspection Guidance #3.
Un-Approved Coating and Printing Operation
Evaluation - Inspection Guidance #4.
Un-Approved Degreaser Evaluation - Inspection
Guidance MS.
Unapproved Combustion Activity Evaluation -
Inspection Guidance #6.
Un-Approved Plating Operation Evaluation -
Inspection Guidance #7.
Un-Approved General Process Evaluation -
Inspection Guidance #8.
Un-Approved Processes with a Fabric Filter Control
Device Evaluation - Inspection Guidance #9.
Un-Approved Processes with a Wet Scrubber Control
Device Evaluation - Inspection Guidance #10.
• Hazardous Waste Stream Evaluation - Inspection Guidance
#11.
• Pollution Prevention Opportunity Evaluation -
Inspection Guidance #12
• Hazardous Waste Accumulation Evaluation - Inspection
Guidance #13
Type B FIRST Inspection Protocol
Final Recommenaation 5/16/94
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6
7
Table cf Contents -- Continued
• Industrial Wastewater Treatment Evaluation - Inspection
Guidance #14 .
• Record Review Evaluation Guidance:
Industrial Waste Water Record Review Evaluation -
Inspection Guidance '#15.
Air Quality Record Review Evaluation - Inspection
Guidance #16.
Hazardous Waste Record Review Evaluation
Inspection Guidance #17
Toxics Use Reduction Act Record Review Evaluation -
Inspection Guidance #15.
Inspection Documentation Guidance:
• Examcle of Completed Inspection Documentation Form
• Blank Inspection Documentation Form
Appendix I. Air Quality Source Categories and Thresholds
Appendix II.
A) Toxics Use Reduction Act SIC Code List
B) Toxics Use Reduction Act Substance List
Aooendix III. Scope of Work for the DEP/EPA Region I Waste
Prevention FIRST Compliance and Enforcement
Workgroups
Appendix IV. Additional Workgroup Recommendations
Type 8 FIRST Inspection Protocol
Fin«; Recommendation 5/16/94
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* TYPE B FIRST INSPECTION PROTOCOL *
PREFACE
This Preface provides some context for the Type B FIRST
Inspection Protocol, and some working assumptions used by the
DSP/EPA Region I Waste Prevention FIRST Inspection Protocol
Workgroup to develop the protocol.,
I. TASK
The Waste Prevention FIRST Inspection Protocol Workgroup was
tasked with developing a protocol for DEP inspections conducted
according to the principles of FIRST (Facility-Wide Inspections to
Reduce the Source of T.oxics) . A FIRST inspection should determine
compliance with a facility's hazardous waste, air quality,
industrial wastewater, and Toxics Use Reduction Act requirements,
and gather information which could be used to encourage the
facility to practice source reduction.
In developing the inspection protocol, the workgroup was
expected to evaluate the costs and benefits of DEP's current FIRST
guidance (including current documentation requirements) and
recommend any improvements to inspection effectiveness and
efficiency. The workgroup was specifically directed by DEP's
Assistant Commissioner for Waste Prevention to consider the value
of conducting very in-depth inspections at a few facilities versus
doing more cursory inspections at a greater number of facilities.
The workaroup was expected to develop a protocol for one type of
inspection. " Furthermore, the resulting new- protocol was to be
developed without the constraints of current compliance inspection
Guidance. For more details see Appendix III which contains the
final Scope of Work for the DEP-/EPA Region I Waste Prevention .FIRST
Compliance and Enforcement Workgroups • (November 1993).
In the course of the workgroup's efforts, a number of
important issues emerged from the notion of an inspection hierarchy
and substantively altering the content of a compliance inspection,
including: 1) What should be the criteria for selecting the
content of each inspection type, 2) What is lost by not evaluating
certain aspects of compliance at the shorter, more focussed
inspections (e.g. level playing field issues), 3) What is the
appropriate mix of inspections, 4) How should facilities be
targeted, 5) How would enforcement be conducted at each inspection
type, and 6) How to account for the proposed inspection in the
present EPA grant structure? The workgroup was not charged with,
nor staffed to address these major issues. However, resolution cf
these issues is critical tc successful implementation of the
workgroup's proposal.
Tyoe B FIRST Inspection Protocol
Final Reconrnenaation 5/16/9i
-------
In order tc forge ahead with the task, the workgroup had tc
make certain assumptions on these and other issues. Many of these
assumptions _are enclosed (or are implicit) in this document. Other
assumptions can be found in the workgroup's earlier
rr.eetir.a summaries.
T T
WORKING'ASSUMPTIONS
The Workgroup recommends that the Bureau's compliance activity
should include a mix of inspection types of varying detail and
level of effort. The workgroup developed a general proposal for a
hierarchy of three inspection types, with the content of each
inspection type determined by the significance of risk posed by
non-compliance. The
hierarchy follows:
general recommendation of an inspection
Type A -
Type B -
Type C
-
The Type A inspection is a thorough evaluation of a every
aspect of a facility's regulatory compliance, perhaps
including an audit of compliance with record-keeping and
self-reporting requirements.
The Type B inspection would be a more detailed evaluation
of only those areas of non-compliance that are likely tc
result in a significant risk to public health and the
environment. The Type B inspection, ana the follow-up
thereto, would also gather information which can be used
to encourage facilities to practice source reduction --
particularly in order to correct violations. Type B
inspections would take more time to complete than Type C,
but significantly less than
Type A.
The Type C inspection would be a cursory scan for
imminent threats, significant areas of non-compliance
(including unregistered waste streams), and some obvious
minor infractions. The Type C inspection would be the
quickest of the three proposed inspection types to
complete.
What follows is the workgroup's recommendation for the content
of a Type B inspection. The workgroup elected not to build the
Type C since it could be developed relatively quickly by building
off existing screening checklists. The workgroup did not develop
the Type A because it would be a massive undertaking, and since the
Type A would probably be the least frequently performed inspection
type.
Note that one of the workgroup's greatest challenges was
attempting to develop the Type B in the absence of consensus on the
definition of significant risk, and without the context of the
ether two inspection types. The workgroup resolved this by relying
Type S FIRST Inspection Protocol
Finai Recofflmenaation 5/16/94
-------
heavily en the intuition of workgroup staff to select the
inspection content.
ELEMENTS CF THE FROT
.
This final protocol consists of two elements: guidance on how
to conduct the Type B FIRST inspection (including a detailed
explanation of the inspection elements) , and a recommendation on
the minimum inspection documentation required by DEP and EPA,
beyond our current reporting mechanisms (RCRIS, PCS, SSEIS, and
FMF) . The documentation will also serve as the primary inspection
field tool.
Note that additional related recommendations of the Workgroup
are enclosed as Appendix IV.
Type B FIRST Inspection Protocol
Final Recortwenaation 5/16/94
-------
* TYPE B FIRST INSPECTION PROTOCOL *
INTRODUCTION
Intent/Applicability
The intent of a Type B FIRST inspection is to determine
compliance with the Department's air quality, hazardous waste,
industrial wastewater, and Toxics Use Reduction Act regulations,
with a focus on abating violations causing current or likely
future significant risks. This inspection is formatted as a
facility-wide, process-based analysis which supports
comprehensive evaluation of compliance as well as identification
of significant pollution prevention opportunities.
This protocol is intended to be a guidance or reference
document outlining the procedure and minimum elements (e.g. what
items to look at and what compliance determinations to make) of a
Type B inspection. This protocol is not a checklist to be filled
out during the course of the inspection. Field staff should not
be expected to implement this protocol without proper training —
the protocol itself is not a stand-alone training tool.
This Type B protocol is designed for use at the majority of
facility-types inspected by DEP's Bureau of Waste Prevention
(BWP). Specifically, this applies to manufacturing and
commercial facilities, not waste management facilities (such as
TSDs, solid waste incinerators, etc.), utilities, fuel
dispensers, bulk fuel storage facilities, and others. The
protocol should be used for all classes of hazardous waste
generators, all categories of air sources, all types of
industrial wastewater dischargers, all potential and current
Toxic Use Reduction Act filers, and any combination thereof.
This is a process-based compliance inspection and does not
address compliance in areas not related to the process (e.g.
asbestos, cross-connections, storm water).
On-Site Inspection Procedure
Once on site, the field staff will gather information, and
make compliance determinations according to the attached Type p
FIRST Inspection Outline and subsequent InfrPeetion Guidance.
Gather the appropriate information by: 1) asking questions, and
2) making observations while conducting these activities in the
following order:
1. Pre-inspection Interview,
2. Process Area Tour (including observations made outside
Type B FIRST Inspection Protocol
Final Recommendation 5/16/94 6
-------
3.
the facility before, during, and/or after the interior
inspection),
Waste Management Area Tour (including hazardous waste
accumulation areas and waste water treatment areas),
4. Review of Records, and
5. Post-inspection Interview.
The field staff should gather as much information as
possible during the pre-inspection interview, and then use
subsequent activities to verify/challenge information obtained
during the interview, and to observe activities not discussed in
the interview. The information initially gathered during the
pre-inspection interview will include some elements from the
process, waste management, and record review portions of the
inspection guidance.
Type B FIRST Inspection Protocol
Final Recommendation 5/16/94
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* FIRST TYPE 3 INSPECTION' PROTOCOL *
?ROCEDTJ3A' OUTLINE
Pre-inspect:ion Activity: Conduct pre-inspection activities
as outlined in DEP/BW? Final Policy 94-3, "Pre/Post
Inspection Reporting Guidance." (This includes generating
the FXF Pre-Inspection Report, which is a useful field tool
and should be attached to the inspection report submitted to
the file.)
On-Site Inspection Activity:
A. Missing Information: Obtain any key missing
information-'from the pre-inspection file review
materials (including the FMF Pre-Inspection Report),
including SIC Code for all sources and UTM coordinates
for air sources.
B. Products Produced by Facility.- Identify/verify the
products/services produced by the facility,"in general.
C. General Facility Evaluation: Conduct a general
facility evaluation for issues like odors, visible
emissions, and evidence of on-site landfilling using
.Inspection Guidance £1 and note any violations.
D. Unit Operation/Process Evaluation: For each unit
operation or major process step, use the guidance below
and note any violations.
2.
3 .
4.
Obtain/Verify the Operation/Process Description
Obtain/Verify Condition of Operation cf the
process. Include Housekeeping.
Obtain/Verify Input Substances and Approximate
Quantities, e.g. for AQ and TURA threshold
determinations, if needed.
Outputs/Waste Streams:
a. Water Waste Stream:
1.
2.
Obtain/Verify the general nature of the
waste stream (what is it, why is it
generated?).
Follow Inspection Guidance #2 and note
ar.y violations.
Type S FIRST Inspection Protocol
Seconrtendation 5/16/9i.
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Procedural Outline - Continued
b. Air Waste Stream:
1. Obtain/Verify the general nature of the
waste stream (what is it, why is it
generated?).
