November 1986
Environmental Audit Protocol
for EPA Facilities
Final Draft
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600086251
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NOTICE
This environmental audit protocol has. been prepared by Arthur
D. Little, Inc., under Contract Number 68-01-7252 for the
Office of Administration and Resources Management, U.S. Envi-
ronmental Protection Agency. It has been developed to assist
in achieving specific environmental audit objectives and
reflects the experience and opinions of Arthur D. Little Inc.,
and not necessarily that of the U.S. Environmental Protection
Agency or any other governmental entity.
This protocol is intended as a guide for conducting compliance
audits of EPA laboratory facilities and may require additions,
revisions, or other modifications to meet the needs of a
particular audit, facility operations, or other special cir-
cumstances. Neither Arthur 0. Little, Inc., nor the U.S.
Environmental Protection Agency make any warranty t>r assume any
liability with respect to the use of any information contained
in this protocol. If specific environmental audit advice or
assistance is required, the services of a competent profes-
sional should be sought.
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ENVIRONMENTAL AUDIT PROTOCOL
INTRODUCTION
This protocol consists of four major parts:
Part 1: Pre-Audit Activities;
Part 2: Understanding Management Systems;
Part 3: Gathering Audit Evidence; and
Part 4: Evaluating Audit Evidence/Reporting
Findings
It is intended to serve as a guide for auditors to plan
and conduct environmental audits at EPA facilities.
This protocol facilitates the gathering of management
and compliance information pertinent to and necessary
for accomplishing the objectives 'of EPA's internal
Environmental Auditing Program. This protocol, however,
may require additions, revisions, or other modifications
in order to meet the needs of facility-specific audit
objectives or other special circumstances.
If there are any questions or comments on this protocol
contact:
Manager, Environmental Compliance Program
Occupational Health and Safety Staff (PM-273)
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
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~RQHMENTAL AUnIT PROTOCOL
TABLE OF CONTENTS
Part 1:
Pre-Audit Act~
A.
B.
C.
D.
Pre-Audit Planninq
Review ot Backqround Intormation
Review ot Requlations
Attachments
1. Example Confirmation Letter
2. Pre-Audi~ Questionnaire
Part 2:
Understandina Manaaement Systems
A.
B.
C.
D.
E.
F.
G.
Openinq Meetinq
Orientation Tour
Internal Controls Questionnaire
Review of Audit Plan
Develop Detailed Underst~ndinq ot Manaqement Systems
Marine Laboratories (Ships) Addendum
Attachments
1. Air Pollution Control Observation Checklist
2. Water Pollution Control Observation Checklist
3. Spill Prevention and Control Observation
Checklist
Solid and Hazardous Waste Manaqement
Observation Checklist
Environmental Manaqement Internal Controls
Questionnaire
Gatherina Audit Evidence
4.
.5.
Part 3:
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
o.
Air Pollution Control
Water Pollution Control
Non-Hazardou8 Solid Waste Manaqement
Hazardous Waste Generation
Hazardous Waste Storaqe and Treatment
Underqround Storaqe Tanks
Past Dispo8al Practice/Reportinq ot Releases
Spill Prevention and Control
Pesticide Control
PCB Manaqement
Drinkinq Water
Radioactive Waste Manaqement
Environmental Assessment/Impact Statement
Marine Laboratories (Ships) Addendum
Attachment
1. List ot Exhibits
~
1-2
1-2
1-3
1-4
1-5
2-2
2-3
2-3
2-3
2-3
2-14
2-16
2-17
2-18
2-19
2-20
3-2
3-8
3-13
3-14
3-29
3-49
3-50
3-51
3-53
3-55
3-60
3-63
3-67
3-6S
3-72
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TABLE OF CONTENTS (Con~inued)
Part 4:
Evalua~ina Audit Evidence/Re~ortina F~ndinas
A.
B.
C.
D.
E.
F.
Develop Complete List ot Audit Exceptions
Interqrate and Summarize Excep~ion8
Exit M..tinq
Complete Workinq Papers Ba.ed on Exit Meetinq
Comments
Audit Report/Workinq Papers
Attachment
1. Close-Out Discussion Sheet
4-2
4-2
4-2
4-2
4-2
4-3
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Facility Name:
Dat.Cs) ot Audit:
Team Members:
Protocol Completed By:
Period Under Review:
Part 1:
Pre-Audit Activities
OBJECTIVE
This part of the protocol outlines the
basic activities to be undertaken before
the commencement of the on-site field
work. It is intended to provide quidance
to the team in reviewinq facili ty
backqround information, allocatinq team
resources, and otherwise preparinq for
the audit.
. l~l
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PART 1:
A.
PRE-AUDIT ACTIVITIES
1.
PRE-AUDIT PLANNING
Contact the facility manaq.r six to eight
week. pri~r to the audit to inform him/har
ot the scheduled all::lit. During this
conversation, the !ollowinq items should oe
discussed:
a. DateCs) ot the audit;
b. Audit team members;
c. Names ot key tacility contacts;
d. Purpose of the audit;
e. Audit process;
t. Documents/reports which may be needed
for review:
q. Cont irmation let.te.r wi th pre-audit
questionnaire; and
2 .
h. Travel arranqements to the facility and
lodqinq in the vicinity ot the tacility.
Select the members of the audit team and
assiqn audit responsibilities.
3.
Send pre-audit questionnaire and audit
contirmation letter to the tacility
manager.
B.
REVIEW OF BACKGROUND INFORMATION
Usinq data supplied by the tacility, agency or
provided by the ~eam leader, review the
followinq:
1.
General
a. Facility layout map;
b. Description ot tacility operations;
c. Facility organization chart;
d. Copies ot local, state and tederal
pollution control statutes and
requlations;
e. Emergency response or contingency
plan;
1-2
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Auditor( s) W.P,
& Comments Ret,
-
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~lorJc ing paper
r-f:..a..,YI.. -,
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'ART 1:
PRE-AUDIT ACTIVITIES (continued)
t. Previous audit reports and their status:
q. Copies of facility environmental
poli:ies ana proc.d~res;
h. copies of EPA environmental policies and
procedures;
i. Operations, maintenance and
implementation programs; a~d
j. Pre-audit questionnaire.
2.
Air Pollution Control
a. Permits and registrations.
:3 .
Wat;.!.LP-2ll.ution ~n.~lli
a. Water discharge permits and
registrations: and
b. Drinking water permits/registrations.
4 .
Solid and Hazardous Waste Manaaement
a. Facility permits and registrations; and
b. Underground storage tank permits and
registrations.
C.
REVIEW OF REGULATIONS
Contact appropriate local and state regulatory
agencies to confirm that copies of regulations
and statutes obtained are current.
1-3
Audltor( s) WP
& Comments Ref.
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ATTACHMENT 1
E~Y~LE CONF!~~TION LETTER
MEMORANDUM
TO:
Mr. John Smith. Nl"WtoW'n FiK:ility MiUaa~e=r
",::
L. V. D.aw:i«111
J. I. Jon~)
P. O. MUrT'o1Y
T. E. Thomp)on
FRO\I.
~I. J. ~1 urph!". Curporat~ ,\uuit Dire<.10r
DATE:
O<.-to'~r 19, 19l5-1
Sl'BJECI
Auuit of XYZ Corporo1tion's N~wtown. N~w York :\1.UlllfilC:tllrinJ( F",,'ilih
Tlais i) to <.'Onfarm the= arroUlJ(ements we= a!CJ'~ on /C)r the ulX,nnllll( envinmment..1
auuit of the N~wtown Fac:ility uunnK the w~k ufNovember 26. 19bo1, Dunlll( the= alluit,
I wiU be oI(.'(.'Omp.anaeU by Jam~) I. Juna. 111UII14&5 E. l11umpson. iU'ld Lauro1 V. Daw:i«lII.
w~ wOlilu lile~ to be~n the iluuit ilt 8:30 a. m. on Nuvt:'mber 27, As clIrTt:'ndy ~nvi.\iullt'(1.
we ~J(pect to <.'Oncluue our audit dunnl( the aftenlUUII of i\"vt:'ml~r 30 oU1U will <.,mulld
.an ~Jut Interview with you at th<&t time to o1ppriJe you of 0111 .audit tlndinlCS.
If I.'mv~ni~nt, we woulu lilee to h.ave a pre=-auuit In~tinl( with yuu .and other f..l"iIih
l~rsonnd on Tu~suay mOn1In~ to ue=sc:ribe briefly the purpuse= of the auuit. UISC:II~~ tilt'
appruadl w~ w,1I talee, anu answer any (Iuestions yuu may boavt!. FollowinJ( this lIIet:'tin~.
it wuulu ~ ht!lpful if we I."ulu r~-eive .. J(t!n~r.al uve=rview of facility 0l~r.'tion) anu tilt'
~nvlf(anment<&.l orxanizoation. After this OVt!rvit:'W. we will beJotin uur /C)nnal auuit pnl(;t"~
As we uis(:uu~u, the= auuit te=am wiJl follow a de=tllileU pru,cr.un ue=siJ(ned to l.unl1nn thilt
the .air o1nu water pollution ",mtrul and wliu ilnd hazoaruous W'...\t~ manaJ(ement pr.lC:ti<.-e\ ut
the fiileJlity are= in <."mplian<.-e with re=Jtulatory I"t=(luiremenb ilnu <."lnlwny fJulil:Y.
Pler~e f_1 fr~ to <.-.ul if yuu have any (Iuestions ur if sc.:heUulinJ( <."nflicb ari~t!.
Reprinted from Environmental AUdttjna: Fundamentals
Techniaues, Copyright 1985, Arthur D. Little, Inc.,
John Wiley' Sons.
and
Published by
1-4
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ATTACHMENT 2
PRE-AUDIT ENVIRONMENTAL MANAGEMENT OUESTIONNA!RE
This pre-audit environmental manaqement questionnaire
is intended to elicit backqround information from EPA
operating facilities pertaining to their environmental
pollution control activities. This backqround
information will assist EPA or their representatives in
the planning and conducting of :acility audits: thus,
accurate and timely completion is requested.
In HQ HLA Ylili
1.
Air Pollution Control
Does the facility:
a. Have air emission permits or
registrations?
b. Conduct air emission monitoring?
----
----
c. COnduct performance tests of air
pollution control systems?
d. Emit any of the following air
contaminations:
----
Beryllium?
--
--
Asbestos?
--
--
Mercury?
vinyl Chloride?
----
----
Benzene?
----
Volatile organic compounds?
Arsenic?
----
----
Radionuclides?
e. Dispense any fuels to trucks, ~
automobiles, or other vehicles.
----
----
f. Have an Air Episode Plan?
----
1-5
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ATTA~NT ~ (Continued)
PRE-AUDIT E~~IRONMENTAL MANAGEMENT OUESTIONNAIRE
2.
Water Pol~on Control
Does the facility:
In HQ ~~
a. Discharge wastewater to:
Navigable Waters?
A PubliclY-Owned Treatment
Facility?
A Privately-Owned Treatment
Facility?
.-. - -- 8""",,
----....
----.-.
A Deep Well by Injection?
A Septic System?
---....
----
b. Have permits for these discharges?
c. Make use of anyon-site wastewater
pretreatment or treatment?
----
----
d. Monitor its wastewater discharges?
e. Discharge any detectable amounts of the
following:
----
Aldrin/Dieldrin?
DDT/DDD/DDE?
===J
Endrin?
----
Toxaphene?
Benzene?
----
----
3.
Polychlorinated Biphenyls?
Safe Dr~na Water
----
Does the facility:
a. Obtain any portion of its drinkinq
water from on-site wells or surface
water sources?
b. Monitor its drinkinq water?
-----
------
1-6
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ATTACHMENT 2 (Con~inued)
PRE-AUDIT E~RONMENTAL MANAGEMENT OUESTIO~~AIrtt
In llQ HLA UNK
4.
s~ill Prevention and Control
Does the facility:
a. Have a Spill Prevention Control and
Countermeasure Plan?
----
b. Conduct spill prevention training?
c. Have a spill response team?
----
----
5.
Solid and Hazardous Waste Manaaement
Does the facility:
a. Have buried storaqe tanks containing
oil or hazardous substances?
----
b. Have above ground tanks containing
waste oil?
----
c. Generate hazardous waste?
--
.--
In excess of 1000 kg/mo?
--
--
d. Generate acutely hazardous waste?
--
--
In excess of 1 kg/mo?
e. Generate hazardous waste classified as:
----
Listed wastes?
-~--
Ignitable?
----
Corrosive?
----
Reactive?
EP Toxic?
----
----
f. Have an EPA ID number?
g. store wastes for longer than 90 day.?
----
----
1-7
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ATTA~NT ~ (Continued)
PRE-AUDIT ENVIRONMENTAL MANAG~NT OUESTIONNAIRE
h. Treat or dispose of hazardous wastes
on-site usinq the followinq?
Incineration?
~ l!Q HLA ~
---...
Other Thermal Treatment?
----
Landtill?
---.....
Land Treatment?
----
Physical/Chemical Treatment?
Bioloqical Treatment?
----
----
Underqround Injection?
i. Have a written waste analysis plan?
----
----
j. Have a closure or Post-closure plan?
k. Have a contingency plan?
----
----
1. Have a preparedness and prevention
plan?
m. Transport its own wastes off-site?
----
----
6.
PCB Manaaement
Does the facility:
a. Have in use or storage PCBs or PCB
contaminated:
Transformers?
----
Capacitors?
Electromagnets?
----
----
Hydraulic Systems?
Lab Samples?
----
--
--
Other?
--
--
Specify
1-8
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ATTACHMENT 2 (Continued)
PRE-AUDIT ENVIRONMENTAL MANAGEMENT OUESTIONNAI~
7.
Past Dis~osal Practices/Re~ortina ot
Releases .
Does the tacility:
a. Have a list ot all potentially
reportable hazardous substances
on-site, with their locations
and quantities?
b. Have a spill reportinq procedure?
8.
Environmental Assessment/Im~act
Statements
Does the tacility:
a. Have any completed environmental impact
statements tor projects initiated
within the last two years?
9.
Radioactive Waste Manaaement
Does the tacility:
a. Have a Nuclear Requlatory Commission
(NRC) License?
b. Generate radioactive waste trom any
ot the tollowinq activities:
Tracers used tor laboratory
equipment?
Radioactive samples?
Other?
10.
Pest~de control
Does the tacility:
a. Generate any pesticide wastes?
b. store pesticides tor use as
standards?
1-9
n~HQ
HLA UNY.
----
----
----
----
----
----
----'
----
----
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Part 2:
Understandinq Manaqement Systems
OBJECTIVE
This part of the protocol outlines the
basic steps to be followed in developinq
an understandinq of manaqement systems at
the facility. It includes a listinq of
the types of information to be reviewed
or obtained and provides quidance to the
audit team in dev8lopinq a basic under-
standinq of the environmental 4ctivities
at the facility and of the manaqement
syste~s in place to direct those
activi ties e.
2-1
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PART 2:
A. .
UNDERSTANDING MANAGEMENT SYS~EMS
OPENING MEETING
Meet with facility manaqement to:
1.
2.
Provide an overview of the audit proqram
includinq its purpose, scope, approach, and
reportinq process. Provide participants
with an openinq meetinq discussion quide.
Obtain an overview of on-site activities
from the facility manaqer. Document your
understandinq of the followinq:
a. Individual(s) responsible for overall
manaqement of the facili~y;
b. Individual(s) responsible for
environmental activities throuqhout the
facility;
c. Role the Environmental Compliance
Coordinator plays in the facili~y's
environmental compliance proqram;
d. Manaqement orqanization, responsi-
bilities, and accountabilities;
e. Description of activities conducted at
the facility;
f. Size of the facility;
q. Number of personnel employed by the
facility (e.q., professional, chemists,
clerical);
h. General environmental manaqement activi-
ties (e.q., number of air source., types
of wastes qenerated, hazardous materials
stored, etc.);
i. Any unique or particular facility
environmental concerns; and
j. Any off-site locations or field
operations under the control of the
facility manaqer.
2-2
A . ~
uditor(s) 'II
& Comments ~
--
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~,
rUT 2:
UNDERSTANDING MANAGEMENT SYSTEMS (Cont.)
B.
ORIENTATION TOUR
Tour the facility to qain a qeneral under-
standinq of the processes and areas of
environmental concern. (Note: U..
ATTACHMENTS 1 throuqh 4 in this part as
appropriate.)
C.
INTERNAL CONTROLS OUESTIONNAIRE
As a team, meet with appropriate facility
personnel and complete the Environmental
Manaqement Internal Controls Questionnaire
(Attachment 5). Make additional inquiries
as desired to increase your understandinq
of the location's responses.
D.
REVIEW AUDIT PLAN
1.
Based on the pre-audit review and
information qathered to date, as a team
determine what activities conducted at the
facility are subject to regulatory
requirements. List and prioritize (rank)
these activities and adjust the audit
protocol to assure that the hiqhest
priority issues are covered appropriately.
Based upon intormation obtained durinq the
openinq meetinq and orientation tour,
determine where a reallocation of team
resources is warranted (if any).
2.
E.
DEVELOP DETAILED UNDERSTANDING OF
MANAGEMENT SYSTEMS
Air Pollution Control
1.
Interview facility personnel and review
available documents to qain an
understandinq of the air pollution control
manaqament systems established at the
facility. Document in a flow chart or
narrative form your understandinq of
proqrams, procedures and. responsibilities
for the followinq air pollution control
activities:
2-3
Auditor( s) W.P.
& Comments Ref.
I
,
.
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PART 2:
UNDERSTANDING MANACEMENT SYSTEMS (Cont.)
a. Emission source identification,
registration, and permitting:
Emission inventories:
Registrations/permits and associated
applications;
Procedures to pay permit tees;
Procedures for updating permits;
Budget allocation for permitting; and
New units and/or modifications.
c. Emission controls:
Pollution control equipment;
Maintenance and operating procedures;
Performance tests;
Preventive maintenance schedules;
Inspections;
Unleaded gasoline labeling;
Vapor recovery systems;
Operational change review procedures;
and
Budget allocation for improving
controls.
c. Emission monitoring:
In8trumentation;
Analytical techniques:
Sampling locations;
Monitoring methods; and
Monitoring schedules.
2-4
Auditor(s)
& Comments
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PART 2:
UNDERSTANDINC HANACEMENT SYSTEMS (Cont.)
d. Training:
Maintenance and operating procedur..:
Training 8chedules, content: and
Employees included.
e. Reporting and recordke.ping:
Record retention policies:
Reviews by outside agencie.;
Air pollution alert and emergency
plan:
Operating procedures to ensure
appropriate documentation c~ntrol:
and
Correspondence tiles.
