NEIC
EPA -330/9-87-001-R
MULTI-MEDIA COMPLIANCE
AUDIT PROCEDURES
June 1987
,
-
•
National Enforcement Investigations Center, Denver
U.S. Environmental Protection Agency
j
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA -330/9-87-001-R
MULTI-MEDIA COMPLIANCE
AUDIT PROCEDURES
June 1987
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
INTRODUCTION 1
PURPOSE 1
OBJECTIVES 2
SCOPE 2
PLANNING THE AUDIT 3
THE AUDIT TEAM 5
KNOWLEDGE AND SKILLS REQUIRED 5
INVESTIGATOR RESPONSIBILITIES 5
AUDIT PREPARATION 8
COMPILATION AND REVIEW OF BACKGROUND INFORMATION 8
Technical Information 8
Legal Information 10
Information Sources 11
NOTIFYING THE FACILITY 13
CONDUCTING THE AUDIT 16
ENTRY 16
OPENING CONFERENCE 20
GENERAL AUDIT PROCEDURES 21
Process Operations 22
Pollution Control, Treatment and Disposal 23
Operation and Maintenance (O&M) 25
MEDIA SPECIFIC AUDIT PROCEDURES 26
Air 26
Operating Conditions 27
Control Systems 27
Water 29
Solid/Hazardous Waste 30
Toxic Substances 41
Pesticides 50
Water Supply 52
CLOSING CONFERENCE 53
THE AUDIT REPORT AND FOLLOWUP 54
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CONTENTS
REFERENCES
ACRONYMS
APPENDICES
A SUMMARY OF POLLUTON CONTROL LEGISLATION
B SAFETY PLAN
C EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G CERCLA CHECKLIST
H TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
I TSCA PCB CHECKLIST
J TSCA SECTIONS 5 AND 8 CHECKLIST
K PESTICIDE CHECKLIST
L WATER SUPPLY CHECKLIST
M UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
TABLES
1 Federal Statutes/Regulations for Multi-Media Compliance
Audits 12
2 Background Review Information Sources 14
3 Inspection Authority Under the Major Environmental Acts 17
4 Summary of Federal Environmental Acts Regarding Right of
Entry, Inspecting, Sampling, Testing, Etc 18
11
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INTRODUCTION
PURPOSE
This manual is intended as a guide for investigators who conduct
multi-media compliance audits of facilities that discharge, emit, prepare,
manage, store or dispose of pollutants controlled by Federal, State or local
environmental laws and regulations. Investigative methods are presented
which integrate the enforcement programs associated with air, water, solid
waste, pesticides and toxic substances. This manual provides general activ-
ities and functions while focusing on special features of specific media
and associated statutes.
The purposes of a facility multi-media compliance audit are to: (1)
review a facility's pollution control practices; (2) evaluate operation,
safety and waste management equipment and (3) determine status of compliance
with applicable laws and regulations. The environmental laws which EPA
administers and enforces are summarized in Appendix A. Emphasis is given
to identifying violations of regulations, permits, approvals, orders and
consent decrees, etc. and the underlying causes of such violations. Due to
the complexity of laws and regulations, a comprehensive, in-depth review is
not always possible. Investigators should conduct the most thorough review
possible so that violations and problems that have an existing or potential
effect on the environment are identified and adequately documented.
Pollution sources may vary in complexity depending on facility size,
process operations and extent and efficiency of existing pollution controls.
Time and personnel resources required to conduct compliance audits will
vary accordingly. A large industrial facility with multiple process opera-
tions may require evaluation under several environmental statutes, such as
the Clean Water Act (CWA), Clean Air Act (CAA), Resource Conservation and
Recovery Act (RCRA), Toxic Substances Control Act (TSCA), Comprehensive
Environmental Resource, Compensation and Liability Act (CERCLA) and Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA). A multi-media compliance
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audit of this magnitude requires an audit team with combined experience in
all environmental media to effectively determine the pollution potential
and/or compliance of the facility.
OBJECTIVES
This guide provides protocols for multi-media compliance audits.
Specific objectives of such audits are to:
Document facility noncompliance with environmental laws, regula-
tions, orders, permits, consent decrees and approvals.
Determine ability of a facility to maintain "continuous compliance"
across all environmental areas.
Identify need for remedial measures and enforcement action(s) to
correct the causes of violations.
SCOPE
The multi-media compliance audit approach is designed to minimize the
number of visits to a single facility. This manual addresses audit team
activities before and during the onsite audit, report writing and followup
procedures.
In performing compliance audits, investigators should follow estab-
lished Agency policies and procedures for: (1) chain-of-custody and document
control; (2) receipt and handling of confidential information; (3) employee
conduct, responsibilities and ethics; (4) quality assurance and quality
control; and (5) safety rules. When established policies and procedures do
not exist, common sense, professional judgment and experience should be
applied. Investigators need to collect valid, factual information and
supporting data which are adequately documented to ensure that they will be
admissible as evidence in any subsequent enforcement action(s).
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PLANNING THE AUDIT
The success of an audit depends on thorough, up-front planning.
Coordination with all interested and knowledgeable parties (e.g., Region,
State, audit team members, NEIC supervisory staff) is essential to ensure a
smooth operation. All the parties concerned should be identified and
informed as soon as possible to ensure the necessary coordination.
A comprehensive plan (project plan) provides a means for informing all
involved parties of the upcoming activities and ensuring an effective com-
pliance audit. The project plan describes the project objectives, tasks
required to fulfill these objectives, methods and procedures to be followed,
resources required and schedules. The plan generally addresses the
following:
Objectives - The plan defines what the audit is to accomplish (e.g.,
". . .to assess environmental compliance with the regulations that
apply to the source—water, air, etc.").
Tasks - The plan defines tasks for accomplishing the objectives and
spells out procedures for obtaining the necessary information and
evaluating facility compliance. The tasks usually involve an evalua-
tion of process operations, pollution control/treatment and disposal
practices, operation and maintenance practices, self-monitoring,
recordkeeping and reporting practices and pollution abatement/control
needs.
Procedures - The plan provides or references policies and procedures
for document control, chain-of-custody, quality assurance, and handling
and processing of confidential information. Unique instructions for
the particular audit may also be provided.
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Safety - The plan includes the written safety procedures which the EPA
audit team must follow [Appendix B]. Additional safety procedures may
be considered for the extensive or prolonged investigations.
Resources - The plan describes personnel needs and equipment require-
ments. Experienced and knowledgeable personnel shall compose the
compliance audit team.
Schedules - The plan provides schedules for the audit activities.
This information is important to the participants as well as the
Headquarters, Regional and/or State officials who requested the project.
The dates for (a) starting and finishing the field activities, (b)
analytical work, and (c) draft and final reports should be established
and agreed upon by all participants.
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THE AUDIT TEAM
KNOWLEDGE AND SKILLS REQUIRED
The audit team should possess a good working knowledge of the various
environmental pollution control statutes. Team members should understand
the rules, regulations and other provisions, including permits, registra-
tions, authorizations, limitations, monitoring requirements, etc., as they
pertain to a specific facility. The investigators should have, as appropri-
ate, knowledge of Agency policies and procedures, inspection authority,
manufacturing and production processes, applicable pollution control tech-
nology, and the nature of pollution problems and possible solutions,
including available treatment and controls.
Individual team members may have more specific knowledge of a process,
monitoring system, control equipment, environmental media, regulation, etc.
than others. The team, as a whole, however, should have collective knowledge
and background to efficiently and effectively conduct all aspects of a facil-
ity audit. Moreover, investigators must be familiar with Agency policies
and procedures and their authority to conduct inspections. They should
also understand the techniques for evidence gathering and possess skill in
collecting information and in interviewing officials of the public and
regulated commumities.
INVESTIGATOR RESPONSIBILITIES
Investigators represent the Agency when they deal with the regulated
community and the public. They should conduct themselves in a professional
manner and maintain their composure and credibility at all times. Coopera-
tion and good working relations with facility personnel should be estab-
lished, and maintained to the degree possible. EPA investigators must adhere
to the regulations described in the EPA handbook "Responsibilities and Conduct
for EPA Employees".
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Applicable safety provisions and precautions are to be followed
throughout the audit. For example, each team member will dress appropri-
ately, including wearing protective clothing or equipment. Safety require-
ments must be identified before the onsite audit so that no delays occur.
Investigators should provide their own safety equipment and should not rely
on the facility, except in unique situations where special equipment may be
required. All required "fit" testing and certifications must be completed
in advance. In general, company safety requirements must be met in addition
to the appropriate EPA requirements and guidelines addressed in the following
documents:
Agency Safety Manual - Chapter 9, Hazardous Substances Responses
Agency Orders - 1000.18 Transportation of Hazardous Materials
- 1440.2 Health and Safety Requirements for Employees
Engaged in Field Activities
- 1440.3 Respiratory Protection
- 1440.4 Health and Safety Training Requirements for
Mine Safety
- 1440.6 Motor Vehicle Occupant Restraint Systems
- 1440.7 Hazard Communication
- 3100.1 Uniforms, Protective Clothing and Protective
Equipment
- 3100.3 Authorization of Performance of Hazardous
Duty
Agency Guidelines - Eye Protection Program Guideline
- Respiratory Protection Program Guideline
- Selection Guide for Chemical Protective Clothing
- Interim Health and Safety Guidelines for EPA
Asbestos Inspectors
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- Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities
Information which is claimed or requested to be confidential must be
handled properly to prevent disclosure to unauthorized persons. Investigators
must have specific authorization for accessing and handling Confidential
Business Information [TSCA Section 14]. They must be familiar with the.
confidentiality regulations to ensure that information is handled properly
and to prevent disclosure to unauthorized persons.
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8
AUDIT PREPARATION
COMPILATION AND REVIEW OF BACKGROUND INFORMATION
Collection and analysis of background information on the facility to
be inspected are essential to the effective planning and overall success of
a compliance audit. Materials can be obtained from the files of Federal,
State and local agencies, technical libraries, EPA databases and other infor-
mation sources. The background review will enable investigators to become
familiar with facility operations, clarify technical and legal issues before
entry, and develop a sound, factual audit report.
During a properly conducted background review, the investigator should
identify both the technical and legal information needed and available.
The types of information which may be acquired and reviewed are discussed
below.
Technical Information
Facility Background
Maps showing facility location and environmental and geographic
features (stacks, discharge pipes, solid waste disposal sites,
etc.)
Geology/hydrogeology of the area
Aerial photographs
Names, titles, phone numbers of responsible facility officials
Process description, process flow charts and major production
areas
Records reflecting changes in facility conditions since previous
audit/permit application
Production levels - past, present and future
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Audit Reports. Records, and Files
Federal and State compliance files
Correspondence between the facility and the local, State and
Federal agencies
Citizens' complaints and reports, followup studies, findings
Audit records, reports, correspondence on past incidents or
violations
Emissions inventory
Self-monitoring data and reports
EPA, State and consultant studies and reports
Annual reports by the facility (e.g., PCB annual documents and
inventories, Securities Exchange Commission §10K reports)
Records, applications, reports, manifest files, etc. (e.g., RCRA
reports, CERCLA submittals)
Laboratory audit reports, QA/QC activities
Records of previous hazardous substances spills
Pollutant and Waste Generation, Control, Treatment and Disposal Systems
Description and design data for pollution control systems and
process operations
Sources and characterization of wastewater discharges, hazardous
wastes, emissions, types of treatment and disposal operations
Type and amount of waste generated which is discharged, emitted,
stored, treated and disposed
Waste storage, treatment and disposal areas
Waste/spill contingency plans
Available bypasses, diversions and spill containment facilities
Industrial process, pollution control, treatment and disposal
methods, monitoring systems
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10
Legal Information
Requirements, Regulations and Limitations
Permit applications, draft or existing permits, registrations,
approvals and applicable Federal, State and local regulations and
requirements
Application certificates, EPA identification numbers
Draft permits or information on draft permit terms which are dif-
ferent from current conditions
Exemptions and waivers
Receiving stream water quality standards, ambient air standards,
State Implementation Plans, protected uses
RCRA notification and Part A and Part B applications
Pesticide labels
Grant applications for publicly owned treatment works, Research &
Development demonstration projects and progress reports on these
projects
Federal and State classification of facility (e.g., Interim Status,
Small Quantity Generator, etc.)
Enforcement History
Status of current and pending litigation against the facility*
Deficiency notices issued to facility and responses by the facility
Status of administrative orders, consent decrees or other regula-
tory corrective actions, if any, and compliance by the facility
Penalties imposed against the company
Coordination should occur prior to the audit (in conjunction with the
Regional office) with the local Assistant United States Attorney or
Justice Department attorney responsible for the civil or criminal case
and any consent decree.
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Information Sources
Laws and Regulations - Federal laws and regulations establish
procedures, controls and other requirements applicable to a facility [Table 1].
In addition, State laws and regulations and sometimes even local ordinances
may be applicable, or take precedence over the same facility.
Permits and Permit Applications - Permits provide information on the
limitations, requirements and restrictions applicable to discharges, emis-
sions and disposal practices; compliance schedules; and monitoring, analy-
tical and reporting requirements. Applications provide technical informa-
tion on facility size, layout and location of pollution sources; waste and
pollutant generation, treatment, control and disposal practices; contin-
gency plans and emergency procedures; and pollutant characterization - types,
amounts, and locations of discharge, emissions or disposal.
Regional and State Files - These files often contain grant records,
applications, facility self-monitoring data and audit reports, as well as
permits and permit applications pertaining to individual facilities. These
information sources can provide compliance, enforcement and litigation
history; special exemptions and waivers applied for and granted or denied;
citizen complaints and action taken; process operational problems/solutions;
pollution problems/solutions; and laboratory capabilities. Consultant
reports can provide design and operating data and recommendations for pro-
cesses; pollutant sources; treatment, control and disposal systems; and
remedial measures.
Technical Reports, Documents and References - These sources provide
information on industrial process operations, data on available treatment,
control and disposal techniques, such as their advantages or drawbacks,
limits of application, etc. Such sources include Effluent Guideline and
New Source Performance Standard development documents and EPA's Treatability
Manual. Similar guidance documents on hazardous waste generation, treatment/
disposal are also becoming available.
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Table 1
FEDERAL STATUTES/REGULATIONS FOR MULTI-MEDIA COMPLIANCE AUDITS
Inspection Authority
Recordkeeping
Authority
Confidential
Information
Air
CAA
114a, 211a
[80.866]
114, 208
[51, 57, 58, 60,
61, 79, 85, 86]
208, 307,
[2.201-2.215,
2.301, 53, 57,
80]
Water
CWA
308, 402
[122.41]
308, 402
[122.41, 122.48]
308
[2.201-2.215,
2.302, 122.7]
Superfund
CERCLA
104
103
104
[2.201-2.215]
Pesticides
FIFRA
8, 9
[160.15, 169.3]
4,8
[160.63, 169,
160.185-195]
7, 10
[2.201-2.215,
2.307]
Solid Waste
RCRA
3007,9005
[270.30]
3001, 3002, 3003,
3004, 9003
[262.40, 263.22,
264.74, 264.279,
264.309, 265.74,
264.309, 270.30]
3007, 9005
[2.201-2.215,
2.305, 260.2,
270.12]
Drinking Water
SDWA
1445
[142.34, 144.51]
1445
[141.31-33,
144.51, 144.54]
1445
[2.201-2.215,
2.304, 144.5]
Toxics
TSCA
11
[717.17, 792.15]
8
[704, 710,
717.15, 720.78,
761.180, 762.60,
763.114,
792.185-195]
14
[2.201-2.215,
2.306, 704.7,
707.75, 710.7,
712.15, 717.19,
720.80-95,
750.16, 750.36,
762.60, 763.74]
Emergency Authority 303
Employee Protection 322
504
507
104, 106
[300.53, 300.65]
110
27
[164.166]
7003
7001
1431
1450
23
Permits
Basic requirements
include applica-
tions, standard
permit conditions.
monitoring, reporting
EPA procedures for [124]
permit issuance
Technical [52]
requirements
Specific References NSPSf
NESHAP9 [61]
CEM* [60]
Sltf [52]
PSD*[50]
[122,125]
[124]
[129, 133. 136,
302cj BMP3 [125]
SPCC8 [112]
Waivers [125, 230]
Effluent guidelines
[400-460]
BMP [125], SPCC
[112], Pretreatment
[125, 403], Toxic
[129]
a Statute (e.g., Clean Air Act, Section 114 or 211)
b [BO, 86] - 40 CFR, Parts 80 and 86;
c Beportable quantities
d BMP - Best Management Practices
e SPCC - Spill Prevention Control and
CFR refers to Code of Federal Regulations
Countermeasures Plan
[270] [144,147]
[124] [124]
[260-266] [146,264]
Generators [262],
Transporters [263],
TSD1 [265], Stds for
TSD Permits [264],
Interim Stds [265],
Storage <90 days [262],
Exemptions [261]
f HSPS - New Source Performance Standards
g NESHAP - national Emission Standards for Hazardous
h CEH - Continuous Emission Monitoring
i TSD - Treatment, Storage and Disposal
j SIP - State Implmentation Plan
k PSD - Prevention of Significant Deterioration
PCBs [761]
Dioxin [775]
Air Pollutants
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The background information sources for all program areas and those
that apply specifically to the water, air, solid waste pesticides and toxic
substances programs are listed in Table 2.
NOTIFYING THE FACILITY
In most cases, notification for routine audits are announced to the
facility, but are not required. In cases where there is concern that physical
conditions may be altered prior to the audit or that records may be des-
troyed, an unannounced audit should be conducted. The initial contact is
usually by phone with followup written confirmation of the anticipated audit
period. The notification letter specifies the authority for the audit and
outlines the areas to be covered during the audit and the information to be
provided. This approach improves the chances that responsible facility
officials will be present and that necessary information will be readily
available.
Typical information requested in a notification letter for availability
during the audit may include the following:
Raw materials, imports, isolated intermediates, products, byproducts,
production levels
Facility maps identifying process areas, discharge and emission
points, waste disposal sites
Flow diagrams or descriptions of processes and waste control,
treatment and disposal systems showing where wastewater, air
emission and solid waste sources are located
Description and design of pollution control and treatment systems
and normal operating parameters
Operations and maintenance procedures and problems
Appropriate packaging and shipping labels
Self-monitoring reports and inventories of discharges and emissions
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Table 2
BACKGROUND REVIEW INFORMATION SOURCES
All Program Areas
Water Pollution
CWA
Air Pollution
CAA
Solid Wastes
Pollution
RCRA
Toxic Substances
Pollution
TSCA
FIFRA
NEIC Information
Retrieval System data
on corporate structure,
financial conditions,
pollution control his-
tory, environmental and
health impacts of pollu-
tants of interest
EPA grants (R&D, con-
structing, planning)
Information available on
process operations; pol-
lutants of interest;
existing treatment, con-
trol and disposal prac-
tices; raw materials;
etc.
Administrative Orders
issued for environmental
noncompliance
Applicable local ordi-
nances on environmental
control
Compliance history and
present compliance status
Available correspondence
between regulating
officer and facility
officials
Available contractor/
consultant report on
facility environmental
control matters
Environmental compliance
schedules and present
status
Available aerial
photography
NPDES permits/permit
applications/draft permits
Applicable effluent
guidelines
Compliance inspection
reports (Federal/State/
local)
Laboratory performance
reports
Self-monitoring require-
ments and self-reporting
data
Best Management Practices
Plan
Spill Prevention Control
and Countermeasure Plan
Pretreatment requirements
if facility discharges to
POTW
Applicable Federal/State
regulations related to
water pollution control
at facility
Technical manuals and
references on pollution
treatment/control tech-
nology, process operation,
monitoring inspection
procedures, etc.
Interstate Commission
water quality date (Ohio
River Sanitary Commission,
Delaware River Basin Com-
mission, Interstate Com-
mission on the Potomac
River, etc.)
Air permits and permit
Applications (Federal/
State/local)
Self-monitoring require-
ments and self-reported
data
Compliance inspection
reports (Federal/State/
local)
Applicable NESHAP
Applicable NSPS
Applicable air quality
standards
State Implementation Plan
Ambient air quality
reports for AQCR
Air pollutants emission
inventories
Continuous monitoring
practices and facility
and applicable perform-
ance inspections
Available contractor/
consultant reports
Technical manuals and
references on applicable
pollution treatment/
control technology,
process operators, air
pollution monitoring,
inspection procedures,
etc.
Part A of permit applica-
tion (TSDs only) to desig-
nate type and volume of
wastes handled, type and
design capacity of treat-
ment, storage and/or
disposal processes
Part B of permit applica-
tion, if available
Draft/final RCRA permit
Applicable regulations for
source designations
Groundwater monitoring
plans/data
UIC permit and present
status
Hydrogeologic reports on
local area relative to UIC
permit
Self-monitoring require-
ments and self-reported
data
Applicable regulation on
manifest requirements
Inspection reports
(Federal/State/local)
Technical manual and
references on applicable
treatment/control and dis-
posal technology, inspec-
tion and monitoring pro-
cedures and techniques,
etc.
Available information on
chemical substances
produced by facility
Applicable regulations
regarding manufacture,
identification, self-
reporting requirements,
concerning toxic mater-
ials (e.g., PCB rules)
Inspection reports
(Federal/State/local)
Technical manuals and
references on applicable
treatment/control and
disposal technology,
inspection and monitoring
procedures and tech-
niques, etc.
Establishment numbers,
Certified Applicator
numbers
Applicable labels
Inspection reports
(Federal/State)
EPA Pesticide Inspection
Manual
State Facility Permits for
procedures, bulk storage,
etc.
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15
Self-monitoring equipment in use, normal operating levels and
available data
Required plans and records
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16
CONDUCTING THE AUDIT
The compliance audit will consist of the following phases:
Entry
Opening conference
The onsite inspection
Closing conference
ENTRY
The team should arrive at the facility during normal working hours,
unless special circumstances, such as suspected illegal activity at night,
are being investigated. The investigators shall identify themselves to the
owner, agent in charge or other responsible facility official; present their
official Agency credentials to the facility official, whether requested or
not; and explain the purpose of the audit. Tables 3 and 4 outline the
various Federal environmental statutes which give Agency employees the
authority to enter facilities, review records and collect samples.
If the audit is conducted at a Federal facility that has national
security information, restricted or classified areas, special procedures
may be required for entry. For example, a military installation regulation
may stipulate that investigators shall provide proof of appropriate security
clearance before entry is approved into restricted areas. When this occurs,
the investigators should refer such special cases to their appropriate legal
staff (e.g., Office of Regional Counsel).
When the facility provides a blank sign-in sheet, log or visitor reg-
ister, it is acceptable for investigators to sign it. Note, however, that
EPA employees must not sign any type of "waiver" or "visitor release" that
would relieve the facility of responsibility for injury or which would limit
the rights of the Agency to use data obtained from the facility. When such
a waiver or release is presented, team members should politely explain they
cannot sign such a document and request a blank sign-in sheet. If they are
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Table 3
INSPECTION AUTHORITY UNDER THE MAJOR ENVIRONMENTAL ACTS
CAA - § 114(a)(2)
". . .the Administrator or his authorized representative, upon presentation of his credentials - shall have a right of
entry to, upon, or through any premises of such person or in which any records required to be maintained. . .are located,
and may at reasonable times have access to and copy any records, inspect any monitoring equipment and method. . .and
sample any emissions. . .".
CWA - § 308(a)(4)(B)
". . .the Administrator or his authorized representative...upon presentation of his credentials - (i) shall have a right
of entry to, upon, or through any premises in which an effluent source is located or in which any records required to be
maintained. . .are located, and (ii) may at reasonable times have access to and copy any records, inspect any monitoring
equipment or method. . .and sample any effluents which the owner or operator of such source is required to sample. . .".
RCRA - § 3007(a)
". . .any person who generates, stores, treats, transports, disposes of or otherwise handles or has handled hazardous
wastes shall upon request of any. . .employee or representative of the Environmental Protection Agency. . .furnish
information relating to such wastes and permit such person at all reasonable times to have access to, and to copy all
records relating to such wastes."
". . .such employees or representatives are authorized. . .to enter at reasonable times any establishment or other place
where hazardous wastes are or have been generated, stored, treated or disposed of or transported from; to Inspect and
obtain samples from any person of any such wastes and samples of any containers or labeling for such wastes."
TSCA - § ll(a)(b)
". . .any duly designated representative of the Administrator, may inspect any establishment. . .in which chemical sub-
stances or mixtures are manufactured, processed, stored or held before or after their distribution in commerce and any
conveyance being used to transport chemical substances, mixtures or such articles in connection with distribution in
commerce. Such an inspection may only be made upon the presentation of appropriate credentials and of a written notice
to the owner, operator or agent in charge of the premises or conveyance to be inspected."
FIFRA - § 8 and 9
". . .any person who sells or offers for sale, delivers or offers for delivery any pesticide. . .shall, upon request
of any officer or employee of the Environmental Protection Agency. . .furnish or permit such person at all reasonable
times to have access to, and to copy: (1) all records showing the delivery, movement or holding of such pesticide or
device, including the quantity, the date of shipment and receipt, and the name of the consignor and consignee. . .".
". . .officers or employees duly designated by the Administrator are authorized to enter at reasonable times, any estab-
lishment or other place where pesticides or devices are held for distribution or sale for the purpose of inspecting and
obtaining samples of any pesticides or devices, packaged, labeled and released for shipment and samples of any containers
or labeling for such pesticides or devices."
"Before undertaking such inspection, the officers or employees must present to the owner, operator or agent in charge
of the establishment. . .appropriate credentials and a written statement as to the reason for the inspection, including
a statement as to whether a violation of the law is suspected."
". . .employees duly designated by the Administrator are empowered to obtain and to execute warrants authorizing entry
. . .inspection and reproduction of all records. . .and the seizure of any pesticide or device which is in violation of
this Act."
SOWA - § 1445
". . .the Administrator, or representatives of the Administrator. . .upon presenting appropriate credentials and a
written notice to any. . .person subject to. . .any requirement. . .is authorized to enter any establishment, facility
or other property. . ,1n order to determine. . .compliance with this title, including for this purpose, inspection, at
reasonable times, of records, files, papers, processes, controls and facilities or in order to test any feature of a
public water system, including its raw water source."
CERCLA (Superfund) - § 104(e)
"Any officer, employee or representative of the President. . .is authorized to. . .
require any person. . .to furnish. . .information or documents relating to. . .identification, nature and quantity of
materials. . .generated, treated or disposed. . .or transported. . .nature or extent of a release. . .ability of a
person to pay. . ."
". . .access. . .to inspect and copy all documents or records. . ."
". . .to enter. . .place or property where any hazardous substance or pollutant or contaminant may be or has been
generated, stored, treated, disposed of, or transported from. . .needed to determine the need for reposnse. . ."
". . .to Inspect and obtain samples. . ."
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Table 4
SUMMARY OF FEDERAL ENVIRONMENTAL ACTS
REGARDING RIGHT OF ENTRY, INSPECTIONS, SAMPLING, TESTING, ETC.
Act/Section
Clean Water
Act
FIFRA
Clean Air
Act
RCRA
SOWA
TSCA
CERCLA
§308(a)
§8(b)
(Books &
Records)
§9(a)
(Inspec-
tions of
estab-
lishments
§114(a)
§3007(a)
9005(a)
§1445(b)
§ll(a,b)
§104(4)
Designated
Representative
Yes, auth. by
Administrator
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, auth. by
Administrator
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, designated
by President
Presentation
of Credentials
Required
Required
Required
Required
Not required
Required
Required
Not required
Notice of
Inspection
Not required
Written notice
required with
reason and sus-
pected violation
note
Written notice
required with
reasons for
inspection
Not required
except notify
State for SIP
sources
Not required
Written notice
required, must
also notify
State with
reasons for
entry if State
has primary
enforcement
responsibility
Written notice
required
Not required
Receipt Return of
Sampling Inspection Sample for Agency's Analytical
Permitted of Records Splits Samples Results
Yes (effluents Yes
which the owner
is required to
sample)
No Yes
Yes See §8
Yes Yes
Yes Yes
Yes Yes
(The Act Yes
does not men-
tion samples
or sampling in
this section.
It does state an
inspection shall
extend to all
things within
the premise of
conveyance. )
Yes Yes
Not required Not required Not required
N/A N/A N/A
Required, Required Required,
if requested promptly
Not required Not required Not required
Required, Required Required,
if requested promptly
Not required Not required Not required
N/A Yes N/A
Required, Required Required,
if requested promptly
CO
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refused entry because they do not sign such a release, the team should leave
and immediately report all pertinent facts to the appropriate supervisory
and legal staff. All events surrounding the refused entry should be fully
documented, including the name of the person refusing entry.
Various Federal environmental statutes give Agency investigators the
authority to enter facilities, review records and collect environmental
samples [Tables 3 and 4]. The audit should be made with the consent of the
facility owner and/or authorized person, unless the audit is conducted under
a warrant. When the investigator is allowed to enter, entry is considered
voluntary and consensual by the facility operator or owner, unless the inves-
tigator is expressly told to leave the premises. Consent to enter can,
however, be revoked at any time during the audit. If this occurs, all infor-
mation collected during the consensual phase remains in possession of the
investigators. When withdrawal of consent takes place, the same procedures
apply as for denial of entry.
Because audits may be considered adversary proceedings, investigators
may be challenged as to their legal authority, techniques and competency.
Facility personnel may also display antagonism to Agency personnel. In all
cases, the investigators must courteously explain the authorities and the
reasons for the protocols followed. If explanations are not satisfactory
or disagreements cannot be resolved, the team should leave and obtain further
direction from the appropriate Agency supervisory or legal staff.
In certain circumstances, audits will be conducted under authority of
search warrants. A warrant is a judicial authorization for appropriate
persons to enter specifically described locations and to perform certain
audit functions. It is possible that a pre-audit warrant could be obtained
when there is reason to believe that entry will be denied or when violations
are expected which could be hidden during the time a search warrant was
obtained. When authorized by a judge or magistrate, administrative search
warrants can be served by a team member. Criminal search warrants, once
obtained, are to be served by designated Federal law enforcement officials
(e.g., U.S. Marshal, EPA criminal investigators) and not by an audit team
member.
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OPENING CONFERENCE
At the opening conference with facility officials, the project
coordinator presents his or her credentials; provides names of the other
team members, purpose of the audit and laws under which the audit is being
conducted; and outlines procedures and proposed schedule to be followed.
If not previously done, any required notices should also be presented to
facility representatives at this time.* A cooperative working relationship
should be established and is encouraged between the investigators and the
facility officials; this arrangement will simplify assignments and contrib-
ute to the success of the compliance audit.
Major discussion topics at the opening conference should include:
audit objectives, processes and areas to be inspected, anticipated audit
schedules within various areas of the facility, basic types of records to
be reviewed, safety requirements, the handling of confidential data (which
should be obtained only if absolutely necessary), manner of handling ques-
tions during the course of the audit and the closing conference. Facility
officials should be informed of their right, under RCRA, CERCLA/Superfund
and FIFRA, to receive duplicates, replicates or splits of any samples taken
and receive the results of analyses. If team members desire to take photo-
graphs or copies of records during the audit, this should also be discussed
in the opening conference.
Photographs are used to prepare a thorough and accurate investigation
report, as evidence in enforcement proceedings and to explain conditions
found at the plant. The facility, however, may object to the use of cameras
in their facility and on their property. If a mutually acceptable solution
cannot be reached and photographs are considered essential to the audit,
Agency supervisory and legal staff should be contacted for advice.
Under FIFRA, TSCA and SDWA, written notification is required before
entry. For "unannounced audits", this notification can be provided at
the time of entry. Under TSCA, the investigator presents a TSCA Inspec-
tion Confidentiality Notice which informs the facility of their right
to claim certain materials as Confidential Business Information (CBI).
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Facility personnel may also request that photographs taken during the
visitation be considered confidential, and the Agency is obliged to comply,
pending further legal determination. Self-developing film, although often
of poor quality, is useful in these situations. A facility may refuse
permission to take photographs unless they can see the finished print.
Duplicate photographs (one for the investigator and the other for the
facility) should satisfy this need. When taking photographs considered
TSCA Confidential Business Information (CBI), self-developing film eliminates
processing problems, because the film processor must also have TSCA CBI
clearance. Note, however, that some self-developing film may contain dispos-
able negatives which must also be handled in accordance with the TSCA CBI
requirements. Giving the facility the option of developing the film may
resolve problems when self-developing film is not satisfactory.
Photographs must be fully documented, following procedures for handling
evidentiary materials [Appendix C].
GENERAL AUDIT PROCEDURES
The general elements that are common to all environmental compliance
areas—process operations, pollution control, treatment and disposal, and
operation and maintenance are discussed below. Specific guidelines that
complement the general elements are contained in the following section,
organized by environmental media—air, water, solid/hazardous wastes, and
toxic substances. Checklists are provided in the appendices.
Activities include reviewing records, reports and data; observing and
evaluating equipment, monitors, devices or activities; and interviewing
facility personnel. It is, therefore, important to have a knowledgeable
facility representative(s) accompany the investigators during these segments
of the audit.
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Process Operations
Collectively, the audit team must have a basic understanding of the
physical plant under investigation and the general processes used at the
facility. This knowledge is necessary to aid in determining the substances
(e.g., raw materials, products, byproducts, including waste materials)
present at the facility and where these may be released as pollutants into
the environment. The compliance audit team is not required to have an in-
depth understanding of all the intricacies of the industrial processes, but
investigators should have sufficient understanding to conduct a thorough
and efficient audit.
The compliance audit team may perform the following:
Determine if changes have occurred since the last audit, permit
issuance, etc. in process units, their operation and flow diagrams
by comparison with available information. Determine the present
production level and rate of product, byproduct and waste gener-
ation. Determine the rate of raw material usage. Determine pro-
duction process unit mode (e.g., continuous or batch). Infor-
mation on production is essential if pollution control limits are
based on production rates or products. Process modifications may
have changed the types and loads of pollutants emitted, discharged
or disposed. Different production levels could cause higher emis-
sion mass loadings or gas flow rates. Varying operating condi-
tions can cause pollutant collection and control problems.
Identify those processes or physical elements of the facility
which contribute to sources of pollution (air, water, solid/
hazardous waste). Identify the sources, characterization, flow
rates, etc. at points where wastewater, gaseous emissions and
solid wastes are generated. Determine fate of byproducts (e.g.,
do they discharge or emit directly to the environment or to storage
facilities or to a treatment facility). Determine types and amounts
of pollutants being discharged.
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Determine the variability of process controls and production rates
and their relationship to pollutant emission discharges, etc.
Determine if production upsets are tied to pollution incidents,
exceedences, etc. and the facility response to these upsets.
Determine if process or facility modifications are proposed or
planned. Obtain information on these modifications, including
schedules, and certainty of the modifications (e.g., is the change
proposed or planned, have funds been reserved). Obtain facility
estimates on wastes generated and discharged.