2. Follow All Appropriate AQ-Process
Inspection Guidance and note any
violations:
* #3 for all Approved Processes
* #4 for Un-Approved Coating and
Printing Operations
* #5 for Un-Approved Deareasers
* #6 for Un-Approved Combustion
Activity
* #7 for Un-Approved Plating
Operations
* #8 for Un-Approved General
Processes
* #9 for Un-Approved Processes with a
Fabric Filter Control Device
* ftlO for Un-Approved Processes with
a Wet Scrubber Control Device
3. Take note if this is an un-approved
process with an afterburner,
electrostatic precipitator, carbon
adsorber, or other control device not
listed in B(2).
c. Hazardous Waste Stream:
1. Obtain/Verify the general nature of the
waste stream (what is it, why is it
generated?).
2. Follow Inspection Guidance #11 and .note
any violations.
d. Solid Waste/Special Waste Stream:
1. Obtain/Verify the general nature of the
waste stream (what is it, why is it
generated?).
5. Identify any media transfer of waste streams after
generation, particularly resulting from pollution
control/management techniques. For example,
scrubber water discharge, or routine use of
speedy-dry to collect waste oil. Evaluate all
such media transfer for compliance in accordance
with each media (items 4a, 4b, and 4c above).
Tyoe B FIRS7 Inspection Protocol
Final Recomnenaation 5/16/94
-------
Procedural Outline - Continued
'€ . _ Identify Potential Pollution Prevention
Opportunities (Follow Inspection Guidance
#12 '
E. Hazardous Waste Accumulation Evaluation: For each
hazardous waste accumulation area, obtain/verify the
information outlined on Inspection Guidance #13 and
note any violations.
F. Industrial Wastewater Treatment: For the industrial
wastewater treatment operation, obtain/verify the
information outlined on Inspection Guidance #14 and
note any violations. Also note any media transfers and
evaluate all such media transfer for compliance in
accordance with each media (items 4a, 4b, and 4c
above!.
Q. Record Review: Conduct a record review and
obtain/verify the information outlined in the
appropriate inspection guidance forms (#15, #16, fll"7,
and #18 ). and note any violations.
H. Communication of Inspection Results: Communicate to
the facility the results of the inspection, including
all obvious violations observed, general follow-up
procedures' (such as how results of the inspection will
be used and what further communications DEP may have
with the facility), any questions that remain to be
asked of the facility, and potential pollution
prevention opportunities. Note that all findings are
preliminary until reviewed by the field staff's
supervisor.
III. Post-Inspection Activity: Complete the Type B FIRST
Inspection Form (for guidance, see Example of Completed Tvce
B FIRST Inspection Documentation Form attached), and conduct
subsequent enforcement. Conduct post-inspection activities,
including all regular reporting to EPA and DEP (e.g. FMF,
SSEIS, RCRIS, PCS) as outlined in DEP/BWP Policy 94-3,
"Pre/Post Inspection Reporting Guidance." Note that the
Type B FIRST Inspection Form, along with any enforcement
documentation, 'replaces all inspection memos, trip reports,
and inspection checklists.
Type B FIRST Inspection Protocol
Final Recommendation 5/16/9i
-------
INSPECTION GUIDANCE #1
GENERAL FACILITY EVALUATION
Page 1 of 3
GENERAL AIR QUALITY EVALUATION
Describe the type and durations of any visible emissions
frorr. any process:
Color (black, white, blue, etc)
Opacity (0%, 10%, 20%, 30%, >
Duration (minutes)
40%)
EVALUATION CRITERIA: Visible emission (opacity) regulations
generically prohibit opacity greater than what is reasonable,
but in no case in excess of; 20 % opacity for incinerators;
0% for spark ignited internal combustion and diesel engines;
20% for more than 2 minutes per hour never to exceed 40 % for
other sources. Sources with written approvals may have lower
opacity limits. Water or water vapor is not considered in any
opacity evaluation.
Any observed opacity should be noted for color, intensity, and
duration. Enforcement of visible emission limits requires the
inspector to be certified by EPA for reading opacity and
r e quires documentation according to EPA Method 9.
2 .
Describe, in general, any detectable odors and/or noise
at the facility site and off-site:
EVALUATION CRITERIA: Both these items should be noted for
general purposes such as indication of control equipment
functioning, use of volatile materials, etc. Actual noise
quantification requires a calibrated noise meter and odor is a
subjective determination. A quantification of noise or odor
for compliance purposes is not part of this inspection.
Type 8 FIRST Insoection. Protocol
Final Recommenoation 5/16/94
-------
INSPECTION GUIDANCE #1
GENERAL FACILITY EVALUATION
Page 2 of 3
GENERAL AIR QUALITY EVALUATION -- CONTINUED
3. Air Quality Control Equipment Condition:
Is there particulate build up on stacks and surrounding area?
Is equipment rusting, leaking or structurally unstable?
EVALUATION CRITERIA: Any process or equipment not in good
condition which could affect the emission or control of air
pollution should be cited or referred for an approval
evaluation
GENERAL HAZARDOUS/SOLID WASTE EVALUATION
1. Is there any evidence of on-site burial of hazardous
waste?
2. Check the dumpster or other solid waste disposal staging
area for evidence of waste being disposed of as "solid
waste" that should be more stringently regulated?
Specifically, watch for hazardous wastes, or any
other industrial waste that in your judgement seems like
it could have an adverse impact oh the environment if
managed/disposed of as solid waste.
RAW MATERIAL STORAGE AREA
Is there evidence of a current or likely significant
threat posed in the raw material storage area(s)? (e.g
signs of spills or leaks -- particularly near floor
drains or other routes of emission.) Also look for
storage of VOCs in open container.
Type 8 FIRST Inspection Protocol
FinaS Recommendation 5/16/94
-------
INSPECTION GUIDANCE #1
GENERAL FACILITY EVALUATION
Page 3 of 3
FACILITY-WIDE O&M/HOUSE-KEEPING
Take note of operation & maintenance and house-keeping
throughout the facility, including process and waste-
management areas. Watch for sloppy housekeeping and poor
OSeM that could result in violations of applicable
regulations or significant 'environmental threats (refer
to"subsequent inspection guidance documents). Also note
that poor housekeeping/O&M >are often excellent source
reduction opportunities.
Examples of house-keeping/O&M areas to watch for:
• Malfunctioning pollution control/treatment equipment
(e.g. leaking pumps in the wastewater treatment
facility which are likely to impair treatment
effectiveness).
• Evidence of spills and mis-management of spills, and
other mis-handling of materials.
• Cleanup procedures which result violations and/or
preventable pollution (e.g. how are cleanup rags
managed and spent solvents managed).
Type 8 PIRST Insoection Protocol
Final Recomrnenaation 5/16/9i
-------
INSPECTION GUIDANCE #2
PROCESS WASTE WATER STREAM EVALUATION
Pacre 1 of 2
(1) Is water used in any process (including boiler blow down,
cooling water, washdown, etc.)?
(a) If yes, where is the water used in the process?
(2) Does the facility discharge waste water?
sanitary cooling water process wate?
boiler/cooling blowdown Other
(a) Where do the discharge(s) go? (e.g., surface
water, sewer system, subsurface system, ground,
holding tank for transport off-site, etc.)
(3) Locate all discharge points at the facility (e.g. floor
drains, sump pumps, blowdowns, cooling water, sanitary
waste, process waste water, etc.)
(a) Are all discharges covered by a permit?
(1) Discharge to surface waters
(2) Discharge to sewer
(3) Discharge to ground/subsurface system
(4) -Discharge to holding tank
(b) If the discharge is permitted:
(1) Has the discharge changed since the permit
was issued (e.g. have there been process
changes/additions that has resulted in changes
to the characteristics or volume of the
discharge since permit issuance?) If yes,
refer to DEP Permitting staff for possible
permit modification.
(2) Has the discharge permit expired?
Has the facility applied for a new permit?
Type B FIRST Inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE #2
PROCESS WASTE WATER .STREAM EVALUATION
(c) If the discharge (surface water,sewer, ground)
is not permitted describe:
(1) the source/type of the wastewater
generated.
(2) the approximate quantity of the wastewater
discharged.
(3) any observable impact of the discharge on
the environment (e.g, oil sheens, grease or
scum layers, foam, floatables, color, odors,
turbidity, fish kills, etc.).
(4) describe any wastewater treatment performed
at facility (including precipitation or pH
adjustment). ;
Refer to EPA and DEP Permitting for further
follow UD.
Type 8 FIRST inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE £3
AIR QUALITY: PROCESS - APPROVED SOURCES
Page 1 of 2
A written approval will specify equipment approved, operating
parameters, control equipment, etc. To be in compliance with
the approval, the process must be in compliance with these
conditions. Below are general conditions of an approval which
should be evaluated:
1. Process equipment manufacturer and model
2. Throughput limitations
Raw material type, amount, formulation-VOG limit, fuels,
etc
3. Control equipment manufacturer and model
With the continuing development of new standards, some older
approvals may be invalidated. The following two items should
be checked. If the answer to either is yes, the source should
be referred for an approval evaluation. The general
conditions listed above should still be evaluated in any case.
4. Is the approval for a process which is potentially
affected by VOC RACT rules? (In other words, does the
process fit the description cf one listed in the Appendix
I and was the approval issued before the date listed).
5. Is the approval for combustion units which are
potentially affected by NOx RACT rules? (In other words,
is total facility, not just the approved portion, a 50
TPY NOx source; approximately equivalent to 1I5,000,GOC
BTU/KR using Natural Gas, 80,000,000 BTU/Kr using
distillate fuel (#2), 30,000,000 BTU/Hr using residual
fuel (#4 or 6) and was the approval issued before
September 1993)
Tyoe B FIRST Inspection Protocol
fmai Recexmvendation 5/16/94
-------
INSPECTION GUIDANCE #3
AIR QUALITY: PROCESS ;- APPROVED SOURCES
Page 2 :of 2
EVALUATION CRITERIA:
General Conditions
If these general conditions are the same at the time of
inspection as that required in the written approval then no
further action is necessary for that process.
If discrepancies are found, a comprehensive inspection of the
process should be conducted and/or enforcement actions
initiated.
Approval Validity
If the approval was issued before the date of the latest
revision listed in the table, or is. a combustion facility
greater than the limits outlined above, then a new approval is,
likely necessary and the source should be referred for an
aocroval evaluation.