2.
Water Pollution Control
Interview facility personnel and review
available documents to gain an
understanding of the water pollution
control management systems established at
the facility. DocUment in a flow chart or
narrative form your understanding of
programs, procedures and responsibilities
for the following water pollution control
activities:
a. Wastewater discharge identification and
permitting:
Source. generating wastewater
(manufacturing, equipment cleaning,
rinsates, etc.);
Location of waste .treams and
di8charge points (sewer maps, process
flow diagrams, etc.);
Type of permits (NPDES, SPDES, POTW,
Pretreatment, septic Tank, etc.);
Procedures for updating permits:
Procedures to pay permit fees: and
New units and/or modifications.
2-5
Auditor(s) w.p-
& Comments R.f.
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PART 2:
UNDERSTANDIN~ MANAGEMENT SYSTEM~ (Cont.)
b. Wastewat8~ treatment:
Operation ot vaate treatment ayatems;
Procedures tor diaposing ot aludge;
and
Equipment maintenance and
calibration.
c. Discharge monitoring:
Instrumentation;
Monitoring methods/procedures;
Monitoring schedules: and
Budget allocated to monitoring.
d. Sample collection, analysis and data
recording:
Analytical procedures;
Composite sampling:
Effluent flow measuring;
In-place monitoring and recording
devices:
Sampling locations: and
Analyses performed by certified
laboratory.
e. Training:
Certification requirements tor
wastewater treatment operators;
Frequency ot training;
Employees included; and
Training documentation.
2-6
....
Auditor(s) I
& Comments I
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PART 2:
UNDERSTANDING M1NAGEMENT SYSTEMS (Cont.)
f. Reporting and recordkeepinq:
Operating procedures to ensure
appropriate documentation control;
Identify date of permit expiration;
and
Intra-agency correspondence relative
to permit limitation issues or
regulatory actions.
3.
Non-Hazardous Solid Waste Manaaement
Interview facility personnel and review
available documents to gain an
understanding of the non-hazardous solid
waste management systems established at the
facility. Document in a flow chart o~
narrative form your understanding of
programs, procedures and responsibilities
for the following non-hazardous solid waste
management activities:
a. Collecting, transporting and disposing
of non-hazardous solid wastes;
b. Procedure for classifying wastesi
c. Waste inventories, analys.s, recycling
or disposal records;
d. Non-hazardous solid waste permit.,
registrations or licenses;
e. Labeling, storage, sampling and
analysis; and
f. Other action and recordkeeping
activities.
4.
Hazardous Waste Generat~
Interview facility personnel and review
available documents to gain an
understanding of the hazardous waste
generation management systems established
at the facility. Document in a flow chart
or narrative form your understanding of
programs, procedures and responsibilities
for the following hazardous waste
generation activities:
2-7
Auditor( s)
& Comments
W.P.
Ref.
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PART 2: UNDERSTANDING MANAt;EMENT SYSTEMS (Cont.)
a. Procedure. tor identitying points ot
;en4ration:
. b. Systems to identify new waste streaDs
and cnanqes in 8Xi5~ing systems;
c. Waste inventories including type.,
location and volum.. generated;
d. Methods to ensure s.a1l quantity
limitations are not exc.eded when the
small quantity exemption i. claimed;
e. Methods for characterizing wastes;
f. samplinq methods;
q. Analytical ~ethods used for waste
detendnation;
h. Manifestinq of oft-site shipments;
i. Systems established to ensure wastes are
shipped off-site within 90 days;
j. Systems used to select off-site TSDF
(EPA off-site policy);
k. Waste packaqinq, marking, labelinq, and
placardinq; and
1. Exception reportinq, annual reports, and
recordkeepinq.
5.
Hazardous Waste Storaae. Treatment and
Discosal
Interview facility per.onnel and review
available documents to gain an under-
standing ot the hazardous waste storaqe,
treatment and disposal management systems
established at the facility. Document in a
flow chart or narrative torm your under-
standing of programs, procedures and
responsibilities for the fOllowinq hazard-
ous waste .toraqe, treatment and disposal
activities:
a. Receipt control methods (samplinq,
analysis);
b. Traceability of wastes throuqh facility
from receipt to final disposition;
"..0
AuditOr( s)
& Comments
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W.I
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J
PART 2:
UNDERSTANDING MANAGEMENT SYSTEMS (Cont.)
c. Approved treatment and .torage .ethod.:
d. Inspection scbad\11es and records;
e. Personnel tr~inin9 proqram8~
t. Contingency plan and emergency
procedures;
g. Annual reports;
h. Manitesting;
i. Closure of the facility;
j. Permitting of the tacility:
k. Co~~unica~ions and alarm systems; and
1. Management of igni~able, reactive and
incompatible wastes.
6.
Underqround Stor~ Tanks
Interview facility personnel and review
available documents to gain an
understanding ot the underground storage
tank management systems established at the
facility. Document in a tlow chart or
narrative torm your understanding' of
programs, procedures and responsibilities
for the following activities:
a. Number ot tanks currently in use;
b. Tanks taken out of service;
c. Agency notitication and reporting; and
d. New tank installation.
7.
Past Dis~osal Practice/Recortina ot
Releases
Interview tacility personnel and review
available documents to gain an
understanding ot the systems established at
the tacility to manage past disposal
practices and the reporting ot hazardous
substance releases. Document in a tlow
chart or narrative torm your understanding
of programs, procedures and responsibili-
ties for the following activities:
2-9
Auditor(s) W.P.
& Comments Ref.
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PART 2: UNCERSTANDING ~AGEMENT SYSTEMS (Con~.)
a. Procedure tor the iden~itica~ion ot
reportable quantities ot hazardous
.ubstance.;
b. Procedure. for repcrtinq Supertund
relea..s; and
c. Pas~ disposal practic.. ot the facility
including companies used and their
locations.
8.
~ll Prevention and Ccntr~l
Interview facility personnel and review
available documen~s to gain an
understanding of the spill prevention and
control management systems astablishe~ at
the facility. Document in a flow chart or
narrative torm your understanding of
programs, procedures and responsibilities
for the followinq spill prevention and
control activities:
a. Procedures used to ~revent and control
spills;
b. Procedures to warn vehicular traffic of
piping, fillinq operations and storage
tank areas;
c. Procedures for fillinq t~nks;
d. Inspections of tanks and piping;
e. Testing of storage tank level sensing
devices;
f. SPCC plan development and
implementation;
g. Spill training (training coordina~or,
trainees etc.); and
h. Spill reporting procedures.
.
2-10
Auditor( s)
& Comment~
-
WI
R~
--
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PART 2:
UNDERST~~DING MANAGEMENT SYSTEMS (Cont.)
9.
P.st~. ContrQl
Interview facility personnel and review
available documents to gain an
understanding of t~e pesticide control
management .ystems e.tablished at the
facility. Document in a flow chart or
narrative form your understanding of
programs, procedure. and re.ponsibilities
for the following pesticide control
activities:
a. Analysis, storage, disposal and"labelinq
of pesticides, and pesticide-related
wastes; and
b. Recordkeeping and reporting of
pesticides an~ pesticide-related wastes
handled, stored and disposed of.
10.
PCB Manaaement
Interview facility personnel and review
available documents to gain an
understanding of the PCB management systems
established at the facility. Documen~ in a
flow chart or narrative form your
understanding of programs, procedures and
responsibilities for the following PCB
activities:
a. Maintenance of equipment:
PCB decontamination procedures;
Inspections of equip~ent used to
handle PCBs; and
Marking of equipment.
b. Handling of PCB containing materials:
Environmental samples;
Lab extracts;
Lab .tandards; and
Immersion oils.
2-11
Audltor(s)
& Comments
WP.
Ref.
-------
PART 2:
11.
UNDERSTANDING MANAGEnNT SYSTEHS {cont.)
..
c. PCB 8toraq. and di8po8al:
-
Storaqe facilities;
.
Inspection procedures for PCB
facilities;
Manifastinq procedures;
otf-site disposal facilities used
(EPA oft-site policy); and
Approval ot disposal vendors.
d. PCB reporting and recordkeeping:
Daily, weekly reports;
Annual reports; and
Records retention policies.
Drinkina Water
Interview tacility personnel and review
available documents to gain an
understanding ot the drinkinq water
management systems established at tr.e
facility. Document in a flow chart or
narrative form your understanding of
programs, procedures and responsibilities
for the tollowing drinking water
activities:
a. Water Supply:
Equipment used;
Operating and maintenance procedures;
Type. of treatment;
Water sources;
Systems to prevent cross
contamination;
Population served; and
Training provided/frequency/documen-
tation.
2-12
.'uditor(s)
& CommentS
~
IN,
~
-
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PART 2:
UNDERSTANDING MANAGEMENT SYSTEMS (Cont.)
b. Monitorinq and AnalY8i8:
Monito~inq equipment calibration and
maintenance; and
Analytical procedures.
c. Reportinq and Recordkeepinq:
Reports prepared and 8ubmitted;
Reportinq schedules;
Record retention procedures; and
Location of files.
12.
Radioactive Waste Manaaement
Interview facility personnel and review
available documents to qain an
understandinq of the radioactive waste
manaqement systems established at the
facility. Document in a flow chart or
narrative form your understandinq of
proqrams, procedures and responsibilities
for the followinq radioactive waste
manaqement activities:
a. Monitorinq and sa~plinq procedures;
b. Requlatory reportinq procedures;
c. Procedures for handlinq radioactive
wastes;
d. Radioactive waste disposal procedures;
e. Procedures for traininq personnel in the
handlinq and disposal of radioactive
material; and
f. The location of all potential sources of
radioactive waste.
13.
~ronmental Assessment/Im~act Statement
Interview lab personnel and review facility
documents to qain an understandinq of the
environmental assessment/impact statement
manaqement systems established at the
facility. Document in a flow chart or
2-13
Audltor( s) W.P.
& Comments Ref.
,
I
I
.
-------
PART 2:
UNDERSTANDING MANAGEMENT SYST~S (Cont.)
narrative form your under8tandinq of
programs, procedures and responsibilities
for the fOllowing activities:
a. Management review procedures for
proposed changes in facility operations
(i.e., modifications or expansions);
b. criteria used for evaluating if
preparation of an environmental
assessment is warranted;
c. criteria used for evaluating if major
federal actions require preparation of
environmental impact statements; and
d. Preparation, submission and comment
response procedures.
F.
MARINE LABORATOrtIES (SHIPS) ADDENDUM
Interview lab personnel and review ship
documents to gain an understanding of the
environmental management systems
established for this vessel. Document in a
flow chart or narrative form your
understanding of programs, procedures and
responsibilities for the following:
a.
Marine San~ion Dev~
- Types of devices;
- Holding tanks on board;
- Discharges to water; and
- Installation approval/permits.
b.
Qij-Water Waste Treatment
- Type of system;
- Flow rate;
- Discharges;
- Discharge concentrations;
- Alarm systems; and
- Training of personnel.
2-14
-
Auditor(s)
& Comments
W.I
Re
-
-
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PART 2:
UNDERSTANDING MANAGEMENT SYSTEMS (Cont.)
~d Waste Dis~osa~
c.
- Type ot system used on-board;
- Storage ot wastes;
- Waste determination; and
- Permits/approvals.
d. Marine S~ill Continaencv Plan .-
- Hazardous substances inventory;
- Spill contingency plan:
- Containment structures: and
- Storage practices.
e. Hull coatinas
- Type of coating;
- Application date; and
- Plans tor new coating.
2-15
Auditor(s)
& Comments
W.P.
Ref.
-------
.,
ATTACHMENT 1
AIR POLLUTION CONTROL
This one-paqe tour checklist i. provided as a reterence for
thinqs to look at durinq the orientation tour and subsequent
tours. The list is not exhaustive; it is meant to serve as an
aid or tool to remind the auditor ot the major considerations.
-
Emission ?oints
Stacks,. ventilators, lab hood vents, wall tans, exhaust
ports, etc.
Permits, reqistrations
Emission inventory
Fuqitive dust
Process losses
Fuel oil storaqe--Vocs
Emission opacities
Monitorinq equipment (calibration checks)
Hazardous pollutants
Stack heiqhts
Proximity to residential areas
Odors
Boilers, incinerators, unit heaters, hoods
Process equipment
Scrubbers, baqhouses, cyclones
Paint spray booths
-
-
-
-
-
-
-
-
Control Devices
-
Vapor recovery or combustion systems
Corrosion on recirculatinq pumps on scrubbers
Pressure drop across baqhouses, scrubbers
Maintenance loqs
Stack monitorinq devices
-
2-16
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1TT1~NT 2
WAT!:R POLLUTION CONTROL
Observation Checkl~
This one-page tour checklist is provided as a reterence tor
things to look at during the orientation tour and subsequent
tours. The list is not exhaustive: it is .eant to serve as an
aid or tool to remind the auditor ot the major considerations.
Intake
Filters
Discharaes
Filters
Discharge points (pipes, sewer connections)
Surface water run-ott
Floor drains
Other drains
Receiving waters
Monitoring equipment (calibration checks)
Sampling locations
Odors, oil sheen, visible greas., t~rbidity, toam, color
Septic systems
Groundwater discharges
Waste piles
Control Eaui~ment
Filters
Neutralization tanks
Wastewater treatment plant
Alarm systems (chlorine)
Standby power
General housekeeping
Sludge disposal
oil and grease separators
Equalization tanks
Units out ot service
Warning signs
Level ot treatment (primary, secondary)
-
-
2-17
-------
A'rI'ACHHENT 3
SPILL PREVENTION AND CO~.OL
Cbserv
This one page site tour checklist is provided as a reference for I
things to look at during the orientation tour and subsequent
tours. This list i. not exhaustive; it i. meant to serve as a~
aid or tool to remind the auditor of the major considerations.
A.
Storaae Equ12~
Above/below ground storage tanks (e.g., fuel oil, gasoline,
waste oil, hazardous substances)
Tank construction (e.g., riveted vs. welded)
Storage ~rea marking and identification
Drum storage areas (layout, labeling)
Loading/unloading areas (spill control)
Small vehicle refueljng points
Above ground valves and pipes (locked, condition)
Tank valves and pump switohes (location, condition)
Surface waters in the area
Location of process water outfalls
Sewer drains
Floor drains
oil filled transformers (location)
~ll Control and Resconse
B.
Fill control devices
Location perimeter
Site security (e.g8' fencing, quarded entrances)
Storm drain inlets
Sumps
Ponds, lagoons, catchment basins
Flow diversion systems
Dikes or berms
oil or hazardous substance spillaqe (or 8vidence of past
spillage)
Deformation or age of tank walls, deep rust, chemical
corrosion, damage or any siqn of leakaqe at the seams
Emergency response equip=ent (8.q., absorbents, booms, etc.)
Personal safety qear (e.g., qoqqle., qloves, rubber boots)
Internal communications or alarm system
Secondary containment (condition, 8.q., cracks, holes, open
drainage valves)
2-18
-------
ATTACHMENT 4
SOLI~ AND F~ZARDOUS WASTE MANAGEME~
Obsc~~ation Check~
This one-paqe aite tour checklist is provided as a reference for
thinqs to look at during the orientation tour and subsequent
tours. This list is not exhaustive; it is meant to serve as an
aid or tool to remind the auditor of the major considerations.
Solid and Hazardous Waste
Hazardous waste generation points
Waste characteristics--toxic flaMmable,
On-site storaqe (sp.qregation, labelinq,
leakers, etc.)
Transportation routes
Past disposal practicas
Groundwater monitoring
Spill potential, control
Disposal of waste oil
Local geoloqy, hydroloqy
Location of contingency plans
Laboratories (management ot samples)
Evidence of past spillage
Incinerator, surface impoundments, etc.
Disposal areas
Safety and Res~onse
Emergency response equipment (e.g., absorbents, booms, etc.)
Personal safety gear (e.q., gogqle., gloves, rubber boots)
Internal communications or alarm system
site security (e.g., fencing, guarded entrances)
site perimeter
-
PCBs
-
-
corrosive, reactive
containmen1:,
Immersion oils
In the samples received at the tacility
Transformers/capacitors and lab samples on-site (active or
inactive)
Documented confirmation ot analYtical results
Past disposal practices
Spills: amount, likelihood, contingency plans
Inspection systems
Labels
2-19
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~
EN'TIROI'ot"MENTAL ~rAGEME~~
INTER!
-------
3.
4.
3.
ATTACHMENT 5 (Continued)
EN\'IRONMntT.A~AGEMENT
INTERN~L CONTROLS OUESTIONNAIRE
Who's the Environmental Compliance
Coordinator (ECC) for this facility?
a.
Where is the ECC located?
b.
It not on-site, how otten has the
ECC been to t~e site during the review
period?
Does th~ facility have any specitic
policies or procedures pertaining to
the following?
a.
Record retention?
b.
Equipment changes?
Use of contractor services?
c.
d.
Waste minimization?
e.
Compliance with established rules and
requlations, and policies and
procedur4ls?
f.
Submission of routine requlatory reports?
Reporting environmental accidents, such
as spills, upsets, releases, etc.?
g.
h.
Inspecting and testing of pollution
control equipment?
Inspecting hazardous waste accumulation
areas?
i.
j .
Monitoring emissions (i.e., air, water)?
For samples received at the facility,
or generated by the facility:
k.
2-21
1n
NO
HLA
--
--
---
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v.
4.
~ACHMENT 5 (Con~inued)
ENVIRONMENTAL MANAGEMENT
INTERNA~ CO~TROLS OUESTIONNAIR~
Collectinq, pre.ervinq and analyzinq
environmental .ample.?
Maintaininq a chain-ot-custody tor
those samples received?
Acceptable methods tor storaqe,
handlinq and disposal ot bioloqical,
chemical or radioactive waste
materials?
1.
Acceptable uses and methods tor disposal
of cleaning aqents (e.q., chromic and
nitric acid mixtures)?
m.
storage, handlinq or disposal ot other
chemicals (e.q., bottled qases,
solvents, toxics, etc.)?
n.
storage, handling or disposal ot
carcasses or contaminated clothinq?
Limitinq materials discharged "down-
the-drains" from the tacility?
o.
p.
Limiting materials used under ventila-
tion hoods within the laboratory?
Responding to outside aqency
inspection or reviews?
q.
r.
Respondinq to citizen complain~s
(e.q., odors, etc.)?
Waste characterization?
s.
t.
Selection ot hazardous waste ~reatment
.torage and transporter vendors?
ott-site waste disposal?
u.