Pollution Control, Treatment and Disposal
After investigators have determined which processes generate wastes,
they should determine how the waste materials are handled and ultimately
released, treated or disposed. This includes tracking the waste from
generation to final disposition, using process flow diagrams, physical
audits and facility records.
The compliance audit team may perform the following:
Determine which waste streams are regulated by Federal, State or
local regulations, licenses and approvals. In doing so, the
investigators will be able to tailor their audit activities to
the handling, disposal and treatment requirements of the appro-
priate regulations. Identification of the various items regulated
under the established Federal regulations were shown in Table 1.
Although it is desirable to obtain information on all waste streams
generated (both those that are and those that are not specifically
regulated), the emphasis must be placed on the handling of regulated
wastes. This will ensure that the audit team accomplishes the
major objective of determining compliance with applicable regula-
tions in a reasonable period.
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Obtain updated descriptions and schematics of major pollution
control equipment and waste storage/treatment/disposal areas.
Visually inspect equipment and storage/treatment/disposal areas.
Locate points of pollutant emission or discharge and waste dis-
posal or storage, including alternative locations, such as diver-
sions, bypasses and overflows.
Obtain design data and startup dates for pollution control/
treatment devices and waste disposal areas. Observe disposal
areas and equipment. Observe disposal equipment during operation.
Locate and observe indicating and recording instrumentation for
monitoring control/treatment devices; compare operating levels to
design specifications to determine if devices are operating normally.
Review operations maintenance and inspection records. Identify
any operating problems and their probable causes.
Evaluate sampling techniques, equipment and locations used for
collection of representative samples. Identify recycle and dilu-
tion streams and other flow characteristics and relate to the
sampling locations. Determine if samples are being collected
consistently with permit/regulation requirements (e.g., grab vs.
composite) and frequency of sample collection. Observe monitoring
procedures such as flow measurement, sample collection and preser-
vation, calibration procedures, in-stack monitors, etc. Determine
if proper parameters are being monitored, if the methods and records
are consistent with permits and regulations, and if results are
properly calculated and reported. Evaluate quality assurance/
quality control procedures followed by the Company.
Determine facility plans to expand existing treatment facilities
and install new treatment units. Obtain copies of design criteria,
consultants' reports, etc. Based on these data and first-hand
observations, determine what additional treatment may be required
to meet existing permit limits, regulations and other requirements.
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Evaluate compliance with schedules, including status of engineering
plans and equipment design, procurement, fabrication, installa-
tion and testing and startup of equipment. Determine if the final
requirements can be achieved on time; verify if structures are in
place. Determine any delays associated with particular construc-
tion schedule and possible violations. If schedules are not being
met, determine if the facility has rescheduled activities; for
example, corporate resolutions, financing agreements, contracts,
equipment orders and engineering services documents. Verify dates
when documents were completed. These documents may be procured
through a formal written request so they can be studied in depth.
Determine if recruitment and training of new personnel (and poten-
tial new hires) for new pollution control activities have been
initiated.
Review laboratory analytical methods, procedures, recordkeeping
and quality control measures. Determine if the methods conform
to permit and regulatory requirements. Determine if laboratory
quality assurance and quality control are sufficient to evaluate
data (e.g., proper and timely calibration, fresh chemical reagents,
scheduled equipment maintenance, etc.). In some cases, laboratory
evaluations may involve offsite (company or contract) laboratories.
In these cases, determine whether the offsite labs have already
been evaluated by EPA as part of the contract program, other
compliance, etc.
Operation and Maintenance (O&M)
Knowledge of the operation and maintenance practices for the process
and control facilities provides the investigator insight into plant manage-
ment and problems including frequency of breakdowns, malfunctions, upsets,
outages, diversions, spills and leaks, bypasses and waste variability. It
is important to determine the causes of these incidents and if they can be
corrected. O&M review includes preventive, routine, and remedial maintenance
programs; spare parts inventory; emergency operating and response programs;
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26
training and certification of plant personnel; alarm systems for power and
equipment failures; backup systems; and housekeeping practices throughout
the plant. The O&M reivew also includes review of facility and corporate
policies and protocols and schedules for such items as reading and calibrat-
ing instrumentation, examining recording charts and logs, and updating O&M
manuals, engineering drawings and specifications, supplier manuals, and
data cards on equipment.
The compliance audit team may determine major factors which affect
process discharge, emissions, disposal, controls and changes in operation.
O&M practices should be evaluated as to whether they are adequate for the
proper management of pollution control equipment. Abnormal releases can be
due to progressive equipment deterioration or lack of repair. Also, as
equipment ages, efficiency drops and original removal rates cannot be achieved.
Startup and shutdown of process and control facilities can create problems
of surge waste releases which may be alleviated by improved plant management.
MEDIA-SPECIFIC AUDIT PROCEDURES
Air
Air pollution audit items are divided into four groups: (1) operating
conditions, (2) control systems, (3) continuous monitoring and (4) compli-
ance records and testing. The team should be prepared to observe, review
and document these audit items so that factual information can later be
evaluated and compliance determined. Before the audit, the checklists in
Appendix D which address the New Source Performance Standards (40 CFR Part
260) and the National Emissions Standards for Hazardous Air Pollutants (40
CFR Part 61), including asbestos, should be reviewed. Furthermore, an
updated emissions inventory will provide a listing of regulated point sources
within the facility.
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27
Operating Conditions
Determine if construction and operating permits are current.
Review records to determine if facility is operating within the
limitations of the permit.
Review records for abnormal operations, shutdowns, malfunctions.
Determine cause, frequency and potential impact on emissions.
Determine if any operational changes (feedstock, fuel flow rate,
temperature changes, etc.) have been made that could potentially
affect emissions.
Observe evidence of air pollution effects on premises, especially
over surrounding areas (e.g., odors, dusting, deposits on cars,
vegetation damage). Fugitive emissions may require special
attention. Odor problems may best be characterized outside the
plant because of olfactory fatigue inside the plant.
Control Systems
Compare observed operating conditions with baseline values obtained
from compliance stack tests or from manufacturer's specifications.
Compare control equipment monitoring values (pressure drop, flow
rates, primary and secondary currents, etc.) with permit and/or
regulatory requirements.
Conduct control system evaluation. Review instrumentation, design
and operational flow rates, temperatures, pressure drops and emis-
sion monitors. From these data, the investigator should be able
to determine if the plant is achieving compliance under normal
circumstances.
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Review control equipment maintenance procedures, malfunctions and
corrective actions taken.
Check number of emissions violations and any complaints filed
since the last audit.
Continuous Emission Monitoring (CEM)
Review operational (calibration, span, checks, etc.) and mainte-
nance practices.
Review records for excess emission reports (EERs) and determine
cause.
Review Performance Specification Tests and compare with 40 CFR
60, Appendix B requirements.
Correlate the opacity monitor readings with VEOs.
Compliance Records and Testing
Check source records for compliance with applicable regulations,
including NESHAP, NSPS.
Review records of compliance test results. The facility should
be able to provide proof that emissions have been within desired
limits by means of a compliance test using a specified or reference
test method (40 CFR Part 260, Appendix A). The test is usually
witnessed by control agency officials. Process and emission param-
eters should be adequately documented during test.
Determine if onsite visible emission observations are warranted;
an investigator doing CAA audits must be certified for visible
emissions reading or the information developed may require
duplication.
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Water
Important water pollution audit components are categorized as control
and treatment systems, self-monitoring systems (including both field and
laboratory measurements), operation and maintenance, and the Best Management
Practices (BMP) plan. Before the audit, the investigators should review
the checklists in Appendix E. The appendix also includes the Spill Preven-
tion Control and Countermeasure (SPCC) plan which companies are required to
develop and maintain to prevent or control spills of petroleum and related
products. Note that spills of hazardous substances are covered by 40 CFR 117.
Control and Treatment Systems
Assess the ability of the wastewater treatment plant to withstand shock
loads, low temperature, excess stormflows, peak process flows and shock
organic loads by reviewing past operating data. Assess impact of storm-
flows, inflow and infiltration on system operation. Determine if SPCC plan
meets §311 requirements of the CWA (see 40 CFR 112).
Self-monitoring Systems
Self-monitoring consists of flow and water quality measurements and
sampling by the facility in addition to the laboratory which analyzes water
samples required under the National Pollutant Discharge Elimination System
permit program.
Field - Confirm that acceptable sampling and flow measurement, as
specified by the NPDES permit, are carried out at the correct loca-
tions and with the proper frequency, and that all necessary calibra-
tions and O&M are performed. Samples must be collected at prescribed
locations. Flow rating and calibration must use standardized techniques.
Clean and properly prepared containers must be used in sampling.
Adequate procedures are to be used in the handling, preserving and
transporting of samples [Appendix E].
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Laboratory - Evaluate analytical procedures including: (1) preservation
methods and holding times of samples, (2) use of approved analyses (40
CFR 136 or approved alternatives), (3) adequacy of instrument cali-
bration and state of repair, (4) adequacy of QA/QC program for all
analyses, and (5) recordkeeping and calculations in the lab. Other
important areas include cleaning and use of glassware, condition of
laboratory instrumentation, reagent quality control, and media
preparation and sterilization techniques.
Evaluate how the data are entered into lab notebooks; the sign-off
procedures used; analysis of spikes, blanks and reference samples; how the
lab data are transposed onto the official, self-monitoring report forms
going to the enforcement agency; and the extent and capability of outside
contract laboratories, if used.
Operation and Maintenance
Observe if vital treatment units are out of service and causes of non-
service, if there is excess accumulation of solids, scum, grease and floating
materials in the treatment units, or if there is a presence of odors, exces-
sive weed growth, etc. Assess handling, treatment and disposal of sludges
and other residues generated from processes and wastewater treatment system.
Best Management Practices (BMP) Plan
Check for BMP plan if the facility handles toxic pollutants. A BMP
plan may be required by the NPDES permit or may be needed if toxics are
contributed from ancillary operations and reasonable opportunity exists for
discharge (40 CFR 125, Subpart K). BMP and SPCC plans, documents and
facilities should be reviewed.
Solid/Hazardous Waste
The initial step in evaluating compliance with solid/hazardous waste
requirements of a facility is to identify all waste streams and determine
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31
which are regulated by Federal*, State** or local regulations, licenses and
approvals. Preferably, this determination is initiated during background
document review before the onsite facility audit and supplemented/modified
using information obtained during an onsite evaluation. All waste streams
generated (even those that the generator claims are not regulated) must be
evaluated for regulatory inclusion. This will allow the investigator to
determine whether or not the generator has properly identified all of the
regulated waste streams.
Once regulated waste is identified, the investigator can track the
material from generation to final onsite disposition (onsite treatment/
disposal) or storage and transport for offsite disposal and determine
compliance with applicable regulations. Throughout the audit, the investi-
gator must keep in mind that both past and present activities need to be
evaluated for compliance with applicable regulations.
In general, the compliance evaluation for solid/hazardous wastes han-
dled at a facility includes obtaining, reviewing and evaluating information
from Federal, State and local regulatory agency files; interviews with facil-
ity personnel regarding waste management activity; examination of facility
records, including any internal waste tracking/storage/disposal logs, audit
records and visual audit of waste management units. An integral part of
any evaluation is the compilation of facility background information includ-
ing facility size, physical description of operating units (area, depth,
volume, etc.) and construction methods (presence/absence of liners, special
compacting, etc.).
Prior to or during the onsite audit, the investigator must determine
how extensive a records review will be necessary to meet the compliance
evaluation objectives of the audit. Factors such as the number of documents
available, resource allocation and time constraints determine whether the
* Definitions, identification and listing of Federally regulated waste
are given in 40 CFR 260 and 261 and CERCLA §101.
** Nonhazardous solid waste is usually regulated by the State and these
regulations must be obtained to evaluate applicable facility activity.
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32
objectives are realistic and can be achieved; however, in all cases, the
records review must be sufficient to demonstrate facility compliance or
noncompliance. Often, because of time constraints, it may be necessary to
obtain copies of documents (either microfilm or photocopies) for future
offsite review and evaluation. To ensure effective use of resources, docu-
ments reviewed/copied while onsite should be limited to those containing
information within the scope of the audit.
Investigators are encouraged to use the various RCRA evaluation check-
lists [Appendix F] during the audit to supplement their knowledge of the
RCRA regulations and to ensure that all items under each activity are ade-
quately addressed. The investigator should also be aware of the requirements
of CERCLA, including a facility's responsibilities to notify the proper
regulatory authorities of former hazardous substance releases and sites
(non-interim status) where hazardous substances have been stored, treated
or disposed of [CERCLA, Section 103(a) and (c)]. Military installations
are also responsible for conducting site assessments through remedial action
programs to identify past hazardous substance releases and handling facil-
ities [40 CFR 300.64-68]. The investigator should determine, through records
review, interviews, etc., whether all RCRA and CERCLA [Appendix G] sites
have been reported to the proper authorities. The investigator should also
evaluate assessment and response programs at a facility, if this objective
is within the scope of the audit.
Additionally, the facility should be evaluated concerning State and
local requirements controlling past and current disposal of municipal waste,
nonhazardous industrial waste and construction debris. The information
concerning such past disposal activities may lead to unreported RCRA and
CERCLA sites.
Areas of potential facility noncompliance must be documented as
thoroughly as possible. Document copies and photographs should be included
for future reference and evidence.
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Information obtained during the audit inspection will be used, with
the applicable regulations, licenses, approvals, etc., to evaluate the
facility's waste handling activities and determine status of compliance as
outlined in the following sections.
General Facility RCRA Status
The investigator should determine if the facility has notified EPA of
its hazardous waste handling activities (waste generation, transport, treat-
ment, storage or disposal) and if it has a required EPA identification number
(40 CFR 262.12).
For treatment, storage or disposal (TSD) facilities, [Section 2010(e)
of RCRA], determine if a RCRA Part A application has been submitted (40 CFR
270). Determine the permit status of the facility. Has the RCRA Part B
permit application been requested by, submitted to (if so, when), or reviewed
by EPA; has the facility been issued a Part B permit? If a permit has been
issued, the facility is subject to the specific permit provisions and
requirements of the permit and 40 CFR, Part 264. If no RCRA Part B permit
has been issued, the facility is subject to the interim status provisions
of 40 CFR, Part 265. In both cases, the facility may also be subject to
requirements of State/local regulations, licenses and approvals. Before
the audit, the investigator should determine if State/local regulations
apply. The investigator should have a copy of the current Part A application
(with amendments), the Part B application (if available) and the RCRA permit
(if applicable) during the audit so that the accuracy of the Part A and
Part B applications can be verified and compliance with the permit determined.
Hazardous Waste Generating Facilities
Generators, as defined in 40 CFR 260.10, are subject to the require-
ments of 40 CFR 262 and any additional State/local regulations, licenses
and approvals. In general, determine if the waste is properly identified
and the waste containers are properly marked, including the date when waste
accumulation was initiated. Also ensure the generator has obtained an EPA
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34
identification number (40 CFR 262.12). Because generators are not authorized
to accumulate waste longer than 90 days or 180 or 270 days for conditionally
exempt small quantity generating, it is important to determine length of
accumulation of all waste in storage.* Determine if the generator has main-
tained signed hazardous waste shipping manifests for waste shipped offsite
for the last 3 years and evaluate if these manifests were completed/ handled
properly (40 CFR 262, Subpart B). The facility's "Contingency Plan and
Emergency Procedures," "Preparedness and Prevention Plans," and "Personnel
Training Program" should also be evaluated (40 CFR 265, Subparts C and D
and CFR 265.16).
The investigator should determine whether the facility is properly
managing containers and tanks (40 CFR 265, Subparts I and J). All containers
onsite during the audit should be inspected for general condition (leaks,
corrosion, etc.) and proper packaging, labeling and marking (40 CFR 262,
Subpart C). The investigator should determine if all storage area inspec-
tions are performed regularly and documented.
The investigator should determine whether the generator manages hazard-
ous wastes that are burned for energy recovery and therefore subject to the
requirements of 40 CFR Part 266, Subparts D or E. If these requirements
are applicable, the generator is either a marketer or burner and must satisfy
the respective notification, storage and recordkeeping requirements. If
used oil that meets specification [§266.40(e)] is burned, only the analysis
and recordkeeping requirements of §266.43(b)(l) and (6) need to be met.
The investigator should review the checklist of Table F-14 [Appendix F]
before conducting the audit.
The investigator should also determine if the generator is managing a
waste subject to the land disposal prohibitions of 40 CFR Part 268. If the
waste is a restricted waste the investigator should determine whether the
If a generator has stored waste for more than 90 days [262.34(a), (b)
and (c)], it is subject to the Federal requirements of 40 CFR 265 and
40 CFR 270 or the comparable State requirements in authorized states.
Small quantity generators are subject to different requirements
[261.5, 262.34(d)t (e) and (f)].
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35
waste is restricted as a result of constituent concentrations and if one of
several extensions or exemptions apply. Generators of restricted wastes
are required to:
Determine whether they generate restricted wastes
Determine waste traceability groups and treatment standards
Determine whether waste exceeds treatment standards
Provide for appropriate treatment and/or disposal
Satisfy documentation, recordkeeping, notification, certification,
packaging and manifesting requirements.
Meet applicable requirements if the generator is or becomes a
TSDF. Appendix F also contains checklists for specific land dis-
posal requirements placed on generators.
Hazardous Waste Transporters
Hazardous waste transporters, as defined in 40 CFR 260.10, are required
to comply with the Federal requirements of 40 CFR 263 and any State/local
regulations, licenses and approvals. The transporter must also meet applic-
able requirements of 49 CFR 171-179.
The investigator should ensure that the transporter has obtained an
EPA identification number (40 CFR 263.11) and is completing and handling
the waste shipping manifests properly, including maintaining a copy of each
one for at least 3 years. If a transporter stores waste in a transfer
facility (40 CFR 263.12), determine length of storage of waste at the facil-
ity.* Any containers of waste in a storage facility should be inspected
Under Federal regulations (40 CFR 263.12), transporters can only store
waste at a transfer facility 10 days or less. State regulations may
differ.
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36
for proper condition and proper marking and labeling. If loaded trucks are
present, proper placarding should be checked.
Treatment. Storage and Disposal Facilities
The investigator should determine if present facility operations and
types and quantities of waste handled are the same as those authorized by
the original Part A permit application (and approved amendments) or the
final RCRA permit, as applicable. Ensure that the TSD facility has obtained
an EPA identification number (40 CFR 265.11/264.11). Operations at all TSD
facilities must be evaluated for compliance with the general requirements
of Subparts A through H of either 40 CFR 265 or 40 CFR 264. The investigator
should determine which of these subparts are applicable to each facility.
Compliance evaluation of a facility includes, but is not limited to,
evaluation of:
Waste Analysis Procedures (40 CFR 265/264.13, Subpart B)
written waste analysis plan
analytical/sampling procedures
recordkeeping
Facility Security (40 CFR 265.14)
access to the facility
display of warning signs
General Facility Audit Requirements (40 CFR 265.15/264)
written audit plan
remedial action
recordkeeping
Personnel Training (40 CFR 265.16/264)
written training plan
recordkeeping
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Facility Preparedness and Prevention (40 CFR 265/264, Subpart C)
general maintenance
communications/alarm system
fire control equipment
arrangements with local authorities
Contingency Plan and Emergency Procedures (40 CFR 265/264, Subpart D)
written contingency plan
availability of emergency coordinator
Manifest System. Recordkeeping (40 CFR 265/264, Subpart E)
use, handling and maintenance of shipping manifests
facility operating record (including waste characterization/
quantity, waste tracking, disposal and treatment location)
Groundwater Protection (40 CFR 265/264, Subpart F)
monitoring system (well location, design, operation)
sampling and analysis
data recordkeeping
characterization of site hydrogeology
preparation, evaluation and response
waiver request (if any)
detection vs. assessment monitoring
corrective action plan(s)
Closure and Post-Closure (40 CFR 265/264, Subpart G)
written closure/post-closure plans
Financial Requirements (40 CFR 265/264, Subpart H)
financial assurance
closure costs
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When evaluating facility compliance with regulations requiring written
plans (waste analysis, facility audits, contingency, training, closure),
copies of the plans should be obtained for an in-depth analysis of their
adequacy. By observing actual facility operations, such as self-inspection
records, the investigator should determine whether or not the facility is
actually following the specifics of these plans. In many cases, a facility
may have used several modifications of these plans, all with different effec-
tive dates. All current plans must be evaluated. Out-of-date plans should
also be reviewed for compliance with applicable regulations in effect at
the time those plans were in place.
The investigator must also evaluate facility records required to be
maintained by the regulations (operating records, manifests, waste analysis
results, audit records, etc.). The extent of this records review must be
sufficient to determine patterns of compliance/noncompliance with the
recordkeeping requirements. Although it may be desirable to review all
available records (from the time the regulations became effective), in the
most comprehensive audit, this is not always possible due to the number of
documents and time and resource constraints. In these cases, the investi-
gators must decide on the minimum number of records necessary to identify
patterns of compliance/noncompliance. There may also be a necessity to
limit the time frame for documents review. Documentation (investigators'
notes, copies of documents and photographs) of noncompliance must be
obtained for future use and evidence.
The investigator should determine whether the TSD is handling a waste
subject to the land disposal prohibitions of 40 CFR Part 268 and as set
forth in the revisions to 40 CFR Parts 260 to 265 and 270 (51 Federal
Register 40636 et seg). Appendix F contains a checklist that highlights
specific requirements placed on storage, treatment and disposal facilities
regarding the land disposal prohibitions. A review of the checklist before
the inspection is recommended because the requirements are dependent upon
the type of facility being inspected.
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In addition to the general requirements specified above, the
investigators must evaluate the facility for compliance with the specific
requirements for each type of hazardous waste management activity. This
includes, but is not limited to, an evaluation of:
Use and Management of Containers (40 CFR 265/264, Subpart I)
general operation procedures
condition of containers (leaks, corrosion, etc.)
marking and labeling of containers
compatability of waste with containers
management of containers
audit records
Tanks (40 CFR 265/264, Subpart J)
general operating procedures
compatability of waste with tank construction material
integrity of tanks
corrosion rate of tank materials
compatability between waste treated/stored in tanks
audit records
closure procedures
Surface Impoundments (40 CFR 265/264, Subpart K)
general operating procedures
freeboard levels
protective coverings of dikes
audit records
closure/post-closure provisions
Waste Piles (40 CFR 265/264, Subpart L)
general operating procedures
protection from wind dispersal of waste
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compatability between various wastes within the pile
run-on protection
runoff characteristics, containment and handling
closure/post-closure provisions
Land Treatment (40 CFR 265/264, Subpart M)
general operating procedures
runoff/run-on control provisions
waste analysis
waste loading
protection of food chain crops
unsaturated zone (zone of aeration) monitoring
recordkeeping
closure/post-closure provisions
Landfills (40 CFR 265/264, Subpart N)
general operating procedures
run-on/runoff control and management
protection from wind dispersal
recordkeeping
required treatment of ignitable/reactive waste and liquid material
(prior to landfill ing)
leachate collection/handling procedures
closure/post-closure provisions
Incinerators (40 CFR 265/264, Subpart 0)
general operating procedures
waste analysis
startup/shutdown procedures
monitoring/control equipment and provisions (combustion and emis-
sion control)
audits
closure procedures
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Thermal Treatment (40 CFR 265, Subpart P)
general operating conditions
waste analysis
monitoring/control equipment and procedures (combustion and emis-
sion controls)
open burning/waste explosives procedures
audits
closure
Other Chemical/Physical Treatment (40 CFR 265/264, Subpart Q)
general operating procedures
waste analysis
monitoring/control equipment
audits
closure
Toxic Substances
This section describes those specific aspects of toxic chemical control
that are addressed by the Toxic Substances Control Act (TSCA) and its
associated rules and regulations (40 CFR Parts 702 to 799).
The regulation of toxics under TSCA is subdivided into two components
for Agency enforcement program management purposes.
"Chemical control" covers enforcement aspects related to specific
chemicals regulated under Section 6 of TSCA, such as polychlor-
inated biphenyls (PCBs), chlorofluorocarbons (CFCs) and asbestos.
"Hazard evaluation" refers to the various recordkeeping, reporting
and marketing submittal requirements specified in Sections 5, 8,
12 and 13 of TSCA; although, some elements of what might be termed
"chemical control" are also addressed in these sections. Sections 12
and 13 of TSCA, which pertain to chemical exports and imports,
respectively, will not be covered in this manual due to their
special nature and unique requirements.
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Prior to discussing TSCA activities* at a facility, the investigator
must present appropriate facility personnel with copies of the following
two TSCA audit forms [Appendix H]:
Notice of Inspection - Shows purpose, nature and extent of TSCA audit
TSCA Inspection Confidentiality Notice - Explains a facility's rights
to claim that some or all of the information regarding toxic substance
handling at the facility is to be considered as TSCA Confidential
Business Information (CBI)
Before leaving the site, the following two forms must be completed, as
appropriate.
Receipt for Samples and Documents - Itemizes all documents, photos and
samples received by the investigator during the audit.
Declaration of CBI** - Itemizes the information that the facility claims
to be TSCA CBI
Inspectional considerations related to the chemical control and hazard
evaluation compliance are given in the following two subsections.
Chemical Control
Although the controlled substances most frequently encountered during
multi-media investigations are polychlorinated biphenyls (PCBs), the inves-
tigator should determine if other regulated toxic substances are present at
* All personnel handling material claimed as Confidential Business Infor-
mation under TSCA must be cleared for access to that material in accord-
ance with Agency procedures. An annual update is required.
** These forms are generally completed during the closing conference.
During the opening conference, facility personnel should be made aware
that the latter form is used to itemize TSCA CBI material.
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the facility. Currently these include metal working fluids (Part 747),
fully halogenated chlorofluoroalkanes (40 CFR 762) and asbestos (40 CFR
763); additional toxic substances may be regulated in the future. Because
the probability of finding PCBs and PCB items at a facility is greater than
finding other TSCA-regulated substances, the following discussion is directed
toward an evaluation of compliance with proper PCB and PCB item handling
procedures. Should other TSCA-regulated substances be present, the investi-
gator should consult the regulations for appropriate requirements.
Management of PCBs/PCB items is regulated under 40 CFR 761. In general,
these regulations address recordkeeping, marking and labeling, audits,
storage and disposal. The investigator is encouraged to use TSCA audit
checklists, such as the ones provided in Appendix I.
Facilities which store and/or dispose of PCBs and PCB items often have
EPA-issued Letters of Approval which contain facility operating and record-
keeping requirements in addition to those specified in 40 CFR 761. The
investigator must obtain a copy of these approvals and any subsequent noti-
fications to evaluate facility compliance.
In general, the compliance evaluation includes obtaining and reviewing
information from Federal, State and local regulatory agency files; inter-
viewing facility personnel regarding material handling activity; examining
facility records and visually auditing material handling units.
Recordkeeping (40 CFR 761, Subpart J)
Every facility using or otherwise handling PCBs/PCB items is required
to maintain specific records. Records regarding use, storage, transport
and disposal must be reviewed for accuracy, completeness and compliance
with applicable regulations. This includes a determination of the accuracy
of the PCB inventory and annual document (40 CFR 761.180). An inventory
checklist is provided in Appendix I. In general, the investigator should
visually inspect all PCB items in service and in storage to verify
completeness/accuracy of the records. Also, current records should be
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compared with past records to ensure that all items have been adequately
accounted for.
Marking/Labeling (40 CFR 761, Subpart C)
Observe PCB and PCB suspect units in service and in storage and deter-
mine if items are properly marked/labeled.
Audits (Items in Use or in Storage for Reuse) [40 CFR 761.30(a)(l)]
Review records to determine if items in use or stored for reuse have
been inspected, as required. Determine whether all audit and maintenance
records are being maintained, as required. Review these records to deter-
mine if problems identified during the internal audit are being addressed
properly. PCB items should be inspected to verify that they are not leaking.
Servicing and Use of Various PCB Items (40 CFR 761.30)
Determine whether the facility is servicing PCB items or using PCBs
for any of the following uses: heat transfer agent, hydraulic fluid,
research purposes, in capacitors or in any other special authorized use
category listed in 40 CFR 761.30. If PCBs are used in these services,
determine if their use complies with the special requirements for each use
category.
Storage for Disposal (40 CFR 761.65)
Identify all areas where PCBs/PCB items are stored for disposal.
Determine the adequacy of these storage facilities, including proper mark-
ing, walls, roof, continuous floor with containment (ensure that contain-
ment is adequate) and location (above/below 100-year floodplain). Visually
inspect all items in storage to determine if they are being stored properly
(i.e., non-leaking, marked/labeled and dated with storage date). Review
storage area records (including the required PCB annual document) for
accuracy and adequacy. Determine whether or not the storage area is being
properly inspected and that remedial action is being taken, as required.
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If PCBs/PCB items are stored outside of the designated storage
facilities (i.e., temporary storage), determine whether (1) items are
leaking, (2) liquids stored in containers have greater than 500 ppm PCBs
[liquids with PCB concentrations greater than 500 ppm cannot be stored in
temporary areas (except for transformers)] and (3) items are properly marked
and labeled and show dates removed from service and placed into storage
(determine length of time items have been in temporary storage). If liquids
with PCBs have been or are being stored in temporary storage, evaluate the
required Spill Prevention Control and Countermeasure (SPCC) plan, as described
in 40 CFR 112, for adequacy and accuracy. If the facility stores, in any
permanent or temporary storage areas, liquid PCBs in any containers larger
than those described in 40 CFR 761.65(c)(6), the facility SPCC plan must
also be reviewed/evaluated.
As of October 1, 1985, installation of PCB transformers (which have
been placed into storage for reuse or have been removed from another loca-
tion) in or near commercial buildings, is prohibited.
Disposal
Incineration (40 CFR 761.70)
If the facility incinerates PCBs/PCB items, determine if the facility
has applied for and received the required EPA approval. Determine if the
facility meets required monitoring, control and recordkeeping requirements
of the approval and of 40 CFR 761. Observe monitoring and control equip-
ment and review the required records (including the PCB annual document)
for adequacy and accuracy and to ensure that the incinerator meets the
specified feed rate, combustion criteria and combustion efficiency. Eval-
uate the required annual document for completion and accuracy.
Landfill ing (40 CFR 761.75)
If the facility landfills PCBs/PCB items, determine if the facility
has applied for and received the required EPA and State approvals. Deter-
mine if the facility meets the specified siting, liner and geological
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46
conditions. Determine if the landfill is in the 100-year floodplain. If
so, inspect for proper water diversion structures. Evaluate general land-
fill operating conditions to determine if waste is being handled properly
(as stated in the EPA Approval Letter and/or 40 CFR 761). This includes,
but is not limited to, evaluation if (1) incompatibles are being land-
filled with the PCBs/PCB items, (2) the facility is maintaining required
records (including concentration of liquids disposed of and three-dimensional
burial coordinates of waste), (3) site security is accurate, (4) liquids
are solidified prior to disposal and (5) transformers and other PCB items
are being properly prepared (drained/triple-rinsed, etc.) prior to disposal.
Evaluate the required PCB annual document for adequacy and accuracy.
Determine if the facility is monitoring surface water, groundwater and
leachates, as required by 40 CFR 761.75(b)(6). This includes identifying,
locating and evaluating operation of groundwater monitoring wells, and
reviewing groundwater sampling and analysis procedures and sample analysis
results (for adequacy of monitoring frequency and proper chemical constit-
uents). Determine, by audit and records review, if the facility has an
operating leachate collection system. Review laboratory data on leachate
characterization to determine if leachate is being adequately monitored and
disposed of properly.
Hazard Evaluation
Establishment of compliance with the various hazard evaluation aspects
of TSCA is best accomplished through review and evaluation of the record-
keeping, reporting and submitted data required by the various regulatory
components of Sections 5 and 8. In general, Section 5 addresses "new
chemicals" (i.e., those not in commercial production when TSCA was passed
in 1977) and Section 8 generally provides for control of "existing chemi-
cals" (i.e., those chemicals that were in commercial production during 1977).
Much of the information to be obtained and reviewed under these two
sections of TSCA will likely be, or have been, declared as TSCA Confidential
Business Information (CBI) by company officials, and thus, requires special
control procedures.
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The glossary, [Appendix J, Table J-l] and 40 CFR Parts 703 to 723
should be consulted for an explanation of TSCA terms and definitions,
respectively. The following listing summarizes the different compliance
objectives of the key TSCA Section 5 and 8 components. Specific checklists
for the important areas to review, evaluate and document for each pertinent
section are given in Appendix J, Table J-2.
1. Premanufacture Notification (PMN)
a. Verify that commercial manufacture or import did not begin prior
to the 90-day review date and not more than 30 days before the
Notice of Commencement (NOC) date. Verify that no NOC has been
submitted if commercial manufacture or import has not begun.
b. Verify the accuracy and documentation of the contents of the PMN
itself.
c. Verify that all commercially manufactured or imported chemicals
are either on the TSCA 8(b) inventory, covered by an exemption or
not subject to TSCA.
2. Research and Development (R&D) Exemption
a. Verify that the recordkeeping and notification requirements are
being met for all R&D chemicals.
b. Verify that "Prudent Laboratory Practices" and hazardous data
searches are adequately documented.
3. Test Marketing Exemption (TME)
a. Verify that the conditions spelled out in the TME application are
being met, particularly with respect to dates of production,
quantity manufactured or imported, number of customers and use(s).
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b. Verify that the TME recordkeeping requirements are being met.
4. Low Volume Exemption (LVE) and Polymer Exemption (PE)
a. Verify that specific contents of the exemption application are
being met, and that all test data have been submitted.
b. For an LVE, verify that the 1,000-Kg limit per 12-month period
has not been exceeded. For a PE, assure that the chemical struc-
ture and monomer composition(s) are accurate.
c. Verify that recordkeeping requirements for both LVEs and PEs are
being met.
5. 5(e)/5(f) Order, Rule or Injunction
a. Verify that all conditions of the order, rule or injunction are
being followed, including use of protective equipment, glove
testing, training and recordkeeping.
b. If testing trigger is specified, verify production volume and
status of testing activity.
6. Significant New Use Rule (SNUR)
a. Verify that no commercial production has occurred prior to the
90-day review date.
b. Verify that SNUR notices have been submitted for all applicable
manufactured, imported or processed chemicals.
c. Verify technical accuracy of SNUR submittal and completeness of
required recordkeeping.
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7. Bona Fide Submittals
Determine the commercial production (or import) status and R&D
history of those bona fide chemicals not found on the confidential
8(b) inventory. Verify findings against applicable PMN, TME or other
exemption.