Type B FIRST Inspection Protocol
Finat Recommendation 5/16/9i
-------
AIR QUALITY: PROCESS - UN-APPROVED SOURCES COVER SHEET
According to the type cf process, refer LO one cf the following:
D Unapproved Coating and Printing
D Unapproved Degreasers (Cold, Vapor, Conveyorized)
D Unapproved Boilers/Combustion
D Unapproved Plating
D Unapproved General Process
Any incinerator should have a written approval and be
evaluated for compliance with the approval. If an
incinerator is found without an approval, it is a violation,
For unaoproved process*with contrcl equipment, refer to one of
the following:
D Unapproved fabric filter
D Unapproved wet scrubber
If one of the following contrcl devices is present, an
approval is likely necessary and the source should be
referred for approval evaluation:
D afterburner
D carbon adsorber
D electrostatic precipitator
D other
Note that an "Approval Evaluation" is often called fcr in the
Evaluation Criteria for the unapproved process/equipment
inspection guidance that follows.' These approval evaluations car
entail detailed engineering evaluations and applicability
determinations, and usually are not appropriate as a field
activity to be conducted by the FIRST inspector. These
evaluations are called for to provide partial closure on the
inspection and to cite the need for additional follow-up by more
specialized staff.
Tyoc B FIRST Insoection Protocol
Finai Recofrrtenaation 5/16/94
-------
AIR
INSPECTION GUIDANCE #4
PROCESS - UNAPPROVED COATING AND PRINTING
Define the source. The type of operation and the daily,
monthly or annual emissions determine the standards/emission
limits with which the process must comply or the need for
approvals.
1. Does the process fie the description of one listed in the
Appendix I.
2. Daily amount of coating or other compounds containing
organics used (maximum gallons used/day)
3. Yearly amount of- coating or!other compounds containing
organics used (gallons used in previous year)
4. Yearly amount of other compounds used (gallons- used in
previous year)
EVALUATION CRITERIA: Estimate daily, monthly and yearly
pounds of all organic compounds emissions by multiplying
organic compounds formulation usages (gallons) by 7.5 (a rule-
of-thumb is that organic compounds formulations contain 7.5
Ibs/gal) and assume all the organic compounds used are emitted
to the air. Other assumptions such as non-volatilized VOC and
recovered VOC amounts can be made at the inspector's
discretion, but must be verifiable.
If the process fits the description of a category (Appendix
I) , and has emissions that would make it applicable to the
category, the process needs to comply with the standards and/
or obtain an approval. Refer' the source for an approval
evaluation. -
If the process, regardless of the categories and
applicability, has emissions greater than ten (10) tons per
year, it should also be referred for an approval evaluation.
Tyoe B FIRST Inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE #5
AIR QUALITY: PROCESS - UNAFFROVED DEGREASERS
Page 1 of 3
Solvent: data
1. Name of solvent used
2. What percentage of the solvent is an organic (other than
water)
3. Monthly usage (gallons)
4. Annual usage (gallons)
EVALUATION CRITERIA: Any degreaser should meet the standards
listed in the subsequent sections.
If the degreaser uses greater than 100 gallons per month of
solvent (this does not include any amount sent out for
disposal or recycling) the unit may also need an approval and
should be referred for an approval evaluation. _
Generic (All Degreasers)
1. Storage of solvents in closed containers
2. No leaks
3. Provisions for draining cleaned parts before removing
from degreasers (drying tunnels, racking of parts, etc!
5. Units covered when not in use
Cold Cleaners
Solvent is unheated or not heated to boiling point. Cleaning
is accomplished by submersion of parts in the fluid. Most of
these units encountered will be unheated small parts cleaners
(such as safety-kleen, etc) and require no evaluation beyond
the Generic requirements.
Tyoe B FIRST Inspection Protocol
Fina, Recommendation 5/16/9*
-------
INSPECTION GUIDANCE #5
AIR QUALITY: PROCESS - UNAPPROVED DEGREASERS
Page 2 .of 3
Vapor Degreasing
Solvent is heated to produce vapors. Cleaning is
accomplished by submersion of parts in the vapor zone (and
sometimes into fluid). :
1. Easily operated cover which;does not disturb vapor zone
2. The following safety switches:
a. sump—s-h-ut-—off for condensor failure
b. spray pump shut off if vapor level falls 4" below
coils
3. One of the following:
a. freeboard ratio of at least 0.75
(if degreaser opening is greater than 10 sq ft then
the unit also needs a power cover).
or
b. refrigerated chiller
or
c. enclosed design
or
d. an adsorption system
or
e. approved alternative device
4. no porous or absorbent materials used
5. less than 1/2 open top area occupied by each work load
6. cover located below lip exhaust, if present.
freeboard ratio:
a. distance from the top of the liquid level to the.lip
of the tank (inches;
b. smaller interior dimension of length, width or
diameter (inches)
c. freeboard ratio (a/b)
Type B FIRST Inspection Protocol
Final Reconrwnaation 5/16/94
-------
INSPECTION GUIDANCE £5
-AIR QUALITY: PROCESS - UNAPPROVED DEGREASERS
Page 3 of 3
Conveyorized Degreasing
Description: Continuous process of cleaning parts. Heated
or unheated solvent used.
1. One of the following if the air/vapor interface is > 21.5
sq ft:
a." refrigerated chiller
or
b. an adsorption system
or
c. approved alternative device
2. The following safety switches:
a. sump shut off for condenser failure
b. spray pump shut off if vapor level falls 4" below
coils
Tyo* 3 FIRST Inspection Protocol
Final Recorroendatton 5/16/94
-------
INSPECTION GUIDANCE #6
AIR QUALITY: PROCESS - UNAPPROVED COMBUSTION SOURCES
Page 1 of 2
I Define the source. The type of combustion source and the
size (BTU/HR) are factors that determine the standards and/oi
emission lirr.its with which the process must comply (see
categories in Appendix I) or the need for approvals.
l. Type of combustion unit (boiler, internal combustion
engine, turbine, space heater, oven, etc)
2. Manufacturer
3. Rating (MMBTU/h*. heat input, gallons/hr of fuel, etc)
4. Type of fuel(s) used (oil, 'natural gas, coal, wood, etc!
5. Grade of fuel used (#2, 4, 6 oil, etc)
6. Sulfur content of fuel (% by weight)
7. Does the unit burn waste oil
8 For boilers, is opacity monitor present on units
> 40,000,000 BTU./hr that burn oil or solid fuel?
a. Are meters operational?
b. Is there an audible alarm?
Tyoe B FIRST Inspection Protocol
Final Recommendation 5/16/9-
-------
INSPECTION GUIDANCE #6
AIR -QUALITY: PROCESS - UNAPPROVED COMBUSTION SOURCES
Page 2 of 2
EVALUATION CRITERIA: If the unit;
a. is an emergency standby engine less than 10,000,000
BTU per hour and has an exhaust silencer (muffler) and a
stack discharge which will not impact the environment, it
is exempt from approval. (note: an emergency engine
cannot be used for load sharing, peak shaving or any
other circumstances. It can only be used when power is
disrupted to the facility and only for as long as the
outage remains)
b. is a part of a total combustion facility, excluding
internal combustion engines, that meets the criteria
below, it should be referred for an approval evaluation.
>. 40,000,000 BTU/HR using natural gas or propane
.> 40,000,000 ETU/KR using distillate fuel (#2)
>. 10,000,000 BTU/HR using residual fuel with a
sulfur content <. 0.5 % by weight
> 5,000,000 BTU/HR using residual fuel with a sulfur
content <. 1.0 % by weight
>. 3,000,000 BTU/HR using solid fuel (with an
automatic feeder for the fuel) or digester gas
.> i, 000,000 BTU/KR using hand fired solid fuel
c. is a part of a total combustion facility that meets
the criteria below, it should be referred for an approval
evaluation
>, 3,000,000 BTU/HR and is an internal combustion
engine (reciprocating or turbine)
Note that for any combustion source:
Residual fuel is prohibited in'any facility < 3,000,000
BTU/Hr.
Residual fuel > 0.5 % sulfur content is prohibited in
Arlington, Belmont, Boston, Brookline, Cambridge,
Chelsea, Everett, Maiden, Meaford, Newton, Somerville,
Waltham and Watertown without written approval.
Any facility utilizing waste oil as a fuel in any unit
other than a space heater must have written aooroval.
Tyoe B FIRST inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE #7
AIR QUALITY: PROCESS - UNAPPROVED PLATING EVALUATION
1. Type cf plating operations [ bright dip - electroless -
anodizing - acid/alkaline - etc]
2. Identify heated baths and baths with exhaust ventilation
3. Compounds used in plating tanks
4. Chemical make-up of compounds
5. Amount of chemicals used (gallons per year)
6. Are any organic ,-compounds or organic compound containing
materials used
7. Amount of organic compounds containing material used
(gallons/year)
8. • Is a scrubber used to control emissions
EVALUATION CRITERIA:
For process that use organic compounds, estimate emissions
from the source on a yearly basis. To obtain pounds of
organic compounds emitted multiply organic compounds usages
(gallons) by 7.5 (a rule-of-thumb organic compounds content
for organic compounds formulations is 7.5 Ibs/gal) and, if
appropriate, assume all the organic compounds used are emitted
to the air.
If the operation;
a. has organic compounds emissions greater than (10) tons
per year, it should be referred for an approval
evaluation;
b. has baths that are equipped with an exhaust
ventilation system and the process does not have a
scrubber, it should be referred for an approval
evaluation.
Type S F!RST Inspection Protocol
v Recommenoation 5/16/9i.
-------
INSPECTION GUIDANCE fc3
AIR QUALITY: PROCESS - UNAFPROVED GENERAL PROCESS
1. description of process
2. Type of equipment used
3. Raw materials used description1 (chemical name, not trade
names where possible)
4. Organic compounds content, if any, of raw materials
(Ibs/gal)
5. Hourly raw materials usage rate (indicate units: Ibs/hr,
gal/hr, etc)
6. Yearly raw materials usage rate (indicate units: Ibs/yr,
gal/yr, etc)
7. Finished product(s) description
8. Emissions
pollutant name
tons/yr
EVALUATION CRITERIA: From the information obtained in Section
I, estimate emissions from the source on a monthly and yearly
basis.
a. For process that use organic compounds, to obtain
pounds of organic compounds emitted multiply organic
compounds usages (gallons) by 7.5 (a rule-of-thumb
craanic compounds content for organic compounds
formulations is 7.5 Ibs :al) and, if appropriate, assume
all the organic compounds used are emitted to the air.
t>. F~_ other processes, an evaluation of emissions needs
to be conducted based on available information.
If the operation;
a. has organic compounds emissions greater than (10) tons
per year, it should be referred for an approval
evaluation;
b. has other emissions (paniculate, for example) greater
than one ton per year it should be referred for an
aDtiroval evaluation. ^==_——=—_____=
Type I FIRST Inspection Protocol
Final Reconroeiaation 5/16/94
-------
INSPECTION GUIDANCE #9
AIR QUALITY: PROCESS-- UNAPPROVED FABRIC FILTER
Fcr any process without an approval that has a fabric filter
(baghouse;:
1. Is there a pressure drop indicated .of at least one inch
water gauge?
2. Is equipment generally in good condition.
3. Is disposal of collected particulate.managed so as not to
expose the material.
4. Is unit exhausted internally (inside the building) or
through an external stack (tc the ambient air)?