Other?
Does the tacility conduct any periodic
environmental monitorinq?
2-22
10
HQ
HLJ
- -
- --
- -
- -
- -
- -
- -
- -
-.--
- -
- -
- -
- -
-------
5.
6.
7.
ATTACHMENT 5 (Continued)
ENVIRONMENTAL MANAGEMENT
INTERNAL CONTROLS OUESTIONNAIRE
a.
Air emission.?
b.
Water discharqes?
Drinkinq water?
c.
Does the facility have an emerqency
respor~se plan?
Does the staff resconsible for environmental
compliance routineiy meet to discuss current
issues (or, if one individual, does the indi-
vidual responsible for environmental compli-
ance routinely meet with facility manaqement
to discuss current concerns)?
Does the facility maintain files for
documents relatinq to environmental
pollution?
a.
Permit applications?
b.
Permits?
c.
Correspondence?
d.
SPCC plans?
Emerqency plans?
e.
#
-.
Waste analys..?
q.
h.
Waste manifests
Annual reports?
i.
Monitorinq r.sults?
Envir9nmental inspections and audits?
j.
k.
Compliance waivers or variances?
Incident reports?
1.
m.
Public complaints?
2-23
:in
HQ
t!LA
---
--
-- --
--
---
---
---
---
---
--
-------
~ (Continued)
ENVIRONMENTAL MAN~GEMENT
INTERNAL COlrrROIS OUESTIONNAIRE
n.
Emission inventories?
o.
Consent agreements or notices of
violation?
8.
Is the tacility currently under a consent
order, compliance schedule, etc., to comply
with requlatory proqram requirements?
It yes, who is responslb~e for insuring
compliance with this order or schedule.
9.
Is any training other than on-the-job
training provided to tacility personnel
in the following categories:
a.
Spill response and control?
b.
Hazardous waste management?
c.
Emergency response?
Wastewater treatment plant operation?
d.
e.
Releases ot hazardous substances?
f.
Use and acceptable storage, handling,
and disposal methods tor biological
or chemical compound. including toxics
and radioactive. materials?
10.
Are these training sessions documented?
How frequently i. training provided in:
11.
a.
Spill response and control?
b.
Hazardous waste management?
2-24
~
HQ
!!LA
- -
- -
- -
- -
- -
- -
- -
- -
- -
-------
ATTACHMENT 5 .(Con~inued)
ENVIRONMENTAL MANAGEMENT
INTERNAL CONTROLS OUESTIONNAIRE
c.
Emergency respon.e?
d.
Wastewater treatment plant operation?
e.
Releases of hazardous subs~ances?
f.
Uses, storage, and disposal of materials?
12.
Who receives this training?
a.
Spill response?
b.
Hazardous waste?
c.
Emergency response?
d.
Wastewater treatment?
e.
Releases of hazardous substances?
f.
Uses, storage, handling and disposal
of materials?
13.
Are there any other off-site locations
that are the responsibility of the
facility director?
2-25
~
HQ
N/A
-------
14.
15.
16.
17.
ATTACHMENT! (Continued)
ENVIRONMENTAL MANAGEMENT
INTERNAL CONTROLS OUESTIONNAIRE
Are there any field operation. which are
the responsibility of the facility
director?
Are there any USEPA reqional or head-
quarter orders or other quidance
materials which require specific
environmental manaqement activities?
Has the facility identified pollution
abatement plans under the A-I06
reportinq requirement?
Describe the facility's past disposal
practices.
2-26
In HQ
liLA
- --
- --
- -
-------
Part 3:
Gathering Audit Evidence
OBJECTI~
This part of the protocol facilitates the
gathering of audit evidence to confirm
compliance ..i th regulatory requirements.
The steps included in this part present 'a
series of testing procedures for
confirming compliance with regulatory
standards. This part, however, does not
present the only testing procedures which
may be used. If alternative testing
methods are used, the auditor should
indicate that the protocol step was not
followed, and that an alternative method
of verification was used. The auditor
should also indicate the method and
rationale for choosing the alternative
methodes) .
3-1
-------
PART 3:
A.
GATHERING AUDIT ~DENCE
AIR POLLUTION CONTROL
Pe~it App~ons (40 CFR Part 51)
1.
Determine through review of process flow
diagrams and observation that facility
records on emission sources are accurate
and complete:
a. Locate and note all (or, as appropriate,
a sample of) points of continuGUs and
periodic emission (stacks, ventilators,
wall fans, exhaust ports, incinerators,
etc.) on a facility layout map. (Some
emission points can be noted during the
facility tour but a thorouqh inspection
of the facility's rooftop(s) should be
conducted in order to locate all
points) ;
b. Identity the location of all emission
control and monitoring facilities and
cross reference to emission list;
c. Note any likely sources of emissions not
included in the above; i.e., open
bumings, fugitive dust, smoke
generator, open containers, pumps,
valves and storage tanks; and
d. Compare the points identified in
a-c above with the most recent
emissions inventory. Note any
discrepancies.
2.
Review for accuracy and completeness the
applications for registration, operation
and construction ot air emission sources
and control equipment:
a. Determine that applications are accurate
and signed by appropriate agency
personnel;
b. Check compliance with prevention ot
significant deterioration and
non-attainment rules, it applicable;
c. Confirm that all sources of emissions
and control equipment noted in (1) above
are properly permitted or registered.
List any sources of emission or control
equipment which are not properly
permitted or registered;
3-2
Auditor(s)
& CommerHs
-
W
~I
-
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, PART. 3: GATHERING AUDIT EVIDENCE
AIR POLLUTION CONTROL (Continued)
d. Confirm that all nece..ary permit. and
registrations are current by checkinq
expiration dates, and confirm that
required fees have been paid in a
~imely mannar by checking facility's
file. and operating expense reports;
and
e. Determine through review of A-106 files
or operating budgets that proposed
expansion of the facility or increases
in emission rates are properly reflected
in applications tor revisions or renewal
of permits.
Permit Conditions
3 .
Prepare a schedule of all permit and
requlatory require~ents currently in
etfect. Confirm compliance with each by
completing this section. Add additional
steps as appropriate.
Verity that operating procedures or
installed systems are capable of providing
intormation substantiating compliance with
requirements:
4.
a. Review calibration and maintenance
records tor emission control equipment
to verity that equipment works as
intended; and
5.
b. Observe or review analytical techniques
and monitoring procedures to verity
contormance with permit or regulatory
requirements.
Review monitoring data to determine whether
all applicable standards and limitations
are being met tor regulated emiaaions for
all sources.
6.
For any permit or regulatory emission
exceedances noted, review internal records
for proposed and completed corrective
actions.
3-3
Audltor(s) W.P.
& Comments Ref.
.
.
-------
PART 31 GATHERING AUDIT EVIDENCE
AIR POLLUTION CONTROL (Continued)
7.
Determine through inquiry (i. a., ask
persoT~el if they have had any
opacity problems), QDs.rva~ions
(i.e., l~ok &t e~is8ions) a~d review
of availahle dQc~~en~s (a;ency
inspections or citations noting
opacity problems) ~~at the facility
is in compliance with applicable
opacity standards.
Review recordk~eping files to confirm that
all required reports (e.g., equipment
ma:funct~ons, a.nnuAl emission reports, air
emer~ency plans) hav~ b~en submitted to the
appropriate r.egulatory agency.
8.
Prepare a schec:.ule ot requirements under
any out~tandir.q cour~ orders and verify
that all requi=e~ents are being met.
New Stationary Source Jitandards (40 CFR Part 60)
9.
A~~licabi1itv (40 CFR~t 60.1)
Review air pollutior. control standards to
determine their applicability to this
facility. Note any modifications or
constr~ction to the facility since _975.
Notification and RecordkeeDina (4~ CFR
Part 60.7)
10.
11.
Interview facility personnel and review
facility records to confirm that the
facility notified the EPA
Administrator regarding construction
of the facility.
Confirm that the facility has .ubmitted
quarterly reports to the
Administrator regarding continuous
emi.sion5 montoring.
12.
13.
Verify that records are kept
regarding facility atart-up,
operating conditions, monitoring,
reports, etc.
Performance Tests (40 CFR Part 60.8)
14.
Interview facility personnel and review
f~cility records to verify that performance
teats were conducted within 180 days after
the start-up of the facility.
3-4
. Auditor(s) I w~~
& Comments I Rei
-t-"
,
I
1
I
-------
lART 3: GATnRING AUDIT u~DENCJ:
~IR POLLUTION CONTROL (Continued)
:L!.
16.
Confirm that the facility conducted
performance tests according to approved
methods by interviewing facility personnel
and reviewinq facility records.
Review facility records to confirm that the
administrator is notified prior to
performance testing and confirm that
performance testing facilities are
available by inspecting facility
operations.
stancards and Maintenance Reauirements (40 CFR
Part; 60.11)
17.
If applicable, inter/iew facility personnel
and observe condition ~f emissions to
confirm that opacity s~andards are met.
18.
Review maintenance and inspection
procedures with appropriate facility
personnel. Review records to confirm that
maintenance work and inspections are
conducted.
Monitorina Reauirements (40 CFR Part
60.13)
Review specific monitoring requirements for
the facility. Confirm that monitoring
equipment is available and functioning.
Scecific Facilitv standards (40 CFR Part
60. Subcarts D throuah PPP)
19.
20.
Review specific monitoring requirements for
the facility. Confirm compliance
with selected facility specific
standards.
Fuel Disoensina Oo.rations (40 CFR Part SO)
21.
22.
VerifY through observation or recorda
review that the appropriate vapor control
systems or submerged fill pipe. have been
installed on gasoline fuel tanks.
Determine whether the fuel dispensed for
motor vehicles is in compliance with
federal requlations by checking fuel
dispensing pumps for appropriate labels and
nozzles and reviewing purchasing records
for fuel deliveries.
3-5
Auditor( s) W.P.
& Comments Ref.
.
I I
I
I
-------
PART 3: GATHERING AUDIT EVIDENCE
AIR POLLUTION CONTROL (Continued)
Hazardous Ai~ p~1lutants (40 CFR Part 61)
23.
If applicable, for ~~e latest National
Emission Sta~dard for P.azardous Air
Pollutants (NESHA?~, cetemine whether
permit or standard l~mitations are ceinq
met where such discharges are a part of the
facility's operation. Establish that
approved testing and reportinq procedures
for emissions of hazardous air
pollutants are being complied with,
especially for:
a. Asbestos;
b. Beryllium;
c. Merc\1r"i~
d. Vinyl Chlo=ide:
e. Radionuclides;
f. Benzene;
g. Radon 222;
h. Fugitive dust emissions: and
i.
Inorganic arsenic.
24.
Review documents applicable to the
construction, modification, or. operation of
any stationary sources which emit hazardous
air pollutants. Check the following:
a. Timeliness with which the information
was filed;
b. Completeness of the information
forwarded to the regulators;
c. Approvals and/or suesequent
correspondence from regulators (e.g.,
waiver of compliance); and
d. Procedures established for handling of
asbestos.
3-6
Auditor(s) f ~
& Commenu Re
~
-
I
I
I
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PART' 3 : GATHERING ApCIT £VIDENCE
AIR POLLUTION CONTROL (Continued)
A1r~on Alert and Emeraency Plan
25.
Review applicable regulations to determine
~f the facility is required to have an Air
Pollution Alert and Emergency Plan. If a
plan is required, review the plan and
confirm that it conforms with regulatory
requirements.
Fuel Burnina Eauicment
26.
By reviewing purchasinq records and other
available doc~entation, confirm that the
sul~ur conten~ of fuel oil used for fuel
burning' equipment (boiler) conforms
with that prescribed in applicable
requlations.
3-7
Audltor(s) W.P.
& Comments Ref.
I
I
-------
PART 3:
GATHERING AUDIT EVIDENCE
B.
WA~ER POLLUTION CONTROL
N?DES Permit A~cl~ons (40 CFR Part 122.
Subcart B'
1.
Determine whether the facility discharges
its effluent through a point source. If
yes, complete the following protocol steps.
This should include a review of storm water
discharges to storm sewers from boat and
motor vehicle maintenance areas, as well as
chemical and oil storage areas.
Confirm that facility records on point
source discharges are accurate and complete
by:
2.
a. Reviewinq sewer maps and process flow
diagrams;
b. Touring the facility (and satellite
facilities) and noting all places where
wastewater or contaminated surface water
leaves or may leave the facility
boundary;
c.
Noting all discharges where there is
visual evidence of impact on rece:ving
waters--oil, foam, color, floatir.g
solids, etc.; and
3 .
d. Identifying points where flow from.
adjacent property may influence facility
effluent quality.
Perform the following to verify that permit
applications (i.e., NPDES, SPDES) are
accurate and complete:
a. Examine the permit for completeness of
data, accuracy and compliance with
required filing dates;
b. Document that the permit application was
siqned by the person specified in
applicable requirements or that person's
duly authorized representative;
c. Confirm that all point source discharges
noted in Step 2 above are properly
permitted. List any point sources which
are not properly permitted;
3-8
T
-
Audltor( s)
& Comment,
'N,
R(
-
-------
~----
~I . ~ ~ ' .... T r. t;-. ~ ,
~.~~_3_. --_G,',j, ri~BDl~ "~..1~~J:_VJ.f) :t.'-.oCt
. !An~B-_PQ 1!1.Q1 IQ~___CQ!iil!QJ.! ( Con t h, ~H~CJ )
d. Determina throUS;L1 review of A-106 fi] AS
or operating bi.ldgets tha.t expansion of
taciliti~s or ~ncr~ases in discharge
rates are properly reflected in
applic~tions tor revisi~~s or renewal of
permits. Also, detenail'le it e,'i
facility changes may have res~lted in
char.ges or type o-r pollutants ~.vt
covered in applications for pel~its or
in existing permits;
e. For those substances r.eported as present
or absent in di sc~.arges et tilte c'f
permit applfc:ation, ascertain if the
b2sis for thd~ description 1s still
valid: and
f. Asce:-tain whether a!"lY water quality
parameters for receiving waters would
necessitate revisio!"l5 in permit
applications.
NPDES Permit Conditio~1~~F~ l22L
S;jbpar~ Cl
4 .
Develop a schedule of all permit
requirements and regul:-.tions C\lrrent:y in
effect. Confirm compliance with eac~ by
completing this section. Add additional
steps as appropriate.
5.
Determine whether operating procedures or
installed systems are cap~ble of providing
information substantiating compliance with
requirements. For example:
a. With facility personn~l, observe the
procedure for sample collection,
analysis, and data recording. Document
and assess the maintenance and
calibration programs for the following
device.s:
Composite sampling;
Effluent flow measuring;
In-place monitoring and recording
devices; and
Control equipment.
3-9
-~ ---=---.
Al.w:"~c..\s) r W p
& Co(tlrJl",n!s ~:r--
_n___~_- -1-'--
I
I
I
-------
I"~~'J:'-~: -~ ~l.!'tifB. \fG l-~tLI.t..IY~tH'-~
!AIJ.F _nJ.J~.--CJTI:_oti._cot{1f\~~r! (Continued)
b. Note tny provi~ion tor crosschecking or
verification by 1ndepende~t analysis, as
well as other quality control
procedures; ~nd
6.
c. Verify that locations of 8ampling points
result in r~pres' ~ative samples, and
sampljng treque! 4 agraes with per~it.
Review monitoring lecords tor inclusion of
all required inf(ln!l.~ '..ion:
a. The date, exact ~lace and time of
sampling;
b. The individuals perfornling the sampling
and analysis; and
7.
c. The analytic?l methods used and results
of such analyses.
Review the laborato~~ analytical procedures
used by the facility to analyze wdste
waters and verify co'plianc~ with the
quidelines and test ~rocedures as outlined
in 40 CFR Part 136. Determine wh~ther
proper sample containers, preservation
techniques, holding times, and quality
control pro~edures a~e used. (Note any
significant discrepancies between
procedures used and those approved.)
8 .
Confirm the operation ot reporting
procedures by obtaining documents for a day
of non-compliance with permit limitations
(if appropriate) and selecting a day of
compliance with per~it limitations and
carrying out the following procedures:
a. Review recorder charts, laboratory
results of required sampling, e'.c.;
b. For the non-com~liance day, review tile
material to ~( ~ain basis tor
non-complianc~
c. Review reports fo~ 'd to regulatory
agency confirming ~.1~: ( complet' "-less,
accuracy, submitted date, etc.;
d. Review interl!al records for the proposed
corrective action; and
3-10
.....
Auditor(s)
& Comments
I .
-------
~~..- - '------.. - ._- .-_.:~~=..J.__1_':,_..' .
JIA1..} ~,- f'~--LtrI'l.QtC~Q~I:BQj" (Co('lliriu..~)
e. D~,ternine wheth~:r CO!.' r~cti ve action was
ettected promptly (i.e., revi,lon of
operatinq proc~du=es, repair or
equipment, j.nst~llat'iorl c! ne"N
equipment, .tc.).
Prepare a sched.ule of requirement-c; under
any outsta.nding C,'dJl't order~ and verity
that all requirements are b~~TI9 met.
$ewer Discharges liO CFR P~~l
9.
10.
Detez-",ine wh~thE!r the faci::.ty dischar~es
effluent into a sa~e~, POTW, or septic
tank. If yes, co~plete the following.
Deve!op a schecule of, and verify
compliance with, all S' . r use regulations
0:- pre~reatment qi.:id~linec- cu:-rently in
effect by conducting the following protocol
steps. Add additi~nal steps as need~d.
Examine permits, licenses, or agre~roents to
determine pollutants for which discharge
limitations have been established.
11.
12.
Observe or review sampling, monitoling and
treatment procedures to verify conformance
with regulations or sewer permit cOiditions
(e.g., sampling points, sampling frequ~ncy,
maintenance and calibl. ation of equipment) .
13.
Obtain an understanding of the composition
of process and treated wastewater to
confirm that the discharge does not
contain:
a. Pollutants which create a fire or
explosion hazard in the POTWi
b. Pollutants which cause corrosive
structural damage to the POT~i
c. Solid or vis~ous pollutants ~hich c~use
tlo~ obstructions in the POTWi
d. Any pollut~nt released at a tlow rate
and/or pollutant concentration which
will cause interference with the porrw i
and
e. He~t in amounts which will inhibit
biological activity in the POTw
resulting in interference.
3-11
Ai.,":'((."S', j w p
&C.~%II~r:~- _~e~
I
I
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L_- --~- ----~---'----'-~"~- _._,-._~~t-_"l:J.~:
IAI~:R }'-9~!;V)"1 lQlL ,~Qtft!".QL (Col'1tlnutC')
14.