8. Section 8(a) Level A PAIR (or CAIR) Report
a. Determine if Preliminary Assessment Information Rule (PAIR) reports
have been submitted for all 8(a) Level A listed chemicals manu-
factured or imported by the facility.
b. Verify the accuracy of submitted PAIR information, particularly
the reported figures for total production volume and worker expo-
sure levels.
NOTE: The Comprehensive Assessment Information Rule (CAIR)
will be addressed when this rule becomes final.
9. Section 8(b) Inventory Update Rule (INUR)
a. Verify the accuracy of the information submitted in response to
the INUR.
b. Determine that required information was submitted by the
prescribed deadline for all chemicals subject to INUR.
10. Section 8(c) Recordkeeping
a. Determine if the facility has a Section 8(c) file and that
allegations of significant health and environmental harm on record
are properly filed and recorded.
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b. Determine that all applicable allegations have been recorded and
filed.
c. Determine if the facility has a written Section 8(c) policy and
if the policy includes outreach to the employees.
11. Section 8(d) Reporting
Determine if copies (or lists) of all unpublished health effects
studies have been submitted by manufacturers, importers and processors
for any Section 8(d) listed chemical.
12. Section 8(e) Reporting
a. Verify that all Section 8(e) substantial risk reports to the Agency
were accurate and submitted within the required time frames.
b. Verify that all substantial risk incidents and/or test results
have been reported to EPA.
c. Determine that the company has an adequate written policy addres-
sing Section 8(e), and that it relieves employees of individual
liability.
Pesticides
Pesticides are regulated by the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA).
The following list is for use in conjunction with the checklist in
Appendix K and specific storage/use/disposal requirements found on pesticide
labels. FIFRA requires a written notice of inspection and written receipt
for samples and documents collected.
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Determine types and registration status of all pesticides produced,
sold, stored and used at the facility, particularly if any are
restricted or experimental use pesticides.
Determine use(s) of each pesticide.
Determine certification status of facility/handlers.
Verify who certifies facility/pesticide handlers (EPA, State,
DOD).
Determine if commercial or private application.
If restricted-use pesticides are used, check if pesticide
applicators are authorized to use these pesticides.
Check expiration dates on licenses/certificates.
Review applicable records.
Check previous audit records and complaints.
Check application records.
Check restricted-use pesticide records (must be kept at least
2 years). Document suspect violations accordingly.
Check inventory records.
Check training records.
Check equipment repair records.
Inspect storage, mixing/loading and container disposal areas.
Check bulk storage areas for compliance with Federal/State
rules.
Check location, ventilation, segregation, shelter and house-
keeping of pesticide storage/handling areas. Check security,
fire protection and warning signs, as may be required by
State regulations.
Check mixing equipment/procedures for reducing handlers'
exposures to pesticides.
Check for safety equipment/procedures/use.
Check container cleanup and disposal procedures.
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Pesticide waste disposal
Check to see that pesticides are disposed of in accordance
with applicable label and RCRA requirements.
Water Supply
Public drinking water supply systems (i.e., serve at least 25 people)
are regulated by the Safe Drinking Water Act (SDWA).
The water supply checklist in Appendix L should be reviewed for those
items of information necessary to determine monitoring requirements for
water supply systems and whether or not the system can be reasonably expected
to routinely provide safe potable water. Many facilities purchase their
potable water supply from a nearby municipality. If no further treatment
is provided (e.g., chlorination by the facility), the facility may not be
directly covered by the SDWA. Nevertheless, the facility does have a
responsibility to assure that their actions do not result in contamination
of the municipal water supply (e.g., through cross-connection). The audit
team should be alert to these possibilities.
There are five classes of injection wells defined in the Underground
Injection Control program (40 CFR Part 146.5). Generally, they can be
defined as:
Class I - Industrial, Municipal or Hazardous waste disposal beneath
the lowermost underground source of drinking water (USDW)
Class II - Oil and gas related wells used for produced fluid disposal,
enhanced recovery
Class III - Mineral extraction wells
Class IV - Hazardous or radioactive waste disposal above or into a
USDW
Class V - All other wells
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The UIC Checklist in Appendix M should be used when inspecting a
facility operating injection wells. The SDWA requires a written notice of
inspection.
CLOSING CONFERENCE
A post-audit or wrap-up conference should be held with the facility.
This should be limited to specific findings of the audit (e.g., factual
observations and measurements). The audit team's main function is to observe
and evaluate compliance. Any official notices of noncompliance, however,
are provided by the Regional or State office upon final review of the report
and other pertinent findings. Therefore, statements on compliance status,
legal effects or enforcement consequences of noncompliance should not be
discussed with the facility or its operating personnel. It is unacceptable
to recommend a particular consulting firm, if asked, but it is proper to
advise that professional societies be contacted.
During the closing conference, there can be a discussion of the audit
team's preliminary findings. This discussion may include observed devia-
tions from prescribed or recommended procedures. Facility officials should
be informed of any leaks, spills or other problems that require immediate
attenton; however, no instructions or orders that repairs be undertaken
should be issued. At this meeting, the investigators may request additional
data, questions may be asked and answered, requested permit changes and
process modifications are noted and necessary receipts are given. The
investigators should make a final review of checklists and field notes before
the conclusion of the visit. Field notes, taken by the investigators at
the time of the field investigation, may not be turned over to the company
officials under any circumstances.
For TSCA, FIFRA, RCRA and CERCLA activities, written receipts are given
for samples and documents taken. A Declaration of Confidential Business
Information (TSCA CBI) shall include a list of items declared confidential
by an authorized facility official, and procedures should be explained if
the company desires to make any subsequent declaration.
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THE AUDIT REPORT AND FOLLOWUP
The audit report organizes and coordinates all evidence gathered during
the audit in a usable manner. It is the compilation of factual information
and professional judgment resulting from the compliance audit. Information
in the report must be accurate, relevant, complete, objective and clear.
The report serves to record the procedures used in gathering the data and
gives factual observations and evaluations from the audit. It is the basis
for any followup activities/enforcement that might occur.
Many different formats are possible for the audit report. A typical
report could be structured in two main sections; the Executive Summary and
the Technical Report. The Executive Summary establishes the objectives of
the audit and presents succinct conclusions which are supported by relevant
findings; recommendations are made if appropriate. Topics in the summary
may include: (a) Overall environmental compliance, (b) adequacy of pollu-
tion control and treatment systems, (c) adequacy of operation and maintenance
practices, (d) multi-media waste abatement needs and (e) followup action.
The Technical Report comprehensively describes the inspection by dis-
cussing such topics as facility history, investigation methods, sampling
programs, and specific problem areas. The Technical Report correlates audit
findings with the conclusions contained in the Executive Summary.
Where potentially criminal activities are discovered during the audit,
the audit team and Regional office should promptly notify the Office of
Criminal Investigations in Denver or the Regional/Special-Agent-in-Charge
for a determination on whether a criminal investigation should be initiated.
Administrative/civil enforcement (including informal negotiations with the
company) should be held in abeyance, pending a decision on the appropriate-
ness of a criminal referral or additional field investigation.
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27. Office of Water Enforcement, Enforcement Division, 1977. NPDES
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1-79-001, EPA-340/l-79-001a, EPA-340/1-80-001.
30. Pesticides and Toxic Substances Enforcement Division, January 1980.
Toxic Substances Control Act Inspection Manual, Volume One: TSCA Base
Manual, Washington, D.C., Environmental Protection Agency.
31. Pesticides and Toxic Substances Enforcement Division, March 1981, Toxic
Substances Control Act Inspection Manual, Volume Two: PCB Inspection
Manual, Washington, D.C., Environmental Protection Agency.
32. A.D. Schwope, et al., March 1985, Guidelines for the Selection of
Chemical Protective Clothing, 2nd Edition. Cambridge, MA, Arthur D.
Little, Inc.
33. Technology Transfer, 1978. Handbook, Industrial Guide for Air Pollu-
tion Control, Environmental Protection Agency, EPA-625/6-78-004.
34. Thomas H. Truitt, et al., 1971. Environmental Audit Handbook - Basic
Principles of Environmental Compliance Auditing, Washington, D.C.,
Wald, Harkrader & Ross and Resource Planning Corp.
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ACRONYMS
AQCR - Air Quality Control Region
BAT - Best Available Technology
BATEA - Best Available Technology Economically Achievable
BCT - Best Conventional Pollution Control Technology
BMP - Best Management Practices
BOD - Biochemical Oxygen Demand
BPT - Best Practicable Control Technology Currently Available
Btu - British thermal units
CAA - Clean Air Act
CBI - Confidential Business Information
CEM - Continuous Emission Monitoring
CERCLA - Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (Superfund)
CFR - Code of Federal Regulations
COD - Chemical Oxygen Demand
CWA - Clean Water Act [aka: Federal Water Pollution Control Act (FWPCA)]
DCO - Document Control Officer
DO - Dissolved Oxygen
DOT - Department of Transportation (Federal)
EPA - Environmental Protection Agency (Federal)
ESP - Electrostatic Precipitators
FIFRA - Federal Insecticide, Fungicide and Rodenticide Act
FIP - Final Implementation Plan
F/M - Food to Microorganism Ratio
HSWA - Hazardous Solid Waste Amendments
HW-FW - Half Wave/Full Wave (electrical distribution)
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INVR - Inventory Updat Rule
ITC - Interagency Testing Committee
LAER - Lowest Achievable Emission Rate
MLVSS - Mixed Liquor Volatile Suspended Solids
N/A - Not Applicable
NAA - Non-Attainment Areas
NAAQS - National Ambient Air Quality Standards
NEIC - National Enforcement Investigations Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NOC - Notice of Commencement
NPDES - National Pollutant Discharge Elimination System
NSPS - New Source Performance Standards
OECM - Office of Enforcement and Compliance Monitoring
O&M - Operation and Maintenance
ORM - Other Regulated Material
OSHA - Occupational Safety and Health Act
PAIR - Preliminary Assessment Information Rule
PCB - Polychlorinated Biphenyls
PMN - Premanufacture Notice
POTW - Publicly-Owned Treatment Works
PSD - Prevention of Significant Deterioration
QA/QC - Quality Assurance/Quality Control
RA - Regional Administrator
RCRA - Resource Conservation and Recovery Act (enacted as amendment to the
Solid Waste Disposal Act)
R&D - Research and Development
SARA - Superfund Amendments and Reauthorization Act
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SDWA - Safe Drinking Water Act (enacted as amendment to the Public Health
Service Act)
SIP - State Implementation Plan
SNUR - Significant New Use Rule
SPCC - Spill, Prevention, Containment and Countermeasures
SPDES - State Pollutant Discharge Elimination System
SSE - Stationary Source Enforcement
THE - Test Marketing Exemption
TOC - Total Organic Carbon
T-R - Transformer-Rectifier
TSCA - Toxic Substances Control Act
TSD - Treatment, Storage and Disposal
TSDF - Treatment, Storage and Disposal Facilities (hazardous waste)
TSS - Total Suspended Solids
UIC - Underground Injection Control
U.S.C. - United States Code
USDW - Underground Source of Drinking Water
VEO - Visible Emissions Observation
WLA/TMDL - Wasteload Allocation/Total Maximum Daily Load
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APPENDICES
A SUMMARY OF POLLUTION CONTROL LEGISLATION
B SAFETY PLAN
C EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G CERCLA CHECKLIST
H TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
I TSCA PCB CHECKLIST
J TSCA SECTIONS 5 AND 8 CHECKLIST
K PESTICIDE CHECKLIST
L WATER SUPPLY CHECKLIST
M UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
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APPENDIX A
SUMMARY OF POLLUTION CONTROL LEGISLATION
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A-l
Appendix A
SUMMARY OF POLLUTION CONTROL LEGISLATION
This appendix is a synopsis of the Federal approach to environmental
regulation, EPA enforcement remedies and a summary of each of the major
pollution control acts: the Clean Air Act (CAA), the Clean Water Act (CWA),
the Resource Conservation and Recovery Act (RCRA), the Comprehensive Envi-
ronmental Response, Compensation and Liability Act (CERCLA/Superfund), the
Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA), and the Safe Drinking Water Act (SDWA). Because
these laws and the regulations promulgated thereunder typically are very
complex and continually are being modified, the investigator should care-
fully review the specific provisions which apply to the operations of the
facility before conducting an inspection.
GENERAL FEDERAL APPROACH TO ENVIRONMENTAL REGULATION
National standards are established to control the handling, emission,
discharge and disposal of harmful substances. Waste sources must comply
with these national standards whether the programs are implemented directly
by the EPA or delegated to the States. In many cases, the national stand-
ards are applied to sources through permit programs which control the release
of pollutants into the environment. The EPA establishes the Federal stand-
ards and requirements and approves State programs for permit issuance.
The States can set stricter standards than those required by Federal
law. Some of the larger programs which have been delegated by the EPA to
qualifying States are the National Emissions Standards for Hazardous Air
Pollutants (NESHAP), the Prevention of Significant Deterioration (PSD) per-
mits under the CAA, the Water Quality Standards and the National Pollution
Discharge Elimination System (NPDES) programs under the CWA, the Hazardous
Waste Program under RCRA, and the Drinking Water and Underground Injection
Control (UIC) programs under the SDWA. Conversely, TSCA is administered
entirely by the Federal government.
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EPA ENFORCEMENT OPTIONS
1. Issuance of an Administrative .Compliance Order, sometimes preceded
by a Notice of Violation*. A Compliance Order will specify the
nature of the violation and give a reasonable time for compliance.
The order, if violated, can lead to enforcement action pursuant
to the civil and/or criminal process of environmental laws.
2. Issuance of an administrative complaint for civil penalties.
Parties named in such complaints must be given notice and an
opportunity for a hearing on the alleged violations before a
penalty can be assessed by EPA.
3. Under certain statutes (e.g., SDWA) EPA may take whatever action
is necessary to protect the public health, in emergency situations,
without first obtaining a judicial order.
4. EPA generally may go directly to Federal court seeking injunctive
relief or a civil penalty without using administrative procedures.
EPA also may obtain an emergency restraining order halting activ-
ity alleged to cause "an imminent and substantial endangerment"
or "imminent hazard", to the health of persons.
5. EPA may go directly to Federal court seeking criminal sanctions
without using administrative procedures. Criminal penalties are
available for "knowing" or for "willful" violations.
In addition, EPA can also "blacklist" a company or party that fails to com-
ply with the CAA or CWA by preventing it from entering into Federal con-
tracts, loans and grants. In. cases where the party had been convicted of
certain criminal offenses under.the CAA or CWA, Federal agencies are
expressly prohibited from entering into contracts, etc., with that entity.
A concise written statement with factual basis for alleging a viola-
tion and a specific reference to each regulation, act, provision or
permit term allegedly violated
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CLEAN AIR ACT
The Clean Air Act (CAA) calls for the EPA to establish national
ambient air standards. These standards are expressed as concentrations of
designated hazardous pollutants called National Ambient Air Quality Stand-
ards (NAAQS). These standards are to be achieved by the States through
State Implementation Plans (SIPs). EPA also sets the following national
air emission standards: New Source Performance Standards (NSPS), National
Emissions Standards for Hazardous Air Pollutants (NESHAP) and standards
governing mobile sources of air pollution (including motor vehicle fuels).
Moreover, special programs have been developed for prevention of significant
deterioration (PSD) in clean air areas and for stringent controls in non-
attainment areas (NAAs).
The SIP provides emission limitations, schedules and timetables for
compliance by stationary sources, as well as transportation control plans
for mobile sources. The act focuses upon "major" stationary sources or
major modifications of existing sources. Major sources are defined as
sources which generally emit more than 100 tons/year of a designated
pollutant.
National Ambient Air Quality Standards/State Implementation Plans
EPA designates harmful pollutants and publishes criteria documents
which discuss potential harmful effects of those pollutants. The Agency
then sets primary and secondary ambient air standards (CAA, Section 109).
Primary standards are intended to protect the health of the population,
whereas, secondary standards are meant to protect the esthetic values of the
environment.
Seven pollutants have been established as harmful and standards estab-
lished. These pollutants include: sulfur dioxides, particulates, carbon
monoxide, ozone, hydrocarbons, nitrogen oxides and lead. These standards
are implemented through SIPs (CAA, Section 110).
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EPA has designated 247 Air Quality Control Regions (AQCRs). These
have been rated as either "clean" or "non-attainment" for each of the cri-
teria pollutants. SIPs must assure attainment of NAAQS by prescribed
dates. SIPs must meet Federal requirements, but each State may choose its
own mix of emissions for stationary and mobile sources to meet the NAAQS.
Control procedures may include stationary source emission limits, transpor-
tation plans, preconstruction review of new sources, NAA and PSD permits
for construction of new sources, monitoring and inspection and testing of
vehicles. Other measures may include emissions charges, closing and relo-
cation of plants, changes in operations and ways to reduce vehicular
traffic including taxes, staggered work hours and mass transportation.
The CAA prescribes that no SIP will be adopted without a public hearing,
and sources affected by the SIP are expected to participate.
New Source Performance Standards
NSPS are established for specific pollutants in industrial categories,
based upon adequately demonstrated control technology. Many States have
been delegated the authority to enforce NSPS. When a State does not have
the authority, EPA enforces NSPS in that state. Waivers from NSPS for up
to 7 years may be obtained, the purpose of which is to encourage use of
innovative technological systems (CAA, Section 111).
National Emissions Standards for Hazardous Air Pollutants
Section 112 of the CAA defines hazardous air pollutants as those for
which no air quality standard is applicable but which are judged to increase
mortality or serious irreversible or incapacitating illness. NESHAP stand-
ards are based on health effects with strong reliance on technological capa-
bilities. They apply to both existing and new stationary sources. The
five substances on the NESHAP list for which there are effective regula-
tions currently are: benzene, beryllium, asbestos, mercury and vinyl
chloride. The NESHAP program can be delegated to any qualifying State
(CAA, Section 112).
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Prevention of Significant Deterioration
The purpose of PSD is to avoid significant future degradation of the
nation's clean air areas. A clean air area is one where the air quality is
better than the ambient primary or secondary standard. Designation is
pollutant specific so that an area can be non-attainment for one pollutant
but clean for another. PSD applies only to new and modified sources in
clean air areas. Clean air areas are divided into three categories: Class
I - only minor air quality degradation allowed; Class II - moderate degra-
dation; and Class III - substantial degradation. In no case would PSD
allow air quality to deteriorate below secondary air quality standards.
"Baseline" is the existing air quality for the area at the time the
first PSD is applied for. "Increments" are the maximum amount of deteri-
oration that can occur in a clean air area over baseline. Increments
in Class I areas are smaller than for Class II and Class II increments
are smaller than Class III areas. For purposes of PSD, a major emitting
source is one of 26 designated categories which emits or has the poten-
tial to emit 100 tons/year of the designated air pollutant. A source
that is not within the 26 designated categories is a major source if it
emits more than 250 tons/year.
New sources are required to obtain permits before construction. The
permit describes the level of control to be applied and what portion of the
increment may be made available to that source by the State (CAA, Part C).
Non-Attainment Areas (NAA)
Non-attainment/areas are those which are not in compliance with
national air quality standards. New construction in an NAA is prohibited
unless the SIP has been amended and approved by EPA to reflect the follow-
ing conditions:
1. Total allowable emissions for the area will be less than emis-
sions from existing sources.
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A-6
2. The new source must comply with the lowest achievable emission
rate (LAER).
3. All other sources within the State owned by the subject Company
are in compliance.
4. The SIP is being carried out for the area.
The applying source in an NAA must, therefore, obtain a greater than
1:1 reduction of the pollutant or pollutants for which the area has been
designated non-attainment. The source must undergo a relatively stringent
pre-construction review.
Emission offsets from existing sources may need to be obtained, espe-
cially if the new source will have emissions that would exceed the allowance
for the NAA. In these situations, the source would need to obtain enforce-
able agreements from other sources in the NAA or from its own plants in the
NAA.
Emission reductions can also be "banked" by an existing source to per-
mit future new source growth. Banked offsets may be sold or traded to other
sources.
Emission Standards for Mobile Sources/Fuel Standards
Section 202 of the CAA directs EPA to regulate air pollutants emitted
by motor vehicles which "cause, or contribute to, air pollution which may
reasonably be anticipated to endanger public health or welfare." In response,
the Agency has set standards governing motor vehicle emissions of carbon
monoxide, hydrocarbons, oxides of nitorgen and particulates. These stand-
ards have given rise to the .emission control systems that first appeared in
automobiles in the early 1970s. The CAA generally prohibits the removal
(or rendering inoperative) of any emission control device that was installed
by the vehicle manufacturer in order to meet the applicable emission stand-
ards. Most states have enacted similar laws enforcing this prohibition
and/or have incorporated such prohibitions as part of SIP.
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The CAA provides EPA with the authority to control or prohibit the use
of fuels which pose a public health risk or which "impair to a significant
degree the performance of any emission control device or system." The
Agency's regulations are based upon both of these rationales. (The best
example of this are the regulations governing the lead content of gasoline.)
Enforcement of the fuel standards is achieved through a combination of
Federal and State efforts, and is based, in part, upon SIP provisions and/or
State laws.
CLEAN WATER ACT (FEDERAL WATER POLLUTION CONTROL ACT)
Through the 1950s and 1960s, emphasis was on the States setting ambient
water quality standards and developing plans to achieve these standards.
In 1972, the Federal Water Pollution Control Act was significantly amended.
These changes emphasized a new approach, combining water quality standards
and effluent limitations (i.e., technology-based standards). The amendments
called for compliance by all point-source discharges with the technology-
based standards. A strong Federal enforcement program was created and sub-
stantial monies were made available for construction of sewage treatment
plants. The Federal Water Pollution Control Act was amended in 1977 to
address toxic water pollutants and in 1987 to refine and strengthen priori-
ties under the Act as well as enhance EPA's enforcement authority. Since
the 1977 amendments, the Federal Water Pollution Control Act has been com-
monly referred to as the Clean Water Act (CWA).
State Water Quality Standards and Water Quality Management Plans
Section 303 of the CWA authorizes the States to establish ambient water
quality standards and water quality management plans. If national technol-
ogy standards are not sufficient to attain desired stream water quality,
the State shall set maximum daily allowable pollutant loads (including toxic
pollutants) for these waters and, accordingly, determine effluent limits
and compliance schedules for point sources to meet the maximum daily allow-
able loads.
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The National Pollutant Discharge Elimination (NPDES) Program
This program was established by Section 402 of the CWA and, under it,
EPA and approved States have issued more than 50,000 NPDES permits. Permits
are required for all point sources from which pollutants are discharged to
navigable waters. An NPDES permit is required for any direct discharge
from new or existing sources. Indirect discharges through POTWs are regu-
lated under a separate program (see discussion of pretreatment standards
below). In 1979 and 1980, the permit program was revised and one of the
new features was the use of Best Management Practices (BMPs) on a case-by-
case basis to minimize the introduction of toxic and hazardous substances
into surface waters. BMPs are industry practices used to reduce secondary
pollution (e.g., raw material storage piles shall be covered and protected
against rain and runoff). BMPs do not have numerical limits and, therefore,
are different from effluent limits.
Section 304 of the CWA sets restrictions on the amount of pollutants
discharged at industrial plant outfalls. Amounts are usually expressed as
weight per unit of product (i.e., 0.5 lb/1,000 Ib product manufactured).
The standards are different for each industry. Effluent guidelines are
applied to individual plants through the NPDES permit program.
There are three levels of technology for existing industrial sources:
Best Practicable Control Technology (BPT), Best Conventional Technology
(BCT) and Best Available Technology Economically Achievable (BAT). Under
the 1972 Act, BPT was intended to be put in place by industry in 1977 and
BAT in 1983. These timetables have been modified by subsequent amendments.
The 1987 CWA Amendments modified the compliance deadlines for the
following:
BPT limits requiring a substantially greater level of control
based on a fundamentally different control technology
BAT for priority toxic pollutants
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BAT for other toxic pollutants
BAT for nonconventional pollutants
BCT for conventional pollutants
For each technology the new deadline requires compliance "as expeditiously
as practicable, but in no case later than 3 years after the date such limi-
tations are promulgated. . .and in no case later than March 31, 1989."
New Source Performance Standards (NSPS) are closely related to BAT for
existing sources but are not quite the same. NSPS are different for each
industrial category. These standards must be achieved when the new indus-
trial source begins to discharge. NSPS permits will be effective for a
period of 10 years vs. 5 years or less for the BPT and BAT-type permits.
This 10-year protection insulates against change in BCT or BAT requirements
but does not hold against Section 307(a) toxic pollutant standards or against
"surrogate" pollutants that are used to control hazardous or toxic pollutants.
A permit application must be made. Adequate information must be sub-
mitted including basic facility descriptions, SIC codes, regulated activ-
ities, lists of current environmental permits, descriptions of all outfalls,
drawings, flows, treatment, production, compliance schedules, effluent char-
acteristics, use of toxics, potential discharges and bio-assay toxicity
tests performed.
Applicants must conduct analytical testing for pollutants for BOD,
COD, TOC, TSS, ammonia, temperature and pH. The applicant, if included
within any of the 34 "primary industry" categories, must sample for all
toxic metals, cyanide and phenols given in EPA Application Form 2C and for
specified organic toxic pollutant fractions.
The applicant must list hazardous substances believed to be present at
the industrial plant. Testing is not required but analytical results must
be provided, if available.
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NPDES Permit
The NPDES permit, issued by EPA or the State, enforces Federal effluent
limitations promulgated for individual industrial categories; NSPS; toxic
effluent standards; State water quality standards under Section 303 of the
CWA, if any are applicable and hazardous substances otherwise regulated
under Section 311 of the CWA that may be incorporated under the NPDES permit
instead. Permit elements include the amount of pollutants to be discharged
expressed in terms of average monthly and maximum daily loads; compliance
schedules, i_f applicable standards cannot be met now and monitoring, test-
ing and reporting requirements.
Routine Non-compliance Reports - The Discharge Monitoring Form
The Discharge Monitoring Report (DMR) gives a summary of the dis-
charger's records on a monthly or quarterly basis for flow measurement,
sample collection and laboratory analyses. Noncompliance reports must be
submitted quarterly on the cause of noncomplying discharges, period of non-
compliance, expected return to compliance and plans to minimize or eliminate
recurrence of incident.
Emergency Reporting
Health: The EPA shall be notified within 24 hours of noncompli-
ance involving discharge of toxic pollutants, threat to drinking
water or injury to human health.
Bypass: Noncompliance due to intentional diversion of waste shall
be reported promptly to the permitting agency and may be permis-
sable if essential to prevent loss of life or serious property
damage.
Upset: Temporary noncompliance due to factors beyond the reason-
able control of the permittee shall be promptly reported to the
agency.
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The 1987 CWA Amendments establish a schedule for the regulation of
municipal and industrial stormwater discharges under NPDES permits. Ini-
tially, (before October 1, 1992), only major dischargers and those who are
significant contributors of pollutants will be required to obtain permits.
Pretreatment Standards for Indirect Discharges to Publicly-Owned Treatment
Works
Coverage
New and existing industrial users who discharge to POTWs are subject
to general and categorical pretreatment standards. The categorical stand-
ards are primarily directed to control of toxic pollutants in specific
industries.
Requirements
General Pretreatment Standards
Prohibit fire or explosion hazards, corrosivity, solid or viscous
obstructions, "slug" discharges, and heat sufficient to inhibit
biological activity at POTWs
Categorical Standards
Standards to be expressed as concentration limits or mass
weight per unit of production.
Source must be in compliance 3 years after promulgation of
standards.
Variances can be obtained for fundamentally different factors
or if industrial pollutants are consistently being removed
by POTW.
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Reports
Users must provide appropriate agency (EPA, State or POTWs having
approved pretreatment programs) with basic information, SIC code,
average and maximum daily discharge, characteristics or pollu-
tants, applicable standards and certification whether standards
are being met and, if not, what pretreatment is necessary and a
compliance schedule.
Monitoring, Sampling and Analysis
Users shall submit sampling data for each regulated pollutant in
discharge.
Progress Reports
Reports and information shall be submitted at 6-month intervals.
Non-point Source Pollution Control
Section 208 of the CWA provides for control of non-point source pollu-
tion and directs States to establish planning bodies to formulate area-wide
pollution control plans. NPDES permits cannot be issued where the permit
may conflict with an approved Section 208 plan.
The 1987 CWA Amendments require States or EPA to develop nonpoint
source management programs under Section 319.
Dredge or Fill Discharge Permit Program
Section 404 of the CWA regulates the discharge of dredged or fill mate-
rial into waters of the United States. Dredged material is excavated or
dredged from a water body. Fill material is that material used to replace
water with dry land. The Section 404 permit program is administered by the
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U.S. Army Corps of Engineers. EPA provides guidelines for the issuance of
permits by the Corps of Engineers. States may assume responsibility for
portions of the program.
Discharge of Oil and Hazardous Substances
Section 311 of the CWA prohibits discharges of oil or hazardous sub-
stances in quantities that may be harmful to waters of the United States.
The appropriate Federal agency must be immediately notified of any spill of
a "reportable quantity." Section 311 provides for cleanup of spills and
requires plans for preparation of Spill Prevention, Control and Counter-
measures (SPCC) plans.
Over 300 substances have been defined as hazardous under Section 311
and each of these substances has a "reportable quantity" (40 CFR, Parts 116
and 117, 1980).
A person or corporation who properly notifies the Agency of the dis-
charge of a reportable quantity of oil or hazardous substance is immune
from criminal prosecution but is liable for civil penalties. Additionally,
those who cause the spill are liable for the costs of cleanup and removal.
If the Federal government must clean up the spill, the discharger of the
spill is liable for cleanup costs. There are maximum liability limits,
depending upon the type of facility and spill. These limits do not apply
if the discharge resulted from willful negligence or willful misconduct of
the owner.
Certain discharges of oil and hazardous material that flow from a
point source may be excluded from Section 311 liability if, during prepara-
tion of the NPDES permit covering that facility, conditions are added to
the permit to avoid the occurrence of a spill.
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RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA)*
RCRA was signed on October 21, 1976 and subsequently amended in 1980
and 1984. The 1984 amendments to RCRA brought about dramatic changes in
the coverage required by the Act. The first in a series of regulations
restricting the land disposal of hazardous wastes have been promulgated.
Regulations also have been proposed which will include expanded coverage in
such areas as waste oil, underground tanks, etc. The Act primarily deals
with current and future waste handling activities; however, one section of
the act (Section 7003), addresses problems which may have arisen prior to
1976. The 7003 provision allows EPA to take action against persons conduct-
ing past and current activities that may present "an imminent or substantial
endangerment to health or to the environment." The 1984 amendments also
provide for corrective actions against contamination resulting from past
releases of hazardous waste even without an imminent hazard. A review of
the Act and the implementing regulations by the inspector is imperative
before conducting an inspection, due to these changes.
Solid wastes, if land disposed, are regulated through State programs
under Subtitle D of RCRA. Hazardous solid wastes are subject to regulation
in their generation, transport, treatment, storage and disposal under Sub-
title C of RCRA. Subtitle C of the statute authorizes a comprehensive
Federal program to regulate hazardous wastes from generation to ultimate
disposal. A waste is hazardous under Subtitle C if it is listed by EPA as
hazardous, if it exhibits hazardous characteristics (corrosivity, reacti-
vity, ignitability and extraction procedure toxicity) and if not delisted
or excluded from regulation. There are special management provisions for
hazardous wastes created by small quantity generators and hazardous wastes
that are intended to be reused or recycled.
Solid waste includes garbage, refuse and sludge, other solid, liquid,
semi-solid or contained gaseous material which is discarded, has served its
43 U.S.C. §§6901 et seq. and Solid Waste Disposal Act amendents of
1980, P.L. 96-482, 94 Stat. 2334.
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intended purpose or is a mining or manufacturing byproduct. Most industrial
and commercial byproducts can qualify as a solid waste. Exclusions from
solid waste include domestic sewage, irrigation return flows, materials
defined by the Atomic Energy Act, in situ mining waste and NPDES point
sources.
Solid wastes excluded from regulation as hazardous solid wastes are
household waste; crop or animal waste; mining overburden and wastes from
processing and benefication of ores and minerals; flyash, bottom ash waste,
slag waste and flue gas emission control waste and drilling fluids from
energy development. A waste can be "delisted" from the hazardous waste
listing or excluded for other reasons. Some materials intended to be reused
or recycled are not fully regulated as solid/hazardous wastes, while others,
depending upon the type of waste generated and the recycling process used,
are fully regulated.
Statutory Restrictions/Prohibitions
November 8, 1984 - The placement of any bulk liquid hazardous
waste in salt domes, salt bed formations, underground mines or
caves is prohibited until the facility receives a permit.
May 8. 1985 - The landfilling of bulk or noncontainerized liquid
hazardous waste or free liquids contained in hazardous waste is
prohibited.
November 8, 1985 - The placement of any nonhazardous waste liquid
in a landfill operating under interim status or a permit, is pro-
hibited unless the only reasonable alternative is a landfill or
unlined surface impoundment which will not endanger groundwater
drinking sources. See Section 3004(b)(3) for full graphics.
November 8, 1986 - The land disposal of solvents (codes F001
through F005) and dioxins (codes F020 through F023) is prohibited
unless human health and the environment will not be endangered.
(Wastes generated by Superfund and RCRA enforcement actions are
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not affected until November 8, 1988.) See final rule, 51 Federal
Register 40572 (November 7, 1986), to be codified at 40 CFR
Part 268, with conforming amendments at 40 CFR Parts 260, 261,
262, 264, 265, 270 and 271.
July 8, 1987 - Land disposal of wastes listed in Section 3004(d)(2)
(the "California list") is prohibited unless human health or the
environment is not endangered (Wastes generated by Superfund and
RCRA enforcement actions not affected until November 8, 1988.)
See proposed rule, 57 Federal Register 44714 (December 11, 1986).
May 8, 1985 - New units, lateral expansions and replacement of
existing units at interim status waste piles are to have single
liners and leachate collection systems.
New units, lateral expansions and replacement of existing units
at interim status landfills and surface impoundments are to have
double liners and leachate collection systems.
August 8, 1988 - Deep well injection of certain wastes is prohib-
ited unless deemed safe by EPA. See Section 3004(d)(2) and (e)(2)
for list of wastes.
List of Hazardous Wastes
Hazardous waste streams from specific major industry groups and some
generic sources (40 CFR, Part 261, Subpart D, §261.31 and 261.32) and well
over 200 toxic commercial chemical wastes (i.e., discarded commercial chemi-
cal products and chemical intermediates) are included on the list of hazard-
ous wastes (40 CFR §261.33). If a commercial chemical substance is on the
list, its off-spec species is also considered hazardous when discarded, as
are spill residues. Some of the listed wastes are acutely toxic and are
more closely regulated, than other hazardous wastes. See e.g., 40 CFR
§§261.33(e), 261.5(e) and 261.7(b)(3).