MUH^ —
EVALUATION CRITERIA: Without knowledge of design.parameters
for the filter it is difficult to evaluate proper performance.
Design parameters can vary widely depending upon the pollutant
being controlled. In general results different than above
merit further investigation.
Type 8 FIRST Insoecf'or. Protocol
Finai Reconwenaatior. 5/16/9-
-------
INSPECTION GUIDANCE #10
AIR QUALITY: PROCESS - UNAPPRCVED WET SCRUBBER
For ar.y process without an approval that has a wet scrubber:
1. Is there water circulating through the unit and does it
appear to cover all packing in the unit.
2. Is there a pressure drop indicated of at least one inch
water gauge?
3. If scrubber water is recirculated and acids or alkalines
are in the air stream, is there a pH control.
EVALUATION CRITERIA: •• Without knowledge of design parameters
for the scrubber it is difficult to evaluate proper
performance. Design parameters can vary widely depending upon
the .pollutant being controlled. In general -; 3sults different
than above merit further investigation.
Type 8 FIRST Inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE #11
HAZARDOUS WASTE: PROCESS - VSQGs
Page 1; of 3
USE THIS PAGE FOR VERY SMALL QUANTITY GENERATOR ONLY
A Very Str.all Quantity Generator (VSQG) generates less that 100
Kas of hazardous waste or waste oil per month. (100 Kg is
approximately 25 gallons or 1/2 barrel.)
IF SQG OF WASTE OIL: USE SQG CHECKLIST
HW; PROCESS (VSQG)
HAZARDOUS WASTE ACCUMULATION
Does the generator accumulate hazardous waste on-site in
tanks or containers?
If yes,
Are containers in good condition?
Are containers closed when not in use?
Are containers properly labelled (with the words
"hazardous waste", the type of waste, the hazard
associated with the waste)?,
Does the facility generate any "P" wastes (acutely
hazardous) which are not allowed under VSQG status?
HW; RECYCLING ACTIVITIES (VSQG)
Does the facility recycle, reclaim or reuse any wastes
en-site?
Describe:
HW; RECORD REVIEW (VSQG)
Are all off-site shipments of hazardous waste documented?
(All documentation should be reviewed.)
Type 8 FIRST Inspection Protocol
Final Recommendation 5/16/9i
-------
INSPECTION GUIDANCE #11
HAZARDOUS WASTE: PROCESS - SQGs and LQGs
Page 2 of 3
SMALL AND LARGE QUANTITY GENERATOR QUESTIONS
A Large Quantity Generator (LQG) generates 1000 kgs of hazardous
waste or more per month. The waste must be shipped in 90 days.
There is no limit to the amount which can be accumulated
A Small Quantity Generator (SQG) generates between 100 and 999 kg
of hazardous waste per month. The waste must be shipped in 180
days and is limited to 6000 kg in tanks and 2000 kg in above
ground containers.
(100 kg approx. 25 - 27 gallons)
This document can be used for both SQG and LQG inspections. If
the company is a LQG, address all questions. If the company is a
SQG address all questions except those followed by "LQG ONLY."
IMPORTANT NOTE FOR PERSONNEL TRAINING AND CONTINGENCY/EMERGENCY
PLANNING REQUIREMENTS: A detailed review of completeness (as
outlined in DEP's existing hazardous waste generator inspection
guidance) should be performed the first time a facility is
inspected and at least every fifth year thereafter.
IMPORTANT NOTE FOR MANIFEST REQUIREMENTS, EXPORTING REQUIREMENTS,
AND LAND DISPOSAL RESTRICTIONS:• During a Type B inspection, only
conduct a detailed evaluation of documentation completeness and
accuracy if warranted. (For guidance on conducting a detailed
evaluation of these items, see existing inspection guidance for
hazardous waste generators, land disposal restrictions, and
exporting requirements.)
Type B FIRST inspection Protocol
Final Recommendation 5/16/94 30
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INSPECTION GUIDANCE
HAZARDOUS WASTE: PROCESS - SQGs and LQGs
Page 3'of 3
(1) Has the facility instituted the use of proper emergency
equipment and information?
•internal communications or alarm system
•telephone or two-way radio to call emergency response
personnel
•fire extinguishers, fire control equipment, spill
control equipment and decontamination equipment
•markings identifying all exits
•up-to-date list's posted near every phone at generation
sites containing: names and number of emergency
coordinators; locations of fire extinguisher, control
materials and alarms; telephone number of fire-
department; and evacuation routes.
(2) Does the facility handle ignitable, reactive or
incompatible (see incompatible attachment) waste?
If yes, are the above wastes properly handled and
segregated?
Properly Segregated (ignitable or reactive):
Separated from sources of ignition or reaction, such as;
• open flames, smoking, 'cutting and welding, hot
surfaces, frictional heat, static electricity,
spontaneous- ignition, radiant heat
Properly handled:
While handling, shall confine smoking and open flames.
"No Smoking" signs shall be posted where there is
potential for a possible hazard.
Properly Segregated (incompatible):
Separated from incompatible by means of a dike, berm,
wall or other device?
Tyoe S FIRST Insoection Protocol
Fina. Recontnenaatior. 5/16/9-
-------
INSPECTION GUIDANCE #12
POLLUTION PREVENTION
Lock for (obvious/significant) F2 opportunities at each
process:
General: Items not related to any one particular
process such as covering of solvent containers to
reduce evaporation, drip boards to reduce drag out,
housekeeping improvements, etc. (Note that any
evidence of spills/leaks indicates a process
inefficiency and a P2 opportunity.)
Specific: Items specific to the process at the
facility -such as replacement of solvent cleaner with
aqueous, use of low or no VOC coatings, etc.
Consider all obvious/significant P2, including TUR, solid
waste, water, and energy.
Consider each generation point when thinking about P2.
Specifically, why is this waste being generated and what
has been considered/could be done differently to reduce
it at the source?
Communicate P2 information/opportunities via any of the
following applicable mechanisms:
Orally communicate general and/or specific F2
opportunities while at facility.
Distribute general P2 literature while at the
facility emphasizing the importance of the facility
conducting it's own efficiency/P2 self
evaluation/planning process.
Distribute promotional literature on the
Massachusetts Office of Technical Assistance (OTA).
Through distribution of industry-specific or
process-specific prepared literature (OTA case
studies, other sources) to show real-world
applications.
In compliance letters.
In enforcement products:
A.
B.
C.
c.
D.
E,
NON cover letters (see DEP/BWP Boilerplate
NON) ,
2. In the body of higher enforcement (ACOs),
3. Copying all enforcement documents to OTA, who
then contact the facility and ask if they can
provide their services.
Type 8 FIRST Inspection Protocol
Final ReccflFtendatior 5/16/94
-------
HAZARDOUS WASTE
INSPECTION GUIDANCE #13
ACCUMULATION AREA EVALUATION - SQGs and LQGs
Paae I of 2
(1) Does the generator accumulate hazardous waste at or near
a generation point (satellite accumulation)?
If yes,
Are containers in good condition (no severe rusting,
structural defects or leaks)?
Are containers closed when not in use?
Are containers properly labelled (with the words
"hazardous waste," the type of waste, and the hazard
associated with the waste)?
(2) Does the generator accumulate other hazardous waste on-
site in tanks or containers?
If yes,
Are containers in good condition?
Are containers closed when not in use?
Are containers properly labelled (same as in question 4
above, but must also include the accumulation start
date)?
If stored outside:
Is area sufficiently impervious to contain leaks, spills
and precipitation until the material is detected and
removed (generally, there should be no; wood or dirt
floors, cracks, gaps, seems, or floor drains)?
Is there sufficient secondary containment (10% of total
volume of waste contained in the area, or 110% of the
volume of the largest container, whichever is greater?)
Is unauthorized entry prevented (By means of a fence,
locked area, or 24 hour guard to; prevent unknowing entry
of persons, reduce the potential of unauthorized entry of
persons and to prevent the entry of livestock)?
If no liquid waste in the hazardous waste accumulation
container:
Is area sloped or designed for drainage? OR
Are containers or tanks protected from contact with
accumulated liquid (such as rain water)?
Type B FIRST Inspection Protocol
Final Recommendation 5/16/9*
-------
INSPECTION GUIDANCE #13
HAZARDOUS WASTE: ACCUMULATION AREA EVALUATION - SQGs and LQGs
Page 2 cf 2
HAZARDOUS WASTE ACCUMULATION (CCNT.)
(3) Is there sufficient aisle space between containers if
hazardous waste to allow for the unobstructed movement of
personnel and emergency equipment (to inspect or allow for
spill or fire control)?
(4) Does the generator have underground accumulation tanks?
Is the tank made' of non-corrosive material?
Has the facility installed leak detection equipment (see
attached waste oil sheet)?
• For hazardous waste (non-waste oil) underground
accumulation tanks, see 310 CMR 30.690.
HW: RECYCLING ACTIVITIES (SQG/LQG)
(1) Does the facility recycle, reclaim or reuse any wastes
en-site?
Tycx 8 FIRST Inspection Protocol
Final Recommendation 5/16/94
-------
INSPECTION GUIDANCE .#14
INDUSTRIAL WASTEWATER TREATMENT FACILITY EVALUATION
(FOR PERMITTED DISCHARGES ONLY)
(1) Have there been any changes in treatment performed at the
facility? If yes, refer to permits staff for possible
permit modification.
(2) Does the facility monitor its discharge as required by
its permit?
(3) Treatment Facility Effectiveness
(a) Is there evidence of current or past upsets,
bypasses,-overflows, clogging, or erosion?
(b) Does the effluent have odor, color, turbidity?
(4) Treatment Facility Staffing
Describe staffing at the treatment facility including the
number of operators and laboratory personnel and their
certifications. (Check current staff levels against
staffing plan.)
(1) Is certified operator on-duty at all times
facility is discharging?
(2) Is operator certified at the proper grade for
the facility?
(5) Treatment Sludge Management!
Is there a sludge generated from the wastewater
treatment? If yes, is it hazardous? (the facility is
required to make this determination). Is the sludge
being managed properly?
Type B FIRST Inspection Protocol
Final Recommendation 5/16/9*
-------
INSPECTION GUIDANCE #15
INDUSTRIAL WASTEWATER: RECORD REVIEW
(FOR PERMITTED DISCHARGES ONLY)
(1) Are there flow or concentration violations? Compare
permitted values against actual reporting results
Describe all violations that are found.
Tyos B HRS* Inspection Protocol
F'ia ResorTneTditior 5/16/9-
-------
INSPECTION GUIDANCE #16
AIR QUALITY: RECORD REVIEW
2.
Are total emissions from the entire unapproved facility
are greater than ten (10) tons per year of all organic
compounds? If so, refer the'facility for an approval
evaluation.
If the facility did not file a Source Registration,
should the source be referred for Registration/Inventory
filing (above thresholds in 310 CMR 7.12)?