15.
16.
17.
18.
Review monitoring d~ta to verify compliance
with s~wer usa regulations or
per-.1li tjl icense agl-eeItentf:!.
It appli~able, r6view strip ch4rts,
laboratory n~sults, etc., to confirm that
recordkeeping and reporting are accurate,
complete and tim~ly.
For any regulatory or pel~it exceedances,
review internal records for proposed ahd
completed corrective actions.
Rc.view the septic tank perluit and permtt
application to ensure that current
discharges were approved.
Determine if the septic tank di~charges to
an absorption field or a sewer line (field
tile). If the stptic tank discharges to a
field tile, determine if the field tile
should be permitted as a point so~rce
discharge.
3-12
--
Auditor{S) t,
& Comments
11.
-------
.;,k6";.~--~-i-~~Jl~~~:"\'}".,;:--l'J:) 'l'_~,_\ .\(.~k~ ~i~
. .
c.
'1.
2.
3.
4.
5.
6.
HQi:I:: R.~..zAB.Q9JU;-~c..tL:t:P_~."~TL-HA~--b~ f L~u';l.
Review and evaluate the adequacy of
facility procedures for classifying w~stes
as non-hazardous.
Determine it there are procedure~ in place
to prevent the mixture of non-hL Jardous and
hazardous wastes.
Confi rm th~t. records are being maint~, in(~d
which in~icate the types and qu~ntities of
non-haz~ 'ous solid waste ;~nerated.
Verify appr~priate procedures or guidelines
are being implement~d for the collp ~ ion,
processing or land disposal of solid
wastes.
Verify that non-hazaldous solid wastes are
being tre6ted, recycled or dispobed of at
an approved site.
If the facility has a land dispo~~l or
storage/treatro~nt unit, verity compliance
with applicable state and local solid waste
managemen t requirelJ',ents, including
groundw~ter monitoring.
3-13
A;.;. - ,..( \~)
& ~! lrrlt;, '1 LoS
W.f'
Re~.
j~._. -- ~----- -~ . .--- ,-~. ~
-------
VR--I. dL---GA11:1.I..RI F -~J&f2J'T_l~{'(DE-~.;E
D.
HAIABPOUS w~~1'L~tl.T1~BA:U.QN
Am2.t-:Lc;. ~Q11 it 'l
The followina se~tion t3S he~~ dev~loped to
confirw compiiance with hazardous waste
generator requireIDent~. If the facility is a
hazardous waste gener0tar and stores or treats
hazardous wast~ on-site, complete only Protocol
Steps 1-6, 8-15, 40-47, th~n com~lete Section E
"Haza~dous Waste storage and Treatment."
ijazarJous Was~e Determindtlon (40 CF~ Part
262.11)
1.
Obtain an understandina of the methods used
by the facility tc determine if wast~s are
hazardous by t.~lki~g to fa~ili~y personnel
and reviewing individual waste
charac~erizatica files. Docu.'l1ent the
method(s) used for each waste reviewed.
2 .
Ccmfirm that the waste determinat.ion
ration;;.,le t:leets the EPA approved methods
(knowledge of materi?ls and processes used
to generate waste, waste characterization
using EPA app~oved testing methods, listing
of wastes) .
Through tours of the laboratory and review
of purchasing records and MSDSs, develop a
list of materials which would potentially
generate hazardous wastes.
3 .
4.
Compare these materials identified with
loc~tion records to confirm that they are
handled appropriately as hazardou~ wastes.
Confirm that the frequency of analysis
adequately add:ress('s new processes and
process modifications.
s.
6.
Determine how s~m~les are manag~d a~ter
analyzed. (Ar~ samples lab packed for dis-
posal or washed down the lab sink?) If
samples are washed down the lab sink, where
do the wastes go?
3-14
...!
AUGi;Uf(S)
& Comments
-
-------
, .".",.: 11.1' ( .....,..,-;.)
----- --yo-l---"- ..~~--::~-:- ~:...-"'%..~~':.,..~.~ '- ....1~.,~.c}~~~-
k9.11~-1-t.i~3l~.U..Y_E><;~.!!\~~~~. 1.1.-.0' 1 ~m;l.tY-_~~~~. },,-Q r~
(40 ~rB-P.~rt 261.51
7.
Determin~ whether the site meets the
r.gu~atory r.~~irem~nts for conditionally
exempt ~mall quantity generator statu5
«100 k~/mo hazardous, <1 kg/mo acutely
hazardous) by reviewing qenerat~on 1095 for
quantities. It yes, complete the
tollowin<;;ji
a. Document what tacili.ties have been used
tor di sposal and verity that t}\ey are
authorized to accept this wa~t~.
(Review site' s permit~. and al--plicable
regulatory requireIDent~.);
b. Review qer.eration and accumulation 109S
and determine it the site has ever
exceeded the conditionally exempt small
quantity generator li~itation. It so,
document this exceedance (conditionally
exempt small quantity generators may
accumulate up to 1000 kg of hazardous
waste); and
c. Confirm t~~t the small quantity
generator has determined if wastes are
hazardous in accordance with 40 CFR Part
262.11 (Steps 1-6).
fPA Identif~cation Number,_.1~O C:f'lL.Eart 262.11.1
8 .
Determine if the facility has received a
generator identification number:
a. Review information on the EPA
identification to verity that it is
correct; and
9.
b. Obtain and review a copy ot the Notice
ot Hazardous Waste Activity Form 8700-12
to verity that the information is
correct.
Doc~.ent the system used by the tacility to
ensure that transporterr: and treatment,
storage and disposal facilities have EPA
identificati~n nu~bers.
3-15
k- .;~)
& I: OI!"oIt:;::LS
~- ~ .<.-..&.--
W.F.
ReI.
-------
IlY ...L - ~ ,;'~; t:~~:'- '''"-- )..-_t~~ )~_J:V i l!~N's.':...
BA.Z}~~ '",: ~__,WAs..r f;.~~J tii.8.A.TJ 9..H (Con t inued)
tWi ~ J_~~ t~-L~r!Lftr~.l..~2 J 01
10.
11.
12.
Obtain c0pies ~f facility ma~ifests for the
review pericd. Cr~gs rafcr~nce. tce
manifests to !ccou~ts p8yable records and
daily ~ecords to ensure that all 8hipments
were manifested.
Review the state regulatory rsquirements
for manif~stinq of wastes shipped off-site
for recycling, treat~ent, storage_or
disposal. Ensure that all additional state
req'-.lired In!on,ation appears on each
mor,ifest ana the proper m~.nifE1st form is
used.
Review the manifes'ts to ensure that the
followi~g fede:ally requi~ed i~~ormation
appears:
a. N~me, address and EPA I.D. number of the
designated treatment, storage or
disposal facility;
b. Name, address and EPA I.D. number of any
des1gnated alternate treatment, storage
or dis~osal facility (if applicable) ;
c. Name, address and EPA I.D. number of the
trC1nsporter(s);
d. Generator's name, address, I.D. number
and telephone nur""'".er;
e. Manifest document number (sequentially
numbered) ;
t. U.S. DOT description;
g. Type of container used to package waste;
h. T('\tal quallti ty of wastes (wt ./vol. ) ;
i. Generatol:' cel'titicatjon (DOT sldpping
re~~irements/waste minimization); and
j. Generator, transporter and facility
signatures.
3-16
. .,.~ - -- -~,--
Auditor (5)
& comrnc.~
I
I
I
I
I
...;.:.,.....
-------
''''''----'''''-:'''-'---' "'-.~L'4.' .~._"'_'_\'..',~
L WA,.~)~';~~~~~. ..t~-- Gt'~iB-; b~_i()1i- (Con.flrltl~~)
IPLQ1{::W.L b)J..Qy
13.
Confirm t.ha~.. the EPA Superfund of!~'site
policy is being followed by cond~cting th~
fo11owlng:
a. Deter-wine if treatment rather than
landfilling is used for the ~anagement
of wastes;
b. Determine how the farility confirms that
the site is permitted to receive and
manag..:: the \0' ..ste; .
c. It landfills are used, document thc~' the
facility has confirmed th~t the TSDF
meets doubl e-line req-uirement::. of the
1984 RCRA amendments;
d. Determine how the facility ensures that
TSDFs selected are meeting RCRA
requirements; and
e. If brokers are used, determine how the
facility deter~ines ultimate disposal.
Pre-Trar.sDort Requir~en~~~FR Parts 26~.30-
L€i2.:3:31
14.
Ensure that wastes desi~lated for
tran~portation are packaged, marked, and
labeled in accordance with applicable U.S.
DOT requirements (49 CFR Part 172).
Determine how the generator a~sures that
the transporter has proper placarding prior
to shipping wastes off-site (49 CF'R Part
172, Subpart F).
Accumulation Tit!le ~1411 cn PartF! ~62 t 34 (a) and
.!!ill.
15.
Containers
16,
Review the facility'~ cont~in~ ~ storage
activities by doing the follo 1ng:
":""'--~
3-17
,,"d?~ '" W p I
& ~~:~n-,~:~~.. ~-~~~',
-------
m:~,-~ 1-- G..~~rRIN ,,-,_A QQl'LrvJ ~trl_,~~
BAttI'~)~J$---~-~J;~t~<}:r~T:toH (C;ont inued)
a. InSl'l?ct the container accumulation areas
to v~rlfy th~ tollowing:
Acc~ulatio~ date is m~rked and
visible OIl contcsinersi
Audi10r (s) ~
& Comments,
I I I
-il. .
I
Containers ale maL "~ed with the words
"Hazardous Waste";
containers are in good condition;
containers are compa~ible with
waste; and
containers are stored closed.
b. Dete~ine if the facility conducts
weekly insp~ctions of container
accumulation areas to look tor leaks and
container deterioration;
c. Determine if containers storing
ignitable or reactive wastes are stored
greater than 50 teet trom the property
line (not required for those generating
100~'1000 kg/mo);
d. Determine how the facility ensures that
containeis used for waste storage are
not incompatible with the wastes. It
product containers are used to stoLe
wastes, deterwine if the wastes are
compatible with the materials previously
held (use Appendix V of 40 CFR Part 265
as an aid) ;
e. Determine if incompatible wastes or
wastes and materials are separated or
protected by other physical means such
as a wall or dik~; and
f. Review accumulation 109S and in~~'8ct
wastes b~ing accumulated to verify that
wastes have not been held tor more than
90 days tor greater than 1000 kg/mo
generators and 180 d~ys tor 100-1000
kg/mo generators unless waste is
transported greater than 200 miles, then
wastes may be retained tor up to 270
days.
17.
If the facility generates between 100-1000
kg/mo of hazardous waste, determine it it
has ever exceeded the 6000 kg limitation.
3-18
-------
. W'~'---)~L G~-1t;~PJ.~ ._~1.!.QD:..J" L(,J) :'~-~j~
BAZ.ABJX'Ig~. "lA$1'~- GLl.{t,BA'IiOH (CCll" r inur: .-)
'; a n It; $.
18.
Review the facility's tank accumulation
areas by doing the following:
a. Dete~ine if the tany is lab~led with
the words "Hazaldous Waste";
b. Determine how the facility assesses
whether wastes and the con-=truction
materials ot tanks lire com-lJatible
(265.192) ;
c. If uncovered tanks are used, determine
how the location ensures that two feet
of freeboard is maintain~d. Inspect the
tanks and review inventory recl...rds to
determine if tell'-' f:-eeboard requirements
are being met (265.192);
d. If the tanks have a continuous teed
mechanism, dltermine wt1at m<:"chanism is
used to stop the flow of wastes into the
tanks. Inspect this device with
location personnel to ensure that it is
operable (265.192);
e. Deten~ine if the facility has conducted
daily inspections of discharge control
equipment, monitoring devices, and level
of waste in the tank. Review a sample
of the inspections to ensure that they
are conducted (265.194);
f. Determine if the facility has conducted
weekly inspections of the const'uction
materials of the tank (corrosion,
leaking) and constructiC);1 materials of
th~ discharge confinement structures and
area imm~diately surrounding (265.194);
q. Determine if any tanks wh~ch ~eld
hazardous w~:tes have been taken out of
8~'rvice. Review the clos; .~ process to
ensure that wastes and re~idues were
removed and disposed of properly
(265.197); .
h. Review inventory records ~o ('~termine if
any ignitable or reactive wastes are
stored in covered tanks. If so, ensure
that wastes are properly manage~ and
meet NFPA buffer zor\e require~ents
(265.198); and
3-19
AuC1t~f(S~- r W.P 1
&- Cc':"n~~~_+~.!
I
I
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h> '---~ t - Ci}.TH)--1; ~(L~Utn:.1'~JJ:l_Q:i'.(J(
BA1!.~,J2QQ~- w~~1L.__Q.tt!j:_&~_TIQH (Continue1)
i. Revie~." invent()ry record~ to det'21'mine if
incot..,atible wlistes are placed in the
~ame tank (se~ Appendix V ot 265 Part
for exa~ples). Deterwjne how the
facility ensures that incompatible
wastes are not placed in the S~e tank
(265.199) .
Fersonnel Training_-t40 CFR p~rt 265.161
Note: Steps 19-21 apply to generators of more
than 1000 kg/mo.
19.
Determi~e if the facility has a personnel
training program:
a. List the job title and credentials of
all persons invo~ved in personnel
training; and
20.
b. Obtain a copy of the or9anizati~n chart
of employees involved in the man~gement
of hazardous wastes and determin~ th~
date of employment in that caf'4city.
Select a random sample of those employees
involved in hazar~ous waste management and
facility operations involving hazardous
wast~s. If possible, sel~ct on~ person
from each job title with greater than six
months' tenure:
a. Review the hazardous waste management
training files for the random s~rnple
selected above. Determine if each
person selected has a defined job title
and job description which includes
requisite skill, education and duties of
the job title;
b. Determine if each file includes a
written description of the type and
am(Junt of both introductory and
continuing training that will be given
to one filling the position; and
3-20
""
-------
, w. .',.- ~: ...~G"','tH1 ~~ J}~ ~. ,. ~r p " '('.- t. Y- 11 t-. (, ~
Wl.MJ>Q.Q$ --W).$ "rt ...G t: !'Jn~,AJ! ~'I t! ( Corl t i Ii ue d)
c. D.v~foP a chec~ . 1st to be use~ for
determinirl9 if documentation exists
which verifies that an emp'oYf~ has
received all the training r~' 'ire( to
fill the pes it ion. (List Q9_th
intrud~ctory (within six mont~s of
employment) and continuing education
(annually) required and indicate it
given.) At a minimum, the training mus'
includt how each person is to ~espond to
an emergency by familiarizing them with
emergency procedures, equipmenf and
system~. This training must include, it
applicable:
Procedures for using, inspecting,
repairing, and replaci~g t~cility
emergency and monitoring equipment;
Key p~ramete~s for automatic waste
feed cut-off systems;
Communications or alarm systems;
Response to fire or explosions;
Response to groundwater
contamination incidents; and
21.
Shutdown of operations.
Select a sample of personnel who have left
the agency and were involved in the manage-
ment of hazardous wastes by reviewing
employment records and job titles.
Determine if the agency has retained
docuroentation of the training given to each
employee.
For generators of 100-1000 kg/mo, confirm
that employees are thoroughly familiar with
proper waste handling and emersency
proc~dures.
Prepare~.t"\~ss anR Pre'Zetl.ti.Q"Q
22.
Required Equ~ment LiO CfF Part 265.321
23.
Confirm that the facility has the following
required equipment:
a. Internal co~unications or alarm system;
3-21
-- -- - ---
~;:p 1,
Raf.
A:.; "'1! :,«(5)
& Cornmt.ll~
~--~"._-
-------
RAR~J3 t_~._GA T1i"]: B~s' ~.--~_tJtt:[~ Q~..c.~
ti.hZA,BDOU$._~Z.~l t\_-~Jct>l~'IIQl! (Continued)
b. Telephcne or ot!l-er cOT;J'Junlcatlons deNice
which 1JJd'j be USeiC fo}~' sUtn:(\onlng help in
case of amergellcy;
c. Portab:e fire .ext!.nguitSihers, tire
control eq\lir"Lt, spill control
equi.pm~mt, and decontamination
equipment; and
d. Water at a vol~e anJ pressure to supply
water hos~ streams, foam producing
equipment, automatic sprinklers, or
water spray systems.
24.
Determine if all equir,cr.ent is loc~ted where
it should be and that it has be~n inspected
as required, is useable and accessibla.
Access t~Co1T::'nunicati_ons or Alarm Systems (40
eFR Part 265.34)
25.
Interview facility pet'sonn~l and inspect
'Waste handl ing areas to COi.! irm thCl. t
communications or alarm systems are
accessible in case of a.1i emergency.
Recruired Aisle Soace (40 eFR Pa~ 26~~
Determine if there is sufficient aisle
space for the unobstructed movement of
personnel and emergency equipment by
auditing storage facilities.
~rranqe~er.ts with Local Authorit.ies (4QH CFR PAU
265.37)
26.
27.
Determine when the last training s ~sion
was conducted to f~miliarize the local
authorities ~ith L 41ity layout and
waste manage~cnt pl~ ~.
28.
Determine if a primary ~IDergency response
authority is designated, if there i~ more
than one pelice or fire departm~nt which
may respond to an emergency.
Obtain copies of the agr~ements made with
local and state £mergency resp~nse
authorities, including emergency response
contractors.
29.
3-22
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~ .
;~~2C::!~~~A$ tL,~~~~tM:ti9.t!-- (C-Ot.~~ H1U€~)
30.
31.
32.
Detenuine if emergency respon--;6 authotity
phone nwnbet's are posted in key locativns
2:1d are available to all .mer"~~ncy and
alternate em~rgency c~ordi~a~or6.
Cetermin6 if the site has inforMed local
hospitals and ~e~ica~ em~rgency teaN~ ot
the types of waste~ managed and th~
potential injuries which could result trom
operatlons. .
Determine if any emerg~ncy response team
has de~lin~d to ent~r into agreemeD~ with
the site. If so, verity that this has teen
documented in the operating record.
Cont;.i nge.r:cy ?Ian ~M_tThtl'..~~C'Y~~~~-i
Cor.te:1t of_C_or.ti~ge!':~,f F~a11 (4~ eFR p~;:t- 26~~.
Note: Prctocol Step~ 33-35 ar~ only applicable
to generators of more thdn 1000 kg/mo.
33.