(06/87)
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A-17
Special Management Provisions
Small Quantity Generators
Small quantity generators are those that generate less than 1,000
kg per month of hazardous waste. There are two classes of small
quantity generators:
1. Generators of between 100 and 1,000 kg per month that are
subject to most of the requirements of 40 CFR Part 262 which
apply to fully regulated generators, except that they are
allowed to accumulate up to 6,000 kg of hazardous waste and
to store waste for up to 180 to 270 days.
2. Generators of less than 100 kg per month that are exempt
from regulation under 40 CFR Part 262 so long as they do not
accumulate greater than 1,000 kg of hazarous waste, properly
identify their wastes and comply with the less stringent
waste treatment, storage and/or disposal requirements of 40
CFR §261.5.
Note that the classification of the generator is a function of
the total wastes generated, not each waste stream. In addition,
for acutely toxic wastes, if more than 1 kg per month of waste or
100 kg per month of spill residues are generated, all quantities
of that waste are fully regulated.
Recycling or Reuse
The type of waste generated and/or the recycling process employed
will determine whether recycled/reused materials are a solid/
hazardous waste. Some of these materials are not considered solid
wastes, some are solid wastes but not hazardous wastes, while
others are hazardous but are not subject to full regulation, and
still other of these materials are both solid and hazardous wastes
(06/87)
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A-18
that are fully regulated. The circumstances surrounding the
apparent recycling/reuse of waste materials should be thoroughly
documented during and inspection.
Requirements for Generators*
Identification - Hazardous wastes must be identified by list,
testing or experience and assigned waste identification numbers.
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State. An EPA identification
number must be received.
Manifest System - Implement the manifest system and follow proce-
dures for tracking and reporting shipments. Beginning Septem-
ber 1, 1985, a waste minimization statement is to be signed by
the generator [see RCRA Section 3002(b)].
Packing - Implement packaging, labeling, marking and placarding
requirements prescribed by DOT regulations (40 CFR, Parts 172,
173, 178 and 179).
Annual Report - Submittal required March 1 using EPA Form 8700-13.
Exception Reports - When generator does not receive signed copy
of manifest from designated TSDF within 45 days, the generator
sends Exception Report to EPA including copy of manifest and letter
describing efforts made to locate waste and findings.
Accumulation - When waste is accumulated for less than 90 days,
generator shall comply with special requirements including con-
tingency plan, prevention plan and staff training (40 CFR, Part
265, Subparts C, D, J and 265.16).
40 CFR Part 262
(06/87)
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A-19
Permit for Storage More Than 90 Days - If hazardous wastes are
retained onsite more than 90 days, generator is subject to all
requirements applicable to TSDFs and must obtain a RCRA permit.
Requirements for Transporters*
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State. Receive EPA identification
number.
Manifest System - The transporter must fully implement the mani-
fest system. The transporter signs and dates manifest, returns
one copy to generator, assures that manifest accompanies waste,
obtains date and signature of TSDF or next receiver and retains
one copy of the manifest for himself.
Delivery to TSDF - The waste is delivered only to designated TSDF
or alternate.
Record Retention - Transporter retains copies of manifest signed
by generator, himself and accepting TSDF or receiver and keeps
these records for a minimum of 3 years.
Discharges - If discharges occur, notice shall be given to National
Response Center. Appropriate immediate action shall be taken to
protect health and the environment and a written report shall be
made to the DOT.
40 CFR Part 263
(06/87)
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A-20
Requirements for Treatment, Storage or Disposal Facilities (TSDFs)*
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State.
Interim Status - These facilities include TSDFs; onsite hazardous
waste disposal; onsite storage for more than 90 days; in transit
storage for greater than 10 days and the storage of hazardous
sludges, listed wastes, or mixtures containing listed wastes
intended for reuse. Interim status is achieved by:
Notification (see above)
Being in existence on November 19, 1980 or on the date of statu-
tory or regulatory changes which require the facility to have a
permit
Filing a Part A by the date specified in the regulation
covering the facility (40 CFR, Parts 261, 264 or 265)
Interim Status Facility Standards - The following standards and
requirements shall be met.
General information (Subpart B)
Waste analysis plan
Security
Inspection plan
Personnel training
Handling requirements
Preparedness and prevention
Contingency planning and emergency procedures (Subparts C
and D)
Records and reports
Manifest system
Operating logs
Annual and other reports (Subpart E)
40 CFR Parts 264 and 265
(06/87)
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A-21
Groundwater Monitoring (Subpart F)
Closure and post-closure plans (Subpart G)
Financial requirements (Subpart H)
Containers, tanks, surface impoundments, piles (Subparts I,
J, K, L)
Land treatment, landfills, incinerators, thermal treatment,
chemical, physical and biological treatment (Subparts M, N,
0, P, Q)
Underground injection (Subpart R)
Permit - In order to obtain a permit:
Facilities with interim status must file a Part B RCRA permit
application when directed to do so by EPA or an authorized
State and final facility standards must be met or the facil-
ity must be on an approved schedule to meet those standards.
The EPA-authorized States are to issue permits or deny the application
by November 8, 1988 for land disposal facilities; by November 8, 1989 for
incinerators; and by November 8, 1992 for other facilities. The following
is a statutory schedule for termination of interim status.
Interim Status Unless Part B
Facility Terminates Submitted
Land Disposal November 1985 November 1985
Incinerators November 1989 November 1986
Other facilities November 1992 November 1988
New facilities and facilities which do not qualify for
interim status are to receive a RCRA permit before construc-
tion can begin or a hazardous waste can be handled.
Used/Recycled Oil - Used oil burned for energy recovery is regu-
lated under 50 CFR Part 266. Although a number of parallel
-------
A-22
off-spec due to flashpoint, metal or halogen content. Additional
regulations governing used/recycled oil are being developed.
Underground Storage Tanks - The 1984 amendments also will cause
certain underground storage tanks to be regulated. By May 8,
1986, all owners of underground tanks are to notify the designated
State or local agency of the existence of the tank and specify
the following:
Age
Size
Type
Location
Uses
For tanks taken out of operation after January 1, 1974, the owner
is to also notify the designated State or local agency of the
existence of the tank and specify the following:
Date the tank was taken out of operation
Age at that time
Size
Type
Location
Type and quantity of substance left in the tank
Rules comprehensively regulating these tanks were proposed
April 17, 1987, 52 Federal Register 12662.
COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION AND LIABILITY ACT
(SUPERFUND)
The Superfund Act was enacted December 11, 1980. The Federal govern-
ment is authorized to clean up toxic or hazardous contaminants at closed
and abandoned hazardous waste dumps and the government is permitted to
(06/87)
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A-23
recover cost of this cleanup and associated damages by suing the responsible
parties involved. Cleanup monies will come out of a "superfund" created by
taxes on chemicals and hazardous wastes.
The act provides that, when there is a release of hazardous substance,
either real or threatened, the parties who operated the vessel or facility
which created the release are liable for the containment, removal, remedial
action, response and injury damages to natural resources under Section 107(a).
The act also establishes limitations on liability.
If claims are presented to the liable parties but are not satisfied,
the act then allows claims to be reimbursed from the Superfund.
Regulatory provisions under Sections 102 and 103 of the act require
that release of hazardous substances into the environment be reported unless
the release is in accordance with an established permit. Spills of any
"reportable quantity", established pursuant to regulations promulgated under
the Act, must be reported.
All owners or operators of any facility handling and disposing of haz-
ardous substances or that has handled hazardous substances in the past
(including previous owners and operators) were required to inform the EPA
Administrator by June 1981 of their facility activities unless they have a
RCRA permit or have been accorded "interim status". Failure of notifica-
tion is a crime and, if the party knowingly fails to provide these data,
they are not entitled to the prescribed limits and defenses of liability.
On October 17, 1986, the Superfund Act was amended under the Superfund
Amendments and Reauthorization Act (SARA). Those amendments provide manda-
tory schedules for the completion of various phases of remedial response
activities, establish detailed cleanup standards and generally strengthen
existing authority to effect the cleanup of superfund sites.
[An integral part of SARA, but not an amendment to the Superfund Act,
is the Emergency Planning and Community Right-to-Know Act of 1986. It
addresses the handling of extremely hazardous chemicals and requires:
(06/87)
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A-24
(1) Emergency planning, (2) emergency notification, (3) community
right-to-know reporting and (4) an emissions inventory.]
TOXIC SUBSTANCES CONTROL ACT (TSCA)
TSCA regulates existing and new chemical substances. TSCA applies
primarily to manufacturers, distributors, processors and importers of chem-
icals. TSCA can be divided into five parts as follows:
Inventory and Pre-manufacture Notification
EPA has published an inventory of existing chemicals. A substance
that is not on this list is considered "new" and requires Pre-manufacture
Notification (PMN) to EPA at least 90 days before the chemical can be manu-
factured, shipped or sold (TSCA, Section 5). If the EPA does not make a
declaration within 90 days to restrict the product, then full marketing can
begin and the chemical is added to the inventory. In addition, a manufac-
turer may obtain a test marketing exemption and distribute the chemical
before the 90-day period has expired. Conversely, EPA, in response, may
reject PMN for insufficient data, negotiate for suitable data, prohibit
manufacture or distribution until risk data are available or pending develop-
ment of a Section 6 rule, completely ban the product from the market or
review the product data for an additional 90 days.
Testing
Under TSCA, Section 4, EPA can require product testing of any substance
which "may present an unreasonable risk of injury to health or to the envi-
ronment." Some testing standards are proposed, but no test requirements
for specific chemicals are yet in effect.
Reporting and Recordkeeping
TSCA, Section 8(a) deals with general reporting. The "first tier"
rule (PAIR) now in effect is a short form seeking production and exposure
(06/87)
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A-25
data on over 2,300 existing chemicals. A "second tier" rule is expected to
obtain more detailed data on a relatively small group of chemicals that may
become priority candidates for regulation.
Section 8(c) calls for records of significant adverse effects of toxic
substances on human health and the environment. It requires that records
of alleged adverse reaction be kept for a minimum of 5 years.
Section 8(d) allows EPA to require that manufacturers, processors and
distributors of certain listed chemicals (designated under 40 CFR 716.13)
submit to the EPA lists of health and safety studies conducted by, known
to or ascertainable by them. Studies include individual files, medical
records, daily monitoring reports, etc.
Section 8(e) requires action upon discovery of certain data. Any per-
son who manufacturers, processes or distributes a chemical substance or
mixture, or who obtains data which reasonably supports the conclusion that
their chemical presents a substantial risk of injury to health or to the
environment, is required to notify EPA immediately. Personal liability can
only be limited if the Company has a response plan in effect.
Regulation Under Section 6
EPA can impose a Section 6 rule if there is reason to believe that the
manufacture, processing, distribution or use or disposal of a chemical
substance or mixture causes, or may cause, an unreasonable risk of injury
to health or to the environment. Regulatory action can range from labeling
requirements to complete prohibition of the product. Section 6 rules are
currently in effect for several chemicals including PCBs. A Section 6 rule
requires informal rulemaking, a hearing, and a cost-benefit analysis.
Imminent Hazard
This is defined as a chemical substance or mixture causing an imminent
and unreasonable risk of serious or widespread injury to health or the
(06/87)
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A-26
environment. When such a condition prevails, EPA is authorized by TSCA,
Section 7, to bring action in U.S. District Court. Remedies include seizure
of the chemical or other relief including notice of risk to the affected
population or recall, replacement or repurchase of the substance.
FEDERAL INSECTICIDE. FUNGICIDE AND RODENTICIDE ACT (FIFRA)
A pesticide is defined as any substance intended to prevent, destroy,
repel or mitigate pests. FIFRA requires registration of all pesticides,
restricts use of certain pesticides, authorizes experimental use permits
and recommends standards for pesticide applicators and the disposal and
transportation of pesticides.
Pesticides are registered for 5 years and classified for either general
or restricted usage. Restricted means that they are to be applied either
by or under the direct supervision of a certified applicator. Pesticides
must be labeled and specify ingredients, uses, warnings, registration number
and any special use restrictions. Regulations also specify tolerance levels
for certain pesticide chemicals in or on agricultural commodities. These
limits apply to 310 different compounds and residue tolerances range from 0
to 100 ppm. A few pesticides are also regulated as toxic pollutants under
Section 307(a) of the CWA and by Primary Drinking Water Standards under the
SDWA.
SAFE DRINKING WATER ACT
The SDWA of 1974 was established to provide safe drinking water to the
public. Both primary and secondary drinking water standards have been set
by EPA regulations which apply to water after treatment by public drinking
water systems. National Interim Primary Drinking Water Regulations were
adopted in 1975 to protect public health (40 CFR, Part 141). Regulations
covering radionuclides were added in 1976. Regulations for trihalomethanes
were promulgated in 1979. Secondary regulations were established in 1979
as guidelines to States to protect the non-health-related qualities of
drinking water. The 1986 amendments to the SDWA: (1) establish a
(06/87)
-------
A-27
mandatory schedule, requiring the promulgation of primary drinking water
regulations for 83 contaminants, (2) prohibit the use of lead in public
water systems, (3) provide civil and criminal penalties for persons who
tamper with public water systems and (4) require closer scrutiny of State
programs, including the direct enforcement of drinking water standards, if
necessary.
The SDWA also provides for protection of underground sources of drink-
ing water. Final regulations have been issued whereby States are to estab-
lish Underground Injection Control (UIC) waste disposal programs to ensure
that contaminants in water supplies do not exceed National Drinking Water
Standards and to prevent endangerment of any underground source of drinking
water. Injection wells are divided into five classes for regulatory han-
dling. Construction and disposal standards are established for the per-
mitting of Class I to III wells. Class I and Class IV wells are subject to
RCRA requirements. Class IV wells are those used by generators of hazardous
or radioactive wastes to dispose of hazardous wastes into formations within
one-quarter-mile of an underground source of drinking water. New Class IV
wells are prohibited and existing Class IV wells must be phased out within
6 months after approval or promulgation of a UIC program in the state.
There are numerous State regulatory requirements affecting groundwater which
should be consulted by multi-media compliance inspectors. In addition, the
1986 amendments to SDWA strengthen EPA's enforcement authority for UIC
programs.
(06/87)
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APPENDIX B
SAFETY PLAN
-------
B-l
Appendix B
NEIC - SAFETY PLAN
Project No.
Approval OHS Designee Date
Project Coordinator Date
Branch Chief Date
On Scene Coordinator Date
Activities
(Note: If sampling is involved, the primary objective is to
minimize the risk of personnel exposure to hazardous materials.)
Hazards Anticipated*
Toxic Vapors: Yes No
If yes, list 1. 2.
3. 4.
5.
TLV 1. 2.
3. 4.
5.
Explosivity: Yes _ No
Radioactivy: Yes _ No
Op Depletion: Yes _ No
Buried Utilities: Yes No
If yes, specify:
* If unknown, mark UK.
-------
B-2
Appendix B (cont.)
Level of Protection Recommended
Level A Type SCBA
Level B Type Cartridge
Level C
Level D
Enhancement
Contractor Equipment Required
Contractor Personnel
Number and Skills
Medical Monitoring Yes No
Respirator/SCBA Qualified (if required for activity)
Yes No
Site Monitoring Procedures (Equipment to be used)
Decontamination/Pi sposal Procedures
-------
Comments
B-3
Appendix B (cont.)
Emergency Contacts*
Project No.
Medical:
Location
Phone No.
Phone No.
Fire:
Phone No.
Police:
Phone No.
.(Hospital)
(EMT)
* Post at site.
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APPENDIX C
EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
-------
C-l
Appendix C
PHOTOGRAPHS
When movies, slides or photographs are taken which visually show the
effluent or emission source and/or any monitoring locations, they are num-
bered to correspond to logbook entries. The name of the photographer, date,
time, site location and site description are entered sequentially in the
logbook as photos are taken. A series entry may be used for rapid sequence
photographs. The photographer is not required to record the aperture set-
tings and shutter speeds for photographs taken within the normal automatic
exposure range. Special lenses, films, filters or other image enhancement
techniques must be noted in the logbook. Chain-of-custody procedures
depend upon the subject matter, type of film and the processing it requires.
Film used for aerial photography, confidential information or criminal
investigations require chain-of-custody procedures. Adequate logbook nota-
tions and receipts may be used to account for routine film processing.
Once developed, the slides or photographic prints shall be serially numbered
corresponding to the logbook descriptions and labeled.
MICROFILM
Microfilm is often used to copy documents that are or may later become
TSCA Confidential Business Information (CBI). This microfilm must be
handled in accordance with the TSCA CBI procedures (see Appendix I for
additional information and forms). Table C-l is the NEIC procedure for
processing microfilm containing TSCA CBI documents.
-------
C-2
Table C-l
NEIC PROCEDURE FOR MICROFILM
PROCESSING OF TSCA CBI DOCUMENTS
1. Kodak Infocapture AMD 1454 microfilm shall be used for filming all
TSCA CBI documents.
2. Obtain packaging materials and instructions from the NEIC Document
Control Officer or Assistant, including:
Preprinted shipping labels
Chain-of-custody records
Custody seals
Double envelopes
Green TSCA cover sheets
TSCA loan receipt
3. Prepare each roll of microfilm for shipment to the processor.
Enclose the film in double-wrapped packages
Place a green TSCA cover sheet in the inner package
Place a TSCA loan receipt in the inner package
Complete a Chain-of-Custody Record, place the white copy in the
inner package and keep the pink copy for the field files
Seal inner package with a custody seal and sign and date it
Mark the inner package:
"TO BE OPENED BY ADDRESSEE ONLY
TSCA CONFIDENTIAL BUSINESS INFORMATION"
4. Ship the film via Federal Express to the Springfield, Virginia Federal
Express office and instruct that it is to be held for pickup. USE
SIGNATURE SECURITY SERVICE ONLY.
This practice requires the courier to sign, the station personnel to
sign and the delivery courier to sign.
Instruct the Springfield Federal Express office to hold the shipment
for pickup and to notify:
Mr. Vern Webb
U.S. EPA/EPIC
Vint Hill Farms Station
Warrenton, Virginia 22186
(730) 557-3110
5. Telephone Mr. Webb and inform him of the date shipped, the number of
rolls of film, the air bill number and your phone number.
6. Telephone the NEIC Document Control Officer or Assistant and inform
them.
7. Telephone Mr. Webb the following day and verify film quality to deter-
mine if repeat microfilming is necessary.
8. The pink copy of the Federal Express form, with the shipment cost and
project number indicated, must be turned in to the Assistant Director,
Planning and Management. If you are in the field for an extended
period of time (3 weeks or more), the pink copies must be mailed to
NEIC.
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APPENDIX D
AIR POLLUTION CHECKLISTS
-------
D-l
Appendix D
NEW SOURCE PERFORMANCE STANDARDS (NSPS)*
Sources Covered
NSPS includes new and modified industrial stationary source categories
for which construction was started after the standard was proposed. The
categories are listed in Table D-l.
Requirements
Notification to Agency
Agency notified before construction Yes No
before startup Yes No
before testing Yes No
Emissions Testing
Performance tests of emission control equipment
conducted using prescribed reference methods Yes No
within 180 days of startup Yes No
written results sent to Agency Yes No
Monitoring
Continuous emission monitoring (CEM) to be conducted for 10 cate-
gories [Table D-2]
CEM recordkeeping kept in permanent form suitable
for inspection Yes No
Records of continuous monitoring system
maintained, including actual data Yes No
performance specification test reports Yes No
calibration checks Yes No
adjustments and maintenance Yes No
Control equipment operating parameters (flow
rates, pressure drops, currents, etc.) Yes No
Reports/Records
Excess reports filed Yes No
Date and time when control equipment was
repaired, adjusted or inoperative. Yes No
Notification given to State/local agency Yes No
40 CFR, Part 60, 1980
(06/87)
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D-2
Table 0-1
SOURCES SUBPART (40 CFR Part 60)
EFFECTIVE DATE OF STANDARD AND POLLUTANTS SUBJECT TO NSPS
Source
Fossil-fuel-fired steam generators
Municipal incinerators
Portland cement plants
Nitric acid plants
Sulfuric acid plants
Asphalt concrete plants
Petroleum refineries
Storage vessels for petroleum liquids
Secondary lead smelters
Secondary brass and bronze ingot
production plants
Iron and steel plants (basic
oxygen furnace)
Sewage treatment plants (incinerators)
Primary copper smelters
Primary zinc smelters
Primary lead smelters
Primary aluminum reduction plants
Phosphate fertilizer industry
(listed as five separate
categories)
Coal preparation plants
Ferro-alloy production facilities
Steel plants (electric arc furnaces)
Kraft pulp mills
Glass plants
Grain elevators
Metal furniture surface coating
Stationary gas turbines
Lime plants
Lead acid battery plants
Metallic mineral processing plants
Auto and light-duty truck, surface
coating operation
Phosphate rock plants
Ammonium sulfate plants
Graphic arts industry
Pressure sensitive tape manufacturing
Appliance surface coating
Metal coil surface coating
Asphalt roofing plants
Synthetic organic chemicals
Beverage can surface coating
Bulk gasoline terminal
Vinyl/urethane coating
Petroleum refineries
Synthetic fiber plants
Petroleum dry cleaners
Onshore natural gas processing plants
Onshore natural gas processing plants
Nonmetallic mineral processing plants
Wool fiberglass insulation manufactur-
ing plants
Subpart
D
Da
E
F
G
H
I
J
K
Ka
L
M
N
0
P
Q
R
S
T U V
W X
Y
Z
AA
BB
CC
DD
EE
EE
HH
KK
LL
MM
NN
PP
QQ
RR
SS
TT
UU
VV
WW
XX
FFF
GGG
HHH
JJJ
KKK
LLL
000
ppp
Effective Date
August 17, 1971
September 18, 1978
August 17, 1971
August 17, 1971
August 17, 1971
August 17, 1971
June 11, 1973
June 11, 1973
June 11, 1973
May 18, 1978
June 11, 1973
June 11, 1973
June 11, 1973
June 11, 1973
October 16, 1974
October 16, 1974
October 16, 1974
October 23, 1974
October 22, 1974
October 24, 1974
October 21, 1974
October 21, 1974
September 24, 1976
June 15, 1979
August 3, 1978
November 28, 1980
September 24, 1976
May 3, 1977
January 14, 1980
August 24, 1982
October 5, 1979
September 21, 1979
February 4, 1980
October 28, 1980
December 30, 1980
December 24, 1980
January 5, 1981
November 18, 1980;
May 26, 1981
January 5, 1981
November 26, 1980
December 17, 1980
January 18, 1983
January 4, 1983
November 23, 1982
September 21, 1984
June 24, 1985
October 1985
August 1, 1985
February 25, 1985
Pollutant
Particulate matter, sulfur dioxide,
nitrogen oxides
Particulate matter
Particulate matter
Nitrogen oxides
Sulfur dioxide, acid mist (sulfuric acid)
Particulate matter
Particulate matter, carbon monoxide, sulfur
dioxide
VOC
Particulate matter
Particulate matter
Particulate matter
Particulate matter
Particulate matter, sulfur dioxide
Particulate matter, sulfur dioxide
Particulate matter, .sulfur dioxide
Fluorides
Fluorides
Particulate matter
Particulate matter, carbon monoxide
Particulate matter
Particulate matter, TRS
Particulate matter
Particulate matter
VOC
Nitrogen oxides, sulfur dioxide
Particulate matter
Lead
Particulate matter
VOC
Particulate matter
Particulate matter
VOC
VOC
VOC
VOC
Particulate matter
Performance standards
VOC
VOC
VOC
Performance standards
VOC
VOC
VOC
S02
Particulate matter
Particulate matter
-------
D-3
Table D-2
NSPS SOURCES REQUIRING CEM
Source
Fossil-fuel-fired steam
generator
Fossil-fuel-fired electric
utilities
Nitric acid plants
Sulfuric acid plants
Petroleum refineries (FBCCU)
Claus sulfur recovery unit
Primary copper smelters
Primary zinc smelters
Primary lead smelters
Ferroalloy production
facil ities
Electric arc furnaces
Kraft pulp mills
Lime manufacturing plants
Phosphate rock plants
Flexible vinyl and urethane
coating and printing
Onshore natural gas processing
plants
Subpart
D
Da
G
H
J
J
P
Q
R
I
AA
BB
HH
NN
FFF
ILL
Effective Date
08/17/71
09/18/78
08/17/71
08/17/71
06/11/73
10/4/76
10/16/74
10/16/74
10/16/74
10/21/74
10/21/74
09/24/76
05/03/77
09/21/79
01/18/83
10/01/85
Monitor
opacity, S02,
NO , 02 or C02
/\
opacity, S02,
N0x, 02 or C02
N0x
S02
opacity, CO,
S02, H2S
opacity, CO,
S02, H2S
opacity, S02
opacity, S02
opacity, S02
opacity
opacity
opacity, TRS
opacity
opacity
VOC
S02/T/TRS
(06/87)
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D-4
Appendix D (cont.)
Date and time when CEM was inoperative,
nature of repairs Yes No
Notification given to State/local agency. Yes No
(06/87)
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D-5.
NATIONAL EMISSIONS STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP)*
Sources Covered
NESHAP includes new and existing stationary sources that emit or have
the potential to emit any one of six hazardous air pollutants. The pollu-
tants and sources covered are listed in Table D-3.
Existing sources must comply within 90 days but can obtain waivers for
up to 2 years for installation of controls. New sources or modified sources
coming online after the publication of standards must achieve immediate
compliance.
Requirements
Compliance Status
Submit to Agency within 90 days of publication
of standard adequate information on design,
method of operation, weight/month of hazardous
material and control devices Yes No
Agency Notification
Proper notice before startup and before
emissions testing Yes No
Emissions Testing
Emission testing conducted using prescribed
reference methods Yes No
Written results sent to Agency Yes No
Monitoring and Reporting
Required monitoring being performed Yes No
Reporting to Agency Yes No
40 CFR, Part 61, 1980
(06/87)
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D-6
Table D-3
SOURCES SUBJECT TO TITLE 40 CFR PART 61
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
Pollutant
Subpart
Source
Asbestos
Beryl!ium
Beryllium
Mercury
Vinyl chloride
Benzene (leaks)
Volatile Hazardous
Air Pollutant (VHAP)
Radon-222
Radionuclides
Radionuclides
M
D
E
B
H
I
Radionuclides
Asbestos mills
Manufacturing
Demolition and renovation
Spraying
Fabrication
Waste disposal
Extraction plants
Ceramic plants
Foundries
Incinerators
Machine shops
Rocket motor firing
Ore processing plants
Chlor-alkali plants
Sludge incinerators
Sludge drying plants
Ethylene dichloride plants
Vinyl chloride plants
Polyvinyl chloride plants
Equipment in benzene service
(plants designed to produce
more than 1,000 megagrams of
benzene per year)
Equipment in VHAP service
Underground uranium mines
DOE facilities
Facilities licensed by the
Nuclear Regulatory Commis-
sion and Federal facilities
not covered by Subpart H
Elemental phosphours plants
(06/87)
-------
D-7
Table D-4
EXAMPLE OF INSPECTION CHECKLIST*
GENERAL INFORMATION
A. Plant Location (mail address)
B. Chief Corporate Officer (name/phone)_
C. Plant Manager (name/phone)
D. Environmental Contact (name/phone)
E. Sources Inspected Production Status
F. Reasons for Inspection (check appropriate items)
Routine Inspection Compliance Progress
Complaint Investigation Permit Review/Renewal
Stack Testing Observed Tax Certification
Special Studies Emergency Episode
Other Equipment Malfunction_
G. Plant Representative Contacted (name and title)
H. Inspection Procedures and Conditions
Prior Notice (check one) Yes No
Time/Date Duration Onsite
Type Inspection (check one) Counterflow Followup_
Other
Weather Wind Direction
II. PRE-INSPECTION INTERVIEW
A. Production Status: Normal Abnormal
B. Control Equipment: Normal Abnormal
C. Permit/Compliance Schedule Changes Needed: Yes No_
D. Comments
Revised from Enforcement Workshop on Plant Inspection and Evaluation,
Volume II, Draft, EPA, OE, SSE, February 1979
(06/87)
-------
0-8
Table D-4 (cont.)
III. INSPECTION RESULTS
A. Preliminary Conclusions
All sources in compliance with:
Mass Emission Regulations
Visible Emission Regulat
Fuel Quality Regulations
Continuous Monitoring Re
Sampling/Testing Require
Recordkeeping Requirements
Special Orders
O&M Practices
Housekeeping
B. Specific Conclusions
Compliance questionable due to:
Changes in raw materials and/or fuels
Production rate increases
.ions
ilations
ons
Yes
Yes
Yes
I Regulations Yes
n'rements
iments
Good
Good
Yes
Yes
Yes
Average
Average
No
No
No
No
No
No
No
Poor
Poor
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Operational changes in process
Deterioration of process equipment
Operational Problems in Control Equipment (check appropriate
items below)
Electrostatic
Precipitators
Resistivity _
TR Sets
Insulators
Fabric
Filters
Tears/pinholes
Blinding
Bleeding
Discharge Wires
High Velocity
Gas Distribution
Rappers
Cleaning System
Hopper Overflow
Corrosion
Wet
Scrubbers
Low Liquor Flow
Gas Flow Rate Low
Bed Plugging
Nozzle Erosion
Demisters
Throat Adjustment
Solids Handling
Plate Warpage
Mass Overload
Other
Tray Collapse
Corrosion
(06/87)
-------
Table D-4 (cont.)
C. Samples Taken (Describe)
D. Comments/Recommended Action
D-9
Inspector Date
(06/87)
-------
D-10
Table D-5
EXAMPLE OF ASBESTOS EMISSION INSPECTION CHECKLIST
I. GENERAL INFORMATION .
A. Facility Location (mail address)
B. Chief Corporate Officer (name/phone)_
C. Facility Manager (name/phone)
D. Environmental Contact (name/phone)
E. Sourses Inspected Production Status
F. Reasons for Inspection (check appropriate items)
Routine Inspection Compliance Progress
Complaint Investigation Permit Review/Renewal
Stack Testing Observed Tax Certification
Special Studies Emergency Episode"
Other Equipment Malfunction_
G. Plant Representative Contacted (name and title)
H. Inspection Procedures and Conditions
Prior Notice (check one) Yes No
Time/Date Duration Onsite
Type Inspection (check one) Counterflow Followup
Other
Weather Wind Direction
II. ASBESTOS MILL
Does the facility discharge to the outside air? Yes No
Are controls in place prior to discharge that meet
air cleaning requirements? Yes No
(If yes, complete air cleaning standards XII.)
(06/87)
-------
D-ll
Table D-5 (cont.)
III. ROADWAYS
Is roadway surfaced with asbestos tailings or
asbestos-contained waste material? Yes No
(Surfacing of temporary roadway in area of
asbestos ore desposits is allowed.)
IV. MANUFACTURING (See 61.144(a) for applicability)
Are visible emissions possible to the outside air? Yes No
Are controls in place prior to discharge? Yes No
(If yes, complete air cleaning standards XII.)
V. DEMOLITION AND RENOVATION
A. If the facility is to be demolished, is the
amount of friable asbestos at least 80 linear
meters (260 linear feet) on pipes or at least
15 square meters (160 square feet) on other
components? Yes No
(If no, go to B below.)
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or delivered at
least 10 days before demolition/renovation
began? Yes No
3. Did the notice include:
a. Name and Address of owner or operator? Yes No
b. A description of the facility to be
demolished or renovated including size,
age and prior use? Yes No
c. The estimated amount of friable
asbestos? Yes No
d. The location of the facility to be
demolished/renovated? Yes No
e. A demolition/renovation schedule? Yes No
f. The methods of demolition/renovation
to be used? Yes No
g. Procedures to be followed to comply
with National Emission Standards for
Asbestos, 40 CFR 61, Subpart M? Yes No
(06/87)
-------
D-12
Table D-5 (cont.)
h. The name and location of the
asbestos disposal site? Yes No
4. Was friable asbestos material removed prior
to wrecking or dismantling? Yes No
If no, was material encased in concrete or
similar material? Yes No
Was material adequately wetted? Yes No
5. When asbestos covered or coated, were
facility components removed? Yes No
a. Were they adequately wetted? Yes No
b. Were they carefully lowered to
ground level? Yes No
6. If asbestos was stripped from facility
components, were they adequately wetted? Yes No
If equipment would be damaged by wetting
during renovation
a. Was Administrator supplied with suffi-
cient information to determine that
wetting would cause unavoidable damage? Yes No
b. Was a local exhaust ventilation and
collection system used? Yes No
i. Are visible emissions possible to
the outside air? Yes No
ii. Was the system operated according
to air cleaning requirements? Yes No
(If a system was used, complete air
cleaning standards XII and continue.)
7. After components were removed as units or
sections,
a. Were they adequately wetted during
stripping? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
(1) Are visible emissions possible to
the outside air? Yes No
(06/87)
-------
D-13
Table D-5 (cont.)
(2) Was the system operated to air
cleaning requirements? Yes No
(If a system was used complete air
cleaning standards XIII and continue.)
8. When friable material was stripped or
removed,
a. Had it been adequately wetted until
collected for disposal? Yes No
b. Had it been lowered, not dropped to
the ground or lower floor? Yes No
c. Had it been tranported via dust-tight
shutes or containers if more than 50
feet above the ground level? Yes No
9. Was the temperature at the point of wetting
below 0 °C (32 °F)? Yes No
(If yes, no other wetting requirements apply
and components are to be removed as units or
in sections to the maximum extent possible.)
B. If the facility is to be demolished,
Is the amount of friable asbestos less than 80
linear meters (260 linear feet) or pipes and less
than 15 square meters (160 square feet) on other
components? Yes No
(If no, go to C below.)
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or delivered
at least 20 days before demolition/renovation
began? Yes No
3. Did the notice include:
a. Name and address of owner or operator? Yes No
b. A description of the facility to be
demolished or renovated including size,
age and prior use? Yes No
c. The estimated amount of friable
asbestos? Yes No
(06/87)
-------
D-14
Table D-5 (cont.)
d. The location of the facility to be
demolished/renovated? _Yes No
e. A demolition/renovation schedule? Yes No
C. Has the demolition been ordered by State or
local government due to structurally unsound
conditions or danger of imminent collapse? Yes No
If no, go to D below.
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or delivered
as early as possible before the demolition
began? Yes No
3. Did the notice include
a. Name and address of owner or operator Yes No
b. A description of the facility to be
demolished or renovated including size,
age and prior use Yes No
c. The estimated amount of friable
asbestos Yes No
d. The location of the facility to be
demolished/renovated Yes No
e. A demolition/renovation schedule Yes No
f. The methods of demolition/renovation
to be used Yes No
g. Procedures to be followed to comply
with national Emission Standard for
Asbestos, 40 CFR 61, Subpart M Yes No
h. The name and location of the asbestos
disposal site Yes No
4. After components were removed as units or
sections,
a. Were they adequately wetted during
stripping? Yes No
b. Was a local exhaust ventilation and
collection system used? Yes No
(1) Are visible emissions possible to
the outside air? Yes No
(2) Was the system operated according
to air cleaning requirements? Yes No
(06/87)
-------
D-15
Table D-5 (cont.)