Type 8 FIRST Inspection Protocol
v Recommendation 5/16/94
-------
INSPECTION GUIDANCE £17
HAZARDOUS WASTE: RECORD REVIEW
(1) Are manifests used for all hazardous waste shipped
off-site and retained for three years from the date of
shipments (manifests should be reviewed for at least
three random months)?
Has the generator exported any wastes out of the United
States?
Does the generator complete Land Disposal Restriction
notifications (LDR notifications are u.sed to indicate to
the receiving facility that the generator's waste is
restricted from land disposal (** except for waste oil
and PCBs **)?
(2) Does the owner/operator have a written personnel training
plan? (LQG ONLY)
(3) Has the owner/operator conducted annual training?
(LQG ONLY)
(4) Does the facility have a contingency plan?
(LQG ONLY)
Has the plan been updated (if; the plan fails in an
emergency, the emergency coordinators change, the
emergency equipment changes, there is a change in
operation or maintenance at the facility)?
Has there been an emergency in which the plan was used?
If yes, were all applicable requirements and response
measures followed (e.g. releases reported, spill cleaned
up and managed/disposed of properly, etc.)?
Tyt* B FIRST Inspection Protocol
Final Recommendation 5/16/9;.
-------
INSPECTION GUIDANCE #18
TURA: RECORD REVIEW
Page 1 of 2
Has the facility.ever filed a MA Annual TUR Report for Toxic
Substance Use? (Fed-Form R, State-Form S and State-Fee)
Yes
(Go to Box 2
No' (Go to Box 1)
Does the facility need to file a MA TUR Report?
A Are there 10 or more full time employee equivalents?
(2JOOO hrs/year/employee full or part-time including consultants)
B Are activities within Standard Industrial
classification (SIC) Codes 20 - 39, 10 - 14, 40, 44 - 51,
72, 73 and 76? 25,000
Ibs. or otherwise use ^10,000 Ibs. of at least one toxic-
flY thVc'SanVis uncertain about usage, ask them to evaluate amounts «cording to the Form S
Guidance and send a written notice to inspector indicating whether or not they need to file.
Manufacture - make a chemical; Process - incorporate a chemical into a product;.Otherwise use -
chemical not incorporated into product (e.g. used for cleaning).
Toxic chemicals - SARA 313 and CERCLA chemicals • See Appendix II.
Note: Count toxic chemicals in pure form and in mixtures. Look at each eon«^"*n^1? • ,
mixture add the content of the constituent m the mixture to the amount of the cnemicai in
p^re form (if any) to determine if together they exceed the threshold. See MSOSs and
purchase/use records, if needed.)
D Does the facility manufacture, process or otherwise
use ^10,000 Ibs. of any other toxic substance(s)?
Fo-- C and D., if yes, note the most recent year the
toxic substance(s) was used, the toxic substance(s) and
approximate amounts:
Year
Toxic Substance(s!
Type B FIRST Inspection Protocol
Finai. Recommenaation 5/16/94
-------
INSPECTION GUIDANCE £15
TURA: RECORD REVIEW
Page 2 of 2
Box 2 - Companies who have Filed TURA Annual Reports
A. Indicate,the year the toxic substance(s) was used and
the toxic substance(s) in the last TUR annual report:
(This information is on the pre-inspect ion report.)
Year
Toxic Substance(s)
B. Did the facility fail to file a TUR report for any
Other tOXiC Substances > 10,000 IbS . ? (Look at pure chemicals and
mixtures in alt parts of the plant including storage and handling, process lines, cleaning
operations and waste management.)
If yes, note the most recent year the toxic substance's)
was used, the toxic substance.(s) and approximate amounts
Year
Toxic Substance(si
C. Does the facility have a TUR plan on-site that has
been certified by a Toxics Use Reduction Planner and a
Senior Facility Manager?
D. For one chemical in one production unit, review for
accuracy and conformance with standard engineering
practice the calculations and documentation for use,
byproduct, and BRI/ERI . (For a complex facility, an inspector may expect to
find some of the following supporting documentation: purchase records, job sheets, inventory
sheets, hazardous waste manifests, air source registration forms, air & water monitoring
records etc. If the calculations and supporting documentation are not available, or sketchy,
then a Type A inspection may need to be done.)
E. For selected production unit/chemical combinations,
does the TUR plan include process flow diagrams and a
list of potential TUR options that were eithe'r
implemented immediately, rejected or studied further?
(If the plan does not include these two elements or if the process flow diagrams look less
detailed than the process observed or if the list of options seems to exclude "obvious" TUR
techniques that weren't already installed, then a Type A inspection may nwd to be done.)
Type S FIRST Inspection Protocol
Fma. Recontneneation 5/16/9w
-------
Multimedia Inspection Protocols
APPENDIX D
Example of Multimedia Checklist for Printing
Operations Incorporating Pollution Prevention
(from USEPA, September 1995)
D-l
August 1998
-------
-------
MULTIMEDIA COMPLIANCE/POLLUTION PREVENTION ASSESSMENT
CHECKLIST FOR LITHOGRAPHIC PRINTERS
Date and Time of Inspection:
Facility Name And Address
Facility Contact
(Name, title, and phone)
Inspector (s):
Name
'Title/Affiliation
Phone Number
November 1995
-------
TABLE OF CONTENTS
Page
I. GENERAL FACILITY INFORMATION A-l
A. General Facility Operations A-2
B. Wastewater A-5
C. Air A-6
D. Emergency Planning and Community Right-to-Know A-8
E. EPCRA Section 313 - Toxic Release Inventory A-9
F. Hazardous Wastes A-9
G. Toxic Substances Control A-12
II. PROCESS EVALUATION A-12
A. General Housekeeping/Materials Storage A-12
B. Image Processing A-14
a. General A-14
b. Process Solutions A-15
c. Silver Recovery A-16
d. Used Film A-17
e. Innovative Technology (Web Printing) A-17
C. Platemaking A-18
a. General A-18
b. Waste Solutions A-19
c. Innovative Technology A-20
D. Printing A-20
a. General A-20
b. Waste Ink and Empty Ink Containers A-21
c. Fountain Solutions A-24
d. Paper Wastes A-25
e. Other A-25
f. Innovative Technology (Web Printing) A-26
E. Cleaning Activities A-26
a. General A-26
b. Spent Cleaner A-27
c. Shop Towels A-29
F. Finishing A-30
III. WASTE HANDLING AND MANAGEMENT A-31
A. Wastewater Management A-31
B. Hazardous Solid Wastes Management A-32
C. Air Emissions Management A-35
11
November 1995
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ACRONYMS
BACT best available control technology
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CESQG conditionally exempt small quantity generator
EHS extremely hazardous substance
EPCRA Emergency Planning and Community Right-to-Know Act
ESR electrolytic silver recovery
HAP hazardous air pollutant
IPA isopropyl alcohol
LAER lowest achievable emission rate
LEPC Local Emergency Planning Committee
LQG large quantity generator
MSDS material safety data sheet
NPDES National Pollutant Discharge Elimination System
NSR new source review
P2 pollution prevention
POTW publicly owned treatment works
PSD prevention of significant deterioration
PTE permanent total enclosure
RACT reasonably available control technology
RCRA Resource Conservation and Recovery Act
SERC State Emergency Response Commission
SQG small quantity generator
VOC volatile organic compound
WWTP wastewater treatment plant
iii
November 1995
-------
GLOSSARY
Best Available Control Technology (BACT)
Technology required pursuant to Part 165 on new major sources and major modifications
subject to prevention of significant deterioration (PSD) requirements, which reflect best
controls in use taking into account costs and other non-air quality factors.
Lowest Achievable Emission Rate (LAER)
Degree of control required pursuant to Part 173 on new major sources and major
modifications in nonattainment areas; technology must be best in use or most stringent in any
State Implementation Plan.
Major Source
Stationary source in an ozone transport region that emits or has the potential to emit at least
50 tons per year of volatile organic compounds (VOCs).
New Source Review (NSR)
Program for pre-construction review of new major sources and major modifications under
prevention of significant deterioration (PSD) and nonattainment requirements.
Nonattainment
Program established pursuant to Part D of Title I requiring controls necessary to attain
National Ambient Air Quality Standards (NAAQSs) in areas currently not meeting them.
Prevention of Significant Deterioration (PSD)
Program established under Part C of Title I to preserve air quality in areas already meeting
National Ambient Air Quality Standards (NAAQSs).
Reasonably Available Control Technology (RACT)
Technology required pursuant to Part 172 to be installed on existing major sources in
nonattainment areas; reflects controls EPA has identified in control technique guidelines
(CTGs) or other guidance.
iv
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
t GENERAL FACILITY INFORMATION
A. General Facility Operations
(1) When did the facility begin operations?
(2) Have there been previous printing operations at this location?
(3) What are the facility's hours of operation?
(4) What types of printing is done at the facility?
Heatset
(5)
Yes
No
Nonheatset Sheet
Nonheatset Web
Describe the printing system. Complete schematic on page A-2 by listing raw materials used
and wastes generated for each process/activity. If possible, obtain a copy of a schematic or
process diagram from the facility.
Complete Table 1 (pages A-3 and A-4) by listing wastes generated by process/activity,
quantity generated, disposal method, and whether the waste is hazardous or nonhazardous.
A-l
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION {Continued)
A. General Facility Operations (Continued)
Schematic of Printing Operations (Example Diagram Included)
Raw Materials Wastes Generated
linage
Processing
Proof
Platemaking
Makeready
Printing and
Drying
Finishing
Final Product
Housekeeping
A-2
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
o
°-
T3
.
3
I
1
be-
1
&
«
S
A-3
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
1
s!
azardous
i-hazardo
rTJ o
C
s
•e*
o
5
«
*S
V)
1
p
ty Generated
r Month
33
•a
S3
AH
W
fcJC
If
11
C "3
O a,
SS
PH
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I,
FACIUTY INFORMATION (CoBtraued)
A. General Facility Operations (Continued)
(7) Has a pollution prevention or waste minimization plan been developed by the
facility?
If yes, under which program(s)?
Yes
No.
Yes
Ho
(8) Has the facility evaluated which wastes are probable candidates for reductions
through pollution prevention activities (i.e., has the facility identified or
implemented any process chemical changes to reduce air emissions or
hazardous waste generation)
If yes, list the wastes and describe pollution prevention activities currently being undertaken.
(9) What type of training activities are conducted at the facility?
(10) Have employees been trained in the fundamentals of pollution prevention?
Yes
No
B. Wastewater
(1) Does the facility discharge wastewater into:
Surface Water?
Municipal Sewer?
Subsurface
System?
Receiving Stream
NPDES Permit No.
Q Name of WWTP
Permit No. (if applicable)
[] Type
A-5
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I.
B.
(2)
GENERAL FACILITY INFORMATION (Continued)
Wastewater (Continued)
In the following table, indicate the volume of wastewater discharged by type and disposal
method.
Wastewater
Type
Sanitary
Process(es)
Noncontact Cooling
Storm Water
Other
Total
C.