Obtain a copy of the facility's Conting..ncy
Plan. Determin~ if the Contingency Plan
adequately addresses each of the required
components (265.52):
a. Actions t~ be taken in response to
eIti.-rgencies. Determine if all
operations and climatic emergencies are
1 isted (fires I expl(H~don, toxic fume or
gas generation, incomp~tible wa~tes,
spills, tornados, hurricanes,
earthquakes, etc.);
b. Arrangements with local emergency
response teams;
c. List of all primary emergency
coordinators and alternate9 includir.g
phone n~bers (home and of rice) and
addresses. Determine it the list is
cur'rent;
d. List of emer~ency equipment, its
location, and description of it~ capa-
bilities. Ensure that the list is
current; and
e. Evacuation plan including siqnf);1,S to be
used and evac; " tion routes and al terna tt:
evacuation routes (if needed).
3-23
...~ji, '(';','1 I U' ~
I"V.J~ ,,.; \-J 9W.7"
&"~on"r..r:~i_~
-------
.
~f!~_3~:_~JiA'!rltEl.t:(- ~t~Or'I'.I_~} rJt~~
Hl'I'A~!!lf J!.h[.~ GfJ'r£.F.:..)'~;}t£ (Continu6\d)
~~~_Qf CQillnqet'\cy- Plan !!O CnJ~rt 26~. 53 t
34.
Verify that copies of the contingency Plan
h~ve been qiver. to the emerqer.cy response
autho~ities including hospitals (cover
let~ers of submittal or certified mail
race i1-' L.s) .
Emergency Coordirta.tor (4JL..~_265. 55}
35.
With respect to the cm~rgency coo~din~tor:
a. Determine who the primary emergency
coordinator is for th€ facility. If
more than one alternate emergency
coordinator is listedl determine how
pl lor i ty is ~.'termined. Determine if
th~re is an emergency coordinator or
alteruate on-site duriT1~ operations;
b, If an emergency coordinator is nct
on-site during operating hours I
determine the proximity to the site of
the e~ergency coordinators. How are
assignments set up during non-operating
hours;
c. Determine what type of
devices are to be used
with the site when the
coordinator is enroute
communications
to 'comIlw.nicate
emcrlJency
to the site; and
d. Determine if the emergency coordinator
has written authority to use all
resources needed to properly manage
emergency situations and that thel~ is a
docwnent which lists his ()'r .
responsibilities fo~ assessing emergency
situations.
Emerqency__Procedures (4Q-~.11Lrart 265.56)
36.
Determine it the p'an addrt~::tes the
following (265.56):
a. Notifications and reporting activities
to be ma0e during and after emergency
situations; and
b. Decontamination ot equipment and
personal protective gear after
incidents.
3-24
r~~djtO((S)
I & Comme!'lts
""...--....
-------
.'
t--.-. --"-."'...:J_---~- -- '".....:.~-~k ..~-~~ ,---._._!.....,l--,.~ (~('""'.1\a.L -- - -.J
... -.....
37.
For qen~t"ators or 100-JOOO kCZ/Ii;O, d~t'--rro!rl'';
it th~ ~enerator has:
a. Designat~d a~ emergency coordinator! and
b. Pos~ed n~ar t~e phone system:
1.
The name a~d telephone nu!ber of the
emergency coordinator;
Location of fire extinguishers and
spill control equip~ent; and
2.
3.
The telephor.e nu~be= ot the fire
departIi1ent.
i..a_tellite AC91mutati..g11_Area-2_L40 CFR_Part 262.34
.!.£U.
38.
If the generator uses satellite
acc~mulatio~ areas loc~ted a~ or
generating process, confir~ that
m~naged as follows:
near the
wastes are
a. Containers of wastes are in good
condition:
b. Wastes are compatible with the
containers;
c. Containers are closed during storage;
and
39.
d. Containers are marked with the words
"Hazardous Waste" or with words which
identify the contents.
Inspect atellite accumulation areas to
determine if the volwne lhdtations (55
gallons hazardous waste, 1 quart acutely
hazardous waste) have b~en exceeded. If
so, confirm that ~ 5tes have not been
accumulating at these excess volumes more
than three days.
RecordkfL~_plrLq (40- CFH Part 262 d~
Note: Generators of 100-1000 kg/mo are not
required to retain biennial or £ ~eption
reports.
3-25
1'-.... -' :.:' '"', I v-..1
&~c,,
-------
L. ..:...:l:-_~~- ~- ~, . .. - :~:...:.t-~ -~_f's~- ~>..'. ...:.!:...!---~ . .' t! tJ!.~ ;,;
BAW~l>9JJS ~~.~.~;:.~tln..&6I.LQH ('Of tlnu.~)
40.
Dete~roine it the fOllowing documents have
b~en retair.ed b~' cr.e gene~.~tor ter &t lenst
three years:
8. Manifests ~t eff-site 6hip~ents of
wast~s:
c. Biennial and exception reports (trom
aate of report): 81.d
c. Test result of wastes shipped o!t-elte.
Biennial Rcpo~~s (~O ~rR Part 26~1
41.
Determine it the genp.rator has submitted
biennial reports to the Regional
AdJn:LJ!istrC\tor or Marc.:h 1 of each even
numbered year. Revie~" the reports to
verify that they cont~in the following
infoLaa tion:
a. The EPA icentificaticn number, name and
address of the genelator:
b. The calendar ye~r c~vered by the report;
c. The EPA identification n~e:-, n~:ne and
address fur each off-site tr~atme~t,
storage or disposal facility to which
waste was shipped during the year; for
exported shipments, the report must
given the na~e and addr~ss of the
foreign facility:
d. The name and EPA identification number
of each transporter used d~ring the
reporting year:
e. A description, EPA hazardous waste
number (froru 40 CFR Part 261, Subpart C
or D), DOT hazard class, and quantity of
each hazardous wa~te shipped ott-site.
This infvrmation must be listed by EPA
identification number of each oft-site
ta~ility to which waste. was shipped;
Note: The tollowing information is
required for reports tiled atter 1985.
f. A description of the eff~.lrts undertaken
during the year to reduce the volume and
toxicity of waste ~enerate~;
3-26
=- Auditor(s) TO"
& Comments I
-..:. ---J,..
I
:
-------
,~ 0",.,. --'0-
'iJ.I.-~" "~\' ,,~',,~ ;..I.Jk l' }:V~lj: (;~t
~~~tKCimU1! Qii- (Cc,jttinue1)
q. A description of the chan9~:s in vel ume
and toxioity of waste actually ac!deved
du:1' inq the year in compcll i !Jon to
previou5 years to the ext-- nt such
1nfor:('Lation is available for YEI:rs prior
to 1984; and
42.
h. The c~rtification signed by the
geneI~~or or authoriz~d r~presentative.
Revie~ with facility personnel ho~ the
information appearing in the biennial
reports was assimilated. It th&~e is any
que~tion regan1ing thift proo..;ess, obtain
facility records for th~ reporting periQd
and confirm that info~ution is complete
and accurate.
Excepti~n Re~~inq (40 CrR~~~4~
43.
Interview shipping and receiving per~onnel
or others responsible for manifesting
ha:~rdous ~aste shipments to determine how
they track manifests to ensure that signed
copies from the treat~ent or disp~ ~1
facility have been received within the 35
day limit. Determine how they manage
missing manifests.
44.
Interview personnel to determine if any
exception repor-s should have been filed
with the requla~ory agency for missing
manifests.
45.
If exception repor~s ~re on file, review to
verify that they include:
a. A legible copy of the manifest for which
the generator does not have confirmation
of delivery; and
b. A cover letter signed by the generator
or hi. authorized representative
explaining the etfoJ.t.s t!tKen to locate
the hazardous w~£te and the results ot
thos', efforts.
3-27
... ~ -~-~ ---- --
AIJc,'-~
-------
~~.: -.Ja,'lrlT~~+,~.Q..'D~mu~L.lY.1.Pt~~E
&.zAR1X~1~ltA~jJ':-_._G~J$..\ T1 oN (Con L inue~.:
~.rn~tj.oT\al S11 ~'p~e~t~ (40_~CTR Part 262.50.-1
46.
Deter!illne if wa.stes hGve been received
or trans90~ted to a foreign country by
reviewing th~ manifest log. It 80:
detet"Uline if:
from
a. The proper authorities were notif'~d
according to regulatory requirements and
that the manifests were signed by the
foreign consignor;
b. The fcr@ign consignee con!irm&d the
shipmen~s rec~lpt by signing and
returning the ma~ifest;
c. Copies of sig~ed ~anirests from the
foreign consign~e ale on file. If not,
confirm th~t the generator has filed an
exception ~~po~t with the proper
autho:- i ties; aIla
d. The generator has fil~d an annual
with the proper auth, _ities which
includes all rec~ired information
regarding for~ign shipments.
Waste Minimization prog::ams .1RCFA~.$..ectior.
3002(Qll
report
47.
Review generator's waste minimization
program to determine if the program
includes all practi~al methods for reducing
the volume of hazardous wastes generated.
Confirm that the generator retains
information which documents waste
minimization activities.
3-28
II"
-
-f
I
1\.
I
I
I
11,
I :
-------
~,,~_G".T~\UU.~9 M!nlr~",EYlnr~'~
4.
E.
IlAZ AADOTJL WASTf;_$~ G..t.~ 'I~~~:C
ferm~~1ng/Noti'1~ati~~
1.
Determine if the facility has interi~
status or has been fully permit: d under
the Federal Part B per~itting p~ocess.
Obtain a copy of the facility'.
Notification of Hazdrdous Waste Act;vity
form (U.S. EPA form 8700-12) and Part. A
application, it the site h~s not been fully
permitted. Confirm th~t th~ inform-tion
which appears on these documents is current
and complete. Review the facility
operations to ensure that no additional
processes have been added or interim 3tatus
capacities for processes exceeded without
regulatory approval.
2.
3.
Determine what the Feder01 Phase Authoriz~-
tion is for the state in which the facility
operates. Review the appropriate re~ula-
tions (state or fed~ral) to determine the
speci f ic interim stc tus requireme,-jts.
Obtain a copy of the facility's operating
permit (if issued). Use the permit ~s a
reference to dE'termin':-~ the facility's
compliance with regulatory requirements.
General Facility Standards
Gene:-al Waste.Ana~~ (40 <;TILPart ~6.5.13)
s.
Obtain a copy of the Waste Analysis Plan.
Compare the plan with regulatory r~
-------
~:'t_~: ,~rl~' ].f'(_~_A~l'I_J;VIP(tl.'"E
HAZL~OO)_s.- WM~. 9J3A.b~1-AmL.'j~J3l1..~ (Cont.)
6.
7.
8.
9 .
10.
.. Was:te ar\ lyses that 9'Ztneratorf; have
ag:ree~ to s~Pl'ly;
t. Methcds which will be used to meet the
speci~l requirements for t~ ~ treatment
and incineration: and
q. Procedures tor inspectin1 and analyzing
waste to ensure that it matches the
manifest.
Observe the techniques and equipment used
to obtain a representative sample. Compare
your observations with the ~ethods
discussed in the Waste ~alysis Plan and
Agency-approved methods.
Determine how sampling equipment is managed
after use. (Is equipment re-used? If so,
is the equipment decontaminated prior to
re-use?) (If discarded, is it stored in
proper conta:ners prior to disposal?)
Review the analytical data assocjated with
waste analysis tOl a random sa~ple of waste
received. Determine if ~ll requireJ
parameters are being monitoled. If
supplemental analy~es are required for
specific wastes, determine it these are
conducted.
Determine if the facility inspects each
waste shipment to determine it it -matches
the waste description on the accompanying
manifest.
Determine how often analyses are repeated
tor wastes which have been previously
received. Assess the rationale behind this
testing program.
Secur ~ ty_.( 40 cn P~.tl.....l~5 !.ill
11.
Walk the active portion of the hazardcus
waste tacility to determine it access 1s
controlled. Ensure that tencinq is sow,d
and that qates are lock~d or monitored.
Also determine it siqns are posted. ~t each
entl~nce to the active area which display
the legend: "Danger--t.1nauthot'ized
Personnel Keep Out." It ar'plicable, deter-
mine it the siqns are written in Engli5"';.
~ the second langu.age common to the area.
3-30
Auditor(s)
& Comments
-------
'~--1-L~...~}.'Ir:l (R.I~G _ML!.!lLFl.QJ~:; t
BAZ.AB.r;~~HJ ~ J.~';~..:;- ~.~ QBA.G.E- .AlHt~~I{kA l-,~ ( Con t . )
~m~."M~.1.lihInS.ll'-C.tJ9.n.L1 ~ '1~U
~:-t 2_~ ti
1'2.
o~tair. a copy ot the facility's written
inspection plan. Compare the plan with
applicabl~ requl~toI'Y requirE:.,jen~ s to
determine whethrr alJ required components
are addressed (.quip~ent inspect~d, fre-
quency of inspections, problems to be
looked tor, remedial ~ction procedures,
date and time ot inspection, name ot
inspector, observatlons, remedial actions).
Review a =andom samplp o~ the facility's
in~pection repo~ts to determine it the plan
is being toll owed. Note any discrepancies.
(Make sure that inspec~ions a~e on file for
at least three years trom the audit.) (In
addition, tollow up problems noted to
confirm that they were corrected.)
13.
A~company the site's in5pector(s) during
his review to detet~ine the adequacy of the
assessmen~s. Ensure that all problem areas
are checked and that all current
equipment/units are inspected.
Pe~sonnel Training (40 eFR Part~~~,
14.
15.
Determine if the facility has a personnel
training program:
a. List the job title and credentials ot
all persons involved in conducting
personnel training;
b. Obtain a copy o~ the organization chart
ot employees involved in the management
ot hazardous wastes and dete!.&nine the
date ot employment in that capacity;
c. Select a random sample of those
employees involved in hazardous waste
management and facility operations
involvin9 hazardous wa~tes. If pos-
sible, select one person trom each job
title with greater than six months
tenure;
d. Review the hazardous waste m~nagement
trainin9 tiles tor the sample selected.
Determine it each per~on selected has a
detined job titJe and job description
which includes requi~ite skill,
education and duties ot the job title;
3-31
-'~~;"~~ '~.~'--I
& ,Cornrn~~~~ I Ref.
.~.-.- -'''' - -~..' .._J
-------
, nB::t_3 L_. (i~TItrBll1_C~_~U_Q}'r; ~VIJ)r~CE
~ARL&U~_Jt1MT>t;;J.I.Q~,Gt~ }",.f) r~,&An:~ (Cont.)
e. Determine it each tile includes a
written description of the ~ype and
a:Daunt ot both introductory and
continuing trait:ing that will be given
to one tillln9 ~~ti position; and
~~~~~'
& eo",ments
;1,
t. Develop a checkli~t to b2 used i~
determinin~ it docum,entation exists
which verities that the employee has
received all the tralning rel.a,.i1r~d to
till the posltion. (List R.Q~-
introductory (wlt.hin six months ot
employment) and con~inuinq education
(annually) required and ir.dicate it
given.) At a minimum, the training must
include how ea~h person i9 to respond to
an emergency by tamili8rizinq them with
emergency procedures, equipment and
systems. This tr~ining must include, it
applica.ble:
Procedures for using, inspecting,
repairing, and replacing facility
eme~gency and monitoring e~ruipment;
Key parameters for automatic waste
feed cut-off systems;
Communications or alarm syst~ms;
Response to fire or explosions;
Response to gron :dwater
contamination incidents; and
16.
Shutdown of operations.
Select a sample ot personnel who have lett
the agency and were invul'\ ed in the ma.nage-
ment of haza~dous wastes by reviewing
employment records and joL titles.
Deten'~T'\e it the loc~.tion has ret~~ned
docwuerlLation of the] training qiven to each
employee tor at least three years trom the
time that they lett the location. (It the
employee tra1tsterred to &1"lother location,
personnel training tiles could accompGny
him/her during this tran~fer.)
3-32
-------
- --"-
. WAp..~~..'j~'"L__$1:~;-"~:L<~~l~~1:~~ N1: (CC1!!t.)
Ig11l\~~J~,__R~~aiVL'Ul~~QJ!l1?-~.tl~~:;~t~~ -< 4oQ.
gR Par.t;..~2.2.5 1-l?.l.
17.
P.eview ~he ~pE'rat::l'\q r09corJ ('..'aste receipt,
logs) to det~~ine if iqr.itable, reactive
or incompatible wa~tes are rac~ive0. (To
determine co:.\patibU.ity, see 40 CF.k Part
265, Appendix V.)
Conduct a field audit of the f~cility where
ignitable, reactive or incompatib1e wa~tes
are stored. Take a map o! the tacility
durir.g t;:e au~it, as well as tile list of
pctentially in~c~~at:ble wastes. Indicate
date, tim~, name and location of the
referenced wa5tes:
18.
a. Determine if the ~astes are separated
and conflned from sources of ignition or
reaction (sfarks, sFontaneous ignition
or radiant hea~). Indi~ate any problem
arsas on th~ ~ap including the details
of the probl€m;
b. Determine if "No Smoking" sigils are
posted in a~eas where ignitable and
reactive wastes are ma!laged arId that
smoking and open flames are conf~ned to
designated areas; and
c. Determine if incompatible wastes are
separated. Use the Co~. tibility Tables
to determine where sepalation should be
required. If incompatible wastes are
not separated, indicate types and
volume, and location of .ias.:es. In
addition, if wastes are in storage
detenuine it incoIr,patibles drain to a
comm<:l!'l sump.
Discuss with operations personnel how they
ensure that incompatible wastes are not
co-mingled.
Ereparedness a~JPxevention
19.
Beauired Equipment (4~_~r.BPart 265.3't
20.
Confirm that the facility has the tollowing
required equipment: .
A. Internal communications or alarm system;
3-33
.A! ,~':; " "
~...- '~J
& Cor"If"i',er,ts
WP.
R~~
_. ..~--~"'""'-~-- _.
-------
W~t..~) :~.~~},'I~J.:Rl},'LAQoJT .iV'.tJ2f;~
M1.M<.C)~JJb~ Wl.Jr'1:rt---ll'Q~~A.tIT21.R£A't1i~NT (Cont.)
b. Telephone or oth~r cO~junicationg device
which may be use} [vr summoning help in
case ot emergency;
c. Portable fire extinguishers, fire
con~rol equipment, spill control
equipment, anu decontamination
equipment; and
21.
d. Water at a volwn.e and pre!"(sure to supply
water hose stre~ms, fo~m producing
equipment, automatic sprinkler~, or
water sp~ay systems.
Determine if all equipment is located where
it should be and that it has beell inspected
as required, is useable and accessible.