(If a system was used, complete air
cleaning standards XIII and continue.)
5. When friable material was stopped or removed,
a. Had it been adequately wetted until col-
lected for disposal? Yes No
b. Had it been lowered, not dropped, to
the ground or lower floor? Yes No
c. Had it been transported via dust-tight
shutes or containers if more than
50 feet above the ground level? Yes No
6. Was the temperature at the point of wetting
below (0 °C (32 °F)? Yes No
(If yes, no other wetting requirements
apply and components are to be removed
as units or in sections to the maximum
extent possible.)
If the facility is to be renovated, is the
amount of friable asbestos to be stripped
at least 80 linear meters (260 linear feet)
on pipes or at least 15 square meters (160
square feet) on other components? Yes No
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or delivered
at least 10 days before demolition/renovation
began? Yes No
3. Did the notice include
a. Name and address of owner or operator? Yes No
b. A description of the facility to be
demolished or renovated including size,
age and prior use? Yes No
c. The estimated amount of friable
asbestos? Yes No
d. The location of the facility to be
demolished/renovated? Yes No
e. A demolition/renovation schedule? Yes No
f. The methods of demolition/renovation
to be used? Yes No
g. Procedures to be followed to comply
with National Emission Standards for
Asbestos, 40 CFR 61, Subpart M? Yes No
(06/87)
-------
D-16
Table D-5 (cont.)
h. The name and location of the
asbestos disposal site? Yes No
4. Was friable asbestos material removed prior
to wrecking or dismantling? Yes No
If no, was material encased in concrete or
similar material and was material adequately
wetted? Yes No
5. When asbestos covered or coated were
facility components removed?
a. Were they adequately wetted? Yes No
b. Were they carefully lowered to
ground level? Yes No
6. If asbestos was stripped from facility
components, were they adequately wetted? Yes No
If equipment would be damaged by wetting
during renovation,
a. Was Administrator supplied with suf-
ficient information to determine that
wetting would cause unavoidable damage? Yes No
b. Was a local exhaust ventilation and
collection system used? Yes No
(1) Are visible emissions possible to
the outside air? Yes No
(2) Was the system operated according
to air cleaning requirements? Yes No
(If a system was used, complete air
cleaning standard XIII and continue.)
7. After components were removed as units or
sections,
a. Were they adequately wetted during
stripping? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
(If a system was used complete air
cleaning standards XIII and continue.)
8. When friable material was stripped or
removed,
(06/87)
-------
D-17
Table D-5 (cont.)
a. Had it been adequately wetted until
collected for disposal? Yes No
b. Had it been lowered, not dropped, to
the ground or lower floor? _Yes No
c. Had it been tranported via dust-tight
shutes or containers if more than 50
feet above the ground level? Yes No
9. Was the temperature at the point of wetting
below 0 °C (32 °F)? Yes No
(If yes, no other wetting requirements apply
and components are to be removed as units or
in sections to the maximum extent possible.)
VI. SPRAYING
If sprayed on asbestos material is encapsulated and the material is not
friable after drying, go to 3.
A. Does material that is sprayed contain:
1% or less asbestos on a dry weight basis? Yes No
B. If greater than 1%,
1. Was the Administrator notified at least
20 days prior to the spraying? Yes No
2. Did the notice include:
a. Name and address of owner or operator? Yes No
b. Location of spraying operation? Yes No
c. Procedures to be followed to comply
with National Emission Standards for
Asbestos, 40 CFR 61, Subpart M? Yes No
3. Are visible emissions possible to the
outside air? Yes No
Were emissions cleaned before discharge? Yes No
(If yes, complete air cleaning standards
XIII and continue.)
VII. FABRICATION (See 61.149 for applicability)
Are visible emissions to the outside air possible? Yes No
(06/87)
-------
D-18
Table D-5 (cont.)
Were emissions cleaned before discharge? Yes No
(If yes, complete air cleaning standards XIII and
continue.)
VIII. INSULATING MATERIALS
Was insulating material containing asbestos that was
molded and friable or wet applied and friable after
drying, installed or re-installed after April 5, 1984? Yes No
IX. WASTE DISPOSAL FOR ASBESTOS MILLS
A. Was asbestos-containing waste material disposed
at an acceptable site? Yes No
(See Active Waste Disposal Site requirements XIV.)
B. Are visible emissions possible to the outside
air? Yes No
Were emissions cleaned before discharge? Yes No
(If yes, complete air cleaning standards XIII
and continue.)
C. Identify the disposal method for wastes from control devices.
1. Was the waste mixed with a wetting agent
prior to disposal? Yes No
a. Was the agent recommended by the
manufacturer for this use? Yes No
b. Was all asbestos containing material
adequately mixed with the wetting
agent? Yes No
c. Are visible emissions possible to the
outside air? Yes No
Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning standards
XIII and continue.)
(06/87)
-------
D-19
Table D-5 (cont.)
d. Was wetting suspended when the ambient
temperature at the waste disposal site
dropped below -9.5 °C (15 °F)? Yes No
(1) Are hourly temperature records
kept during suspension of wetting
operations? Yes No
(2) Are records kept for at least
2 years? Yes No
2. Was waste mixed with water to form a slurry? Yes No
a. Are visible emissions possible to the
outside air? Yes No
Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards and continue XIII.) Yes No
b. Was all wet asbestos-containing material
in leak-tight containers? Yes No
c. Were the containers labeled with
appropriate warnings? Yes No
(See 61.152(b)(l)(iv) or OSHA 29 CFR
1910.1001(g)(2)(ii) for labeling
requirements.)
3. Is waste processed into nonfriable pellets
or other shapes? Yes No
a. Are visible emissions possible from
the operation to the outside air? Yes No
b. Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
4. If an alternate method is used, was it
approved by the Administrator? Yes No
(06/87)
-------
D-20
Table D-5 (cont.)
X. STANDARD FOR WASTE DISPOSAL FOR MANUFACTURING, DEMOLITION, RENOVATION,
SPRAYING AND FABRICATING OPERATIONS
A. Are wastes disposed at acceptable sites? Yes No
(See Active Waste Disposal Site XIV
requirements.)
B. Are visible emissions possible to the outside
air during collection, processing, incineration,
packaging, transporting of deposition of waste? Yes No
1. Was the waste mixed with a wetting agent
prior to disposal? Yes No
a. Was the agent recommended by the
manufacturer for this use? Yes No
b. Was all asbestos containing material
adequately mixed with the wetting
agent? Yes No
c. Are visible emissions possible to the
outside air? Yes No
Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
d. Was wetting suspended when the ambient
temperature at the waste disposal site
dropped below -9.5 °C (15 °F)? Yes No
(1) Are hourly temperature records
kept during suspension of wetting
operations? Yes No
(2) Are records kept for at least
2 years? Yes No
2. Was waste mixed with water to form a slurry? Yes No
a. Are visible emissions possible to the
outside air? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
b. Was all wet asbestos-containing material
in leak-tight containers? Yes No
(06/87)
-------
D-21
Table D-5 (cont.)
c. Were the containers labeled with
appropriate warnings? Yes No
(See 61.152(b)(l)(iv) or OSHA 29 CFR
1910.1001(g)(2)(ii) for labeling
requirements.)
3. Is waste processed into nonfriable pellets
or other shapes? Yes No
a. Are visible emissions possible from
the operation to the outside air? Yes No
b. Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
4. If an alternate method is used, was it
approved by the Administrator? Yes No
XI. STANDARDS FOR INACTIVE WASTE DISPOSAL SITES FOR ASBESTOS MILLS AND
MANUFACTURING AND FABRICATING OPERATIONS
A. Are visible emissions possible from the site? Yes No
Is the site covered with at least 15 centi-
meters (6 inches) of clean compacted material? Yes No
Is a vegetation cover present? Yes No
Is the site covered with at least 60 centimeters
(2 feet) of clean compacted material? Yes No
Is a dust suppression agent applied that has
been recommended by the manufacturer and
approved by the Administrator? Yes No
B. Is there a barrier restricting access to the
site? Yes No
C. Are warning signs placed at 100-meter (330-foot)
or less intervals around the site? Yes No
1. Are they easily read? Yes No
2. Do they meet the size requirements
61.153(b)(l)ii)? Yes No
(06/87)
-------
D-22
Table D-5 (cont.)
3. Do they meet the legend requirements of
61.153(b)(l)(iii)? Yes No
D. Has the Administrator approved an alternate
access control method? Yes No
XII. AIR CLEANING STANDARDS
A. Are fabric filter collection devices used? Yes No
If no, go to D.
1. Is the filter pressure drop no more than
.995 kilopascal (4 inches water guage)? Yes No
2. Does the air flow permeability meet the
requirements of 61.154(a)(l)(ii)? Yes No
3. Does the fabric meet the requirements of
61.154(a)(l)(iii)? Yes No
4. If a synthetic fabric is used, is the fill
yarn spun? Yes No
B. Is all equipment properly installed, used,
operated and maintained? Yes No
C. Are bypasses only used during suspect or
emergency conditions? Yes No
D. Has the Administrator authorized wet collectors
if fabric creates a fire or explosion hazard? Yes No
E. Has the Administrator authorized the use of any
other alternate cleaning equipment? Yes No
XIII. REPORTING REQUIREMENTS
Has the facility submitted the following information
to the Administrator by July 4, 1984 (90 days after
April 5, 1984)? Yes No
A. For all sources:
1. Description of the emission control equip-
ment for each process? Yes No
2. The pressure drop across the fabric filter,
if used? Yes No
(06/87)
-------
D-23
Table D-5 (cont.)
3. The airflow permeability of a woven fabric
filter and of synthetic, if the the fill
yarn is spun? Yes No
B. For sources subject to 61.151 and 152:
1. Description of each process that generates
asbestos-containing waste? Yes No
2. The average weight of material disposed
in kg. per day? Yes No
3. The emission control methods used? Yes No
4. The type of disposal method or site and
the name, location and operator of the site? Yes No
C. For sources subject to 61.153:
1. Description of the site? Yes No
2. Methods used to comply with the standards? Yes No
XIV. ACTIVE WASTE DISPOSAL SITE STANDARDS
A. Are visible emissions possible from the site? Yes No
Is at least 15 centimeters (6 inches) of com-
pacted cover placed on the waste at the end of
each day or 24-hour period? Yes No
Is dust suppressant used that has been approved
by the Administrator? Yes No
If an alternate method is used, has it been
approved by the Administrator?
B. Is there a barrier restricting access to the
site? Yes No
C. Are warning signs placed at 100-meter (330-foot)
or less intervals around the site? Yes No
1. Are they easily read? Yes No
2. Do they meet the size requirements of
61.153(b)(l)(ii)? Yes No
3. Do they meet the legend requirements of
61.153(b)(l)(iii)? Yes No
(06/87)
-------
D-24
Check pressure drop across
each coapartaenc; also,
check condition of iir.es
and pressure gauges.
Check cleaning syscea:
-Pulse Jec pressure
-Solenoids
-Reverse air blowers
-Shakers
Check solids reaovai equip-
ment:
-Screv conveyor
-Pneuaatle systea
-Heacers
-Vibrators
Chec<. coniii.on 01 bags:
-•Sag tears
-Sag deterioration
-Dropped bags •
-Oily bags
-Vet bags
-laproper ba? tension
-Deposits on floor
Are
there any
indications of
nonoptioal per-
formance?
Chacic ;-;an air cr.arser :or
possible leakage.
solids reaoval
ENTER CM IT TO CO:.TI?.«.
EVALUATION'S. M-VV :;S:IO
TO RŁSCKEDIT.E INSPECTIOX.
::T:X.N-AL FASSIC TILTER
INSPECTION.
NO - END FABRIC FILTER INSPECTIOS
Figure D-] •
Fabric Filter Inspection Flowsheet
[From Enforcement Workshop on Plant Inspection & Evaluation, Volume II,
Draft, EPA, OE, SSE, February 1979].
-------
D-25
Can
Incernal Inspection be
Perforeed?
Reschedule inspection
for a tise when unit Is
operational
Inspect Ir.carr.ai pares:
Srotsl« condition
?resensa of corrosion
Presensa of erosior.
Presence of scaiiaj
Check tnte?ricy of shell
recencion jrisj, and otr.a
pares.
Check slurry handling
syscea.
Check puaos an purge,
oake-up, and reciccula-
cion Lines.
Read Clou eecers if aval
able. Check liquor casp
on lalacs and ouclacs.
T
Check pressure jau;es anc
differencial pressure
=oni:ors across cha fol-
lowing:
Spriv nozzles
Scrubber bads
Vencuri chroac
Check c:;r;3 ar.d recircu-
laclon can/LI:
-Liquor cespecacura
-Liquor ?K
Check inlee csndiiicns:
-Has :e=perature
-?resaturacor vacar
clow race
::o 3cu'33ŁR :NS?ECTIOM
Figure D-2
Scrubber Inspection Flowsheet
[From Enforcement l.'orkshop on Plant Inspection & Evaluation, Volume II
Draft, EPA, OE, SSE, February 1979].
-------
D-26
P«rfora Internal
Inspection.
Top section, check:
-Sappers
-Drives
-Insulators
-Heaters
-Slouers
Eleccrical Field section,
check:
-Alignment
-Build-up
-Sappers
-Drives
-Insulators
-irosion
-Corrosion
Cheek:
-Hopper section
-3uild-up
-Corrsiion
-Hopper dairies
Check:
Gas distribution devices
cS? -tnlec
-Outlet
-Ductwork
-Corrostoa
-Erosion
-Plugging
-Rapping systeas
i
End ESP inspection, return
for operational inspection.
Is
Precipitator
Operating?
YES
Identify ius section nuabering
system.
Check for bus sections which
are r.oc operating.
Check electrical characteris-
tics of each bus section
that is operating.
-Primary voltage
-Prinary current
-Secondary current
-Secondary voltage (if
measured)
-spark rate
Check rapper sequence and
tl.-_--.?.
Ch«ck .r.sulators purge and
hea:.-j systen.
Check operational status
Hopper '-.eaters i vibrators
Solids rer.oval svsten
At a
:here ar.y in-
dications -at non
compliance oo-
ratlon?
Reschedule operational in-
spection. RecoTc-end mainte-
nance vork.
ENT ŁSP IXC""CTION.
Figure D-3
Electrostatic Precipitator Inspection Flowsheet
[From Enforcement l.'orkshop On Plant Inspection & Evaluation,
Volume II, Draft, EPA, OE, SSE, Washington, O.C., February 1979]
-------
APPENDIX E
WATER POLLUTION CHECKLISTS
-------
Table E-l
NPDES Compliance Inspection Report (Form 3560-3)
dEPA NPDES
United Stales Environmental Protection Agency
Washington, D. C. 20460
Compliance Inspection Report
Form Approved
OMB No. 2040-0003
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES
il 1 d6| d
Reserved Facility Evaluation Rating
67| | 69 70| | .
yr/mo/day Inspection Type Inspector Fac Type
11 id 1 1 1 17 id 1 id 1 ad 1
Remarks
1 1 1 1 1 1 1 1 1 1
1 1 1
66
7lU 72LJ 7d 1 |74 7d 1
1 80
Section B: Facility Data
Name and Location of Facility Inspected
Name(s) of On-Site Representative(s)
Name, Address of Responsible Official
Entry Time rj ... rj ... Permit Effective Date
Exit Time/Date Permit Expiration Date
Title(s) Phone No(s)
Title
Phone No. Contacted
d Yes CD No
Section C: Areas Evaluated During Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)
Permit F
Records/Reports L
Facility Site Review E
low Measurement Pretreatment
aboratory Compliance Schedules
ffluent/Receiving Waters Self-Monitoring Program
Operations & Maintenance
Sludge Disposal
Other:
Section D: Summary of Findings/Comments (Attach additional sheets if necessary)
Name(s) and Sighature(s) of Inspector(s)
Signature of Reviewer
Action Taken
Agency/Off ice/Telephone
Agency/Office
Regulatory Office Use Only
Date
Date
Date
Compliance Status
1 — 1 Noncompliance
1 1 Compliance
EPA Form 3S60-3 (Rev. 3-RRi Pravinus editions are obsolete.
-------
INSTRUCTIONS
Section A: National Data System Coding (i.e., PCS)
Column 1: Transaction Code: Use N, C, or D for New, Change, or Delete. All inspections will be new
unless there is an error in the data entered.
Columns 3-11: NPDES Permit No. Enter the facility's NPDES permit number. (Use the Remarks
columns to record the State permit number, if necessary.)
Columns 12-17: Inspection Date. Insert the date entry was made into the facility. Use the
year/month/day format (e.g., 82/06/30 = June 30, 1982).
Column 18: Inspection Type. Use one of the codes listed below to describe the type of inspection:
A — Performance Audit E — Corps of Engrs Inspection S — Compliance Sampling
B — Biomonitoring L — Enforcement Case Support X — Toxic Sampling
C — Compliance Evaluation P — Pretreatment
D — Diagnostic R — Reconnaissance Inspection
Column 19: Inspector Code. Use one of the codes listed below to describe the lead agency in the
inspection.
C — Contractor or Other Inspectors (Specify in N — NEIC Inspectors
Remarks columns) R — EPA Regional Inspector
E — Corps of Engineers S — State Inspector
J — Joint EPA/State Inspectors—EPA lead T — Joint State/EPA Inspectors—State lead
Column 20: Facility Type. Use one of the codes below to describe the facility.
1 — Municipal. Publicly Owned Treatment Works (POTWs) with 1972 Standard Industrial Code
(SIC) 4952.
2 — Industrial. Other than municipal, agricultural, and Federal facilities.
3 — Agricultural. Facilities classified with 1972 SIC 0111 to 0971.
4 — Federal. Facilities identified as Federal by the EPA Regional Office.
Columns 21 -66: Remarks. These columns are reserved for remarks at the discretion of the Region.
Column 70: Facility Evaluation Rating. Use information gathered during the inspection (regardless
of inspection type) to evaluate the quality of the facility self-monitoring program. Grade the program
using a scale of 1 to 5 with a score of 5 being used for very reliable self-monitoring programs, 3 being
satisfactory, and 1 being used for very unreliable programs.
Column 71: Biomonitoring Information. Enter D for static testing. Enter F for flow through testing.
Enter N for no biomonitoring.
Column 72: Quality Assurance Data Inspection. Enter Q if the inspection was conducted as
followup on quality assurance sample results. Enter N otherwise.
Columns 73-80: These columns are reserved for regionally defined information.
Section B: Facility Data
This section is self-explanatory.
Section C: Areas Evaluated During Inspection
Indicate findings (S, M, U, or N) in the appropriate box. Use Section D and additional sheets as
necessary. Support the findings, as necessary, in a brief narrative report. Use the headings given on
the report form (e.g., Permit, Records/Reports) when discussing the areas evaluated during the
inspection. The heading marked "Other" may include activities such as SPCC, BMP's, and multime-
dia concerns.
Section D: Summary of Findings/Comments
Briefly summarize the inspection findings. This summary should abstract the pertinent inspection
findings, not replace the narrative report. Reference a list of attachments, such as completed
checklists taken from the NPDES Compliance Inspection Manuals and pretreatment guidance
documents, including effluent data when sampling has been done. Use extra sheets as necessary.
EPA Form 3560-3 (Rev. 3-85) Reverse
-------
E-3
Appendix E (cont.)
SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN
(SPCC) CHECKLIST
1. Does this facility have:
a. More than 1,320 gallons of above-ground
oil storage capacity or a single container
with a capacity of more than 660 gallons? Yes No
b. More than 42,000 gallons of underground
oil storage capacity? Yes No
2. Does this facility have a Spill Prevention
Control and Countermeasure (SPCC) plan? Yes No
a. Has the SPCC plan been certified by a
registered professional engineer? Yes No
b. Date the SPCC plan was last certified:
c. Original date SPCC plan was prepared:
3. Are there other State or local requirements
for hazardous materials spill prevention and
control plan? Yes No
a. Is this hazardous materials SPCC plan
available? Yes No
4. Have any reportable spills of petroleum products
or hazardous materials occurred at this facility
within the last review period? Yes No
List:
a. Were these spills reported to the proper
authorities? Yes No
b. Were these spills cleaned up properly? Yes No
c. Were measures taken to prevent future spills? Yes No
d. Is there evidence of these reported spills
or other spills at the facility? Yes No
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E-4
Appendix E (cont.)
5. Does the SPCC plan include:
a. Notification procedures? Yes No
b. Inspection procedures? Yes No
c. A facility drawing which includes storage
tanks and containment areas? Yes No
d. Oil spill prevention designee? Yes No
6. Does the facility have:
a. Secondary containment or diversionary
structures at oil storage areas? Yes No
b. Spill cleanup materials available or infor-
mation on where these materials are available? Yes No
c. Security? Yes No
COMMENTS:
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APPENDIX F
RCRA CHECKLISTS
-------
F-l
RCRA INSPECTION CHECKLISTS*
Table F-l
RCRA COMPLIANCE INSPECTION REPORT
GENERATORS CHECKLIST
Note: State laws, in many cases are more stringent than Federal law for
many of the generator requirements, but particularly in the area of accumu-
lation time. Be aware of these differences and modify this protocol as
needed!
Does the State in which the generator is located
have RCRA State authorization? Yes No
Has the generator identified the differences
between the State program and the Federal
program? Yes No
SECTION A - EPA ID NUMBER
1. Does generator have EPA ID Number? Yes No
a. If yes, EPA ID Number
2. Are there other EPA ID Numbers used at this location?
(If yes, list the other numbers and identify where
they are used and for what they were issued.) Yes No
SECTION B - HAZARDOUS WASTE DETERMINATION
1. Are hazardous waste(s) (§261 Subpart D) generated at this
facility? Yes No
a. If yes, list waste and quantities on an attachment. (Include EPA
Hazardous Waste Number. Provide waste name and description.)
2. Are solid wastes that exhibit hazardous characteristics
generated (§261 Subpart C)? Yes No
a. If yes, list wastes and quantities on an attachment. Include EPA
Hazardous Waste Number. Provide waste name and description.)
b. How are waste charactistics determined (testing, knowledge of
process)?
These checklists are to be used only as guides and references should
be made to both RCRA and the regulations (40 CFR Parts 260 through
270) for recent changes.
(06/87)
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F-2
Table F-l (cont.)
(1) If determined by testing, did generator
use test methods in Part 261, Subpart C
(or equivalent)? Yes No
(2) If equivalent test methods used, attach copy of
methods.
3. Identify total quantities of hazardous waste generated per month,
for the last 12 months, for both acutely hazardous waste and other
hazardous waste.
(kg/mo) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Acutely toxic
Other hazardous
waste
4. Does the generator qualify as a Small Quantity Generator
(SQG) for the entire last 12-month period (§261.5)? Yes No
(If no, list the months that the generator was a full generator.)
5. Is generator exempted or conditionally exempted from regulation
because of:
a. Small quantity generator (§261.5) Yes No
b. Produces nonhazardous waste at this time
(§261.4) Yes No
6. Are any nonhazardous wastes generated? Yes No
a. If yes, did generator identify them as nonhazardous
by testing or by knowledge of process? Yes No
(1) If determined by testing, did generator
use test methods in Part 261 Subpart C
(or equivalent)? Yes No
(2) If equivalent test methods used, attach copy of methods.
b. List wastes and quantities deemed nonhazardous or processes from
which nonhazardous wastes were produced. Use narrative explana-
tion sheets.
(06/87)
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F-3
Table F-l (cont.)
SECTION C - UNIFORM HAZARDOUS WASTE MANIFEST SYSTEM
1. Has generator shipped hazardous waste offsite
since November 19, 1980 (§262 Subpart B)? Yes No
a. If no skip to Section D, Question #8.
b. If yes identify the name, EPA ID Number and site address(es) of
the offsite facilities. (Use back of page for additional facilities
if needed.)
Name
Name
Name
Name
Address
Address
Address
Address
2. If not exempt, is the waste manifested on the
Uniform Hazardous Waste Manifest (§262, Appendix) Yes No
If so, do the manifests contain:
a. Name and mailing address of generator? Yes No
b. The name and EPA ID Number of each transporter? Yes No
c. DOT waste description, including proper shipping
name, hazardous class and DOT identification
number? Yes No
d. Number and type of containers (if applicable)? Yes No
e. Quantity of each waste transported? Yes No
f. Name, EPA ID Number and site address of facility
designated to receive the waste? Yes No
g. The following certification: effective
September 1, 1985? Yes No
"I hereby declare that the contents of this consignment are fully and
accurately described above by proper shipping name and are classified, packed,
marked, and labeled, and are in all respects in proper condition for transport
by highway according to applicable international and national government
regulations.
Unless I am a small quantity generator who has been exempted by statute
or regulation from the duty to make a waste minimization certification under
Section 3002(b) of RCRA, I also certify that I have a program in place to
reduce the volume and toxicity of waste generated to the degree I have
(06/87)
-------
F-4
Table F-l (cont.)
determined to be economically practicable and I have selected the method of
treatment, storage or disposal currently available to me which minimizes
the present and future threat to human health and the environment."
3. Does the facility designated to receive the waste have:
a. A RCRA permit? Yes No
b. Interim status? Yes No
c. A permit, license or registration from a state
to manage municipal or industrial solid waste? Yes No
4. Does the generator retain copies of the manifests? Yes No
If yes, complete 6a through 6e (§262.23).
(Inspect completed manifests at random and indicate how many manifests
were inspected. Obtain copies of all manifests with violations and describe
violations.)
a. Did the generator sign and date all manifests? Yes No
Who signed the manifests for the generator?
Name Title
Name Title
b. Did the generator obtain the handwritten
signature and date of acceptance from the
initial transporter? Yes No
c. Does generator retain one copy of the manifest
signed by the generator and transporter? Yes No
d. Do return copies of manifest include facility
owner/operator signature and date of acceptance? Yes No
e. If the copy of the manifest from the facility was
not returned within 45 days, did generator file
an Exception Report (§262.42)? Yes No
If yes, did it contain:
(1) A legible copy of the manifest Yes No
(06/87)
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F-5
Table F-l (cont.)
(2) A cover letter explaining generator's
efforts to locate waste and the results
of those efforts? Yes No
f. Has generator retained copies for 3 years? Yes No
SECTION D - PRETRANSPORT REQUIREMENTS
1. Does the generator package waste? . Yes No
If not, why not? (Skip the rest of Section D)
If yes, complete the following questions.
2. Does generator package waste in accordance with DOT
requirements 49 CFR 173, 178 and 179 (§262.30)? Yes No
3. Inspect containers to be shipped. (Use narrative explanation sheet to
describe containers and condition.)
a. Are containers leaking, corroding or bulging? Yes No
b. Is there evidence of heat generation from
incompatible wastes in containers? Yes No
c. Are containers labeled according to DOT (49 CFR
172 Subpart E)? Yes No
d. Are containers marked according to DOT require-
ments (49 CFR 172 Subpart D)? Yes No
e. Is each container of 110 gallons or less marked
with the following words? Yes No
"HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found,
contact the nearest police or public safety authority or the U.S. Envi-
ronmental Protection Agency."
Generator's name and address
Manifest Document Number
( Note: During accumulation times, see below, only the words "Hazardous
Waste" must appear on containers of 110 gallons or less.)
(06/87)
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F-6
Table F-l (cont.)
4. If there are any vehicles present onsite loading or unloading hazardous
waste, inspect for presence of placards (49 CFR 172 Subpart F). Note
this instance on narrative explanation sheet.
5. Accumulation time (§262.34)
a. Is facility a permitted storage facility? Yes, No
b. Has all hazardous waste, generated in excess
of the SQG limits, been shipped offsite or sent
to onsite treatment, storage or disposal within
90 days. • ' " Yes No
(1) Is the waste placed in containers and
managed in accordance with the container
management requirements for facility owners
or operators (§265 Subpart I)? Yes No
(Generators who qualify for the SQG provi-
sions need not comply with the 50-foot
buffer requirement for ignitable waste.)
(2) Is the date upon which each period of
accumulation began clearly marked on each
container? Yes No
(3) What system does the generator use to deter-
mine when the SQG rate is exceeded? Explain
(4) Are the words "Hazardous Waste" clearly
marked on each container of 110 gallons or
less and visible for inspection? . Yes No
(5) For quantities in excess of the respective '. ,
SQG rates, is the generator complying with
the facility standards for Preparedness and
Prevention (Part 265 Subpart C) and Contin-
gency Plan/Emergency Procedures (Part 265
Subpart D)? Yes No
(6). For hazardous waste generated below the
respective SQG rates, is the generator
complying with the modified requirements
for SQGs (§261.5)? Yes No
(06/87)
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F-7
Table F-l (cont.)
(7) Do the facility hazardous waste management
personnel have the requisite training docu-
mented in their personnel file (§265.16) Yes No
c. Have hazardous wastes, generated at a rate
between 100 kg/mo and 1,000 kg/mo, been
accumulated less than 180 days, or 270 days if
the facility is over 200 miles away (effec-
tive September 22, 1986)? Yes No
d. Is the total amount of all hazardous waste
accumulated onsite and generated below
100 kg/mo, less than 1,000 kg? Yes No
e. Is the total amount of hazardous waste, accumu-
lated onsite, generated at a rate between
100 kg/mo and 1,000 kg/mo, less than 6,000 kg? Yes No
f. Does the generator inspect containers for
leakage or corrosion (§265.174)? Yes No
(1) If yes, how often?
(Review inspection records.)
g. Does the generator handle ignitable or reactive
waste? Yes No
(1) If yes, does the generator locate ignitable
or reactive wastes at least 15 meters (50
feet) inside facility's property line
(§265.176)? Yes No
(2) Does the generator separate and protect
ignitable or reactive wastes from sources
of ignition (§265.17)? Yes No
Note: If generator accumulates waste onsite for more than 90 days, fill out
facilities checklist, Section A-9, Personnel Training; Section B - Pre-
paredness and Prevention; and Section C - Contingency Plan and Emergency
Procedures.
9. Describe storage/accumulation area(s). Use photographs and narrative
explanation sheet.
SECTION E - RECORDKEEPING AND RECORDS
1. Is generator keeping the following records (§262.40)?
(Note: The following must be kept for a minimum of 3 years.)
(06/87)
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F-8
Table F-l (cont.)
a. Manifests or signed copies from designated
facilities? Yes No
b. Biennial reports (does not apply to SQGs)? Yes No
c. Exception reports (does not apply to SQGs)?
d. Test results or other means of determination,
as required? Yes No
2. Where are facility records kept (at the facility, offsite, etc.)
3. Who is responsible for keeping the records?
Title:
SECTION F - SPECIAL CONDITIONS
1. Have hazardous wastes been received from or transported
to a foreign source (§262.50)? Yes No
If yes,
a. For imports, has generator filed a notice with
the Regional Administrator? Yes No
b. For exports, has generator filed a notice with the
Administrator, Office of International
Activities, A-106, 4 weeks before the initial
shipment to each country? Yes No
c. For exports, are waste manifests signed by the
foreign consignee? Yes No
d. If the generator transported wastes out of the
country, has he received confirmation of delivery
of the shipment? Yes No
(1) Identify those shipments for which confir-
mation of delivery have not been received
within 90 days of shipment by manifest
number.
(2) Has generator filed an Exception Report
for all those shipments identified in ld(l)
above? Yes No
(06/87)
-------
F-9
Table F-l (cont.)
Has the exporter filed, with the Administrator,
an export summary report for the previous year
by March 1? Yes No
(06/87)
-------
F-10
Table F-2
RCRA COMPLIANCE INSPECTION REPORT
TRANSPORTER(S) AND VEHICLE CHECKLIST
A. General Transporter Information
1. Does transporter have EPA Identification Number? Yes No
EPA No.
2. Does more than one transporter or address use this
identification number? How many? Yes No
3. Identify the mode(s) of transportation used by transporter.
Air Rail Highway Water Other (specify)
Specification:
4. Does transporter have all necessary permits? Yes No
State permit number:
Federal permit number:
5. Does transporter ship hazardous waste out of the
U.S.? Yes No
6. Does transporter ship hazardous waste into the U.S.? Yes No
If yes, complete "Generator Checklist" for these hazardous wastes.
7. Does transporter mix hazardous wastes of different
DOT shipping descriptions by placing them into a
single container? Yes No
If yes, complete "Generator Checklist" for these mixtures.
B. Transfer Facilities
1. Does the transporter store manifested shipments of
hazardous waste in containers meeting the requirements
of §262.30 at a transfer facility? Yes No
2. Is all manifested hazardous waste, temporarily
stored by the transporter, shipped offsite within
10 days? Yes No
If not, complete "TSDF Checklist".
(06/87)
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F-ll
Table F-2 (cont.)
C. Manifest and Recordkeeping Requirements
1. Are all shipments of hazardous wastes accompanied by
an approved manifest (EPA Form 8700-22 or EPA Form
8700-22A)? Yes No
2. Does all required information appear on the manifest
(49 CFR 172.205)? Yes No
3. Inspect completed manifests at random and indicate number inspected.
Obtain copies of all manifests with deficiencies and provide narrative
explanation.
4. If transporter has shipped hazardous waste(s) out of
the United States, is the date of exit and the name
and address of receiving facility indicated on
manifest? Yes No
5. Special Conditions
a. If transportation occurs by water (bulk shipment),
does the transporter:
(1) Ship to the designated facility? Yes No
(2) Maintain shipping papers with information
contained on manifest? Yes No
(3) Obtain designated facility signature and
date of receipt? Yes No
(4) Retain a copy of manifest or shipping papers? Yes No
b. If transportation occurs by rail, does the
transporter:
(1) Sign and date manifest acknowledging
acceptance? Yes No
(2) Return signed copy to nonrail transporter? Yes No
(3) Forward at least three copies of the
manifest to the next appropriate
destination? Yes No
(06/87)
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F-12
Table F-2 (cont.)
(4) Retain one copy of manifest and rail
shipping papers? Yes No
(5) Ensure shipping papers accompany the
waste(s)? Yes No
(6) On delivery, obtain name, date and
signature of designated facility or
transporter? Yes No
6. Does transporter retain copies of manifests and
shipping papers for the required 3-year period? Yes No
D. Manifest Compliance
1. Does the transporter ship all waste to either the
designated facility listed on the manifest or the
alternate facility (when applicable) or the next
designated transporter? Yes No
2. Does the transporter assure delivery to the
designated facility outside the U.S.? Yes No
3. What procedures does the transporter follow when delivery of hazardous
wastes to designated facility is prevented? (Use narrative explanation
sheets.)