(1)
(2)
Surface
Water
Municipal
Sewer
Disposal
Subsurface
System
Other
Notes to Inspector;
If the facility does not know the volume of its sanitary -waste du
multiplying the number of employees by the residential equivalent at
day per worker.
Storm water discharges only apply to outdoor, exposed industrial an
as areas where material handling equipment or activities f raw mater
products, waste materials, by-products, or industrial machinery art
•charge, it can be estimated by
tits estimate of '25-$$ gallons per
eas. Industrial areas are defined
ials, intermediate products, final
' exposed to storm water.
Air
Is the facility located in an area designated as nonattainment for the National
Ambient Air Quality Standard for Ozone?
Is the facility designated as a major source of:
• VOCs?
• NOx?
• Hazardous Air Pollutants (HAPs)
IHliB
illi'lS^I
A-6
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. 0ENERAL FACimT INFORMATION (Continued)
C. Air (Continued)
(3) If yes, is the facility subject to applicable Reasonably Available Control
Technology (RACT) requirements for lithographic printers?
Yes
No
(4) Indicate types and estimated amounts of air emissions (e.g., VOCs) from various sources.
Type of Emissions
(e.g., VOCs)
Source
(e.g.» Cleaning Tank)
Amount
Notes to Inspector: , ,„„' " -
The mass balance method can be used to estimate VOC emissions. An example of a mass batame to
calculate VOC emissions is presented below:
Example: A printer's Chemical usage for one year is ink (10,000 lbs> 15% VOC content)) alcohol
(1MO gallons, density 6,0 ths/gallon), mdpress wash (1>QW gallons, 50% VOC and specific gravity
0.7). 10& lb& of ink are disposed of in -waste shipments,
t
first, determine how many pounds of each chemical is med,
ink = 10,000 Ibs
alcohol - J,0&0 gallons x 6 Ibs/gallon - 6,000 Ibs
press wash = 1,006 gallonsx(Q,7x 8.34 Ibs/gal) = 5,838Ibs
Next, determine the annual amount of VOCs used by multiplying the pounds used by the VOC fraction.
ink ~ 10,000 Ibs x 0.15 ~ 1,500 Ibs
" alcohol = 6,000 Ibs x 1.0 = 6,000 Ibs
press -wash = $,8$$ Ibs xO.$ = 2,919 lbsr
Emissions of VOCs can now be estimated by subtracting the disposed amount (or the amount remaining
with the proditct) from the amount used.
discarded ink = WQ Ibs x # 1$ = 15 Ibs
1,5W Ibs (from second step) -15 Ibs = I.4SS tbs
press -wash disposed of in ,
cleaning cloths - 5GQ Ibs
2,912 (from second step) ~ (5GO Ibs x &5) = 2,649 Ibs.
Total VOC emissions are 1,485 Ibs (ink) + 6fOO&Jbs (alcohol) -f- 2,669 Ibs (press wash) -10,154
A-7
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
C. Air (Continued)
(5) Was equipment installed under New Source Review requirements?
If yes, to which of the following is the equipment subject? Check the one that applies.
Major source best available control technology (BACT) requirements under prevention
of significant deterioration (PSD)
Lowest achievable emission rate (LAER) requirements for nonattainment areas
Minor source State or local new source review (NSR) requirements
(6) Does the facility have a permit?
Permit ID
Yes
No
If yes, does the permit cover any of the following activities? Check any that apply.
Construction/operation of presses, control devices, distillation units and proofing
and/or binding equipment
Operation of existing presses, control devices, distillation units and/or proofing and
binding equipment
Modification of existing equipment or changing materials (e.g., inks, fountain
solutions, cleaning solvents, etc.)
D. Emergency Planning and Community Right-To-Know
(1) Does the facility have on-site any of the Extremely Hazardous Substances (EHS)
in excess of the established threshold planning quantities?
If yes, list substances.
(2) If hazardous chemicals are present in excess of 10,000 Ibs., have the
material safety data sheets (MSDS) (or a list of chemicals) and chemical
inventory forms been submitted to State and local emergency planning
authorities and fire departments?
N/A
Yes
No
A-8
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
X,
D.
(3)
(4)
(5)
E.
(D
(2)
F.
(D
GENERAL FACILITY INFORMATION (Continued)
Emergency Planning and Community Right-To-Know (Continued)
N/A
Was the State Emergency Response Commission (SERC) and Local
Emergency Planning Committee (LEPC) notified of the presence of
Yes
No
hazardous chemicals for local planning purposes?
Has the facility released an extremely hazardous substance (EHS) or a CERCLA
Yes
No
hazardous substance in excess of the Superfund reportable quantity?
• If yes, was notification of the release provided?
• To whom?
Yes
No
• Was notification oral or written?
• Was oral notification followed up by written notification?
Does the facility have Material Safety Data Sheets (MSDS) readily available
for all hazardous chemicals used? (OSHA requirement)
Yes
Yes
No
No
EPCRA Section 313 - Toxic Release Inventory
Does the facility have ten or more full-time employees?
Did the facility use more than 10,000 Ibs. of at least one toxic chemical
during a previous calendar year?
N/A
If yes, did the facility file a Section 313 Toxic Chemical Release Inventory
Yes
Yes
No
No
Yes
No
Form R for the chemical(s)?
Hazardous Wastes
Does the facility generate hazardous waste from printing activities?
!•
llli
-
A-9
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
(2) Does the facility have an EPA ID No.?
EPA ID No.:
(3) Is the facility's waste determination method (i.e., to determine whether
a waste is hazardous or nonhazardous) adequate?
(a) Does the facility determine if its waste is excluded from regulation under
Part 261.4(b) (i.e., solid wastes which are not hazardous wastes, such as
household waste)?
(b) If no, does the facility determine if the waste is listed in Part 261,
Subpart D (examples of listed wastes typically found in the printing
industry include tetrachloroethylene, methylene chloride, xylene, and
acetone)?
If yes, does the facility determine if the waste has been excluded
from the lists in Subpart D or Part 261.3 in accordance with 260.20
or 260.22 (which allows petitions to amend Part 261 to exclude a
waste produced at a particular facility)?
If no, does the facility determine if the waste exhibits any of the
characteristics specified in Part 261, Subpart C (for example,
characteristics of ignitability, corrosivity, reactivity, and EP toxicity)?
(4) Is the facility a
Yes
No
Yes
No
Yes
No
Large quantity generator?
Small quantity generator?
Conditionally exempt small quantity (CESQG) generator?
A-10
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I, GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
Notes to Inspector:
Check amounts in Table I to determine appropriate classification, for facility,
Large quantity generator (LQG) generates WOOkgs (2200 Ibs) of hazardous -waste (SW) or more per
month. The waste must be shipped in 90 days and there is no limit to the amount that may be
accumulated.
Small quantity generator (SQG) generates between 100kg (220 Ibs) and 1000kg (2200Ibs) nonacute HW
in a calendar month. The waste must be shipped in 180 days: and is limited to accumulating no more
than 6000kg (33200 Ibs) ftWon~$ite.
A conditionally exempt small quantity generator (CESQG) generates no more than 100kg {220 Ibs) HW
in a calendar month and accumulates less than 1000kg {2200 Ibs) on-site; OR, generates less than 1kg'
(2,2 lb$) acute ffWtn & calendar month and accumulates less than tOOkg (220 &£> acute HW,
N/A
(5) Excluding CESQGs, are the hazardous wastes at the facility consistent with
generator notification records (i.e., are wastes generated for which
the facility has not notified State or EPA?)
(6) What are the hazardous wastes management practices? Check all that apply.
On-site: Satellite Accumulation
Container storage
Tank storage
Treatment
Disposal
Other
(7) If the facility ships hazardous wastes off-site, is a manifest system used?
D
Yes
No
Yes
No
A-ll
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I. GENERAL FACILITY INFORMATION (Continued)
F. Hazardous Wastes (Continued)
(8) Does the facility generate wastes that are restricted from land disposal
(i.e., liquid hazardous wastes having a pH < 2.0; liquid hazardous wastes
containing halogenated organic compounds at ^ 1,000 mg/L)?
If yes, does the facility comply with Part 268 for land disposal restricted wastes?
''•'•'''•' '•'<'j*i'*,''' •''-'• • '•''
Yes
Yes
G. Toxic Substances Control
(1) Does the facility import any chemical substances (e.g., ink)?
N/A
If yes, has the facility completed the appropriate certification statement?
Yes
Yes
No
No
,
II. PROCESS EVALUATION \ „ \ ,:
'.
A. General Housekeeping/Materials Storage
Note to Inspector: »- J -
Check Table 1 (let> Sitmmaty of Wastes Generated, Quantity, and Disposal methods) to verify -wastes
generated as yoit complete this section of the checklist, v
(1) Note any potential or actual problems regarding housekeeping and storage (e.g., a
hazardous and nonhazardous solid wastes, and wastewater).
(2) Is the shop clean and orderly to prevent accidents and spills?
(3) Does the facility use spigots and pumps when dispensing raw materials?
ir emissions,
Yes
Yes
No
No
A-12
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II, PROCESS EVALUATION (Coatinuea)
A. General Housekeeping/Materials Storage (Continued)
(4) Does the facility use funnels for transferring wastes to storage containers?
(5) Does the facility implement dry methods for cleanup whenever possible?
(6) Does the facility have a spill prevention plan?
No
Yes
Yes
Yes
No
Note to Inspector?
Some. POWs may require, -printing facilities to develop spill'prevention (or slug control} plans that
include the following;
• Description of discharge practices, including non^routine batch discharges
• Description of stored chemicals
* Procedures for immediately notifying the POTW of slug discharges
* Procedures: to prevent adverse impacts from spitts
(7) Are there any floor drains leading directly to the sewer where the solvent or ink
is stored?
Yes
No
If yes, in the event of a spill, will contaminants enter the floor drains?
Yes
No
If yes, what is the characteristic of wastewater contained in the floor drams and where do the
floor drains discharge?
(8) Does the facility use a "first-in first-out" policy to avoid the expiration of raw
materials?
(9) Are infrequently used materials ordered in small containers?
Yes
No
Yes
No
A-13
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II.
A.
PROCESS EVALUATION (Continued)
General Housekeeping/Materials Storage (Continued)
(10) Are frequently used materials ordered in large containers?
(11) Can the facility store products in locations that will preserve their shelf life?
N/A
(12) If materials have exceeded their shelf life, are alternative uses considered
before discarding?
N/A
(13) Does the facility purchase materials from manufacturers that will accept
B.
(1)
returned materials if shelf lite is exceeded?
Image Processing
a. General
Is image processing done at the facility?
Yes No
®:iEpi?™ Mffiiii
ifei:;;l:!ii
Yes No '
Yes No
ilfllllll
Note to Inspector: ,"v", , ' ' ' ' ,';
Check Table I (Le., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify "wastes
generated as you complete this section of the checklist,
Typical wastes from image processing include the following: used film, process solutions containing
photographic chemicals (fixer and developer) and silver (dissolved from processing film).