Acces_L..to Communication.~ or >'larm Systems (40
CFR _Part 265.341
Interview facility personnel and inspect
waste he'r!dling areas to confirm that
comm~ ,icaticns or al~rm SystLMS are
accessible in case ot an emergency.
Recruir'ed Aisle Space (40 CFR. Part 26~. 35l
22.
Deter~ine if there i~ suffi~ient aisle
space for the uno~~tructed movement ot
personnel and em~ .ency equipment by
auditing storage idcilities.
Arranq~ments with Local AuthQ~ities (40 CFR
Part 265.371
23.
24.
Deter~ine when the last training session
was conducted to familiarize the local
authorities with the facility layout and
waste managemeht practices.
Determine if a primary emergency response
an.thority i8 designated, if there is mor~
than one police or fire depart~ent which
may respond to an emergency.
25.
26.
Obtain copies of the agreements made with
local and state em~rqency response
authorities, including emergency response
contractors.
27.
Determine it emergency response authority
phone numbels are posted in key locations
and are available to all emergency and
alterna~e emergency coordinators.
3-34
Auditor(s)
& Coml11en~
I
I :
I
I
I
J-.'~
-------
. -,<,,---,...... - .-
r.A:i.A~ c, °r:~ JIi' <;'1'," S'j (,.1" '.:.f "', ; Fl'''' ,. ~ 1 r" "
~ ,OL.'I._~- .~~ ~. ~-"'-- "'. t-- ~--"'--- (">-.c,". -1L:. - ...oJ" -. -- '-..
28.
29.
( ~ \..;:~... " )
[)f!tenlline it t' ~ site ha~ i",rOl,"-d l("lc~l
hos~litals and ~~1ical eTtergancy t@al!1S with
tha t~~e9 ot wast~s ~~; ~~ed and tile
potential injuries which ~ould result frum
operations.
Determ{ne it' any em~rgency response. team
has d~lined to entar into aqreewent with
the site. It 80, verify that this has been
docwuented in th~ operating record.
~onti"gen~y Plan and ;~erqenc~,iIocedure~
~onte!1t of CO~~~:i';:.Y ztar. _(4'J CfRJ'_~;rU_~5 ._~21..
30.
Obtain a copy of the facility's Contingency
Plan. Detenlinc if' the Contingency P:an
adequately address~s each Qf the required
comp,:,rl.:n ts :
a. Actions ~o be taken in re~~onse to
emergencies. Detercine if-all.
operations and clim?tic emergencies ar~ .
listed (fire&, explosion, toxic fume or
gas generation, incompatible wastes,
spills, tornados, h~rricanes,
earthquakes, etc.);
b. Arrangements with local emergency
response teamsi
c. List of all Frimary emergency
coordinators and alternates including
phone n~~ers (home and office) and
addresses. Determine if the list is
current;
d. List of emergency eq\lipme'o,' I its
location, and descri~tion of its capa-
bilities. Ensure th~t the list is
current; and
e. Evacuation plan including siqnals to be
used and evacuation routes and alternate
.vac~ation rQut~s (' needed).
Cooies o~.QD!jngency Plan (4~_CFR Part 265~~
31.
Verify that copies of the contingency Plan
have been given to the emergency response
authorities including hospitals (cover
letters of submittal or certified mail
receipts) .
3-35
kJ ..;!t:" ,..:;
& ~lfI i~ .1L5
WP
Ref.
. ~-~---- ~--'I~--~-
I
I
-------
~~l_"_.- ~ :_G,.\~;~A.K.k NCL}..:(P!'C J...." ~(P' ,~;J';
&-t~!J>
-------
1...,'"' . .1_~~5Jlf"" r'~r..J. ~ -.;-- t'LIL q'..~l \.pl~~ (t
~&.&J~0Q.~I~L~Sl~ $I9M.Gf._..AH:~.»'~d\1'l"~.:.N".( «.~nt.)
~ U e S.~~~!t~~k....R e C.s' Y~lK~0P .1.D9:...Ju!~. P !.'~~s,' t:tln.g
YLEL_~f~lllt~Jt Sy~tftJ!L.1.~O _~nL.p.~rt......~ ~5..t-lll.
35.
36.
37.
38.
39.
C.terMine it th~ facility r~celves wast..s
tro~ off-site by rpviewing the ~~erating
log receipt contro1, records and m~nitest
files.
Det~rmine it the site retain~ cories of
manifests of incoming wastes by comparing
receipt control records with the manifE.:st
files.
Review reg1.11a.tory requirel"ents tc\ deter:nine
if the apprcpliate manifest is ussd.
Deterrttine how the facil i ty operator assures
that ma~ifests are retur~ed to the
generator once they are signed ahd dated to
verify receipt of the wastes.
Determine (if applicable) that shi~ping
papers are signed, dated and returned to
the generator if wastes a~e received by
rail or barge.
Manifest Discrepancies l4_Q_~nLEart 265.72}
40.
Determine how discrepancies between the
manifest and shipment are identified.
(Verify that the tacili~y has a means to
determine discrepancies in bulk shipments
and characteristics of wa~tes.):
a. Determine how discrepancies are resolved
and that documentation is available to
confirm that discrepancies have been
tound and resolved; and
b. Determine how unresolved discrepancies
are reportecL Confirm that reporti,ng is
cOIH~istent with requlato:cy requirements.
Operating Record (4_0 CFR_Part 26S.73.l
41.
DeterTJiine where the components of t~\e
facility operat'nq record are kept
(inspections, waste analysis, qroundw~ter
monitoring data, etc.). Determine if the
records are kept in a fireproof tile.
3-37
.~. -------- [" .
AudftO((s) W.P.
. & Comrner~~ . ~
I
I
I
-------
BR'L..l1~" __GA.':(Rt.~.JJ~GJQTl ~ LiYlt~ 5C~ -
V.~"'. '~ROO&TS W\.S.TI' _~f'tiOb~""" ~N'F1 PfI~~.t.I'''''"'~N'l' (Cont.)
It~J~.\ ~ '- ~~,...:. - () ! ~4.-~~!~W'~~L.~ --~icl..
42.
43.
Confirm that the site hils a r.1ear!~ to
describe the wt$~e q~lantity rec~;ived and
methO(\5 and da't.~s o~ treat_.ent and storage.
Select a ran1~m samp:e ot wnste =eceiv~d.
verify th~t each wdste may be tracked trom
the ti111e rec.ived to the final disr,osition
(landfillin9, incineration, etc.) and that
wartes currently in storage may be located.
Us~ the inventory records, including
manifests, daily receipt, storage and
treat~ent 109S, and waste transfer slips to
dete~ine if records of waste handling are
cross-referenc~d to the mani~est used for
shipmen~ of the waste.
Deterroine it an incident tile is kept.
Biel':l11.i~l Report {40 CF'R Part 265.721.
44.
45.
Revie~ the ap!,l;.c~ble regulatory
requirements and confirm that an annual or
biennial report has been filed with the
appropriate requ1a~o~y agency. Verify that
the report includes all required
informatio:"l.
Interview !a~ility personnel to determine
how information used to complete the report
was assimilated. If there is any question
as to the accuracy or completeness of the
report, obtain other facility reco~ds
(i.e., manifests, inventory records) to
confirm that the report ref1ec~s facility
operations.
Cnmanifested Waste R~p~rt C4Q CFR PA~_~5.76)
46.
Review a sample of the tacility inventory
records to verify that all shipments were
accompanied by a m~nifest. It manifests
are missing confirm that an unmanifested
waste report was filed with approp!iate
agency officials.
3-38
AUditor(s)l
& Commt.r1ts I
~-+
!
-------
. ..
-. _. -
. ~X-t'::,>~,.~ ,---,!/'.,;: ,~£t- ,,~. :-:;..1.' ~o,-~- ~~~_~
-------
'"' ,-.... 10" , '.\' j ..,,, i \ ,-- ..;
~t f70 ..~. -. '-~-~- --~:.:-~~~~ -~o.-~ ..---..: - ..--~
&:';~'~;Y:11,i~LWA$J"l: ~':tQ.&t~~f..A"!~} 'J;J<,t~,"f!"fl~:!O> (COflt.)
~ce£1~LR~i1 ~ ~;ile!,t. ~".=f2.L.:tgni t~bJ_~il rg~~tJv~
wa~te~{jO .GLB~~-1~5,1751
Ceterr...ine }'\,ow iqnit~b1~ and reactive \-!Clste.S
are m~naged. (!nterview receipt control
and storage ar~~ superviso~s.) Conduct a
field survey to confirm that ignitable and
reactive waste~ are stored qr.at~r than 50
teet frtJl!1 the f~,cil ity property line.
~'Qecia 1 ~~.ID,1..i.remEU1ts fQI IItCQ1f1P£_1.!Ue Was~e?-L4 0
gR Part 265.17-':d.
53.
54.
Determine how inc~mpatible wastes are
managed. (See Ap1-'endix V of Part 265 for
~otentially incompatible waste~). Confirm
that incQmpatible wastes ar. separated
and/or pLotected by a physical barrier
(i.e., wall or dike).
Closure
55.
Confirm that there i~ a closure plan for
e~ch regulated storage area. Ensure that
the closure plan addresses all appropriat~
closure requirements for hazardous waste
container storage ~reas uStd since
Nove~~er 19, 1980.
'ranks
General OperatiT19'- Reqtl..trernents J.!.9,. CF'R Ea:ct
265.1921
56.
Determine how the location assesses whether
wastes and the construction materials of
tanks are compatible.
'57.
If uncovered tanks are used, determine how
the location .ensures that two feet of free-
board is maintained. Inspect the taHks and
review inventory record.~ to determine if
the freel"~lard requirements are being met.
If the tanks have a continuous feed
mechanism, deteri\'!ine whllt mechanis1" if; used
to stop the flow of wastes into the t(nks.
Inspect thi~ device with location personnel
to ensure that. it is operable.
58.
3-40
AudI10r{s) -r;
& Comments I ~I
, -
J
-------
. 6:.h. . !.._.',-.
. BA-'..f~~i.'-'C'.:-\.;~ WAS'l~J..'I9.Bt&t~tL'1'~!.:hl~,'N'r (COnt,)
h$..1o\.-.b_MIYrllJJ'\sL'rwl_b~L!.!Q.~R_P.~
U-S . 19 3 )
59.
Determine if the tacility conducts waste
analyses, bench test~, or storage tests
prior to storing a substantially ditf.r~nt
waste or conducting a ditterent process in
storaJ~'e tanks.
Ir\spections ~O~._Par~ 265 .194l.
60.
Dete~ine it the location has cOoducted
daily inspections of discharg~ control
equipment, monitoring devices, and level of
waste in the tank. Review a sample of the
inspections to ensure that they are
cOilducted.
61.
Cetermine it the location has conducted
weekly inspections of the construction
materials of the tank (corrosion, leaking)
and construction materials of the discharge
confinern~nt structures and area imme0iat~ly
surrounding.
elos'-lre (40 eFR part 265~71
Determine if any tanks which held hazardous
wastes have been tak~n out of service.
Review the closure process to ensure that
wastes and residues were removed and
disposed of properly.
Spec ia 1 Eequi rernents for ~E.ni t:.able 0t: React i ve
Wastes (40 eFR Pa~t 265.198L
62.
63.
Review inventory records to determine it
any ignitable or reactiv~ wastes ar~ sto~ed
in tanks. It so, ensure that wastes are
properly ~anaged and meet NFPA butter zone
requirements.
~ecial Re~re~ents t~LJlD~ompatible W~ste~,-1!Q
CFR Part 265.s..lill
64.
Review inventory records to determine it
incompatible wastes are placed in the same
tank (see Appendix V ot Part 265 tor
examples). Determine how the location
ensures that incompatible wastes are not
placed in the same tank.
3-41
Aur:::~1..). ,~}
& Comtj~;,l)
W.P.
~.
-------
~-.~r,- t.,,'.;,;. 'J2l.:t J'{J,\\l'..!~:..,~t:
io ~ ~~,~ s.:}i }J!:; ,~Sj'_9_~g~~~~j) --~. r' r~. "i tfTF[ (CO!. t . )
1~a~~('Lf!
Kg?_t.e. AnalY$i~ (4Q,...c;'~ P~.-r~- '6_~. 34JJ.
65. Detennine what receipt c(Jlttrol ~rocedures
are i!llemenl.ed before a waste 15 accepted
for incineratio~. Compare this procedure
with applicable regulatory requiremul':;s to
determine its adequacy. Review lite
records and lntprview personnel to deter-
mine if re9~1~tory standards are met.
Gener~l o~erati~Requir~~~~~3.~FR Part
li~ . 3 4 5 )
Deterw!~e what procedure~ are in plac(. to
ensure that haz?rdous ~aste3 are not ~ed
into the incinerator unless steady state
has beel! achievt.:d. Interview personnel and
review incinerator data to dcterwine
compliance with the pracedur~s.
Monitoring and ~nspections (40 CFR Par~_~~5.347)
66.
67.
Review the instrument controls u~~J to
ensure that the incinerator is operating
properly. Compare the equipme!lt USE'd with
what is required, Deter-mirle how the
facility assures that instruments are
operdting properly. Review facility
records to confirm that all equipment is
monitored in accordance with regulatory
standards.
Clos,urE'---1.!.O CFR Par1;. 265.3511
68.
Review the current facility closure'plan to
ensure that closure of the inclrlerator is
addressed. Compare the pl~n with
app~ic.:able regulat.ory. standards to verity
that all required components of the plan
are addl-eSsf.\d.
69.
Det;~ rr;;ine how the ash re~:.idue and scrubber
waters are managed by interviewing
appropriate personnel and observing
operations. Confirm thtit the management of
these wastes meets applica~le regulatory
requirements.
3-42
-~
Auditor( s}
& Comments
-..
-
-------
.." - - .....
~ "~r.w~_~i.~-;1; __~I9~.~ ::__A.~.
- .
?"t<-~J:r!'1i~.;,: (Ct')flt.)
~nt~rj,.1!L.Jtt~ tg~~'rhe~~,~~l. Tr..t.ill~' i1t.~Q~.y.1.,~~ 9 ~\!rni!1g
,fart icul~..-: 8a z ar.ae'J-'__ti~~.tes L4lL~f.P ~.fAn
26S.3a:n
iO.
Review the receLr~ centro1 log~ and
interview facil j 'i personnel to deter'~ine
if F02C, F021, F022, r023, F026 or F027
wastes are receiv~d. It 80, review
incineration logs to determine it these
wastes are thermally treated.
Il these wastes are incinerat~d, verity
that certi~ication of this prucess was
obta ::1ed ~ I Ot:l t:~
-------
~j.}'r_.~ :_". c;.~/t ~l ~;. N~u AJ.lJ'!'L ~,tP£,t; ~~
P ~,~.,t;!,r ~:!(J,S. ~A~11:....S'f') ?A~L_"'.ErLXiJ:h!~ (Cont.)
1M :'.lli.l5W U!Q.~[E~ R~ rt 2!5-L.2.lli
Determlfte throuSj~~ inquIry and review of
records if th~ facility co~ducts daily
inspections of surf~ce impoundment
t,eebvard levels and w~ckly inspections of
dikes and vegetation (leaks, deterioration
of dike).
Closure ~nd~B.::C~?JJ.r.e_.L4.9~_fR Pa:rt..265. 228)
76.
77.
-
Review thr closure plan for the surface
impouildment to determine if any ha:Gardous
was'ce surface impoundments have 'been closed
since November 19, 1980. If 80, co},firm
that closu%e f~ilowcd an approved closure
plan.
Detel~ine if the closure pl~n inclu~es all
requirements as denoted in Subpart G of 40
eFR Part 265. Document whether all wastes
and underlying liners (50il or synthetic)
are to be remov~'d at closure. If not,
confirm that th. closure and associated
post-closure pl~n includ~9 required
elements for tht proper man~gement of a
landfill (Subpart G and 40 CFR 265.3~0).
Special Req\J~rements for Iqni~;,,"'~d
Radioactive ~~~tes (40 ~rE Part..2~.24!9-1.
78.
79.
Review inventory recorns to determinA if
any ignitable or reactive wastes are
managed in the sUlface impoundment. If so,
ensure that ignitable aild reactive wastes
are treated prior to or immediately after
placement into the surface impoundment so
that they no lonq~r exhibit th~se
characteristics. Determin~ how the
facility documents that tl~at~e~t is
successful.
H2~e: The above does not apply if the
sUI"face imp()un(~" ant is used solely for
emergency situations.
~e..9Ja.U~'tr€'~t;.u.Q.I:.Jn~t{\~le Wastes (40
CFR Part 265.2JQL
80.
Review inventory records to deterJI\ine if
incoml-,atibl e waste:. are placed in the same
surface impoundments (see Appendix V of
Part 265 for example). Determine how the
tacility ensures that incompatible wastes
are not placed in the same surface
impoundment.
3-44
Auditor(s)
& Comments
-------
!l. _.~ ..--..'""-"" . '~'-"~:_"'--'. ~~-~ ;.'.' ...!,).ti:'~~1
BAZ f.RQQQ.~. WAS'rtiI..Q.E,t._::1t ~,~L'r~t t.~ ~ ".;.-"i~' (Cont.)
JtCRA Re~~h2.r1~~~. ion
81.
De~erm1ne if t.he faci 1 i~' has pL~,:is tor
,retrof it t in9 t~e surface impcundtip-nt bj'
198e to meet the design rec.r.J..treJ]J,:~nt.5 of
Section 3004 (0) of 1,C~A, and if expansions
of existlng surface impou1"\0ments were made
after November 1984, these e>q.,-.,.1si, '!IS meet
the above requirements.
Dete~ine if the facility has certified
that groundwater ~onltoring programs aye :.n
co~pliance with fe~€ral standards.
82.
Vt"lderarO,~.H"\d_Iniect iOrL~-9ntrol-
Classiflcdtion~f_Wel1s (40 C~ part 14.~~
8:3.
Determine if t~e inje~tio~ well is properly
classified acccrdi~g to U.S. EPA
requirements.
84.
Determine if any injection wells have been
installed since July '0, 1984. Verify that
the design and const::tion of those wells
meet U.S. EPA sta~dards.
Permits, Applications and Com~tat"lce Qrde~3
85.
Obtain and review the Underground Injection
Control Program's permits and permit
application. Verify that:
a. Pe~it Applications:
Reflect current operations (complete
and accu~ate); and
Have proper signatories.
b. Permits:
Are current; and
Reflect current operations.