E. Pretransport Review
I. Does the transporter check to assure that the generator has complied
with the following requirements?
a. Has the generator packaged wastes in accordance
with DOT requirements (49 CFR 173)? Yes No
b. Has the generator packaged wastes in repacks? Yes No
c. Has the generator labeled wastes in accordance
with DOT requirements (49 CFR 172, Supbart E)? Yes No
d. Has the generator marked wastes in accordance
with DOT requirements (49 CFR 172, Subpart D)? Yes No
e. Has generator marked each container of 110
gallons or less used in such transportation
, with the following words and information dis-
played in accordance with the requirements of
49 CFR 172.304? Yes No
(06/87)
-------
F-13
Table F-2 (cont.)
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found,
contact the nearest police or public safety authority or the U.S. Environ-
mental Protection Agency.
Generator's Name and Address:
Manifest Document Number:
f. Did generator placard or offer the initial
transporter the appropriate placards according
to DOT (49 CFR 172, Subpart F)? Yes No
F. Emergency Action
1. Has transporter ever been involved in a dis-
charge of hazardous wastes? Yes No
a. If yes, was the National Response Center
(800-424-8802 or 202-426-2675), U.S.
Coast Guard, the State and the principal
office of transporter notified? Yes No
b. Was a written report submitted to DOT
within 10 days following the discharge Yes No
Attach copy of report (if available).
2. Has the transporter obtained an Emergency
Identification Number from EPA for the
cleanup operation? Yes No
a. If yes, identify the number(s):
G. Transport Vehicle Inspection
1. Company/name/designation of vehicle:
2. Truck driver's name:
3. What hazardous wastes are listed on manifest? List in narrative
explanation.
4. Form of containerization of hazardous wastes:
drums, size: gallons (ea), amount (i.e., 30 drums)
portable tanks - number volume (ea)
gondola
tanker-type volume (ea)
(06/87)
-------
F-14
Table F-2 (cont.)
5. Narrative explanation of condition of containerization (leaking,
corroded, fuming, damaged, improperly sealed, poor condition,
improper lining, etc.)
6. Is truck properly placarded and marked
(49 CFR Subpart F)? Yes No
7. Did generator have to repackage wastes by
truck driver's request? Yes No
8. Is truck driver aware of any special handling
of materials? Yes No
If yes, describe.
9. Does truck driver have the National Response
Center phone number accessible? Yes No
COMMENTS:
(06/87)
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F-15
Table F-3
RCRA COMPLIANCE INSPECTION REPORT
TREATMENT, STORAGE AND DISPOSAL FACILITIES (TSDFs)
CHECKLIST FOR INTERIM STATUS FACILITIES (PART 265)
SECTION A - GENERAL FACILITY STANDARDS
1. Does facility have EPA identification number
(§265.11)? Yes No
a. If yes, EPA identification number:
If no, explain:
2. Has facility received hazardous waste from a
foreign source (§265.12)? Yes No
a. If yes, has he filed a notice with the
Regional Administrator 4 weeks in advance
of the initial shipment? Yes No
Waste Analysis
3. Does the facility have a written waste analysis
plan (§265.13)? Yes No
a. If yes, is a copy maintained at the facility? Yes No
If no, proceed to question 5.
4. Does the plan include:
a. Parameters for which each waste will be analyzed? Yes No
b. Rationale for the selection of these parameters? Yes No
c. Test methods used to test for these parameters? Yes No
d. Sampling method used to obtain sample? Yes No
e. Frequency with which the initial analysis will
be reviewed or repeated? Yes No
(1) If yes, does it include requirements to
re-test when the process or operation
generating the waste has changed? Yes No
f. (For offsite facilities) Waste analyses that
generators have agreed to supply? Yes No
(06/87)
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F-16
Table F-3 (cont.)
(For offsite facilities) Procedures which are
used to inspect and analyze each movement of
hazardous waste including:
(1) Procedures to be used to determine the
identity of each movement of waste? Yes No
(2) Sampling method to be used to obtain
representative sample of the waste to
be identified? Yes No
Security
5. Does the facility provide adequate security to mini-
mize the possibility for the unauthorized entry of
persons or livestock onto the active portions of the
facility (§265.14)? Yes No
If no, describe inadequacies. (Use narrative explanation sheet and
include a drawing indicating any inadequacies in the facility's
security system.)
If yes, is security provided through:
a. 24-hour surveillance system (e.g., television
monitoring or guards)? Yes No
OR
b. (1) Artificial or natural barrier around
facility (e.g., fence or fence and cliff)? Yes No
Describe type of security:
AND
(2) Means to control entry through entrances
(e.g., attendant, television monitors,
locked entrance, controlled roadway
access)? ;Yes No
Describe type of security:
6. Is a sign with the legend, "Danger-Unauthorized
Personnel Keep Out", posted at the entrance to the
active portion of the facility? Yes No
Is it written in English and legible from at least
25 feet? Yes No
(06/87)
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F-17
Table F-3 (cont.)
Note: The sign must also be written in any other language predominant in
the area surrounding the facility (e.g., in New Mexico and Texas areas bord-
ering Mexico, the sign must be in Spanish).
If a sign exists with a legend other than "Danger-Unauthorized
Personnel Keep Out", what does that legend say?
General Inspection Requirements
7. a. Does the owner/operator maintain a written
schedule for inspecting (§265.15)? Yes No
(1) Monitoring equipment, if applicable? Yes No
(2) Safety and emergency equipment? Yes No
(3) Security devices? Yes No
(4) Operating and structural equipment, if
applicable? Yes No
(5) Does the schedule or plan identify the
types of problems to be looked for during
inspection? Yes No
(a) Malfunction or deterioration (e.g.,
inoperative sump pump, leaking fitting,
eroding dike, corroded pipes or tanks,
etc.)? Yes No
(b) Operator error? Yes No
(c) Discharges (e.g., leaks from valves
or pipes, joint breaks, etc.)? Yes No
b. Is a written schedule for these inspections
maintained at the facility? Yes No
(1) Are records of these inspections
maintained in an inspection log
(§265.15)? Yes No
(2) If yes, does it include:
(a) Date and time of inspection? Yes No
(b) Name of inspector? Yes No
(06/87)
-------
F-18
Table F-3 (cont.)
(c) Notation of observations? Yes No
(d) Date and nature of repairs or reme-
dial action? Yes No
(3) Are there any malfunctions or other defi-
ciencies noted in the inspection log that
remain uncorrected? Use narrative explana-
tion sheet. Yes No
(4) Are records of the inspection log maintained
at the facility for at least 3 years? Yes No
(Obtain copies of incomplete or inadequate
inspection records.)
Personnel Training
8. Does the owner/operator maintain a personnel
training program (§265.16)? Yes No
a. If yes,
(1) Is the program directed by a person
trained in hazardous waste manage-
ment procedures? Yes No
(2) Is the program designed to prepare
employees to respond effectively to
hazardous waste emergencies? Yes No
(3) Is a training review given annually? Yes No
c. Does the owner/operator keep the following
records:
(1) Job title and written job description
of each position? Yes No
(2) Description of the type and amount of
introductory and continuing training? Yes No
(3) Documentation that training has been
given to employees? Yes No
c. Are these records maintained at the
facility? Yes No
(06/87)
-------
F-19
Table F-3 (cont.)
Requirements for Ignitable, Reactive or Incompatible Waste
9. Does facility handle ignitable or reactive
waste (§265.17)? Yes No
a. If yes, is waste separated and confined
from sources of ignition or reaction? Yes No
b. Are "No Smoking" signs posted in hazardous
areas where ignitable or reactive wastes
are handled? Yes No
10. Observe containers (§265.17)
a. Are containers leaking, corroding or
bulging? Yes No
Use narrative explanation sheet to describe containers in
this condition.
b. Has the facility ever placed incompatible
wastes together? Yes No
If yes, what were the results? Use narrative explanation
sheet. Look for signs of mixing of incompatible wastes
(e.g., fire, toxic mist, heat generation, bulging con-
tainers, etc.).
SECTION B - PREPAREDNESS AND PREVENTION
1. Is there evidence of fire, explosion or contamination
of the environment (§265.31)? Yes No
If yes, use narrative explanation sheet to explain.
2. Is the facility equipped with (§265.32)?
a. Easily accessible internal communications or alarm
system? Yes No
b. Telephone or two-way radio to call emergency
response personnel? Yes No
c. Portable fire extinguishers, fire control
equipment, spill control equipment and
decontamination equipment? Yes No
(1) Is this equipment tested and maintained as
necessary to assure its proper operation?
(Note last inspection/test date.) Yes No
(06/87)
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F-20
Table F-3 (cont.)
d. Water of adequate volume for hoses, sprinklers
or water spray system? Yes No
(1) Describe source of water
(2) Indicate flow rate and/or pressure and storage capacity,
if applicable.
3. Is there sufficient aisle space to allow unobstructed
movement of personnel and equipment (§265.35)? Yes ' No
4. Has the owner/operator made arrangements with the
local authorities to familiarize them with charac-
teristics of the facility (§265.37)? Yes No
If no, has the owner/operator attempted to make
such arrangements? Yes No
5. In the case that more than one police or fire
department might respond, is there a designated
primary authority (§265.37)? Yes No
If yes, indicate primary authority:
a. Is the fire department a city, volunteer or onsite fire department?
6. Does the owner/operator have phone numbers of and
agreements with State emergency response teams,
emergency response contractors and equipment
suppliers? Yes No
Are they readily available to the emergency
coordinator (§265.37)? Yes No
7. Has the owner/operator arranged to familiarize
local hospitals with the properties of hazardous
waste handled and typed of injuries that could
result from fires, explosions or releases at the
facility? Yes No
If no, has the owner/operator attempted to do this
(§265.37)? Yes No
8. If the State or local authorities decline to enter
into the above-referenced agreements, is there
documentation of this (§265.37)? Yes No
(06/87)
-------
F-21
Table F-3 (cont.)
SECTION C - CONTINGENCY PLAN AND EMERGENCY PROCEDURES
1. Does the facility have a contingency plan (§265.52)? Yes No
a. If yes, does it contain:
(1) Actions to be taken in response to
emergencies? Yes No
(2) Description of arrangements with police,
fire and hospital officials? Yes No
(3) List of names, addresses, phone numbers
of personnel qualified to act as emergency
coordinator? Yes No
(4) List of all emergency equipment at the
f aci 1 i ty? Yes No
(5) Evacuation plan for facility personnel? Yes No
2. Is a copy of the contingency plan maintained at the
facility (§265.53)? Yes No
3. Has a copy been supplied to local police and fire
departments (§265.53)? Yes No
4. Is the plan a revised SPCC plan (§265.52)? Yes No
5. Is there an emergency coordinator onsite or within
short driving distance of the plant at all times? Yes No
If yes, list primary emergency coordinator:
SECTION D - MANIFEST SYSTEM, RECORDKEEPING AND REPORTING
1. Has facility received hazardous waste from offsite
since November 19, 1980 (§265.71)? Yes No
If no, proceed to question 5.
If yes, does the facility retain copies of all
manifests? (Inspect manifests at random, indicate
number inspected, describe deficiencies and obtain
copies of all deficient manifests.) Yes No
2. Has the facility received any hazardous waste from
a rail or water (bulk shipment) transporter since
November 19, 1980 (§265.71)? Yes No
(06/87)
-------
F-22
Table F-3 (cont.)
a. If yes, is it accompanied by a shipping paper? Yes No
(1) Has the owner/operator signed and dated the
shipping paper and returned a copy to the
generator? Yes No
(2) Is a signed copy given to the transporter? Yes No
3. Has the facility received any shipments of hazardous
waste since November 19, 1980, which were inconsistent
with the manifest (§265.72)? Yes No
a. If yes, has he resolved the discrepancy with
the generator and transporter? Yes No
b. If no, has Regional Administrator been
notified? Yes No
4. Has the facility received any waste (that does
not come under the small generator exclusion)
not accompanied by a manifest (§265.76)? Yes No
If yes, has facility submitted an unmanifested
waste report to the Regional Administrator? Yes No
5. Does the facility have a written operating record
(§265.73)? Yes No
a. Is a copy maintained at the facility? Yes No
b. Does the record include:
(1) Description and quantity of each hazardous
waste and the methods and dates of its
treatment, storage or disposal at the
facility? Yes No
(2) Location and quantity of each hazardous
waste? Yes No
(a) Is this information cross-referenced
with specific manifest document
numbers, if applicable? Yes No
(3) Location and quantity of each hazardous
waste recorded on a map or diagram of
each cell or disposal area (for disposal
facilities only)? Yes No
(4) Record and results of waste analyses? Yes No
(06/87)
-------
F-23
Table F-3 (cont.)
(5) Reports of incidents involving imple-
mentation of the contingency plan (if
applicable)? Yes No
(6) Records and results of required
inspections? Yes No
(7) Monitoring, testing or analytical data
where required? Yes No
(8) Closure cost estimates and, for land disposal
facilities, post-closure cost estimates? Yes No
SECTION E - PLANS AND REPORTS
1. Have all plans and reports been visually inspected
and/or been made available for inspection (§265.74)? Yes No
List plans and/or reports not made available for inspection.
2. Did operator provide inspector with a drawing of
the facility? Yes No
If yes, identify which are hazardous waste management units on the
drawing.
3. Indicate which of the following apply to wastes managed by this
facility:
Groundwater Monitoring Program (Subpart F) [Table F-4]
Containers (Subpart I) [Table F-5]
Tanks (Subpart J) [Table F-6]
Surface Impoundments (Subpart K) [Table F-7]
Waste Piles (Subpart L) [Table F-8]
Land Treatment (Subpart M) [Table F-9]
Landfill (Subpart N) [Table F-10]
Incinerator (Subpart 0) [Table F-ll]
Thermal Treatment (Subpart P) [Table F-12]
Chemical, Physical and Biological Treatment (Subpart Q)
[Table F-13]
Underground Injection (Subpart R) [Appendix M]
(06/87)
-------
F-24
Table F-4
GROUNDWATER MONITORING
1. Is the facility operating under
a. Interim status Yes No
b. RCRA permit (or State equivalent) Yes No
2. Has the facility implemented a groundwater monitoring
program under
a. Interim status Yes No
b. RCRA Permit (or State equivalent) Yes No
3. Has a waiver demonstration been prepared? Yes No
a. Does it describe the potential for migration of
waste from the waste management unit to the upper-
most aquifer? Yes No
b. Does it describe the potential for waste to enter
a water supply or surface water? Yes No
c. Is it certified by a qualified geologist or geo-
technical engineer? Yes No
4. Have required monitoring reports been submitted to
EPA and/or the State? Yes No
5. Has an adequate hydrogeologic characterization investi-
gation been conducted at the facility? Yes No
a. Has the uppermost aquifer been adequately defined? Yes No
b. Have flow directions been adequately defined for
the uppermost aquifer? Yes No
c. Have groundwater flow rates been determined for
hydrologic units within the uppermost aquifer? Yes No
6. Has the facility developed and implemented an operation
and maintenance plan for the monitoring well network
and sampling equipment? Yes No
(06/87)
-------
F-25
Table F-4 (cont.)
INTERIM STATUS PROGRAMS
7. Did the facility initially implement a detection
monitoring program (40 CFR 265.92) or an assessment
monitoring program (40 CFR 265.93)? Yes No
8. If a detection monitoring program was implemented,
a. Was a sampling and analysis plan prepared? Yes No
b. Was a sampling and analysis plan in effect on
November 19, 1981? Yes No
c. Did the program include upgradient wells not
apparently affected by the facility? Yes No
d. Did the program include at least four down-
gradient wells at the limit of the waste manage-
ment area(s)? Yes No
9. Sampling and Analysis Plan
a. Is the sample collection adequately described? Yes No
b. Is the sample preservation adequately described? Yes No
c. Is the sample shipping adequately described? Yes No
d. Are the analytical procedures specifically
identified? Yes No
e. Is the sample chain-of-custody adequate? Yes No
f. Are the quality assurance/quality control
procedures identified? Yes No
g. Are parameters to be analyzed for those specified
in 40 CFR 265.92(b)? Yes No
h. Does the,pi an contain a sampling schedule? Yes No
i. Does the schedule conform to regulatory
requirements? Yes No
10. If an assessment monitoring program was implemented,
a. Did the notification of the Regional Administrator
or State Director comply with 40 CFR 265.93(d)? Yes No
(06/87)
-------
F-26
Table F-4 (cont.)
b. Did submittal of the plan comply with 40 CFR
265.93(d)? Yes No
c. Was it certified by a qualified geologist or a
geotechnical engineer? Yes No
d. Was it approved by EPA or the State? Yes No
e. Does it determine the rate and extent of waste
migration? Yes No
f. Does it determine the concentrations of waste
constituents in groundwater? Yes No
g. Has a groundwater quality assessment report
been submitted? Yes No
h. Does the facility keep records on the results of
analyses and evaluations? Yes No
RCRA PERMIT PROGRAMS
11. Which of the following programs are required by the
permit? Yes No
a. Detection monitoring (40 CFR 264.98) Yes No
b. Compliance monitoring (40 CFR 264.99) Yes No
c. Corrective action (40 CFR 264.100) Yes No
12. Have sampling and analysis plans been developed for
the required groundwater monitoring program(s)? Yes No
a. Has the required plan(s) been approved by EPA
or the State? Yes No
b. Has the program been implemented? Yes No
c. Are the selected monitoring parameters adequate? Yes No
d. Is the point of compliance properly located? Yes No
e. Is the delineation of waste management areas
appropriate? Yes No
(06/87)
-------
F-27
Table F-4 (cont.)
f. Is leakage from non-regulated units expected to
affect groundwater quality at the point of
compliance? Yes No
g. Have any groundwater samples been analyzed for
Appendix VIII parameters (40 CFR 261)? Yes No
MONITORING WELLS
13. Are wells
a. Adequately designed Yes No
b. Properly constructed Yes No
c. Appropriate materials used Yes No
d. Located as indicated on map in sampling plan Yes No
e. Marked with proper identifying designation Yes No
f. Installed in appropriate hydrologic zones Yes No
g. Secured from unauthorized entry Yes No
h. Protected from damage by vehicular traffic Yes No
i. Surveyed for elevation Yes No
j. Marked for surveyed point _Yes No
14. Are the locations and numbers of wells adequate to
satisfy the requirements of 40 CFR 265.91 for interim
status facilities or 40 CFR 264.97 for permitted
facilities? Yes No
15. Are the wells being adequately maintained? Yes No
16. Are the wells accessible year round? Yes No
MONITORING PROCEDURES
17. Are adequate field procedures being used for
a. Measuring depth to water Yes No
(06/87)
-------
F-28
Table F-4 (cont.)
b. Purging the well before sampling Yes No
c. Measuring pH, conductivity and temperature Yes No
d. Other field parameters Yes No
e. Collecting samples Yes No
f. Preserving samples Yes No
g. Cleaning reused equipment between wells Yes No
h. Storing samples after collection Yes No
i. Disposal of purge water Yes No
j. Monitoring for vapors and radiation Yes No
18. Is the field crew adequately trained for sampling? Yes No
19. Are the records kept during sampling adequate? Yes No
20. Are sampling and analysis plan procedures being
followed for:
a. Approaching the well Yes No
b. Opening the well Yes No
c. Measuring the water level Yes No
d. Purging the well Yes No
e. Collecting samples Yes No
f. Preserving samples Yes No
g. Chain-of-custody Yes No
h. Documenting sampling Yes No
i. Shipping samples Yes No
(06/87)
-------
F-29
Table F-5
CONTAINER STORAGE CHECKLIST
(Subpart I)
1. Does the facility store hazardous waste in containers? Yes No
2. Are the containers marked "Hazardous Waste" or equiv-
alent to identify the contents? Yes No
3. Are the containers in good condition (check for
leaks, corrosion, bulges, etc.)? Yes No
If no, explain in narrative and document with photograph.
4. If a container is found to be leaking, does the
operator transfer the hazardous waste from the
leaking container? Yes No
5. Is the waste compatible with the containers and/or
its liner? Yes No
If no, explain in narrative.
6. Are the stored containers closed? Yes No
If no, explain in narrative.
7. Are containers holding hazardous waste opened, handled
or stored in such a manner as to cause the container
to rupture or leak? Yes No
8. Does facility have records that the containers are
inspected at least weekly? Yes No
If no, explain in the narrative the frequency of inspection.
9. Are containers holding ignitible or reactive wastes
located at least 15 meters (50 feet) from the
facility property line? Yes No
If no, explain in narrative and document with photograph.
10. Are incompatible wastes stored in the same containers? Yes No
11. Are containers holding incompatible wastes kept apart
by physical barrier or sufficient distance? Yes No
If no, explain in narrative and document with photograph(s).
12. Does the facility have satellite storage at the
point of hazardous waste generation §262.34 (C)(l)? Yes No
(06/87)
-------
F-30
Table F-5 (cont.)
13. Do the containers at any one generation point
exceed 55 gallons of hazardous waste or 1 quart of
acutely hazardous wastes? Yes No
14. If yes, in the previous question:
(a) Is the container holding the excess
wastes marked with the date the excess
amount began accumulating? Yes No
(b) Has this excess waste been accumulating
for more than 3 days? Yes No
15. Are these points at or near the process generating
the waste? Yes No
(0$/87)
-------
F-31
Table F-6
TANKS CHECKLIST
(Subpart J)
NOTE: List each tank and specify compliance status. Complete an individual
checklist for each tank. [Collective checklist(s) may be used for all simi-
lar tanks in compliance.] This checklist does not apply to covered under-
ground tanks that cannot be entered for inspection.
1. Are there any tanks which are not being used which
the facility no longer plans to use? Yes No
a. If yes, has all hazardous waste and hazardous
waste residue been removed from these tanks,
discharge control equipment, and discharge
confinement structures? Yes No
2. Are tanks presently used to treat or store waste? Yes No
a. If no, do not complete rest of form.
b. If yes, inspect tanks.
3. Is there evidence that wastes placed in the tank
are incompatible with the tank or liner? Yes No
Note any evidence of ruptures, leaks or corrosion. Use narrative
explanations sheet.
4. Are there any uncovered tanks? Yes No
a. If no, do not complete 4b thru e.
b. If yes, do they have 2 feet (60 cm) freeboard? Yes No
OR
c. A containment structure (e.g., dike or trench)? Yes No
OR
d. A drainage control system? Yes No
OR
e. A diversion structure (e.g., standby tank)? Yes No
NOTE: The structure in c, d or e must have a capacity that equals or exceeds
the volume of the top 2 feet (60 cm) of the tank.
(06/87)
-------
F-32
Table F-6 (cont.)
If the answers to 4b thru e are "no", explain current conditions using
narrative sheets.
5. Are any of the tanks continuous feed? Yes No
a. If yes, is it equipped with a means to stop
flow (e.g., waste feed cutoff or bypass to
a standby tank)? Yes No
Waste Analysis
6. Is the tank used to store one waste exclusively? Yes No
a. If no, what are the different wastes stored in
the tank? Use narrative explanation sheet.
(1) Are waste analyses and trial tests con-
ducted on these wastes? Yes No
OR
Does the owner/operator have written
documented information on similar treat-
ment of similar wastes under similar
operating conditions? Yes No
(2) Is this information retained in the
operating record? Yes No
Inspections
7. Does the owner/operator inspect the following at
least daily, where present: (Indicate which items
are present in 7 and 8.)
a. Discharge control equipment (e.g., waste feed
cutoff, bypass and/or drainage systems)? Yes No
b. Data gathered from monitoring equipment (e.g.,
pressure and temperature gages)? Yes No
c. Level of waste in each uncovered tank? Yes No
8. Does the owner/operator inspect the following at
least weekly:
a. Construction materials of tanks for corrosion
or leaks? Yes No
b. Construction materials of and area surrounding
discharge confinement structures for erosion
or signs of leakage? Yes No
(06/87)
-------
F-33
Table F-6 (cont.)
9. What is the procedure for assessing the condition
of the tank(s)? Explain in narrative (e.g., how
does the procedure allow for detection of cracks,
leaks or corrosion or procedures for emptying the
tank to allow entrance, etc.).
10. Does the facility have a closure plan? Yes No
a. Does the plan address the closure of each
tank? Yes No
If no, explain in narrative.
b. Is the plan maintained at the facility? Yes No
11. Are ignitable or reactive wastes placed in tanks? Yes No
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
tank so it no longer meets the definition of
ignitable or reactive? Yes No
OR
b. Is the waste protected from sources of igni-
tion or reaction?
(1) If yes, use narrative explanations sheet
to describe separation and confinement
procedures.
(2) If no, use narrative explanations sheet
to describe sources of ignition or
reaction.
OR
c. Is the tank used solely for emergencies? Yes No
12. Has the facility ever placed incompatible wastes
in the tank? Yes No
a. If yes, what were the results. Use narrative
explanations sheet. Look for signs of mixing
of incompatible wastes (e.g., fire, toxic mist,
heat generation, bulging containers, etc.).
(06/87)
-------
F-34
Table F-6 (cont.)
13. If a waste is to be placed in a tank that previously
held an incompatible waste, was that tank washed? Yes No
a. If yes, describe washing procedures. Use
narrative explanation sheet.
Describe how it is possible for incompatible
wastes to be placed in the same tank. Use
narrative explanations sheet.
(06/87)
-------
F-35
Table F-7
SURFACE IMPOUNDMENTS CHECKLIST
(Subpart K)
NOTE: List each surface impoundment and specify compliance status. Complete
an individual checklist for each impoundment. [Collective checklist(s) may
be used for all similar impoundments.]
I. Are there any surface impoundments which are not
being used which the facility does not plan to
use in the future? Yes No
a. If yes, has all hazardous waste and hazardous
waste residue been removed from the
impoundment? Yes No
2. Are impoundments presently used to treat or store
waste? Yes No
3. Has any new unit, replacement of an existing unit
or lateral expansion of an existing unit that is
within the area identified in the Part A, received
waste beginning 05/08/85? Yes No
a. If no, go to question 4.
b. If yes,
(1) Did the facility notify the Regional
Administrator (RA) 60 days prior to
receiving waste? Yes No
(2) Did the facility file a Part B within
6 months of receipt of such notice? Yes No
c. Does the impoundment have at least two liners
and a leachate collection system? Yes No
If no, use narrative explanation to describe alternate system or,
if waiver was granted, demonstration to RA (§265.221).
4. Does the impoundment have at least 2 feet (60 cm)
of freeboard? Yes No
If no, what is the freeboard?
5. Is there evidence of overtopping of the dike? Yes No
If yes, describe.
(06/87)
-------
F-36
Table F-7 (cont.)
6. What type of dike (e.g., earthen, concrete, steel) does the impound-
ment have?
a. If the dike is earthen, does it have adequate
protective cover (e.g., grass, shale, rock) to
minimize wind and water erosion? Use narrative
explanation sheet to explain deficiencies. Yes No
b. Describe dike and its condition.
7. What wastes are treated or stored in the impoundment? Use narrative
explanations sheet.
8. Are hazardous wastes chemically treated in the
impoundment? Yes No
a. If yes:
(1) Are waste analyses and trial tests
conducted on these wastes? Yes No
(2) Does the owner/operator have written
documented information on similar treat-
ment of similar wastes under similar
operating conditions? Yes No
b. Is this information retained in the operating
record? Yes No
9. Do records indicate that freeboard level is inspected
daily? Yes No
10. Do records indicate the impoundment, dike and sur-
rounding vegetation are inspected to detect leaks,
deterioration or failures at least once a week? Yes No
11. Does the facility maintain a record of the closure
plan on site? Yes No
12. Are ignitable or reactive wastes placed in the
impoundment? Yes No
a. If no, proceed to question 13.
b. If yes, are they treated, rendered or mixed
before or immediately after placement in the
impoundment so they no longer meet the defini-
tion of ignitable or reactive? Yes No
(06/87)
-------
F-37
Table F-7 (cont.)
OR
c. Are the wastes protected from possible ignition or
reaction sources and certified as such by a qualified
chemist? Use narrative explanation sheet to describe
situation. Yes No
OR
d. Is the impoundment used solely for emergencies? Yes No
(1) If yes, has treatment, storage or disposal
been conducted on these wastes? Describe
this situation. Yes No
13. Has the facility ever placed incompatible wastes in
the impoundment? Yes No
a. If yes, what were the results. Use narrative
explanation sheet. Look for signs of mixing
of incompatible wastes (e.g., fire, toxic mist,
heat generation, bulging containers, etc.).
14. What is the impoundment lined with?
15. Does the impoundment solely neutralize corrosive
waste or waste listed in Subpart I solely
because of corrosivity? Yes No
(06/87)
-------
F-38
Table F-8
WASTE PILES CHECKLIST
(Subpart L)
NOTE: Waste piles may also be managed as a landfill.
1. Is the pile containing hazardous waste protected
from wind? Yes No
2. For offsite facilities, is a representative sample of
waste from each incoming shipment analyzed before
the waste is added to the pile to determine the
compatibility of the wastes? Yes No
a. For offsite facilities, does the analysis include
a visual comparison of color and texture? Yes No
3. Is the leachate or runoff from the pile considered
a hazardous waste? Yes No
a. If yes, is the pile managed with following?
(1) An impermeable base compatible with the
waste? Yes No
(2) Run-on diversion? Yes No
(3) Leachate and runoff collection? Yes No
OR
b. Is the pile protected from precipitation and
run-on by some other means? Yes No
Describe on narrative explanations sheet.
4. Are liquids or wastes containing free liquids placed
in the pile? Yes No
5. Are ignitable or reactive wastes placed in the pile? Yes No
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
pile so it no longer meets the definition of
ignitable or reactive? Use narrative sheet
to describe procedure. Yes No
OR
b. Is the waste protected from sources of ignition
or reaction? Yes No
(06/87)
-------
F-39
Table F-8 (cont.)
(1) If yes, use narrative explanations sheet
to describe separation and confinement
procedures.
(2) If no, use narrative explanations sheet
to describe source of ignition or
reaction.
6. Is there evidence of fire, explosion, gaseous
emissions, leaching or other discharge from the
hazardous waste pile? Use narrative explanation
sheet. Yes No
a. Does the waste pile have a leachate detection,
collection and removal system? Yes No
b. If no, does the inspection plan include a
schedule of inspection of the devices for
controlling precipitation and run-on and
runoff? Yes No
c. Is the waste pile periodically removed for
inspection of the base? Yes No
7. Have incompatible wastes ever been placed together
in the waste pile? Yes No
If yes, what was the result?
8. Have there been other wastes previously stored at
the site of the present waste pile? Yes No
a. Have hazardous wastes been piled in the same
area where incompatible wastes or materials
were previously piled? Yes No
b. If yes, was the area decontaminated? Use
narrative explanation sheet. Yes No
9. Is a closure plan available? Yes No
a. Will all waste residues, system components,
subsoils, etc., be decontaminated and/or
removed? Yes No
b. If the above cannot be decontaminated, will
the facility be closed as a landfill? Yes No
(06/87)
-------
F-40
Table F-9
LAND TREATMENT CHECKLIST
(Subpart M)
1. Is run-on diverted away from the land treatment
facility? Yes No
Describe using narrative explanations sheet.
2. Is runoff from the land treatment facility collected? Yes No
3. Is the runoff analyzed to see if it is a hazardous
waste? Yes No
a. If the runoff is considered hazardous, how is
it handled? Use narrative explanation sheet. Yes _No
b. If it is not a hazardous waste, is it
discharged through a point source to
surface waters? Yes No
(1) If yes, list NPDES Permit No.
4. Is wind dispersal controlled? Yes No
Describe using narrative explanations sheet.
5. What hazardous wastes are treated at the land treatment facility?
Use narrative explanation sheet.
Part 261, Subpart D Listed Wastes Characteristic Wastes
a. For those listed wastes, were analyses done
to determine the concentrations of those
constituents which caused the waste to be
listed? Yes No
(1) If yes, what are these concentrations? Use narrative
explanation sheet.
b. For those characteristic wastes designated EP toxic because of the
extraction procedure, what are the concentrations of the
following?
Concentration Waste
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
(06/87)
-------
F-41
Table F-9 (cont.)
Concentration
Endrin
Lindane
Methoxychlor
Toxaphene
2,4 D
2,4,5-TP Silvex
6. Obtain a copy of the land treatment process and
include it with the report.
7. Are food chain crops grown?
a. If no, go to question 9.
b. If yes, can the owner/operator demonstrate
from field testing that arsenic, lead, mercury
or other toxic waste constituents:
(1) Will not be transferred to the food
portion of the crop or ingested by
food chain animals
OR
(2) Will not occur in greater concentrations
in the crops on the facility than in the
same crops on untreated soils in the
same region?
c. Is the following information used for making
the above demonstration and is it kept at
the facility?
(1) Tests for specific wastes and application
rates being used at the facility
(2) Crop characteristics
(3) Soil characteristics
(4) Sample selection criteria
(5) Sample size determination
(6) Analytical methods used
(7) Statistical procedures
Waste
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
_No
No
No
No
No
No
(06/87)
-------
F-42
Table F-9 (cont.)
d. Was the Regional Administrator notified by
January 19, 1981 that food chain crops had
been or would be grown at the facility? Yes No
e. Does the facility treat wastes that contain
cadmium? Yes No
(1) If no, go to question 9.
(2) If yes, list these wastes. Use narrative
explanation sheet.
(3) Was the pH of the soil and waste mixture
6.5 or greater at the time of each waste
application? Yes No
(a) If the pH was less than 6.5, did the
waste contain cadmium concentrations
of 2 mg/kg (dry weight) or less? Yes No
(4) Is the annual application rate of cadmium
less than 0.5 kg/ha (kilograms per
hectare) for the following: tobacco,
leafy vegetables, or root crops grown for
human consumption? Yes No
(a) For all other food chain crops, is
the annual cadmium application rate :
(1) Less than or equal to 2.0 kg/ha
(through June 30, 1984) Yes No
(2) Less than or equal to 1.25 kg/ha
(July 1, 1984 through December 31,
1986) Yes No
(3) Less than or equal to 0.5 kg/ha
(January 1, 1987 to present) Yes No
8. Does the facility have an unsaturated zone monitor-
ing plan? Yes No
a. If no, explain circumstances on narrative explanation sheet.
b. If yes, does the plan include:
(1) Soil monitoring Yes No
(2) Soil pore water monitoring (water above
the saturated zone) Yes No
(06/87)
-------
F-43
Table F-9 (cont.)