Typical hazardous wastes generated from imflge processing include: developers and fixers. Most'
developers contain levels of hydroquinone. If disposed of as an unused product it may be defined as
a hazardous -waste in applicable State regulations due to the concentration of hydroquinone. If the
hydroquinone is consumed daring use and does not show up in used developer, it is not considered
hazardous. Fixers which allow silver to dissolve out of the film and paper can contain up to 4, 000 ppm
silver. Any solutions containing silver at concentrations greater than 5 ppm are considered hazardous
wastes. . ' '
In addition, some POTWs may have limits for silver in industrial discharges that are below $ppm. the
facility should be aware of the applicable silver limits for its discharge.
A-14
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
I, PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Note any potential or actual problems regarding image processing with respect to air
emissions, nonhazardous and hazardous solid wastes, and wastewater.
b. Process Solutions
(1) List the chemicals/solutions and amounts used for:
Type
Developer
Fixer
Stop Bath
Amount
(2) How are bath solutions currently monitored?
(3) Are bath solutions changed on a set schedule?
If yes, what is the schedule?
Yes
No
(4) With respect to the process bath, does the facility do any of the following:
« Add ammonium thiosulfate to silver-contaminated baths to extend the
allowable build-up of silver?
Prolong the potency of oxidation process baths by reducing their exposure to
air?
Routinely monitor pH?
Yes
No
Yes
No
Yes
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(5) Does the facility use squeegees following all processing solutions and washes in
automatic processing machines?
Yes
Note to Inspector:
Squeegees can significantly reduce the amount of solution carried out of the bath on the film. This
reduces bath changeouts and replenishment rates. Types of squeegees include Wiper blades, air
squeegees, vacuum squeegees* v/ringersling squeegees, and rotary-buffer squeegees.
(6) Does the facility use water recirculation units to reduce water use and wastewater
generation?
(7) If the facility uses multiple rinses, is counter current rinsing used?
N/A
Yes
Yes
No
Note to Inspector:
If no, water recirculation units can reuse photoprocessing bath waters but filters from water
recirculation units require disposal and may be considered hazardous wa$te$.
N/A
Yes
Yes
No
No
(8) Is an automatic film processor used?
If yes, is a continuous rinse used?
How often are the processor's chemical tanks cleaned out?
c. Silver Recovery
(1) Does the facility use any of the following on-site silver recovery techniques to reduce silver
concentrations in the discharge? (Check any that apply.)
Electrolytic silver recovery
Automatic recirculating silver recovery
Metallic replacement canisters
Ion exchange units
Other (specify)
A-16
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
It PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Does the facility ship wastes for off-site silver recovery?
Yes
Nates to
Several on-site and off-site silver recovery Methods are available.
Silver removed from the ESR and the -metallic cartridges and fixer solutions are hazardous wastes
and must be handled properly.
Qff"Site silver recovery includes sending fixer bath solutions to a fixer recycler to recover silver and
possibly regenerate the fixer or processing off-site cartridges from an on-site metallic replacement
canister.
d. Used Film
(1) Has the facility explored the use of silverless films?
If yes, which type? (Check any that apply.)
Diazo
Yes
No
Photopolymer
Electrostatic
N/A
Has the use of these films reduced the amount of silver contaminated
fixing or wash solutions?
(2) Does the facility recycle photographic film?
e. Innovative Technology (Web Printing)
(1) Has the facility considered installing waterless paper and film developing units to
reduce the volume of fixer waste?
Yes
No
Yes
No
Yes
A-17
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
B. Image Processing (Continued)
(2) Does the facility use electronic imaging?
Yes
No
C. Platemaking
a. General
(1) Is platemaking done at the facility?
Notes to Inspector: *
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist,
Typical wastes from plafemaking include the fallowing: used plates, developed film, adds, alkalis,
solvent, plate coatings, plate developers, and waste-water.
Typical hazardous wastes generatedfrom the ptatemakingprocess may include: plate developers and
activators. , '"
(2) Note any potential or actual problems regarding platemaking with respect to air emissions,
hazardous and nonhazardous solid wastes, and wastewater.
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
JL PROCESS EVALUATION (Continued)
C. Platemaking (Continued)
(3) What type of plates are used?
Presensitized
Laser Imaged
Electrostatic
Diffusion Transfer
Photo Direct
Direct Image
(4) How many plates are developed?
(5) What material(s) are the plates made from?
(6) Are plates recycled?
Yes
No
(7) Does the facility use two-sided plates to reduce the number of plates used?
b. Waste Solutions
(1) Is the platemaker a self-contained system?
(2) What are the types and quantities of coatings and developers used?
Yes
No
Quantity
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H. PROCESS EVALUATION (Continued)
C. Platemaking (Continued)
(3) Is the developer washed off the plates to the sewer?
If no, what is done with the developer?
c. Innovative Technology
(1) Has the facility considered laser imaged platemaking?
Yes
No
lie!
If yes, note the status of its use (e.g., currently using for approximately 50% of business) and
any impediments to its use.
D. Printing
a. General
Notes to Inspector: , , ,
Check Table 1 (i.e., Summary of Wastes Generated, Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
Typical wastes from printing processes include thefollowing: paper^ volatile organic compounds, waste
ink, empty ink containers, and used plates. , -, ,
Typical hazardous wastes generated from the printing process include; ink/ink skirts and fountain
solutions. Used printing inks can contain materials that would be considered hazardous wastes, for
some chemicals the wastes are hazardous at any concentration while for other chemicals, the wastes are
hazardous if they exceed specific regulatory limits. " ,
"" !
Some agencies have requirements on the maximum VOC content for printing inks,
Fountain solutions are made up of water and chemical additives. The most common additive is IP A
and is a volatile organic compound. To avoid VOCs, alternative chemicals may be used. Certain
alternatives, such as ethylene glycol (>10%) could be a hazardous waste (under State regulations) if
spent solutions are disposed.
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(1) Note any potential or actual problems regarding printing with respect to air emissions,
hazardous and nonhazardous solid wastes, and wastewater.
b. Waste Ink and Empty Ink Containers
(1) Do any of the inks contain hazardous materials such as solvents or heavy metals
(i.e., fluorescent/bright-colored inks frequently contain higher concentrations of
heavy metals)?
List the hazardous constituents.
Yes
No
(2) Does the facility use any of the following less hazardous inks? (Check any that apply.)
Vegetable/soy inks
Ultraviolet curable inks
Electron beam curable inks
Water washable ink system
Waterless inks
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(3) Does the facility do any of the following? (Check any that apply.)
/
/
/
c
t
Fill ink fountains according to need as opposed to routine filling?
Use automatic ink levelers?
Clean ink fountains between runs?
Properly reseal ink containers (or cover with a lid or wax paper) after use to reduce
skinning and to maintain ink quality?
il$i
• Use any other measures to prevent drying ink or formation of skins inside the
fountain?
If yes, describe the measures:
in
• Use anti-skinning aerosols to prevent ink dry-up during shutdowns?
If yes, list type of aerosol used:
Vote to Inspector: \ - -
lerosols used for ink anti-skinning may contain hazardous chemicals such as 1,1,1-irichloroethant
olnene. The F listed RCRA wastes are always considered hazardous' after being used. Aerosol c
ontaining "listed" chemicals are considered hazardous waste if they are thrown, away before they
•mpty*
'., . vStY-.v.'.v;
Sp:?tfe
Bill
2 or
am
are
A-22
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H, PROCESS EVALUATION (Continued)
D. Printing (Continued)
(4) Does the facility use any of the following measures to reduce cleaning?
(Check any that apply.)
Use a standard ink sequence
Run similar jobs on the same day or schedule jobs using light colored inks before
darker ones
Dedicate one press for inks containing hazardous pigments or solvents
(5) Does the facility do any of the following with unused portions of ink? (Check
any that apply.)
Yes
No
Save for house colors
Offer customer discounts on leftover inks
Use on donated jobs
If no, what do they do with the unused inks?
(6) Does the facility do any of the following with waste inks? (Check any that apply.)
Reuse
Recycle
Return to the manufacturer
(7) Does the facility purchase ink in bulk containers that may be returned to the
supplier for refilling?
Yes
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II, PROCESS EVALUATION (Continued)
D. Printing (Continued)
c. Fountain Solutions
(1) What type of VOC fountain solution is used?
(2) Does the facility use compliant (low-VOC) fountain solutions to meet regulatory
requirements?
Yes
No
Notes to Inspector:
Most regulations offer the option of'low-VOCfountain solutions or air pollution control devices. The
EPA recommended levels of control for reasonably available control technology (RACf) are as follows:
• Heatset web: No greater than 1.6percent alcohol by volume or no greater than 3.0 percent Alcohol
by volume if the solution is refrigerated to less than 6G°F, Higher levels of control are possible
using alcohol substitutes or less alcohol in the fountain solution.
• Sheetfed: No greater than 5.0 percent alcohol by volume or no greater than 8.0 percent alcohol by
volume if the solution is refrigerated. Higher levels of control are possible using alcohol substitutes
or less alcohol.
* Nonheatset web: Nonalcohal additives or alcohol substitutes can be used to, tnake the final solution
less than 3,0 percent additive by volume.
(3) Have alternative fountain solutions been tried?
(4) Has the facility considered refrigerating fountain solutions to maximize the
efficiency of isopropyl alcohol (IPA) and non-IPA solutions?
(5) Does the facility fill ink fountains based on the run or shift?
(6) Does the facility use permanent total enclosures (PTEs) to caputure press
emissions?
Yes
No
N/A
Yes
No
Yes
No
A-24
November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
D. Printing (Continued)
d. Paper Wastes
(1) Is paper use minimized by proper pre-production planning and lay-out?
(2) Does the facility utilize improved start-up procedures to reduce paper waste to a
minimum?
(3) Is waste paper and trash sent to a recycler?
(4) Does the facility view jobs on a personal computer before printing?
(5) What are the most common causes of off-specification printing?
Yes
Yes
No
Yes
Yes
No
(6) Does the facility monitor press performance continuously to minimize bad runs
and waste?
(7) Has the facility evaluated press performance by integrating the amount of waste
generated per process?
e. Other
(1) Are there any waste oils from the presses?
Yes
No
Yes
No
If yes, is waste lube-oil sent to a recycler?
(2) Are used oil storage tanks and containers in good condition?
N/A
Yes
Yes
No
No
N/A
Yes
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H. PROCESS EVALUATION (Continued)
D. Printing (Continued)
(3) Are the storage tanks labeled "used oil?"
(4) Are there any used-oil spills or leaks to the environment?
f. Innovative Technology (Web Printing)
(1) Is an automatic web splicer used to save time and reduce paper waste?
(2) Do the presses employ web break detectors to prevent damage to the
press?