3-45
,- --- .'--, --r ._-
Audi1o'(s) I w.?_j
&_Com:OISJ~.:
: I
! I
t
-------
lAA'1,3L_,G~~Tf{;.B.t~~._A!-' tL~10EN(~:
t; 7~rJQ!L~_W~~,~_:-:j~;.9 t: }. ~m='1ji12/I'1iE~.1 (Con t . )
Prepare a .Icllecule which includes
rep~e~antative sa~ple9 cf pe~it conditions
and requlatcll. re'l'.1irerumts. Veri~y t:H"~
the location h~s ~et these obligat~on5 by
observing ~p~ra~icm~., ro?vie'o/lng location
records an,J intet'viewinq location
personnel.
Undergrqilnd Inj ect ion Contro.J-B~'port 5 !1~and
~.cordk~j.ng
86.
87.
Confirm that the location conducts required
reportiilg activities.
Verify that the following recorus h&ve been
maintained for a ~inimuQ ot three years:
88"
a. Calibratio~ an~ Maintenance r.ecords;
b. Orj.ginal s~ripchart recordings for
continuous ~c~itvring instrumentation;
c. Monitori~g reports; and
d. Permit application data.
89.
Determine how the location will main~ain
inventory records of plugged wells f:)r
three years after they are taken out of
service (40 CFR Part 144.51).
Data Collection Sy?terns
Review the location's maintenfnce and
calibratio~ records and observe operations
to verify t.lat automatic monitoring systems
are functioning properly.
I1li~~tJs,n Well Operation'
90.
91.
Review a representative sam. \e ot location
monitoring data to verity th~.t permitted
operating lim5tations (injection pressure,
temperature, pH) are being met.
92.
Verity that othet '
are addressed by t.ll~
are being met (receip~
inspections, etc.).
'ating requirt1J1ents
,"'ation and that they
\-ontrol,
3-46
-
Auditor(s)
& Commer.:ts
-
-------
lAB-r - ~ =-_G~I:~R.rNG._~~QJ;:t ~tV j rn ,,~-,~,
BAZ-~nc~g.!s _!-1M:rf.:... S.!QJ
-------
1"''K1:~_) L_"G.lJJI E. R} N G.. ~ ~ p 1::t3\11 (')~~J'!:~~
W-~-RJX'iJ~WAS11Lll.9f1)"'~ 1~l:.:A~.h': j-fft.!I (Cont.)
l.re~J'e.~~ 1.9~yal UCJt ton~TI~~~~Jj 0 ~I:B
Part 265-,-93)
97.
Deter~ine wh~th~r th~ f~ciljty ha~
developp.d a qroundwat£r as~ess~~nt program
outline.
98.
Determine if the f~cility h~s conducted
Student T-test evaluations of groundwater
monitoring data. Note whether a
statistically significant change in the
groundwater has been noted.
It there has bE!en ii char:ge in the
9round~ater, deterr.ine whether aFpropriate
authorities were co~tacted verb~11y and in
writing.
100. If the !acility is in the assess~ent
~onitorir.g ptu5e ~or gro~ndwater
monitoring, confirm that an epprovad
assessment pr~g~am is being followed.
99.
RecordkernnfLand Report iJ:1,g.--'..!'L<;DLPart 2 6~. ~"~.t1..
"
101. Review the facility groundwater monitoring
data for the review peliod. Confinl that
all required data are being retainec.
102. Determine whether the facility has
submitted groundwcter monitoring reports
annually. Review the reports to verify
that all required components are denoted.
3-48
Auditor(s) "1
& Commonls I
-1
I
I
I
-------
iAET_:LL_-G..~Itj;.B.; t{~ A1LQ.t.T.~VI QJJ!.~
F.
~..tttBGRQ.WP_s.I..Q.RAGE TANK~
~ohiJ2.i.t~ons (~~rR.j':'; ::.L.,eo .-~l
1.
Verify that all underground sto!age tanks
installed after May 1985 are cathodically
protected or designed to prevent any
releases.
Confirm that the constructio~ material ot
new tanks is compatible with the material
being stored.
Notification R~.tirer"ent:;--L40 cfB..f..aG-.~80.3)
2.
Note: See Appendix II of 40 eFR Part 280.3 for
th~ list of agencies to receive notification.
3 .
Verify that each underground tank was
identified by facility per~onnel and
appropriately reported to th~ proper
governmental agencj by May 8, 1986.
Ascertain through interview~ with facility
personnel if any ~nderground storage tanks
have been taken out of service since
January 1, 1974. Confirm that all such
ta~ks were identified by the facility and
reported to the proper agency by May 8,
1986.
4.
5 .
Determine through interviews with facility
personnel and review of purchase orders if
the facility has brought into use any
underground storage tanks after May 8,
1986. Confirm that the location has
notified the designated agencies within 30
days of bringing each tank into use.
...
3-49
----
A~di10(( s)
& COfNII~(]t;;
WP
Rt)f.
.---"-- 0-
-------
lAf~l 3_L=~Gl~rHIIU1~9__AJ.'LPI~.A.k-..fT' A(1'I.C.t"$L~~
t)~r Y;;'}'S"'C'
~!;,~' t"",1
1.
oetennine: t.~rollgh interviews with mo~e
senior personnel and review of documents,
how and where wastes have be~n di~posed of
since the facil! t.y started 01Jert. ..ions.
C~nfirm that the facility has filed
notification of past treatm~nt, storage or
dispos;..l ~.ctb, i t.ies at this location under
RCRA section 3016.
2.
Eeport~ple Ouantii. ies/Rel~ase Noti t'ication~
LCEPCLA Sectior. 103)
3 .
Interview facility personnel and review
incident records to determine i~ any
releases of reportable ~~antities of
hazardous SQostances have occurred during
the review period.
If releases have occurred, verify that the
proper authorities were notified of the
release(s) .
4 .
5.
From a review or the facility inventory
records, determine if all reportable
quantities for hazardous substances at the
location have been documented.
6 .
Interview appropriate
determine if they are
4
reportable quantities
proper procedures for
hazardous s\1.bstances.
facility personnel to
aware of the
listing and the
reporting releases of
3-50
-------
~a. 't."
~=-~,--,~~- ~---~_._" -01:_...:-
.~'":. --......- EYJ I~t ~-:
H. RILL PR:;VttU\t9r!~OH.1KQ.I1
~e~eIlj_~pt1.£ID 1 ~ ~Y.,~~u:L1.12 .1)
Insp:ct the facility and re.vie"w facility
documents to determine if the facility is
required to have an SPCC pl~n. If ye~, complete
the re~ainin9 p~rtion of this section of the
protocol.
~d~e:'nents tor. Prep~ration ~JJ9_1~~~nhtJ.QJ1
9f Spill Prevent:iQ~Qnt:r~~nd CQ.lJntu:m.~\ln
llin~
1.
Determine if the facility h~s developed an
SPCC Plan, and who is re:ronsible and
accountable for the managem~nt of oil
spills.
Revi~~ the SPCC Plan to confirm that it has
been certified by a R~~istered Professional
Engineer.
2.
3.
Revie~ the SPCC Plan to determine if it
contains the recommended elements or
federal, state and local regulations.
exa:r.ple:
a. Consid~ration of all oils and oil
cCJntaining substances;
For
b. Consideration of any recent facility
design or operation changes which affect
the spill potential;
c. Tank inspections and site security; or
d. Containment structures and/or
diversionary structures or equipment
used to prevent and/or co~trol spills.
Plan Implement~tion and Control P~ac~ices
4.
Tour the facility to confirm that spill
control ac~ivities stipulated in the plan
have been im~lemented.
Inspect the facility to ensure that it is
fully fenced and entra;~ce qates locked when
the laboratory is not attended.
5.
3-51
W.P
Ref.
-------
. ~-;~_._~ -~. ~>J~';"'_J,.1.1l!)J'_:t._\.'~-Q.U.~~-
h.,~_1';~Yk_~1X.0tLM_.)~~~~Q.i.J (Con t Inue~)
6.
7.
Det~ni\lne Wh,::t~ler, when not in ..rvice,
master flow and drain valves are locked in
closed positio~, starter controls tor pumps
locked in off position, and
loading/unloading connections of oil
pipelines capped or blank flanged.
Determi~e whether ths storage tank
s€condary cOutainm('h't vulume is adeq~ate.
For tanks with no secondary cont&inm~nt,
confirm the impracticality of such systems.
~1.l1 Traintng
8.
9.
10.
Determine who is responsible for conducting
SPCC training and docum~nt his/her
qualifications.
Determine who is required to att~nd the
SPCC trainihg sessions, and how often th~y
are conducted. Review SPCC training files
to confirm that training is provided at
established intervals and that required
personnel attend.
Location Tr~nsfer 9perations
11.
Ascertain whether the warning system for
vehicular traffic is adequate.
Review prucedures to control spills during
loading operations or inspect loading
containment al"eaS and assess adequacy.
12.
3-52
Auditor(s) '\
& Comments.
-------
~~~,..~L~~~ f,,-~U. -:0 .-A~.Q.r rtY "'.o.r~ ~.~
I.
EES!lCIDE_QQHIF.QI-
Storag.e (~P_. ~ry. Pa:,.t._~~ll
1.
Determinll! throug~ in!,!ui1i I observatioll and
available documentation th~t on-site
pesticid-- and pesti(:id,:'-r(:lated wCt.':\te
storage areas were selectl!d with dt, re9~uJ
to the amount, toxi~ity and enviro~~ental
hazard of pesticid~s, and the number ~nd
size of containers to b~ hand10d.
2.
Physically e~aroin~ the st~rage facility to
confi~ t~at ~e~ticid~r. and
pesticide-related ~a5t~s are stored in a
dry, ~ell ven~ilated, separate rocm,
building or cov~red area w1jere fire
protection is provide1.
3.
Tour the storage arp.a to confirm that:
a. Containers of toxic o~ moder~tely toxic
pesticides or pesticid~-r~lated wastes
are clearly l~beled with the signal
words: Danger, Poison, Warning, or the
Skull and Crossbones sj~ol;
b. Containers of pesticides or
pesticide-related wastes are stored with
the appropriate lab~l plainly visible;
c. Rigid containers are stored in an
upright position and off lhe ground;
d. Containers are free of corrosion and
leaks; and
4.
e. Food, beverages, tobacco, eating
utensils or smoking equipment are not
present.
Inquire and evaluate as to the types of
protective clothing and r~spirators used
when handling pesticides in a concentrate0
form.
3-53
A1Idilco"S),S I W.P.
& :omn1en~ p~,
I
-------
bf.- ...-:v - (L- ~'_r:;-~. t;~ t:!."" _~:I ~, t' -_t.:.1/J. l~ t~~~~
n~.tI~Ir:E__~Qti1.BQII (Contirlye~)
5.
It lat 9'e qu~nti ties 0: l',gsticides or
pe~ticlde-related wastes are stor(l,
determine t:-.:r:ough inq,Jj .,-y and revie\. of
corr~spondence files if the lOGal fire
departJ1~nt, hOSl,italf I police department,
etc., h. ve been inform~:l in wri tinq of the
hazards that sucl'~ pesticides m{::' present in
the case of a fi~e.
lli-posal Li~.-CrlLPal.t 165.1
6.
Obtain an understanding of how the facility
disposps of pesticides and
pes~icide-related wastes and dete'rmine if
this pr.actice is consistent with
recommended procedures.
7.
Ob~~in an understanding of how the facili~y
disposes of Groups I, II, and III pesticide
containers and pesticide residues and
determine if thr.se prartices are consistent
wi th recommended pr~,cl- ..lures.
8.
Interview key faciliti personnel and review
wastewat~r effluent monitoring data to
confirm that pesticide-related wastes are
not disposed of through a facility effluent
stream if ordinarily not contained w~thin
the facility effluent stream.
3-54
Auditor(s)
& Comments
-'-
-------
w~~ 3.J_GAT:HJ:R.L~.~Q.QJ,I- r.,{X-Q-f,~~t~
J.
~.CIL..M.&~lfr:
Use Q! ~CBs~ ~Q P~-LI~m~L.!4LqLPs;:~ 761, ~lQ.l
1.
Revi~w j,nformati"n devoe1oped by the
laboratory to e~. tabl ish the extent of pca
use (e.g., transfcr~ers, capaciturs, heat
transfer systems) at tilis facility.
Tour the facility to confirm that all PCBs
and PCB items have been lncluded in the
above referenced infor~a~io~. In addition,
confirm that:
2 .
a. Q~arterly insp~~ti~ns of PCB
transformers are oeing ~onducted;
b. PCB items a~e in go~d condition and are
repaired ~hen le3xs are no~ed;
c. The facility's action plan for ensuring
the phasing out, removal and disposition
of PCB items is in accordance with
federal re~~ire~ents;
d. PCB tra~sformers hcve been properly
registered with local fire depart~ents;
and
e. Flammables are not stored near PCB
transformers.
3 .
Intervie~ lab personnel and review facility
files to ensur~ that maintenance and
inspection records for PCB transformers are
retained for three years after disposing of
the transformer.
4.
If a fire-related incident has occurred at
the laboratory which involved a PCB
transformer, confirm that the National
Respon&e Center was contacted.
M.~rk' ""q: ot P~~PC8 ItF:'.1'ns (!.L~-~~tl
761.6-==..1.
5.
During a tour of the laboratory grounds,
confirm that all PCBs and PCB items have
been properly marked with PCB labels. In
addition confirm that vault doors,
machinery room doors, fences or other means
of access to a PCB transformer are marked
50 that the marking may be easily read by
firefighters responding to a fire involving
the PCB transformer.
3-55
k~;G{;:J--T w,~
& Co(,lin,el~s iRe'
--.......~........-
-------
~'l'._1..:__~JiA::'~I~,-,~I~~ ~~r'.lJ1~t.<{.rnl!~~
~CfLJQJ!b.G;.m;~I (ContiflUe~)
~t9~~~~r Pisvosal_(40_~IR ~3~~6lt65)
Auditor(s)
& Comments
6.
Inspec~ PCBs and PCB items in storage{ and
~evip.w Etorag~ a~~ di~p~sal =~cords to
co~titm that PCEs and PCB it!ms are
disposed of withi~ one year from the date
when thay welc first placed into storage.
Confirm that storage facilities meet
federal requirements including=
7.
a. Roof and walls whic~ prevent riinwater
from re&ching PCBs and ?CB items;
b. Adequate fleer an1 cor;,tin'.Jous curbing
(minimum six inches). Containment
volume must ~qual ~r exce~d the volume
eau&l to tw:ce the inter~al.volame of
the largest PCB article or container or
25% of the total internal volume of all
pca articles or containers, whichever is
gr~ater;
c. No openings which would permit liquids
to flow from t~e curbed area;
d. Floors and curbing which are
continuously smooth and impervious; and
e. Stolage area is located above lOO-year
floodplain.
8 .
If PCB items are stored in are~s not
meeting the above referenced requirements,
inspect these areaa to confirm t!!at:
a. PCB items and containers have a notation
which indicates the date they were taken
out of service;
b. PCB items and containers have not been
in storage greater than 30 days;
c. Limitations on the typ~s of PCB items
which may be stored are followed;
d. An SPCC Plan has been developed for
liquid PCBs in containers; and
e. PCB container includes a notation
indicating that the concentration of
PCBs is 50-500 ppm.
3-56
-------
lAF_T. 3L... GAT H"E.R..1.~ (;._.~ ~QJ 't..LYli1l~;.; f.1
~~"1AG~~ (Continue.cl)
'9.
10.
11.
. ")
.40.
13.
14.
15.
16.
17.
Confirm that all storage ~reas are properly
marked.
Confirm that PCB articles and. contail'1~r.c; in
storage are i~spected eV.l~ 30 days tor
leaks.
If large PCB high voltage c~pacitors and/or
PCB-contamindted equipment 18 stored
immediately outside an EPA ap~rov~d storage
facility, confirm that there 1s av~ilable
in the storage t~cility a volume eq~al to
10% of the total volume of the capacitors
and equipment. Additionally confirm that
these PCBs are stored on pallets and
inspected weekly for leaks.
Interview lab personnel to determine how
:novable equipment used to handle PCBs ai,d
PCB ite~s in storage and which comes into
direct contact vith PCBs are decon~aminated
prior to leavir.~ the storage area.
Review federal re~1irements and then
confirm by observation that liquid PCBs are
stored in U.S. DOT approved containers.
If liquid PCBs are stored in containers
larger than 110 gallons, confirm that the
facility complies with OSHA standards found
in 29 CFR Part 1910.106, which addresses
flammable and combustible liquids.
Additior -ly, confirm that the site
reviewed the design of the containers used
to confirm that they are structurally safe.
If PCBs are stored in these larger
containers, confirm that an SPCC Plan has
been developed and is implemented which
addresses the PCBs in stora~e.
Confirm that the facility documents the
quantity of the batch and da',-,- t. ~ batch is
added to the larger container, as well as
the date, quantity and disposition of PCBs
removed from the container.
Interview lab personnel to determine how
the storage area is managed. Confirm by
observation that all articles and
containers are dated when they are placed
into storage and that PCBs are stored
according to the date that they enter
storage.
3-57
~~dit;~~~-l w rJ
~o::n~--4 Ref.
, I
I I
i I
I
!
-------
lAi~';~.,3~; c_-~ G.\ m.E_lN~1> ~LP.1J'~,_t:!J.QfJi Ct
KfL.MlJ'T ~~.G ;'J:.u~.wr ( Con t.l n l\ ( ~.)
DecQ1'lY.rn.in.r~ilin.-L42-~>t-_7 6..J,. 7 i1
18.
Interv iiPW lab p+p:-soI;r.el tCj cO:1f i 'nil hoW' t:-CB
contl\inera arE: ae=vntaro.i.na ~~d. Conf i rIli
that EPA approve1 m~~hocs ara used
includlng:
a. Flushing th~ container three times with
a solvent cuntaining less than 50 ppm
PCB;
b. Sol ubi 11 ty of: F:"'~" : r1 the &01 vent is 5%
by weight; anr.
c. p4nse shall be ~~~toximately 10\ ot the
v.... ..lIne of the PCB conti!&ir ~=.
19.
Determine how the liquid or. so~id PCBs are
disposed of. Con! inn t.'1at thcJ' are
disposed of in ac~ordance with 40 CFR Part
761.60(a) ~nd (a) (4) respec.:tively.
~Qrds and Re~orts (40 ~fF Part 7JUL!180}
20.