(3) Sample depths below waste incorporation Yes No
(4) Number of samples to be taken Yes No
(5) Frequency and time of sampling Yes No
(6) Analysis of soil samples Yes No
9. Does implementation of the plan yield:
a. Background soil-pore liquid quality and chemical
makeup of soil not affected by treatment zone
leakage Yes No
b. The quality of soil-pore liquid and chemical
makeup of soil below the treatment zone Yes No
10. Have background levels of soil quality been
established? Yes No
11. Is monitoring occurring in the soil-pore zone
immediately below the treatment zone? Yes No
12. Has a sampling and analysis plan been prepared and
does it include:
a. Sample collection techniques Yes No
b. Sample preservation and shipment Yes No
c. Analytical procedures Yes No
d. Chain-of-custody control Yes No
13. Has a statistically significant change over back-
ground been found in the soil quality? Yes No
a. If yes, has the RA or State been notified? Yes No
b. Have operating practices been modified? Yes No
14. Is the following information (for each hazardous
waste) kept at the facility?
a. Application dates Yes No
b. Application rates Yes No
c. Quantities Yes No
d. Waste location Yes No
(06/87)
-------
F-44
Table F-9 (cont.)
15. Does the facility have a closure/post-closure plan? Yes No
a. If yes, where is it kept?
16. Are ignitable or reactive wastes treated at the
facility? (circle appropriate waste) Yes No
a. If yes, are the wastes immediately incorporated
into the soil so that they are no longer
reactive or ignitable? Yes No
b. Describe or attach a copy of treatment.
17. Are incompatible wastes placed in the facility? Yes No
a. Are the incompatible wastes placed in different
locations in the facility? Yes No
(1) If no, look for signs of fire, heat generation, toxic mists,
etc. (use narrative explanation sheet).
(06/87)
-------
F-45
Table F-10
LANDFILLS CHECKLIST
(Subpart N)
1. Has any new unit, replacement of an existing unit
or lateral expansion of an existing unit that is
within the area identified in the Part A, received
waste after 05/08/85? Yes No
a. If no, proceed to question 4.
b. If yes,
(1) Did the facility notify the Regional
Administrator 60 days prior to receiving
waste? Yes No
(2) Did the facility file a Part B within
6 months of receipt of such notice? Yes No
c. Does the landfill have at least two liners
and a leachate collection system? Yes No
If no, use narrative explanation sheet to describe alternate
system, or, if waiver was granted, to describe demonstration
to Regional Administrator (§265.301).
2. Is there a run-on control system? Yes No
Describe on narrative explanations sheet.
3. Is runoff from the landfill collected? Yes No
a. Is runoff analyzed to determine if it is a
hazardous waste? Yes No
b. If it is a hazardous waste, how is it managed?
(Use narrative explanation sheet.)
c. Is the collected runoff discharged through
a point source to surface waters? Yes No
If yes, list NPDES permit number
4. Is the landfill managed so that wind dispersal is
controlled? (Note blowing debris.) Yes No
5. Is the following information maintained in the
operating record? Yes No
a. On a map, the exact location and dimensions,
including depth of each cell with respect to
permanently surveyed benchmarks? Yes No
(06/87)
-------
F-46
Table F-10 (cont.)
AND
b. Contents of each cell and the approximate
location of each hazardous waste type
within each cell? Yes No
6. Are reactive or ignitable wastes placed in the
landfill? Yes No
a. If yes, are they treated, rendered or mixed before
or immediately after placement in the landfill
so they are no longer reactive or ignitable? Yes No
b. Describe treatment, etc. or attach a copy of treatment.
7. Are incompatible wastes placed in the same landfill
cell? Yes No
a. If yes, what are the results? (Use narrative
explanation sheet.) (Look for signs of mixing
of incompatible wastes, e.g., fire, toxic mist,
heat generation, etc.)
Describe how it is possible for incompatible wastes
to be placed in the same landfill cell. (Use
narrative explanation sheet.)
8. Have bulk or non-containerized, hazardous liquid
wastes or wastes containing free liquids been placed
in the landfill since May 8, 1985? Yes No
9. Is the liquid waste treated chemically or
physically so that free liquids are no longer
present? (Use narrative explanation sheet.) Yes No
10. Are containers holding liquid wastes placed in the
landfill? Yes No
If yes,
a. Has all free-standing liquid been removed? Yes No
OR
b. Has waste been mixed with absorbent or solidified
so that free-standing liquid is no longer
observed? Yes No
OR
c. Is the container very small, such as an ampule? Yes No
(06/87)
-------
F-47
Table F-10 (cont.)
OR
d. Is the container designed to hold free liquids
for use other than storage, such as a battery
or capacitor? Yes No
OR
e. Is the container a lab pack? Yes No
11. Are empty containers placed in the landfill? Yes No
a. If yes, are they reduced in volume (e.g.,
shredded, crushed)? Yes No
12. Does the landfill or cell(s) have a cover? Yes No
a. If no, go to question 12.
b. If yes, answer the following:
(1) Is there evidence of site instability
(e.g., erosion, settling)? (Use narrative
explanation sheet.) Yes No
(2) Is there evidence of ponding of water onsite?
(Use narrative explanation sheet.) Yes No
(3) Is there any indication of improper or inadequate
drainage? (Use narrative explanation sheet.) Yes No
13. Does the facility have closure/post-closure plans? Yes No
a. If yes, where are they maintained?
b. Do the plans address the following items?
(1) Control of pollutant migration? Yes No
(2) Control of surface water infiltration? Yes No
(3) Prevention of erosion? Yes No
(06/87)
-------
F-48
Table F-ll
INCINERATORS CHECKLIST
(Subpart 0)
1. Is the incinerator operating at steady state
conditions (temperature and air flow) before adding
hazardous waste? Yes No
If no, explain in narrative.
2. Is a waste analysis performed on hazardous waste not
previously incinerated at facility? Yes No
3. Does it include analysis for the following?
a. Heating value Yes No
b. Halogen content Yes No
c. Sulfur content Yes No
d. Concentration of lead Yes No
e. Concentration of mercury Yes No
f. Is the above information documented in the
operating record? Yes No
(NOTE: D and e are not required if the facility has written documented
data that show the elements are not present.)
4. Are any of the following instruments existing on the incinerator?
Does the owner/operator monitor them at least every 15 minutes when
incinerating hazardous waste? Check under applicable column.
Existing Monitored
Waste feed Yes No Yes No
Auxiliary fuel feed Yes No Yes No
Air flow Yes No Yes No
Incinerator temperature Yes No Yes No
Scrubber flow Yes No Yes No
Scrubber pH Yes No Yes No
Relevant level controls Yes No Yes No
(NOTE: Afterburner and temperature, 02, and CO meters are examples of
relevant level controls.)
a. Does the owner/operator monitor the stack plume (emissions) at
least hourly for:
(1) Color (normal) Yes No
(06/87)
-------
F-49
Table F-ll (cont.)
5.
6.
(2) Opacity
Yes
No
b. Does the owner/operator monitor the incinerator and associated
equipment at least daily including: (circle those not in
compliance)
(1) Pumps, valves, conveyors, pipes for leaks,
spills and fugitive emissons. (Use
narrative explanation sheet.)
(2) Emergency shutdown controls
(3) System alarms
c. Are these inspections referenced in the
inspection log? Review inspection plan,
note deficiencies in narrative.
Is a closure plan maintained for the incinerator?
If yes, is it kept at the facility?
What wastes are incinerated onsite?
__Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
_No
No
EPA Hazardous Waste No.
Description
Weight or Volume
Incinerated Daily
(06/87)
-------
F-50
Table F-12
THERMAL TREATMENT CHECKLIST
(Subpart P)
NOTE: Applies to thermal treatment of hazardous waste in devices other
than incinerators.
1. Is the process a non-continuous (batch) process? Yes No
a. If no, is the process operating at steady State
conditions (including temperature) before
adding hazardous waste? Yes No
2. Is a waste analysis, for wastes not previously burned,
documented in the operating record? Yes No
a. Does it include analyses for the following:
(1) Heating value Yes No
(2) Halogen content Yes No
(3) Sulfur content Yes No
(4) Concentation of lead Yes No
(5) Concentration of mercury Yes No
b. Is this information documented in the operating
record? Yes No
(NOTE: 4 and 5 are not required if the facility has written documented
data that show the elements are not present.)
3. Are the existing instruments which relate to combustion and emission
control monitored at least every 15 minutes?
Existing Monitored
a. Waste feed Yes No Yes No
b. Auxiliary fuel feed Yes No Yes No
c. Treatment process temp. Yes No Yes No
d. Relevant process flow Yes No Yes No
e. Relevant controls (e.g.,
afterburner and tempera-
ture controls, 02 and CO
meters) Yes No Yes No
4. Are stack plume (emissions) monitored at least
hourly? Yes No
a. Color (normal) Yes No
b. Opacity Yes No
5. Is thermal treatment process equipment monitored at
least daily including: (NOTE: circle those not in
compliance). Yes No
(06/87)
-------
F-51
Table F-12 (cont.)
a. Pumps, valves, conveyors, pipes, etc., (for
leaks, spills and fugitive emissions) Yes No
b. Emergency shutdown controls Yes No
c. System alarms Yes No
6. Is a closure plan maintained at the facility? Yes No
7. Is open burning or detonation of waste explosives
conducted? Yes No
a. If yes, is the detonation performed in
accordance with the following table? Yes No
Pounds of Waste Minimum Distance From Open
Explosives or Burning or Detonation to
Propel!ants the Property of Others
0-100 204m (670 ft.)
101-1,000 380m (1,250 ft.)
1,001-10,000 530m (1,730 ft.)
10,001-30,000 690m (2,260 ft.)
8. Is there evidence of open burning of
hazardous wastes except for waste explosives? Yes No
Use narrative explanations sheet to describe details.
(06/87)
-------
F-52
Table F-13
CHEMICAL, PHYSICAL AND BIOLOGICAL TREATMENT CHECKLIST
(Subpart Q)
NOTE: Applies to treatment in other than tanks, surface impoundments and
land treatment facilities.
1. Describe treatment process (include information on wastes treated).
2. Inspect treatment process and equipment:
a. Are there any leaks, corrosion or other failures
evident? Yes No
If yes, describe.
3. Is the process a continuous feed system? Yes No
a. If yes, is it equipped with a means to stop
waste inflow (e.g., waste feed cutoff system
or bypass). Yes No
4. If hazardous waste is to be treated which is substantially different
from any hazardous waste previously treated at the facility or if a
substantially different process than any previously used at the facil-
ity is to be used to chemically treat hazardous wastes, are the fol-
lowing obtained:
a. Waste analyses and trial treatment tests (e.g.,
bench scale)? Yes No
OR
b. Written, documented information on similar
treatment or similar wastes? Yes No
5. Does the owner/operator inspect the following,
where present (indicate which items are present)?
a. At least daily
(1) Discharge control and safety equipment
(e.g., waste feed cutoff, bypass, drainage
or pressure relief systems)? Yes No
(2) Data gathered from monitoring equipment
(e.g., pressure and temperature gauges)? Yes No
(06/87)
-------
F-53
Table F-13 (cont.)
b. At least weekly.
(1) Construction materials of treatment process
or equipment to detect erosion or obvious
signs of leakage? Yes No
(2) Construction materials of an area
immediately surrounding discharge
confinement structures? Yes No
6. Does the facility have a closure plan? Yes No
7. Where is the plan maintained?
8. Are ignitable or reactive wastes placed in the
treatment process (circle appropriate waste). Yes No
a. If yes, is the waste treated, rendered or mixed
before or immediately after being placed in the
treatment process so it no longer meets the
definition of ignitable or reactive? Describe
or attach a copy of the treatment. Yes No
9. Has the facility treated incompatible wastes? Yes No
a. If yes, what were the results. Use narrative explanations sheet.
Look for signs of mixing of incompatible wastes (e.g., fire, toxic
mist, heat generation, etc.)
10. If a waste is to be placed in treatment equipment
that previously held an incompatible waste, was
that equipment washed? Yes No
a. If yes, describe washing procedures. Use narrative explanations
sheet.
Describe how it is possible for incompatible wastes to be placed
in the same treating equipment. Use narrative explanations
sheet.
(06/87)
-------
F-54
Table F-14
RCRA CHECKLIST FOR RECYCLING WASTES
TO BE BURNED FOR ENERGY RECOVERY
Name of Facility:
Address:
EPA I.D. Number
Facility Inspection Representative:
Title:
Telephone Number:
These are questions pertaining to facilities that recycle wastes to be
burned for energy recovery (Marketers and Burners).
Note: Regarding generators and waste as fuel standards. Generators of used
oil or hazardous waste are subject to the waste as fuel marketer standards
if they sell waste fuels directly to burners for energy recovery. Generators
are subject to the burner standards if they burn used oil or hazardous waste
for energy recovery.
1. Does the facility receive used oils or hazardous
waste for the purpose of marketing waste as fuel
for energy recovery? Yes No
If yes, complete the marketer checklist of Section A.
2. Does the facility burn its waste as fuel for energy
recovery? Yes No
If yes, complete the burner checklist of Section B.
SECTION A - MARKETERS/PROCESSORS OF WASTE FUELS
Site Characterization
1. Does the facility accept waste oil? Yes No
Specify types and source:
2. Does the facility blend hazardous waste with waste
oil to be marketed as fuel? Yes No
(06/87)
-------
F-55
Table F-14 (cont.)
3. Does the facility accept hazardous waste fuel (i.e.,
used oil previously blended with hazardous waste)?
4. Does the facility accept hazardous waste?
Specify waste and generator type:
Yes No
Yes No
5.
6.
Does the facility accept only used oil?
Does the facility have Interim Status or a permit
(RCRA §3005)?
Specify:
8.
Does the facility generate hazardous waste?
If yes, refer to the generator checklist, also.
Inspect the following general operating practices:
Storage Treatment
_Drum
_Above-ground tanks(s)
_Underground tank(s)
_0ther
Tank sizes
_Settling
_Heat addition
_In-Line Filtering
_Certrifugation
_Screen Filtration
_Dehydration
Emulsion Breaking
Blending
Yes No
Yes No
Yes No
Disposal
Landfill
_Land
Treatment
_Surface
Impoundment
Other
Descriptions and Observations:
9. Specify other material recycled as fuel.
10. Has the facility notified the Agency of their waste
fuel activity [§266.34(b), or §266.43(b)(3)]? Yes No
(06/87)
-------
F-56
Table F-14 (cont.)
If no, explain:
11. Does the facility have manifests for all shipments
of hazardous waste and blended hazardous waste fuel
(received or sent) (§265.70)? Yes No
Review manifests and obtain copies of deficient documents.
12. Does the facility have a copy of the required
notice from burners or marketers to whom waste
fuel is marketed [§266.34(e) or §266.43(b)(5)]? Yes No
13. Does the facility have invoice information for
shipments of used oil claimed to be specification
used oil fuel [§266.43(b)(6)]7 Yes No
14. Does the above invoice information for specification
used oil fuel have a cross-reference to analysis or
other information? Yes No
15. Does the facility analyze for metals and halogens? Yes No
Specify methods:
16. Does the facility have records of analysis or other
information documenting that the used oil meets the
specification? Yes No
17. Does the facility have the records required under
§266.34(f) or §266.43(b)(6)? Yes No
Comments:
Note: If a facility markets hazardous waste fuel, the facility is
subject to storage requirements of Parts 262, 264 or 265 and 270,
Subparts A through L. Complete the TSDF checklist.
SECTION B - BURNERS OF USED OIL FUEL AND HAZARDOUS WASTE FUEL
The following questions pertain to facilities regulated under Part 266
who burn waste fuel for energy recovery. These do not necessarily apply to
incineration under Subpart 0 of Part 265.
(06/87)
-------
F-57
Table F-14 (cont.)
1. Does the facility burn used oil fuel? Yes No
Specify: Off-specification Specification
2. Does the facility burn hazardous waste fuel? Yes No
If yes, was the facility in existence before
May 29, 1986?* Yes No
3. Does the facility's burning unit(s) classify as
industrial boiler(s) or industrial furnace(s)? Yes No
If no, does the facility have records of analysis
or other information documenting that the used oil
meets the required specifications [§266.44(b)]? Yes No
4. Has the owner/operator notified EPA of their waste
fuel acitivity [§266.35(b) or §266.44(b)]? Yes No
5. Does the facility have records of the required
notices sent to the fuel suppliers (marketers)
for hazardous waste fuel or off-specification used
oil [§266.35(d) or §266.44(c)]? Yes No
6. Does the facility have Interim Status or a permit
(§3005)? Yes No
Comments:
Storage requirements for hazardous waste fuel under Subparts A
through L, Parts 262, 264 or 265 and 260 apply to these facilities
as of Nay 29, 1986. Therefore, refer to the checklist for inspection
of TSDF.
(06/87)
-------
F-58
Table F-15
LAND DISPOSAL RESTRICTION
F-SOLVENT GENERATOR CHECKLIST
I. HANDLER IDENTIFICATION
A. Handler Name B. Street (or other identifier)
C. City D. State E. Zip Code F. County Name
G. Nature of Business; Identification of Operations
H. EPA ID #
I. Handler Contact (Name and Phone Number)
II. GENERATOR COMPLIANCE
A. F-Solvent Identification
1. Does the handler generate the following wastes?
a. F001 Yes No
b. F002 Yes No
c. F003 Yes No
If an F003 wastestream listed solely for ignit-
ability has been mixed with a nonrestricted
solid or nonlisted hazardous waste, does the
resultant mixture exhibit a hazardous
characteristic? Yes No
d. F004 Yes No
e. F005 Yes No
2. Source of the above: Form 8700-12 ; Part A ;
Part B ; other (specify)
Table F-19 is intended to assist the inspector and enforcement official in
determining whether the facility is generating F-solvent wastes, if such
wastes were not identified by the facility previously. If you are concerned
that F-solvent wastes may be misclassified or mislabeled, complete Table F-.
Note concerns below:
(06/87)
-------
F-59
Table F-15 (cont.)
B. BOAT Treatability Group - Treatment Standards Identification
1. Did the generator correctly determine the
appropriate treatability group (§268.41) of
the waste (wastewaters containing solvents,
pharmaceutical wastewaters containing spent
methylene chloride, all other spent solvent
wastes)? Yes No
C. Waste Analysis
1. Did the generator determine whether the waste
exceeds treatment standards based on §268.7(a):
a. Knowledge of wastes Yes No
b. TCLP Yes No
c. Other (specify)
If knowledge, note how this is adequate:
If determined by TCLP, provide date of last test,
frequency of testing and attach test results.
Dates/frequency:
Note any problems:
d. Were wastes tested using TCLP when a
process or wastestream changes? Yes No
2. Did the F-solvent wastes exceed applicable
treatability group treatment standards upon
generation [§268.7(a)(l)]? Yes No
Some
3. Did the generator dilute the waste or the
treatment residual so as to substitute for
adequate treatment (§268.3) Yes No
(06/87)
-------
F-60
Table F-15 (cont.)
D. Management
1. Onsite management
a. Were F-solvent wastes managed onsite? Yes No
If no, proceed to question 2.
b. For wastes that exceed treatment standards,
was treatment, storage and/or disposal
conducted? Yes No
If yes, complete Land Disposal Restriction F-Solvent
TSD Requirements Checklist.
c. Are test results maintained in the
operating record? Yes No
2. Offsite Management
a. If F-solvent wastes exceed treatment standards,
did generator provide treatment facility
[§268.7(a)(l)]:
(1) EPA waste number? Yes No
(2) Applicable treatment standard? Yes No
(3) Manifest number Yes No
(4) Waste analysis date, if available? Yes No
Identify offsite treatment facilities
b. If F-solvent wastes do not exceed treatment standards, did
generator provide the disposal facility [§268.7(a)(2)]:
(1) EPA hazardous waste number? Yes No
(2) Applicable treatment standard? Yes No
(3) Manifest number? Yes No
(4) Waste analysis data, if available? Yes No
(5) Certification regarding waste and that
it meets treatment standards? Yes No
(06/87)
-------
F-61
Table F-15 (cont.)
Identify land disposal facilities receiving the BOAT certified wastes
c. If waste is subject to nation-wide variance
(e.g., solvent-water mixtures less than 1%),
extension (268.5) or petition (268.6) does
generator provide notice to disposer that
wastes is exempt from land disposal
restrictions [§268.7(a)(3)]? Yes No
E. Storage of F-Solvent Waste
1. Did facility store restricted wastes exceeding
treatment standards? Yes No
If yes, were the wastes stored solely for the
purpose of facilitating proper recovery, treat-
ment or disposal? Yes No
2. Are all containers clearly marked to identify
content and date(s) entering storage? Yes No
3. Was F-solvent waste stored for greater than
90 days (after variance, 180/270 days for SQG)? Yes No
If yes, was facility operating as a TSDF under
interim status or final permit? Yes No
If yes, complete Tabe F-17 for TSDFs.
F. Treatment Using RCRA 264/265 Exempt Units or Processes
(i.e., boilers, furnaces, distillation units, wastewater treatment
tanks, etc.)
1. Were treatment residuals generated from RCRA
264/265 exempt units or processes? Yes No
If yes, list type of treatment unit and processes
In most cases, if the residuals from a RCRA-exempt treatment unit are
above the treatment standards, the owner/operator is considered a generator
of restricted waste. The inspector should determine whether the generator
requirements, particularly waste identification requriements, have been met
for the treatment residuals.
(06/87)
-------
F-62
Table F-15 (cont.)
If the residuals from a RCRA-exempt treatment unit are above the treatment
standards, the owner/operator is considered a generator of restricted waste.
The inspector should determine whether the generator requirements, particu-
larly waste identification requirements, have been met for the treatment
residuals.
(06/87)
-------
F-63
Table F-16
LAND DISPOSAL RESTRICTION F-SOLVENT TRANSPORTER CHECKLIST
I. FACILITY IDENTIFICATION
A. Site Name
B. Street (or other identifier)
C. City
D. State
E. Zip Code F. County Name
G. Description of Operations
H. EPA ID #
I. Facility Contact (Name and Phone Number)
II. TRANSPORTER REQUIREMENTS
A. Does the transporter store restricted wastes for
greater than 10 days [268.50(a)(3)]?
B.
1. If yes, does transporters have 264/265 status
as storage facility (e.g., has submitted part A)
Does a review of records indicate storage of
restricted wastes for greater than 10 days?
_Yes
_Yes
Yes
_No
_No
No
C. Describe inventory controls to ensure that restricted wastes are not
stored for greater than 10 days.
(06/87)
-------
F-64
Table F-17
LAND DISPOSAL RESTRICTION F-SOLVENT TREATMENT,
STORAGE AND DISPOSAL REQUIREMENTS CHECKLIST
I. FACILITY IDENTIFICATION
A. Facility Name B. Street (or other identifier)
C. City D. State E. Zip Code F. County Name
G. Nature of business; identification of operations
H. EPA ID #
I. Facility Contact (Name and Phone Number)
For onsite facilities, complete the generator checklist
II.
A. General Facility Standards
1. Was waste analysis plan revised to cover
Part 268 requirements [§264.13 or 265.13]? Yes No
2. Did facility obtain representative chemical
and physical analysis of wastes and residues? Yes No
a. Did testing include analyses for all F001-
F005 constituents? Yes No
b. Were analyses performed using TCLP? Yes No
c. Were analyses conducted onsite or off-
site (identify offsite lab)? On Off
d. Describe frequency of sampling_
(06/87)
-------
F-65
Table F-17 (cont.)
e. Describe procedures used to identify manifest dis-
crepancies
3. Are the operating records, including analy-
ses and quantities, complete (264.73/265.73)? Yes No
B. Storage (§268.50)
1. Were restricted wastes exceeding treatment
standards stored? Yes No
2. Are all containers clearly marked to
identify content and date(s) entering
storage? Yes No
3. Do operating records track the location,
quantity and dates the restricted wastes
exceeding treatment standards entered and
were removed from storage? Yes No
4. Do operating records agree with container
labeling? Yes No
5. Is waste exceeding treatment standards
stored for less than 1 year? Yes No
If yes, can you show that such accumulation
is not necessary to facilitate proper
recovery, treatment or disposal? Yes No
If yes, state how:
6. Were tanks emptied at least once per year
and do operating records show that volume
of waste removed from tanks annually at
least equals tank volume? Yes No
7. Was/is waste exceeding treatment standards
stored for more than 1 year? Yes No
If yes, state the owner/operator's proof that such storage
was solely for the purposes of accumulation of such quantities
of hazardous waste as are necessary to facilitate proper
recovery, treatment or disposal:
(06/87)
-------
F-66
Table F-17 (cont.)
8. Are F-solvent wastes exceeding treatment
standards placed in surface impoundments for
treatment? Yes No
C. Treatment in Surface Impoundments (§268.4)
1. Were F001-F005 wastes exceeding treatment
standards placed in surface impoundments
for treatment? Yes No
If no, go on to D.
2. Did the facility submit a certification
of compliance with minimum technology and
groundwater monitoring requirements and
the waste analysis plan to the Agency? Yes No
3. Have the minimum technology requirements
been met? Yes No
a. If the minimum technology requirements
have not been met, has a waiver/exemption
been granted for that unit(s)? Yes No
4. Have the Subpart F groundwater monitoring
requirements been met? Yes No
5. Have representative samples of the sludge
and supernatant from the surface impound-
ment been tested separately, acceptably
and in accordance with the sampling fre-
quency and analysis specified in the waste
analysis plan and are the results in the
operating record? Yes No
6. Did the hazardous waste residue (sludge
Łr liquid) exceed the treatment standards
specified in §268.41? Yes No
7. Provide the frequency of analyses conducted on treatment
residues:
8. Does the operating record adequately
document the results of waste analyses
performed in accordance with §268.41? Yes No
(06/87)
-------
F-67
Table F-17 (cont.)
9. Have the hazardous waste residues that
exceed the treatment standards (§268.41)
been removed adequately and on an annual
basis? Yes No
a. If no and supernatant is determined
to exceed treatment concentrations,
is annual throughput greater than
impoundment volume? Yes No
10. If residues were removed annually, were
adequate precautions taken to protect
liners and do records indicate that
inspections of liner integrity are
performed? Yes No
11. When removed, were solvent wastes managed
subsequently in another surface impoundment? Yes No
12. When removed, were wastes treated prior to
disposal? Yes No
a. If yes, are waste residues treated
on or offsite? Onsite Offsite
b. Identify management method
D. Treatment
1. Did the facility operate treatment
facilities for F-solvent waste (not
including surface impountment? Yes No
If no, proceed to "F."
2. Describe the treatment processes for F-solvent wastes:
(06/87)
-------
F-68
Table F-17 (cont.)
3. Does the facility, in accordance with an
acceptable waste analysis plan, verify that
the residue extract from all treatment pro-
cesses for the F-solvent wastes are less
than treatment standards [§268.7(b)(2)]? Yes No
4. Describe frequency of testing of treatment residuals:
5. Was dilution used as a substitute for
treatment? Yes No
6. Are certifications and results of waste
analyses kept in the operating record? Yes No
7. Are notices with waste number, treatment
standard, manifest number and analytical
data (where available) submitted for each
shipment of waste or treatment residual
that meets the treatment standard stating
that waste has been treated to treatment
performance standards [§268.7(b)]? Yes No
8. Are certifications submitted for each
shipment [§268.7(b)(2)(i)]? Yes No
E. Land Disposal
1. Were F-solvent wastes placed in land
disposal units [landfills, surface
impoundments (for this question, do not
include if in "D")] waste piles, wells,
land treatment units, salt domes/beds,
mines/caves concrete vault or bunker? Yes No
2. Did facility have the notice and certifi-
cation from generators/treaters in its
operating record [§§268.7(c); 268.7(a), (b)]? Yes No
3. Did the facility obtain waste analysis data
through testing of the waste to determine
that the wastes are in compliance with the
applicable treatment standards [§268.7(c)]? Yes No
(06/87)
-------
F-69
Table F-17 (cont.)
If yes, at what frequency?
4. Were F-solvent wastes exceeding the treat-
ment standards placed in land disposal units
[268.30] excluding national capacity variances
[268.30(a)]7 Yes No
If yes, did facility have an approved waiver
based on no migration petition [268.6] or
approved case-by-case capacity extension
[268.5] or variance [268.44]? Yes No
5. Were F-solvent wastes subject to a national
or case-by-case capacity variance/extension
disposed? Yes No
a. If yes, were these wastes disposed of
in a facility that has a new, replace-
ment or laterally expanded landfill or
impoundment? Yes No
If (a) is yes, have the minimum technol-
ogy requirements been met for all such
units at the facility? Yes No
6. Were adequate records of disposal maintained? Yes No
7. If wastes subject to a nationwide variance,
case-by-case extensions [268.5], or no
migration petitions [268.6] were disposed,
does facility have notices [268.7(a)(3)]
and records of disposal? Yes No
8. What is the volume of F-solvent waste disposed to date by
waste?
9. If the facility has a case-by-case exten-
sion, can the inspector verify that the
facility is making progress as described
in progress reports? Yes No
(06/87)
-------
Table F-18
SOLVENT IDENTIFICATION CHECKLIST
1. Does the handler generate any of the following constituents (i.e., spent
halogenated solvents used in degreasing) as a result of being used in
the process either in pure form or commercial grade?
Tetrachloroethylene Yes No
Trichloroethylene Yes No
Methylene chloride Yes No
1,1,1-Trichloroethane Yes No
Carbon tetrachloride Yes No
Chlorinated fluorocarbons Yes No
2. Does the handler generate any of the following F002 constituents (i.e.,
spent halogenated solvents) as a result of being used in the process
either in pure form or commercial grade?
Tetrachloroethylene Yes No
Trichloroethylene Yes No
Methylene chloride Yes No
1,1,1-trichloroethane Yes No
Cnlorobenzene Yes No
Trichlorofluoromethane Yes No
l,l,2-trichloro-l,2,2-
trifluoroethane Yes No
Ortho-dichlorobenzene Yes No
1,1,2-trichloroethane Yes No
3. Does the handler generate any of the following F003 constituents (i.e.,
spent nonhalogenated solvents) as a result of being used in the process
either in pure form or commercial grade?
Xylene Yes _No
Acetone Yes No
Ethyl acetate Yes No
Ethyl benzene Yes No
Ethyl ether Yes No
Methyl isobutyl ketone Yes No
n-Butyl alcohol Yes No
Cyclohexane Yes No
Methanol Yes No
If the F003 wastestream has been mixed with a non-
restricted solid or nonlisted hazardous waste, does
the resultant mixture exhibit the ignitability
characteristic? Yes No
4. Does the handler generate any of the following F004
constituents (i.e., spent nonhalogenated solvents)
as a result of being used in the process either in
pure form or commercial grade?
(06/87)
-------
F-71
Table F-18 (cont.)
Cresols and cresylic acid Yes No
Nitrobenzene Yes No
5. Does the handler generate any of the following F005
constituents (i.e., spent nonhalogenated solvents)
as a result of being used in the process either in
pure form or commercial grade?
Toluene Yes No
Methyl ethyl ketone Yes No
Carbon disulfide Yes No
Isobutanol Yes No
Pyridine Yes No
6. Are any of the constituents listed in the questions 1 through 5 used
for their "solvent" properties -- that is to solubilize (dissolve) or
mobilize other constituents? The following questions will be helpful
in confirming this determination.
a. Chemical carriers? Yes No
If the answer is yes, list the constituents.
b. Degreasing/cleaning? Yes No
c. Diluents? Yes No
d. Extractants Yes No
If the answer is yes, list the constituents.
e. Fabric scouring? Yes No
If the answer is yes, list the constituents.
(06/87)
-------
F-72
Table F-18 (cont.)
f. Reaction and synthesis media? Yes No
If the answer is yes, list the constituents.
If questions 1 through 6 led the inspector to believe that the waste may be
an F-solvent, answer question 7.
7. Are any of the above constituents spent solvents?
A solvent is considered "spent" when it has been
used and is no longer used without being regenerated,
reclaimed or otherwise reprocessed. Yes No
8. If the waste is a mixture of constituents, as determined in questions
1 through 6, answer this to determine whether it is a "solvent mixture"
covered by the listings.
If the wastestream is mixed and contains more than one of the F001 to
F005 constituents listed in questions 1 through 5 (by volume), give
the concentration before use of all the constituents in the solvent
mixture/blend. For example:
5% methylene chloride
2% trichloroethylene
25% 1,1,1-trichloroethane
68% mineral spirits
100%
If the wastestream is a mixture containing a total of 10% or more (by
volume) of one or more of the F001, F002, F004 or F005 listed constit-
uents before use, it is a listed waste.
With respect to the F003 solvent wastes, if, before use, the waste-
stream is mixed and contains only F003 constituents, it is a listed
waste. For example:
33% acetone
16% methanol
51% ethyl ether
100%
If the wastestream is a mixture containing F003 constituents and a
total of 10% or more of one or more of the F001, F002, F004 and F005
listed constituents before use, it is a listed waste. For example:
(06/87)
-------
F-73
Table F-18 (cont.)
50% xylene F003
12% TCE F001
38% mineral spirits
100%
If, in light of the above, the handler appears to be generating F001 to
F005 hazardous wastes, refer this facility to the enforcement official
for followup actions verifying the use of solvents at the facility.
(06/87)
-------
F-74
Table F-19
TREATMENT STANDARDS FOR F-SOLVENTS
Concentration (in Mg/L)
F001-F005 Spent Solvents
Acetone
N-butyl alcohol
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Cresols (and cresylic acid)
Cyclohexanone
1 , 2-di chl orobenzene
Ethyl acetate
Ethyl benzene
Ethyl ether
Isobutanol
Methanol
Methylene chloride
Methylene chloride (from the
pharmaceutical industry)
Methyl ethyl ketone
Methyl isobutyl ketone
Nitrobenzene
Pyridine
Tetrachl oroethyl ene
Toluene
1,1,1-Trichloroethane
1,2,2-Trichloro
1,2,2-trifluoroethane
Trichloroethylene
Tri chl orof 1 uoromethane
Xylene
Wastewaters
0.05
5.0
1.05
.05
.15
2.82
.125
.65
.05
.05
.05
5.0
.25
.20
12.7
0.05
0.05
0.66
1.12
0.079
1.12
1.05
1.05
0.062
0.05
0.05
Other Wastes
0.59
5.0
4.81
.96
.05
.75
.75
.125
.75
.053
.75
5.0
.75
.96
.96
0.75
0.33
0.125
0.33
0.05
0.33
0.41
0.96
0.091
0.96
0.15
(06/87)
-------
APPENDIX G
CERCLA CHECKLIST
-------
G-l
Appendix G
CERCLA CHECKLIST
1. Notification
a. Has the facility notified the proper regulatory
authorities concerning sites of past hazardous
substance releases and former hazardous sub-
stance storage, treatment and disposal areas
[CERCLA 103(a) and (c)]? Yes No
b. What sites have been listed in any notification?
2. Unreported Sites
a. Are there indications of other sites at the
facility which may be appropriate for notifi-
cation (from records review, interviews,
evidence of spills, aerial photographs, etc.)? Yes No
b. List any potentially contaminated sites which have not been
reported.
3. Is this a Department of Defense (DOD) facility? Yes No
(If so, go to question 5)
4. Non-DOD facilities
a. Has the facility (non-DOD) participated in any
response actions (40 CFR 300.25)? Yes No
b. What is the facility's participation?