N/A
Yes
No
Yes
No
N/A
Yes
No
N/A Yes No
E. Cleaning Activities
a. General
(1) What type of cleaning activities does the facility perform and how often are they performed?
Notes to Inspector:
v!i i
Check Table I (le.t Summary of Wastes Generated, Quantity•„ and Disposal Methods} to verify wastes
generated as you complete this section of the checklist.
Typical wastes from cleaning activities include: waste cleaner with residual ink, waste ink ft am. the ink
fountain, rags or shop towels containing cleaner and ink, empty solvent containers, and VOC emissions
from cleaners. [ '<
Typical hazardous wastes generatedfrom cleaning activities may include* parts washer solvents, shop
towels, press washes, arid ink cleanup sludges. Parts washer solvents typically become hazardous when
they can't be used any longer. Shop towels may be considered a hazardous waste depending on the
materials they are in contact with (e.g., inks, solvents) and how they are handled (e.g., thrown away).
Press washes have a high VOC content and may contain F listed RCRA chemicals that would make
them hazardous when disposed. Ink cleanup sludges are generated from press cleaning, operations and
are considered hazardous when they are mixed.
Tear-down and repair of equipment can produce large quantities of cleaning waste as compared to
waste produced during normal operation .i
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
IX. PROCESS EVALUATION (Continued)
E, Cleaning Activities (Continued)
(2) Note any potential or actual problems regarding cleaning activities with respect to
emissions, nonhazardous and hazardous solid wastes, and wastewater.
b. Spent Cleaner
(1) List the type of solvents or other solutions used as cleaners.
(2) Has the use of less hazardous cleaning s
detergents) for cleaning?
If yes, list type of solvent.
Ntite to Inspector
Citric-acid mtd aqueous~betsed cleaners may
aromatic compounds.
(3) Has the facility worked with its vendor
still works effectively?
olvents been attempted (e.g., soaps and
air
Yes
No
replace -petroleum-based solvents and those containing
to find the lowest VOC press wash that
(4) Does the facility have a solvent management plan to reduce solvent waste at the
facility?
Yes
Yes
No
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H. PROCESS EVALUATION (Continued)
E. Cleaning Activities (Continued)
(5) Does the facility have solvent containers or tanks?
If yes, are solvent container lids tight fitting and in place when not in use?
(6) Are solvent tanks equipped with emission control equipment?
If yes, specify
N/A
Yes
liii
Yes
No
No
(7) Has the facility considered using automatic cleaning equipment (e.g., an
automatic blanket cleaner)?
(8) Is the roller blade kept in good condition and its angle checked for most effective
cleaning?
(9) Does the facility segregate spent solvents according to color or ink?
(10) How are waste solvents handled? (Check any that apply.)
Discharged to drains
Yes
No
Yes
No
Captured as liquid
Associated with rags, shop towels, or other absorbent materials
(11) Does the facility reuse or recycle solvents?
If yes, how is it reused or recycled?
fill
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
II. PROCESS EVALUATION (Continued)
E. Cleaning Activities (Continued)
(12) If solvents are recycled on-site:
Does the solvent recycling process generate cooling water?
N/A
Yes
No
What procedures are used to ensure cooling water is not contaminated from equipment leaks?
c. Shop Towels
(1) How are rags handled? (Check one that applies.)
Washed on premises
Picked up by commercial laundry:
(name of laundry)
(2) Does the facility use press wipes as long as possible before discarding or
laundering?
(3) Does the facility implement procedures to remove excess solvents or inks in the
rags so they can be cleaned by an industrial laundry?
Yes
No
Yes
No
Note to Inspectors
A variety of approaches can be used fa minimize the amount of solvents or inks in rags. These include;
1 "* " j f
* Changing clean up procedures so that solvent levels are kept ta. a minimum in the rags
- Use practices that limit the worker Js ability to soak rags in solvent (pl-unger cans, squeeze bottles,
daily solvent allocations, directly pour solvent waste into labeled drums, etc,,,)
• Developing a procedure to separate a majority of the ink afid solvent from soaked rags
- Centrifugal extractor or wringer
• Using parts washing equipment as an alternative to rags for cleaning trays that collect, solvents and
inks below each roller of the press.
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
H. PROCESS EVALUATION (Continued)
F. Finishing
(1) What type of finishing operations are done at the facility?
Note to Inspector:
Check Table I (i.&., Summary of Wastes Generated Quantity, and Disposal Methods) to verify wastes
generated as you complete this section of the checklist.
(2) Note any potential or actual problems regarding finishing operations with respect to air
emissions, nonhazardous and hazardous solid wastes, and wastewater.
Note to Inspector:
Typical wastes from the finishing process include the following: waste paper trimmings, VOCsf and
•waste glue. ...... ,,
(3) Does the facility incorporate pollution prevention techniques or use innovative
technology to reduce finishing wastes?
If yes, describe the techniques or technology.
Yes
Nil:
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
HI. WASTE HANDLING ANI> MANAGEMENT
A. Wastewater Management
(1) List the expected pollutants in the facility's wastewater discharge.
(2) Does the POTW have sewer use limits for any of these pollutants?
If yes, list the pollutants.
(3) Does the facility have a current wastewater discharge permit?
If no, has the facility applied for a permit?
(4) If the facility has a wastewater discharge permit, complete the following:
List the parameters limited in the facility's permit.
N/A
N/A
Yes
Yes
No
Parameter
Limit
Is the facility in compliance with the following requirements in its permit?
Permit limits
Sampling location
Sampling frequency
Parameters analyzed
Analytical methods
Reporting
Recordkeeping
N/A
Yes
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
ID. WASTE HANPLINO ANI> MANAGEMENT (Continued)
A. Wastewater Management (Continued)
If no is checked for any of the above items, describe the potential or actual noncoi
with specific permit requirements.
(5) Describe any observable impact of the wastewater discharge. (For example, is the
clear and free of solids or are there any unusual odors?)
(6) Describe any wastewater treatment employed at the facility. (Note: This does no
recovery systems.)
(7) Is wastewater treatment sludge generated on-site?
If yes, how is it disposed?
If applicable, where does the water, removed from the sludge dewatering process,
the facility?
(8) For facilities that discharge to POTWs, did the facility notify the POTW if any
substances discharged by the facility would be a hazardous waste under 40 CFR
Part 261?
"npliance
5 discharge
t include any
Yes
No
return to
Yes
No
B. Hazardous Solid Wastes Management
(1) Is hazardous waste accumulated hi containers at or near the point of generation
(i.e., in the process areas)?
N/A
If yes, is the capacity of the containers less than 55 gallons or is the
quantity of wastes accumulated less than 55 gallons?
pi||
Yes
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
III. WASTE HANDLING ANI> MANAGEMENT (Continued)
B. Hazardous Solid Wastes Management (Continued)
Is excess accumulation removed within 3 days?
(2) Does the facility have a hazardous waste storage area?
(3) Are the waste storage containers indoors or in covered areas to prevent moisture
from seeping in?
Yes
Yes
Yes
No
(4)
Are the hazardous wastes containers managed as follows? (Check all that apply.)
Containers in good condition (no rusting, defects or evidence of leaks)
Containers properly labeled as "Hazardous Waste" and start date of accumulation
Containers compatible with waste
Containers closed when not in use
Containers opened, handled, and stored in a manner not to cause a leak
Containers storing incompatibles kept separate
Containers appropriately stored for:
90 days or less
180 days or less
270 days or less
For items not marked, please describe the problem.
(5) Is there adequate secondary containment capacity for free liquid wastes stored in
a storage area?
Yes
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
in. WASTE HANDLING AND MANAGEMENT (Continued)
B. Hazardous Solid Wastes Management (Continued)
(6) Are any hazardous wastes shipped off-site?
If yes, does the facility use a manifest system?
(7) Do the manifest records contain the following? Check all that apply.
Yes
Generator EPA ID number
Generator name, address, phone number
Transporter name, EPA ID number
Designate facility name, address, phone number, and EPA ID number
Alternate facility identified
Five digit document number
DOT shipping name, hazard class, waste code, and RQ
Containers: number, type, quantity, unit wt/vol
Proper certification, including waste minimization
Dates and signatures
(8) Have exception reports been required?
If yes, have they been submitted?
(9) Are manifest records maintained for 3 years?
N/A
N/A
Yes
Yes
Yes
No
No
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
Tfl, WASTE HANDLING ANJ> MANAGEMENT
B. Hazardous Solid Wastes Management (Continued)
(10) If wastes are reclaimed, does facility have copy of the contractual
agreement with reclaimer?
(11) Has the facility determined and submitted notifications of hazardous waste
restricted from land disposal?
If yes, do the notifications contain the following? (Check all that apply.)
EPA hazardous waste number (e.g., F002)
1
N/A
N/A
Yes
Yes
No
No
The corresponding treatment standard(s) (see 40 CFR 268.7(a)(l)(ii) for details)
The manifest number associated with the shipment of waste
Waste analysis data, where available
(12) If land disposal restricted wastes are treated on-site, does facility have
records documenting that wastes meet land disposal restriction treatment
standards?
N/A
Yes
No
C. Air Emissions Management
(1) Does the facility have any of the air pollution control technologies?
If yes, check any that apply.
Incinerator
Carbon Absorption Unit
Condenser
Ventilation Capture System
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November 1995
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Multimedia Compliance/Pollution Prevention Assessment Checklist
IH. WASTE HANDLING AMJ> MANAGEMENT
C. Air Emissions Management (Continued)
Note to Inspector:
Air pollution control technologies Include the following:
* Incinerators (including catalytic) - Incineration of exhaust gas is widely used in the printing
industry. Often, heat is recycled back into the building (i.e,, heat-set offset) or process dryers.
Compliance is monitored by incineration temperature or change in temperature across the catalytic
surface. ^
• Carbon Absorption - Carbon beds capture exhaust VOCs that are urged with steam. On-site
distillation can be used to recover the solvent. Presses/facilities utilizing a single solvent can
efficiently recover solvent for on-site use. This method is typically used on larger presses -with
hydrocarbon monitors to confirm efficiency.
• Condensers - Refrigerated coils are used to cool exhaust gas and cause solvent to condense far
recovery. Condensers are not widely used in the graphics arts industry.
• Ventilation/capture. Systems - VOCs are emitted primarily from fountain solutions, rollers and
dryers on presses. Depending upon the design, these may or may not be enclosed parts oj'thepress.
The control efficiencies discussed below generally are based upon capture and control. Capture
efficiency describes the ability of the system to pick-up VOC emissions and transfer them to th&
control device,
(2) Does the facility have an air permit?
If no, has the facility applied for a permit?
Yes
Yes
No
No
(3) If the facility has an air permit, is it in compliance with the following requirements in its
permit?
Emissions limits
Emissions monitoring
Analytical methods
Reporting
Recordkeeping
Other (describe):
N/A
Yes
No
(4) If no is checked for any of the above items, describe any actual or potential violations with
specific permit requirements.
A-36
November 1995
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