Interview lab personnel to dete~ine it a
PCB annual report is completed. It so,
review ho'"" the la.bcratory assimilated the
data used to compile the report.' I; there
is any question regarding the repor~ls
compl~teness or accuracy, select daily
inventory records and manifest to confirm
that the report represents PCB activities
during that year. Confirm that the report
addresses all iequired types of inforwa-
tion.
Note: Annual reports are required if the
tacility has stored at least 45 kg
(99.4 pounds) of PCBs during the year, one
or more PCB transformers or 50 or more
large PCB capacitors.
U'_~ Off-S;te ?ol1.Qy
21.
Determine comp1iance with the EPA orf-site
policy by conductin~ the following:
3-58
Aud~~
& co'nm~o,ts~
I
I
I
,
I
I
_."--..-.0-
-------
&.!:
~~Ll~.. '. -.'~' .
_. -. -- -- --
.
~ ",....111". uHJed)
a. Confirm thtlt the PCB \i~3tes (50 Pl"'l or
qreater) are 1nci~erat~d;
b. Confirm t~at the facility use~ is
permit Led to accept FCSs and th(it there
are no outstandin9 TSCA violations; and
c. If brokers transport wastE orf-site,
determine what system is USed by the
facility to verify ultimate disposal.
3-59
AUCiI.Q(\S)
& Corflrnen:.s
WP
Rei.
.-. - -.---- ----1-- - - -
I
I
-------
~'rJLnG.~_TI1I 8 rN C; -_A.Q QI."-- -~-YI Q~~~ C~
K.
~I N1\I t!G W [I.'rYB
~pU~.ability l
-------
Ei~~ . l:.' ,L' " ~ t
ptU~f1
-------
!M:~'--:.i :.- . Ji.l. '1'J1t ~ ~J~~._~.~ ~ )JIj::Y~li!E3~ ~.t
DPTN(;r N.Gy~ f~JJ~ (Con t inu~d)
d. Records ccmcernin9' varian-"" or eX6ir,ption
qrant~d to ~l~ .ystem have been
.aint~in~d tor at l«ast tive years
tollowillg the eJ1d of the variance or
exemption.
3-62
I'
'-
Auditor(s) I
& Comments
,"
?
-------
iART 3 :
Gl~H~R?NG Arrr,!.-. ~1Irt~' . . .
.1111!0_--- ~--..:..~.. -- - ... &. , ~~ ~~. , . {:~1~£ - f~
L.
BADIO~C'ilYL.¥AS TE. ~A.GPfF:~{~
Ge~~~al I~~o~~t1~
1.
Re""1e"",, tr.f.' f3,:i.li-:.:y l:.cer''3e ar.d q~in a:'l
understanding o! the specific re~~irements
that the tacility is obligated to fulfill.
2.
Review any previous audits of the
facility's radioactive waste procedures.
Review action plans implemented as a result
of any audits and document any activities
which have not been fully addressed.
Review facility docume~t9 and interview
personnel to deterIDinc if the facility
sends any samples of.f-site for testinq.
Determine the fre~ency cf audits or
outside l~bcratcri~s and examine results of
those audit-so
j.
4.
Obtain and ~evie~ on-site documents for the
management of licensed and non-licensed
radioactive materials. Confirm compliance
with this document (i.e., procedures for
monitoring areas of potential
c~nta:nina":ion) .
Procedures for Pickina Up, Feceiving and Cpening
Packacr~s
5.
Review facility procedures and documents
concerning picking up, receiving and
opening packages to determine if the
licensee:
a. Makes arrangem~nts to receive package~
when they are offered for delivery at
the facility;
b. If the package is to be picked up by the
licensee at the carrier's terminal,
whether the facility JI'~\(es arrai"t)'ements
to receive notificati~ from the ca~~ler
of the arrival of the package;
c. Picks up packages expeditiously upon
receipt of notificatinn fLom the carrier
of its arrival;
3-63
,'. ~di10~(~01~ p
& Comrr.~r,ts Ref
--------- --- -'''-~--
-------
IA~'! --3 :.~jJA.Itrr ~Jtl,~~_gOIJ'--J:Y-Ir) ~S; (:~,
Fe ; ~t! LO~:;;'l' I'i};,_~ -~I:h_- MlJ{b~.OO!\~ ( Con t ! !\ ue d)
d. Monitors, 8uhject to the .x~~ption8 in
10 CFR Part 20.205(b), th~ external
SUl!aces of the package for r~dioactive
c~ntamination cau$ed by leakage and
monitors the radiation levels external to
p; ckages containirl9' quantities of
radioactive ll{'!teri&1 in 6xcess of the Type
A quantities specified in 10 CFR Ptrt
20.205;
e. Notifies the carrie~ and the Nuclear
Requlat~ry Commissicn when radioactive
contamination in excess ot the levels
.1esignated in 10 eFR Part 20.205' is
fow'ld; and
f. Establishes and maintains procedures for
safely opening ~ .ckages in which
licensed material is received.
Storage. and Control of ~nsed Mat~,.rJa~s.-.in
pnrestricted A~eas
6.
Determine whether all licens€d materials
stored in unrestricted areas are secured
from unauthorized removal from the place of
storage.
Determine whether licensed mat~rials in
unrestricted areas and not in storage are
undeL the constant surveillance and
immediate control ~t the licensee.
7.
Disposal of Licensed M~~~rial
8 .
Review facility docw,ients and procedures
and inspect the facil{ty to determine how
the facility dispos€3 of its licensed
material.
9.
It the facility dischal~es licensed
material into a sanitary sewerage system,
det~lwine whether the discharge meets the
reql.lirements of 10 CE'R Part 20.303.
It the facility disposes of licensed
material by incineration, determine whether
such m~~erial is listed under 10 CFR
Part 20.306, or whethe such material has
been specifically approved for incineration
by the Commission.
10.
3-64
..- --.............---
Audi1or{s)
& Comments
W,F
Rei
~
-
-------
1iPj,V&~~~-_W i\;;~t.~b.-c;t ~£~- '( c~ il t inu~ d)
n-ans fer Q.1._L ice n s (~ d J1f1 ~ ~.r.l~lL.!(').r_Qi-~9_gJ,1
,
11.
12.
13.
Re7iew the facili~y's proc~dure~ for the
trans fer ot 1 iC:4!ns ed ma tll!r ia' s at ,C ~h~
faci' ity' s shipr.:e:'1t. DeterAtine whether
each shipment ot r.adioactive wa~te is
accompanied by a shipping manife~t and that
a~l manifests contain the intormC';Lioll
specified in 10 eFR Part 20.311(b) and (c).
If the generati~g licensee transfers waste
to a land disposal facility or a licensed
waste collector, review the applicability
of, and deteriLine ~:hether the lic~nsee:
a. Prepares all wastes so that they are
classified accorJing ~c 10 eFR Part
61.55 and that t~ey ~eet the waste
c~ara~terist:~z r~~irsme~ts in 10 eFR
Part 61.56;
b. Labe~s e~ch pac%age ~f waste to identify
it as Class A, B or C waste;
c. Conducts a quality control progra~ which
includes ~a~age~ent evaluation of
audits;
d. Prepa~es stipping manifest and
distribute the~ as specified in 1J CFR
Part 20.311(d) (4-7): and
e. Conducts investigations (in accordance
with 10 CFR Part 20.311(h» of all
shipments not received within the times
set forth in 10 CFR Part 20.
If the facili~y is a waste collector,
licensee who handles prepackaged waste, a
licensed processor who treats a repackages
waste, or a land disposal facility
operator, dete~nine whether the facility
follo\ the procedures specified in 10 eFR
Part 2u.311 (e-g).
Records
14.
Review facility records and determine
whether the facility has maintained records
of disposals and burials.
3-65
Au~;tO((SJ \ w ~ \
& (-""~~~"~-l~e' ..
1 I
\ t
, I
I
-------
b-: ..~,11 GA..;'c (i<;!:.iG._~.r(J '_~{H)f:J"_~~~
&,.)!O) ''''i.J: <{t. Wh~lLJ1.A~A(.J ~T1fi: (COli t Inuel1)
~pillJng
15.
Raview facility r~corde and interview
pe!'50nneJ. tC' detf)r.ni~e ",heth~1': any loss~s
or th€.fts of licensed mat~ri(\l have
occurred and if so, whether the reports
have 1:H>'n filed in accordance with 10 CFR
Part 20.402.
16.
Review facility records and determine
~hethe~ excessive levels and concentLations
of radioactive mate=!al have been reported
in ~c~orc~r.c~ w~th 10 eFR Part 20.405.
3-66
- Au~i~;(;-TW~
& Comments I R
--,1-.-
I
-------
'EART 3:
M.
GArH.tl<..lF~ A tIPI_'t,,(Y ;rQ.f;l!~r
mrlRQNm:~ At A~~~Mlli1 LI.MEA~~LUf,.M!'tf~
En\' j. ro r\J'~e n tal ~ sse S S"Me n ~~_L~flLF.a r_t...l ~.l1.
,
- .
cr.tain an understandiug and develop a
schedule by interviewing ~y facility
personnel and reviewing capit~l budget
files and other appropriate t~co~ds, of
proposed or initiated changes in facility
operations (i.e., modifications or
expansions) .
2.
Determine whether environmental assessments
have been conducted for the items listed on
the schedule developed in (1) above.
3.
:f environmental assessments have been
conduc~ed, docQ~ent which assessments
resulted in a decision to prepare an impact
state~ent and which did not.
4.
If the agency determined on the basis of
the assess~ent not to prepare an impact
state~ent, verify by reviewing appropriate
documents that the agency proposed and
subnitted a finding of no signi.ficant
i~pact.
E~v:ro~me~tal Impact Statement (4~_~FR Pa~~s
1502 a!"ld 1503)
5.
For those proposed actions identified in
the previous step which require the
preparation of impact statements, review
selected statements to confirm
incorporation of the following required
items:
a. Cover sheet listing responsible
agencies, title ot proposed action,
statement abstract, comment date,
statement designation--draft, tinal;
b. Sum:fo1ary which adequatf:... ~..J accurately
summarizes the statement;
c. Purpose and need of the proposed action
and alternatives;
d. Alternatives to the proposed action and
the provosed action;
3-67
~Ud~;:(~0;- ;'1'
& Comn .0;; -:~ I ~e'
~--_._-. --+_._~-
I t
I
I
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-------
~~" _l_:___~G}.~rt'i!RtNq --A~:IJ),t1'~.Ir,.~!;
~ K01!1~~~f_t! h.-A!:' S E ~-~.f~mLnU~LcrJTA~I
(C(,Hltinu~d)
e. E~viroru~e~t ~tf~ct~d ~~ c~e~t!d by the
alternatives ~,de= consideration;
f. !:nviror..m(mt~l 1~pa~ts cr conse~ences of
the alternatives 1ncl~dinq the proposed
action:
q. List of prepare=s: a~d
h. If applicahle, an appendix.
6.
If COinments on {.n i%pact statement have
b£~n received, obtain an underst~ndinq ot'
how the agency re$pc~ds and evaluate
adequacy of this procedu~e (i.e., will they
be incorporated, it not, ~hy not).
3-68
Auditor(s) ~
& Comments I F
of-
-------
il.ET ..3.: ___GA THtB.lli.~.MI~.I~.L...E.Y.1J)f.Ji.g;
N.
MAJU ~~-~~o.RA !oBJ.E.L! SijI~~J_.M2QElrnJlM
Mar ine Sani tat ion D~y ic~-L.J.]~FR--E.2JJ:t ;l ~ll
,
- .
2.
:3 .
4.
Intervi~w ship p~~~onnel and review
operations to de~ermine the typ~ of
sanitary system in opeiation aboard shjp.
Review sewer maps and int~l~iew ship
personnel to determine if grey water
pollutants (laundry, kitchen, showEr,
etc.) are:
('ink,
a. connected ~o sanitary sys~em; and
b. Discharged directly overboard;
Dete~ine the maxim~~ vclum~s of holding
tar.ks for:
a, Black water (sewage);
b. Grey water (laundry, kitchen, shower,
sink, etc.): and
c. Combined black and grey water.
5.
Intervie. ship personnel and review 3hip
~ecords to dpte=mine what distance from
coastline black water pollutants (sew~ge)
a~e regularly discharged.
Dete~ine through review of records and
operations and interviews with ship
personnel the type of marine ~anitation
device (MSD) in operation abca:d vessel as
certified by U.S.C.G.
6.
Dete~ine the date that 5 ~age treatment
~evices were installed a~J verify their
approval.
Confirm that sewag treatment equipment is
operated in accordance with applicable
regulatory requirements.
7.
Oil-Water Waste (33 CFR~rt 151)
8 .
If an oil-w~ter waste separ~tor (OWS) is
operated a~oard ship, review process flow
diagrams and inspect system to determine:
a. Maximum process flow rate (qpm);
3-69
_.-. -."-- . ---~-.1- -'
Audilor;s) W P
& COnlrr:t:?nts Rei
...~~.._---_.
I
!
I
I
-------
~'t .,:- ."j;~,1-1f~_~JMG_.MUUT ~~J.t~~.~c~
HAR:tl!, t!>P,OFJ.j.'..Q.BI ES~ J SI.\ f~ l~~I")QJ:NDfI.M (Continued)
b. Typ~.of discharge system;
9.
c. Average discharge concentration;
d. Setting for bilge alarm; and
e. It there is an operable bilge monitor.
Discuss oil-water waste dischLrge practices
with crew including:
a. Concentrations of O/W waste released at
specific distances (within 12nmi, >12
runi) ;
c. Operation of manual OWS (if applicable)
including training of personnel; and
c. Tlansfer of O/W waste to shore holding
facilities.
Solid-W~ste Dlspo?al (Refuse Act, HARPOL)
10.
11.
Review ship operations and intervieu ship
personnel to determine type of solid wa~te .
disposa' in operation aboard ship:
a. Incineration;
b. Complete storage and transfer to shore
facilities;
c. Pulped (grinded) trash discharg~;
d. Unpulpe~ trash discharge;
e. Buoyant, compacted trash discharge; and
f. Negatively buoyant, compacted trash
discharge.
Confirm that all on-L\.,~_u waste disposal
facilities are operated according to
applic~ble regulatory requirements.
MA.rJne SPi.ll Cont;tng~ncy Planning
12.
Review the ship's Spill Prevention
Control and Countermeasures (SPCC) Plan and
det~rmine who is responsible for managemen~
of on-board and over-board hazardous
substances and oil spllls,
3-70
-
Auditor(s)
& Comment~
W
R,
-
-------
~_._~- '-~::B:'- -- . - ...
MAR~Nt..._.k'~9AA~l
-------
Location:
Auditor:
Exhibit Numbtl
---
~CHMENT. 1
.t1<.hiQll.~t~.~
Date:
-~ .--.....--
----
Description
---
/
..
---..-----
. ---~. .--.-....--~~
3-72
-------
c.
2.
3 .
D.
iABI~:--tv~LUATrNG AUDIT tYJ-Qt~~~9FT~NG
fIUD:~G~
A.
'p"'r;'.'F.!.p~SO:1E.:'f-:!: .r.! ~L_QE.._l..r;C T:~-t2<:~:.: ~J J.~~
Review wo=king pap~r5 and develop a complete
list cf audit exceptions, listed by functiona~
area.
B.
INTEGRA'rF; .\ND St~~IZE EX£LPTIONS
1.
Identi!y any patterns or trends among
ex~~ptions a~d gr~up these exceptio~s
acco:-d:ngly.
2.
Develop a final list of exceptions prepared
in an crga~ized man~e~ for each fun~t:~nal
area. Use Attach~ent 1 "Close-out
Discuss ion She~ t ,: to : ist exceptions fer.
pres~~tatic.n ~c m~n~geme~t.
EXIT ~E':!~G
1.
Provide a detailed list of all audit
exceptions to facility manage~ent for
discussion.
Review each exception noting its
disposition (i.e., "for local attention" or
"for report").
Based on co~~nts received from facility
management, note any factual
misunderstandings and prior to leaving the
site, attempt to reconcile each.
COMP~~~E WORKING PAP~~ASED ON EXIT
MEET ING CO~.M£NTS
If any exceptions are changed b~~2d on comments
during the exit meeting, specifically document
the rationale for such changes.
E.
1.
~DIT REPORT/WORKING PAPER~
Team leaders rev ie',' all working papers for
completeness, organization and file after
review.
4-2
-';~itc>:~--- TI ~'p-j
& Comrnen:s Ref
.-----4- ~
I
I
I
-------
Part 4:
Evaluating Audit EvidencejRepo!-ting Findings
~~.'a
The objective of this part of the
protocol is to: (1) analyze evidence
developed during the audit., and
{2} report all audit results to facility
management. During this par~, the team
will integrate and summarize exceptions
and evaluate audit evidence with respect
to compliance. The outcome of this
activity is a complete list of audit
exce~tions which will be communicated to
manag~ment. This cOml~unication also
provides a final opportunitj to identify
and resolve any factual misunderstandings
develo~ed during the audit.
4-1
-------
k~1 . ~ :- -~-~.V1\+.lI ~.I .!.-~LG .__~f~r OJ:C k,V l Q~ ~,~; /~J:'';--~ ~:J. N~~
~~Ql~~~ (Ccntinuej)
2 .
'II
:3 .
Prepare draft audit report within two weeks
of the exit meeting. Submit to Manager,
Environmental Comp:iance Prog~am for revie~
and distributio~.
Update facility profiles as necessary7
s'..l.b~i t to Mana;~er, Env i~oru.uental Coropl ia71ce
P:-og:-a~.
4 .
Revie'"" d:-a~t audit report comr"ients, revise
report as necessary within two weeks of
recei.v~ng cOtunents, and submit final audit
report to Manage;., Envi~onroen~al Corol ' {ance
Progra~ for d~s~:-:bution.
4-3
~ ---.. ---
AuCltor;Sj
&. Cornn:~.'1ts
WP
F{~!
--- -.---"- .....-.- ~- '~.....--'-
-------
All~. - ,'-'c
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----&"- -"'.0_-,,,,-._.-
U.S. E~VIRONME~TAL PROTECTION AGE~CY
At'DIT P ROGRA..'1
P~. _of
Exit Meeting Djscu~icn Sheet
It
--'----- F'-8nr.~ionil S~.,pe of Aucit
T
Pr
it .,m e~nt
.- '.. -- . .--------- ----
t Minigem.nt Present - -~._-- ----..,.....--
. -' -_......~.
III Present .-~---- -----.~_.-----
--- -_.~.-
UISIO n DUe Prepared By Reviewed By ----- -
. -~
- ~:_F '- ""--""-"- ............. -- -
EXCEPTION W/P REF. CO(\;l~ENT
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