-------
G-2
Appendix G (cont.)
c. What is the status of any response by regulatory agencies?
5. DOD Facility Sites:
a. (1) Has the preliminary assessment (40 CFR
300.64) been completed? Yes No
(2) Was the preliminary assessment adequate? Yes No
(3) Findings and status:
b. (1) Were immediate removals (40 CFR 300.65)
conducted at any of the sites? Yes No
(2) Was the removal adequate (verification
data)? Yes No
(3) Findings and status:
c. (1) Has there been an evaluation and determina-
tion of appropriate response for a planned
removal and remedial action (40 CFR 300.66)? Yes No
(2) Was this evaluation and determination
adequate? Yes No
(3) Status:
-------
G-3
Appendix G (cont.)
d. (1) Was a planned removal or remedial action
(40 CFR 300.67 and 68) taken? Yes No
(2) Was this planned removal or remedial action
successful? Yes No
(3) Status:
6. Comments:
-------
APPENDIX H
TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
-------
H-l
Appendix H
CONFIDENTIALITY NOTES AND DISCUSSIONS
The TSCA Notice of Inspection [Figure 1-1] and Inspection Confidentiality
Notice [Figure 1-2] are presented to the facility owner or agent in charge
during the opening conference. These notices inform facility officials of
their right to claim as confidential business information any information
(documents, physical samples or other material) collected by the inspector.
Authority to Make Confidentiality Claims
The inspector must ascertain whether the facility official to whom the
notice were given has the authority to make business confidentiality claims
for the company. The facility official's signature must be obtained at the
appropriate places on the notices certifying that he does or does not have
such authority.
The facility owner is assumed to always have the authority to
make business confidentiality claims. In most cases, it is
expected that the agent in charge will also have such authority.
It is possible that the officials will want to consult with their
attorneys (or superiors in the case of agents in charge) regard-
ing this issue.
If no one at the site has the authority to make business confi-
dentiality claims, a copy of the TSCA Inspection Confidentiality
Notice and Notice and Declaration of Confidential Business Infor-
mation form [Figure 1-3] are to be sent to the chief executive
officer of the firm within 2 days of the inspection. He will
then have 7 calendar days in which to make confidentiality claims.
The facility official may designate a company official, in addi-
tion to the chief executive officer, who should also receive a
copy of the notices and any accompanying forms.
-------
H-2
Figure H-l
US ENVIRONMENTAL PROTECTION AGENCY
^^ ^•••^Jft WASHINGTON, DO 20460
hW^PIHr*^iX TOXIC SUBSTANCES CONTROL ACT
^^~" * * NOTICE OF INSPECTION
1. INVESTIGATION IDENTIFICATION 2. TIME 3. FIRM NAME
DATE INSPECTOR NO. DAILYSEQ. NO.
Form Approved
OMB No. 2070-0007
Expires 3-31 -88
4. INSPECTOR ADDRESS 5. FIRM ADDRESS
REASON FOR INSPECTION
Under the authority of Section 1 1 of the Toxic Substances Control Act :
CD For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establish-
ment, facility, or other premises in which chemical substances or mixtures or articles containing same are manufactured, proc-
essed or stored, or held before or after their distribution in commerce (including records, file's, papers, processes, controls, and
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same in connection
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether the
requirements of the Act applicable to-the chemical substances, mixtures, or articles within or associated with such premises or
conveyance have been complied with.
C3 In addition, this inspection extends to (Check appropriate blocks):
D A. Financial data D D. Personnel data
CD B. Sales data CH E. Research data
CU C. Pricing data
The nature and extent of inspection of such data specified in A through E above is as follows;
INSPECTOR SIGNATURE RECIPIENT SIGNATURE
NAME NAME
TITLE DATE SIGNED TITLE
DATE SIGNED
-------
Figure H-2
H-3
>?xEPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
TSCA INSPECTION CONFIDENTIALITY NOTICE
Form Approved
OMB No. 2070-0007
expires 3-31-88
1. INVESTIGATION IDENTIFICATION
DATE
INSPECTOR NO.
DAILY SEQ. NO.
2. FIRM NAME
3. INSPECTOR NAME
4. FIRM ADDRESS
5. INSPECTOR ADDRESS
6. CHIEF EXECUTIVE OFFICER NAME
7. TITLE
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that EPA will receive public requests for release of the
information obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act (FOIA), 5 USC 552; EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act (TSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of the
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the information collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to be confidential business infor-
mation. If you assert a CBI claim, EPA will disclose the information
only to the extent, and by means of the procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you have claimed as confidential business information.
A confidential business information (CBI) claim may be asserted at any
time. You may assert a CBI claim prior to, during, or after the infor-
mation is collected. The declaration form was developed by the Agency
to assist you in asserting a CBI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential business information," it is
not necessary for you to use this form. The inspector will be glad to
answer any questions you may have regarding the Agency's CBI
procedures.
While you may claim any collected information or sample as confiden-
tial business information, such claims are unlikely to be upheld if they
are challenged unless the information meets the following criteria:
1. Your company has taken measures to protect the confi-
dentiality of the information, and it intends to continue
to take such measures.
2. The information is not, and has not been, reasonably obtainable
without your company's consent by other persons (other than
governmental bodies) by use of legitimate means (other than
discovery based on showing of special need in a judicial or
quasi-judicial proceeding).
3. The information is not publicly available elsewhere.
4. Disclosure of the information would cause substantial
harm to your company's competitive position.
At the completion of the inspection, you will be given a receipt for all
documents, samples, and other materials collected. At that time, you
may make claims that some or all of the information is confidential
business information.
If you are not authorized by your company to assert a CBI claim, this
notice will be sent by certified mail, along with the receipt for docu-
ments, samples, and other materials to the Chief Executive Officer of
your firm within 2 days of this date. The Chief Executive Officer must
return a statement specifying any information which should receive
confidential treatment.
The statement from the Chief Executive Officer should be addressed
to:
and mailed by registered, return-receipt requested mail within 7 calen-
dar days of receipt of this Notice. Claims may be made any time
after the inspection, but inspection data will not be entered into the
special security system for TSCA confidential business information
until an official confidentiality claim is made. The data will be handled
under the agency's routine security system unless and until a claim is
made.
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE:
I have received and read the notice
If there is no one on the premises of the facility who is authorized to make
business confidentiality claims for the firm, a copy of this Notice and other
inspection materials will be sent to the company's chief executive officer. If
there is another company official who should also receive this information,
please designate below.
SIGNATURE
NAME
FITLE
TITLE
DATE SIGNED
ADDRESS
EPA Form 7740-4 (12-82)
-------
H-4
Figure H-3
US ENVIRONMENTALPROTECtlON AGENCY
^^ P^V^JL WASHINGTON, DC 20460
^5*5^ • " BJF^ TOXIC SUBSTANCES CONTRO L ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
r 1. INVESTIGATION IDENTIFICATION 2. FIRM NAME
DATE
INSPECTOR NO. DAILY SEQ. NO.
Form Approved
OMB No. 2070-0007
Expires 3-31 -88
3. INSPECTOR ADDRESS 4. FIRM ADDRESS
INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION
NO.
DESCRIPTION
•
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE CLAIMANT SIGNATURE
NAME NAME
TITLE DATE SIGNED TITLE
DATE SIGNED
* Fr-rm 774O-? H7-
-------
H-5
Appendix H (cont.)
Confidentiality Discussion
Officials should be informed of the procedures and requirements that
EPA must follow in handling TSCA confidential business information. The
inspector should explain that these procedures were established to protect
the companies subject to TSCA and cover the following points during the
discussion.
Data may be claimed confidential business information during the
closing conference if a person authorized to make such claims is
onsite at the facility.
It is suggested that a company official accompany the inspector
during the inspection to facilitate designation (or avoidance, if
possible) of confidential business data.
A detailed receipt for all documents, photographs, physical
samples, and other materials [Figure 1-4] collected during the
inspection will be issued at the closing conference.
An authorized person may make immediate declarations that some or
all of the information is confidential business information. This
is done by completing the Declaration of Confidential Business
Information form. Each item claimed must meet all four of the
criteria shown on the TSCA Inspection Confidentiality Notice.
If no authorized person is available onsite, a copy of the notices,
along with the Receipt for Samples and Documents, will be sent by
certified, return-receipt-requested mail to the Chief Executive
Officer of the firm and to another company official, if one has
been designated.
Four copies are made of the Declaration of Confidential Information
form and distributed to:
-------
H-6
Appendix H (cont.)
Facility owner or agent in charge
Other company official (if designated)
Document Control Officer
Inspection report
-------
Figure H-4
H-7
US ENVIRONMENTAL PROTECTION AGENCY
^^ ••••^ A WASHINGTON, DC 20460
^••U LiftJ^^ TOXIC SUBSTANCES CONTROL ACT
^^ t lirm RECEIPT FOR SAMPLES AND DOCUMENTS
1. INVESTIGATION IDENTIFICATION
DATE INSPECTOR NO. DAILY SEQ. NO.
i}. INSPECTOR ADDRESS '
2. FIRM NAME
Form Approved.
OMB No. 2070-0007
Approval expires 3-31-88
4. FIRM ADDRESS
The documents and samples of chemical substances and/or mixtures described below were collected in connection with the
administration and enforcement of the Toxic Substances Control Act.
RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE (S) DESCRIBED IS HEREBY ACKNOWLEDGED:
NO.
DESCRIPTION
OPTIONAL:
DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROVIDED C]
INSPECTOR SIGNATURE
NAME
TITLE DATE SIGNED
NOT REQUESTED D
RECIPIENT SIGNATURE
NAME
TITLE
DATE SIGNED
EPA Form 7740-1 (12-82)
-------
APPENDIX I
TSCA PCB CHECKLIST
-------
1-1
Appendix I
PCB COMPLIANCE INSPECTION REPORT
(40 CFR Part 761)
SECTION A. FACILITY SUMMARY
Name and address of facility (include county, state and zip code)
(Responsible Official)
(Title)
(Phone)
(Facility Representative)
(Title)
(Phone)
Type of facility (utility, salvage yard, etc.)
SECTION B. INSPECTION/REVIEW
Inspected by:
Reviewed by:
(Signature)
(Signature)
(Agency and Date)
(Agency and Date)
COMMENTS:
-------
1-2
Appendix I (cont.)
SECTION C. INVENTORY
1. As of July 2, 1978, did facility contain in-
service, stored for future use, or disposal:
a. 50 or more large high- or low-voltage
PCB capacitors? Yes No N/A C/A_
b. One or more PCB transformers? Yes No N/A C/A_
c. 45 kgs (99.4 IDS.) or more PCB chemi-
cals, substances or mixtures? Yes No N/A C/A
2. Disposition of PCB items at time of inspec-
tion:
Identify source of the above information (company records, manufacturer's
labels, etc.)
* N/A - Not applicable
C/A - Comments attached
(06/87)
-------
1-3
Appendix I (cont.)
If any PCB items are not properly marked, describe deficiencies below.
Description must include information on amount of PCBs involved.
3. If company has PCB-contaminated transformers, explain how company
determined the transformers contained 50 to 500 ppm PCB.
4. Does the facility have any other PCB items
(electromagnets, hydraulic systems, etc.)? Yes No N/A C/A_
If yes, list number and type of item; whether it is in-service, storage,
or sent to disposal; and if it is properly marked.
5. a. Were there observations of leaks or
spills or any sign of improper dis-
posal of PCB substances or mixtures. Yes No N/A C/A
b. If yes, document, sample and describe below. Description must
include information on amount of PCBs involved.
6. a. Was there any indication that water-
ways in the vicinity have been con-
taminated by spills, leaks or improper
disposal?
Yes No N/A C/A
b. If yes, document, sample and describe below. Description must
include information on the amount of PCBs involved and the name of
the waterway.
(06/87)
-------
1-4
Appendix I (cont.)
7. a. Were samples collected for analysis
of PCB residual concentration? Yes No N/A C/A_
b. If yes, describe below.
SECTION D. STORAGE AND HANDLING
1. Location:
a. Does the facility have its own
storage site for PCBs? Yes No N/A C/A_
b. If the storage site is not within the boundary of the facility,
give the site's name and address.
2. Does storage site meet physical requirements
(761.42(a) - Physical Requirements)
a. Provide protection from rainfall?
b. Meet floor requirements with 6-inch
continuous curbing?
c. Meet containment volume requirements?
(1) What is total containment volume of
Yes
Yes
Yes
Yes
storage
No
No
No
No
site?
N/A
N/A
N/A
N/A
C/A
C/A
C/A
C/A
(Length x Width x Height)
(2) What is the internal volume of the largest PCB article or
container stored within the storage site?
(3) What is the total internal volume of all PCB articles and
containers within the storage site?
Is item 1 greater than two
times item 2? Yes No N/A C/A
(06/87)
-------
1-5
Appendix I (cont.)
or
25% of item 3? Yes No N/A C/A_
d. (1) Is the area within the curbed
area void of drains, valves,
expansion joints or other
openings? . Yes No N/A C/A
(2) If no, document location of opening, drainage patch and ulti-
mate disposal location in logbook and describe below.
e. Is storage site located above the
100-year flood water elevation level? Yes No N/A C/A
f. Are storage areas adequately marked? Yes No N/A C/A
g. Any deficiencies in permanent storage facility must be documented
with photographs and described below. Description must include
amount of PCBs involved.
3. Containers:
a. Are all PCB items which are located
within storage areas dated
[761.65(c)(8)]? Yes No N/A C/A
b. Do PCB containers comply with DOT
specifications except as noted in 3c
and 3d below [761.65(c)(6)]? Yes No N/A C/A_
c. Are any non-liquid PCBs being stored
in containers larger than those speci-
fied in DOT regulations
[761.65(c)(6)]? Yes No N/A C/A_
(1) Do these containers provide as
much protection and have the
same strength as DOT containers? Yes No N/A C/A
(06/87)
-------
1-6
Appendix I (cont.)
d. Are any liquid PCBs being stored in
containers larger than those specified
in DOT regulations [761.42(c)(7)]7 Yes No N/A C/A_
(1) Do containers comply with OSHA
specifications? Yes No N/A C/A_
(2) Has SPCC plan been prepared and
implemented? Yes No N/A C/A_
4. Storage Site Operations:
a. Are all PCB items arranged so they can
be located by date? [761.65(c)(8)] Yes No N/A C/A
b. Do observations indicate good house-
keeping procedures? Yes No N/A C/A_
c. Is moveable equipment decontaminated
by approved procedures? Yes No N/A C/A_
d. Are PCB items stored and handled in
a manner that protects them from acci-
dental breakage or damage? Yes No N/A C/A
5. Other Storage Areas:
a. Are any of the following temporarily
being stored outside the prescribed
area: [761.65(c)(l)]
(1) Nonleaking PCB articles and PCB
equipment? Yes No N/A C/A_
Is date removed from service
noted on the article or equipment? Yes No N/A C/A_
Have they been there fewer than
30 days? Yes No N/A C/A_
(2) Leaking PCB articles and PCB
equipment placed in a non-
leaking PCB containers? Yes No N/A C/A
Is the date removed from service
noted on the container? Yes No N/A C/A_
Have they been there fewer than
30 days? Yes No N/A C/A_
(06/87)
-------
1-7
Appendix I (cont.)
(3) Containers of liquid PCBs at con-
centrations of 50 to 500 ppm? Yes No N/A C/A_
Is SPCC plan available pertaining
to temporary storage area? Yes No N/A C/A_
Are containers marked to indicate
the liquid does not exceed 500 ppm? Yes No N/A C/A
Is the date removed from service
noted on the containers? Yes No N/A C/A
Have containers been there fewer
than 30 days? Yes No N/A C/A
b. Are there any large high voltage
capacitors or PCB contaminated trans-
formers next to the storage site
[761.65(c)(2)]? Yes No N/A C/A
Are they on pallets? Yes No N/A C/A
Is there adequate space within the
storage site to contain 10% of the
volume of these capacitors and
transformers? Yes No N/A C/A
c. Any deficiencies in temporary storage must be documented with
photographs and described below. Descriptions must include infor-
mation on the amount of PCBs involved.
SECTION E. DECONTAMINATION
1. Does the facility drain or cleanse PCB
transformers or other equipment containing
PCB substances or mixtures prior to dis-
posal or decontaminate movable equipment? Yes No N/A C/A_
2. Does the facility claim to have an
exemption from incineration [761.60(e)]
or exemptions under 761.80? Yes No N/A C/A_
3. Is the drainage and solvent filling site
adequate to protect against spills and
leaks and consequent contamination of sur-
rounding areas and waterways? Yes No N/A C/A_
(06/87)
-------
1-8
Appendix I (cont.)
4. Do solvents to be used for removing PCBs
contain less than 50 ppm PCBs [761.79]? Yes No N/A C/A_
5. Was a sample of the solvent which was used
for PCB removal obtained? Yes No N/A C/A_
6. Was the rinse volume of the dilutant approxi-
mately equal to 10% of the container's total
volume [761.79(a)]? Yes No N/A C/A_
7. Are PCB transformers completely filled
with solvent and allowed to stand for at
least 18 hours before being drained
[761.60(b)(l)]? Yes No N/A C/A_
8. Are the drained PCB chemical substances
or PCB solvent mixtures properly disposed
of or stored? Yes No N/A C/A
9. Are solvents or materials which have been
used for decontamination of PCB equipment
disposed of or stored in the same manner as
PCB mixtures? Yes No N/A C/A_
10. If decontamination procedures were not
observed during inspection, did facility
representative demonstrate knowledge of
proper decontamination procedures? Yes No N/A C/A_
11. Does facility have written decontamination
procedures? Yes No N/A C/A
12. Any deficiencies in the decontamination procedures must be described
below.
SECTION F. RECORDKEEPING
1. Do records indicate the date PCBs were:
a. Removed from service? Yes No N/A C/A
b. Placed in storage for disposal? Yes No N/A C/A_
c. Placed in transport for disposal? Yes No N/A C/A_
(06/87)
-------
1-9
Appendix I (cont.)
2. Do records indicate the quantity of the above items as follows:
a. The weights of PCBs and PCB items in
PCB containers? Yes No N/A C/A
b.
c.
d.
e.
The identification of contents of
PCB containers? Yes
The number of PCB transformers? Yes
The weight of PCBs in PCB transformers? Yes
The number of PCB large, high- and low-
voltage capacitors? Yes
3. Do records indicate the quantities of PCBs remaining
down as follows:
a. The weight of PCBs and PCB items in
PCB containers? Yes
b.
c.
d.
e.
4. a.
b.
The identification of the contents
in PCB containers? Yes
The number of PCB transformers? Yes
The weight of PCBs in PCB transformers? Yes
The number of PCB large, high- and low-
voltage capacitors? Yes
Is the information requested in para-
graphs 1, 2 and 3 above compiled in an
annual document? (This document must
be prepared by July 1 and cover the
previous calendar year.) Yes
List years for which annual documents
are available.
5. Any deficiencies in recordkeeping must be described
information on amount of PCBs involved.
No N/A
No N/A
No N/A
No N/A
C/A
C/A
C/A
C/A
in service broken
No N/A C/A
No N/A
No N/A
No N/A
No N/A
No N/A
below incl
C/A
C/A
C/A
C/A
C/A
uding
(06/87)
-------
1-10
Appendix I (cont.)
6. If owners or operators maintain more than
one facility that contains PCBs in the
quantities prescribed in paragraph C I,
are records and documents kept at a single
location? Yes No N/A C/A_
If yes, list location.
7. Do records provide information on a PCB
disposal facility? Yes No N/A C/A_
If yes, list name, location and type of facility (i.e., incinerator,
boiler, landfill, etc.
SECTION G. DISPOSAL
1. Are PCB articles or containers, which were
stored for disposal after January 1, 1983,
disposed of within I year? Yes No
2. Were items stored for disposal before
January 1, 1983? Yes No
a. Were they disposed of by January 1, 1984? Yes No
3. What items are disposed and state the disposal methods?
(06/87)
-------
APPENDIX J
TSCA SECTIONS 5 AND 8 CHECKLIST
-------
J-l
Table J-l
GLOSSARY OF TERMS AND ACRONYMS:
TOXIC SUBSTANCES CONTROL ACT SECTIONS 5 AND 8
SECTION 5: "New Chemicals"
PMS
SNURs
NOC
TME
R & D
SECTION 5(e)
Order
"Bona fide"
Inquiry
SECTION 5(f)
Order/Rule
SECTION 8
PAIR
(Note: TSCA Chemicals do not include pesticides,
drugs, cosmetics, firearms, etc., by definition)
Premanufacture notification to EPA is required for all "new"
TSCA chemicals, i.e., those not listed on the §8(b) existing
chemical inventory.
Significant New Use Rules require subsequent notification to
EPA when usage/exposure changes (i.e., in addition to PMN).
Notice of Commencement to Agency is required before manufac-
ture begins (after PMN review period has expired).
Test Marketing Exemption to PMN requirement can be obtained
on application to and approval by EPA - usually subject to
specific restrictions.
Research and Development Exemption - automatic exemption,
does not require Agency review or approval.
An administrative order prohibiting or limiting the manufac-
ture, processing, distribution, use and/or disposal of a chem-
ical for which a PMN is required because there is insufficient
information to permit evaluation.
Inquiry by manufacturer that intends to manufacture a specific
chemical to determine whether that chemical is on the confi-
dential portion of the Section 8)b) inventory. (Manufacturer
must establish intent to manufacture to get reply from EPA.)
If the chemical in question is not on the inventory and no
PMN is filed subsequently, the manufacturer may be targeted
for an inspection.
An administrative order or rule prohibiting/limiting the
manufacture, etc., of a chemical for which a PMN is required
because there is a reasonable basis to conclude that such
activities present an unreasonable risk to health/evironment.
"Existing Chemicals"
Preliminary Assessment Information Reporting Rules
Promulgated under section 8(a) Level A - require reporting
to Agency of production, uses and exposure of specific
chemicals or classes of chemicals.
(06/87)
-------
J-2
Table J-l (cont.)
ITC
SECTION 8(a)
Level A
Inspection
SECTION 8(b)
Inventory
SECTION 8(c)
Inspection
SECTION 8(d)
Inspection
SECTION 8(e)
Inspection
Interagency Testing Committee - designates chemicals listed
in PAIR rules as well as some of the chemicals in section 8(d)
rules. ITC is established under section 4(e) of TSCA. It
also recommends chemicals for inclusion in testing rules
under section 4(a).
An inspection to determine compliance with PAIR rules.
Inventory compiled by EPA of all chemicals manufactured/
processed in U.S. that were manufactured, imported or pro-
cessed in the period 1975-1977. Chemicals for which PMN is
submitted are added to inventory when manufacturing/processing
commences (i.e., upon receipt of NOC). A major updating of
the inventory will be undertaken in 1986.
An inspection to determine whether the manufacturer,
processor, etc., has kept required records concerning
allegations of previously unknown signifTEant adverse
reactions to health or environment.
An inspection to determine compliance with rules requiring
submission of health and safety studies for chemicals or
classes of chemicals designated by the Agency or the ITC.
An inspection to determine whether the manufacturer,
processor, etc., has properly notified EPA (within 15 days of
knowledge) regarding chemicals that present a substantial
risk to health or environment.
(06/87)
-------
J-3
Table J-2
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
TSCA SECTIONS 5 AND 8 CHECKLIST
Completed
I. Inspection Management .
II. Nature of Facility . .
III. §5 General Information
IV. Bona fide Review . . .
V. Specific PMN Review
VI. 5(e) and 5(f) Order
VII. TME Review
VIII. TSCA §5 Research & Development (R&D)
IX. Low Volume Exemption (LVE)
X. Polymer Exemption
XI. Significant New Use Rule (SNUR)
XII. TSCA §8(a) Level A and 8(d) Compliance Review . . .
XIII. TSCA §8(c) and 8(e) Compliance Review
(06/87)
-------
J-4
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
TSCA SECTION 5/8 CHECKLIST
I. INSPECTION MANAGEMENT (Attach additional information as necessary)
1. Name and Address of Facility:
2.
3.
4.
5.
6.
7.
8.
9.
Telephone No.:
DUNS No.:
Telephone Contact (Name, Title and Date):
Written Notification (Date):
Date and Time of Inspection:
Inspection Team:
[Exhibit 1]
(lead)
TSCA Notice of Inspection Issued to (Name, Title):
TSCA ICN Notice Issued to (Name, Title):
Other Company Inspection Participants (Names, Titles):
1.
2. , -
3.
4.
5.
[Exhibit 2]
[Exhibit 3]
10. Type of Inspection:
_Routine
Followup
Special Request
(06/87)
-------
J-5
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
INSPECTION MANAGEMENT (cont.)
11. Scope of Inspection (List by Federal Register, CAS No. or other
designation):
Gen. Inv.:
Spec. PMN:
TMEs:
LVEs:
PEs:
5(e)/5(f):
BFs:
. 8(a) L(A):
. 8(b):
. 8(c):
. 8(d):
. 8(e):
Sect. 4:
Other:
Other:
12. Walk-through:
Areas:
Yes
No
13. TSCA Receipt for Samples and Documents Issued to:
(Name and Title)
[Exhibit 4]
TSCA Declaration of CBI Issued to:
(Name and Title)
[Exhibit 5]
14. Followup Information Requested:
15. Remarks:
Date Received:
Yes No
(06/87)
-------
J-6
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
II. NATURE OF THE FACILITY (Attach additional information as necessary):
1. Facility History, Organization and Corporate Relationship:
2. Scope, Size and Functions of the Facility:
3. Facility Description and Layout:
(06/87)
-------
J-7
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE_
III. TSCA §5 GENERAL CHEMICAL INVENTORY COMPLIANCE REVIEW
A. Interviewee(s): 1.
2.
B. Chemicals: Manufactured Imported Processed Other
1. Prepared list of chemicals available by CASR No. Yes No
2. List verified against company business records: Yes No
What records:
3. Records reviewed in lieu of prepared list (type and dates):
4. Chemicals reviewed on open inventory by
via
Date search completed:
No. unlisted chemicals: (attach list)
Date unlisted chemicals sent to OCM:
Date reply:
No. chemicals unlisted in conf. inventory:
Date followup with facility: (attach copy)
Date reply: Status:
5. Additional Notes and Remarks:
(06/87)
-------
J-8
INSPECTION NO.:
FACILITY/CITY:
INSPECTION DATE:
IV. TSCA §5 BONA FIDE REVIEW:
A. Interviewee(s): (1)
(2)
B. 1. EPA Accession No.
2. Name of chemical:
3. CAS Registry No. if known:
4. Date of submission:
5. Date of response by Agency:
6. Was chemical found on confidential inventory?
If yes, did company commercialize product?
7. What records were reviewed during inspection?
8. Remarks:
C. 1. Was PMN filed for chemical?
2. Date of submission: PMN No.:
3. Was NOC submitted?
4. Was PMN reviewed during this inspection?
5. Remarks:
(06/87)
-------
J-9
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
V. SPECIFIC PREMANUFACTURE NOTIFICATION (PMN) COMPLIANCE REVIEW
(One PMN per form)
A. Interviewees: (1)
(2)
B. General Information:
1.
2.
3.
4.
5.
PMN No. :
Advance copy avai
Copy at site:
Chemical Name:
Other Names:
Use at site:
90 day Date:
lable:
Manufacture
R & D
NOC Date:
_Yes _No
_Yes _No
Import Process
Other
C. Production Compliance:
1. Date of first commercial manufacture or import (circle):
How verified (records reviewed and dates):
2. Dates and amounts of R & D Production: (1)
Use
(2)
Use
(Attach if more than 2 R & D batches)
How verified (records reviewed and dates):
(06/87)
-------
J-10
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
V. SPECIFIC PREMANUFACTURE NOTIFICATION (PMN) COMPLIANCE REVIEW (cont.)
Mass balance and disposition of R & D material:
3. PMN and R & D records complete as per 40 CFR Part 720.78:
Yes No
Description of PMN records:
Description of R & D records:
4. Additional remarks:
(06/87)
-------
J-ll
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
V. SPECIFIC PREMANUFACTURE NOTIFICATION (PMN) COMPLIANCE REVIEW (cont.)
D. Technical Content
1. Chemical identity:
2. Monomer verification (for polymers only):
3. Impurities:
4. By-products:
5. Use(s):
6. Operation:
7. Exposure:
8. Env. Release:
9. Processing:
10. Test data:
11. Additional Information:
(06/87)
-------
J-12
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VI. SPECIFIC PMN-§5(e) and 5(f) ORDER
A. Interviewee(s): (1)
(2)
B. Compliance Restrictive Elements:
Was PMN chemical in commercial production at time of inspection?
_Yes _No
1. Testing Trigger
Specified Testing Production Volume Trigger
Was a Trigger volume reached? Yes No
If yes, when
If yes, has prescribed testing been initiated? Yes No
If yes, was commercial production stopped? Yes No
Remarks:
2. Gloves
Was glove testing a requirement? Yes No
If yes, was imperviosity testing conducted? Yes No
Was testing conducted by PMN Submitter/
Contractor (circle one)?
Did testing protocol meet Agency guidelines? Yes No
Were gloves demonstrated to be impervious? Yes No
Was glove usage observed? Yes No
Remarks:
(06/87)
-------
J-13
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE_
VI. SPECIFIC PMN-§5(e) and 5(f) ORDER (cont.)
3. Protective Devices and Hazard Communication
What were protective clothing requirements?
Were employees observed to be wearing protective clothing as
described in consent order? Yes No
Were other protective measures and equipment in use by
employees as described in consent order? Yes No
Describe:
Were employees instructed and trained in the proper use of
protective equipment and measures? Yes No
How was this documented?
Were affected employees notified in training sessions with
respect to the hazards, dangers and concerns of the PMN
chemical? Yes No
Were signed attendance sheets available for review by the
inspector? Yes No
Had all operators received appropriate training? Yes No
How verified:
4. Waste Disposal
What was specified disposal requirement?
Was evidence of proper disposal present? Yes No
How verified:
(06/87)
-------
J-14
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VI. SPECIFIC PMN-§5(e) and 5(f) ORDER (cont.)
5. Label Requirements
What was type size specification?
Actual type size on label:
Remarks:
6. Evidence for Customer Compliance
Was there evidence of customer compliance with Agency
restrictions on use as described in manufacturer's letter
to final users? Yes No
Remarks:
7. General (Cleanliness and Housekeeping)
Was the production area of PMN Chemical clean and well-
maintained? Yes No
Was there any evidence of spillage or environmental release?
_Yes _No
Remarks:
(06/87)
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VII. TSCA §5 TEST MARKETING EXEMPTION
A. Interviewees: (1)
(2)
B. General
1. THE No.:
2. Chemical:
CASR No.:
Date of Receipt:
Verification of Chemical Structure:
C. Restrictions
J-15
1. Period of Approved Use
to
Verified via:
2. Production Volume Allowed:
Actual
Verified via:
3. Number of Customers: Allowed:
Actual
Verified via:
(06/87)
-------
J-16
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VII. TSCA §5 TEST MARKETING EXEMPTION (cont.)
4. Use: Allowed: Actual
Verified via:
5. Worker/Consumer Exposure: Actual:
Allowed: _
Verified via:
6. Additional Remarks:
(06/87)
-------
J-17
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA §5 RESEARCH & DEVELOPMENT (R & D)
A. Interviewees: (1)
(2)
B. Background
1. Does facility conduct TSCA defined R & D activities?
_Yes _No
2. If not, where is basic R & D conducted for company?
3. Does facility/company have a written TSCA R & D policy?
_Yes _No
If yes, does the policy reflect recordkeeping and notifica-
tion requirements that became effective 08/04/86?
_Yes _No
Does the facility/company routinely submit bona fide
inquiries? Yes No
4. Remarks:
(06/87)
-------
J-18
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA §5 RESEARCH & DEVELOPMENT (R & D) (cont. )
C. Specific R & D Chemicals (one chemical per page)
1. Were any R & D chemicals specifically verified for compliance
with R & D exemptions? Yes No
a. Name of chemical:
b. Was chemical produced in a quantity over 100 kg/year?
_Yes _No
c. Was recordkeeping complete? Yes No
What type of records?
d. Were notifications adequate? Yes No
How verified?
e. Were "technically qualified individuals" supervising use
of the chemical(s)? Yes No
f. Were risk reviews adequately documented?
_Yes _No
g. Were "prudent Laboratory practices" documented?
_Yes _No
How documented?
h. Were disposition records complete? Yes No
i. Could a reasonable mass balance be accomplished for
reviewed chemicals? Yes No
j. Did amounts produced exceed R & D requirements?
Yes No
(06/87)
-------
J-19
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA §5 RESEARCH & DEVELOPMENT (R & D) (cont.)
k. What was disposition of excess R & D material(s)?
2. Remarks:
(06/87)
-------
J-20
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
IX. LOW VOLUME EXEMPTION (LVE) (One LVE per form)
A. Interviewees: (1)
(2)
B. General:
1. LVE No: Date of Receipt:
21-Day Review Date
2. Chemical:
Other Names:
3. Use(s):
CAS No.
4. Manufacturing Site(s):
C. Restrictions:
D. Compliance:
(06/87)
-------
J-21
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
IX. LOW VOLUME EXEMPTION (LVE) (cont.)
E. Production: 1st 12-month period ( to ): kg
2nd 12-month period ( to ): kg
3rd 12-month period ( to ): kg
F. Test Date: Were test data reviewed for
completeness? Yes No
Were data complete? Yes No
Couldn't determine
G. Remarks:
(06/87)
-------
J-22
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
X. POLYMER EXEMPTION (One PE per form)
A. Interviewees: (1)
(2)
B. General:
1. PE No.:
21-Day Review Date:
2. Chemical Name:
Monomer Composition:
(Verified? )
Date of Receipt:
CAS No.:
_% Residue
_% Residue
% Residue
Number Average MW:
Use(s):
Verified: Yes No
Annual Production Vol.: kg
(Actual): kg
Facility/Address of Manufacturer/Importer:
3. Remarks:
(06/87)
-------
J-23
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XI. SIGNIFICANT NEW USE RULE (SNUR) (One SNUR Chemical per form)
A. Interviewees: (1)
(2)
B. General Information
1. SNUR No.: 90-Day Review Date:
2. Chemical Name: CAS No.:
Other Names:
3. Use at site:
C. Production Compliance
1. Date of first commercial manufacture, report or processing
(circle):
How verified (records reviewed and dates):
2. Remarks
Note: The PMN Technical Content (Part V) and 5(e)/5(f) Order
(Part VII) forms are to be used as appropriate for any
SNUR review.
(06/87)
-------
J-24
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XII. TSCA §8(a) LEVEL A AND 8(d) COMPLIANCE REVIEW
A. Interviewees: (1)
(2)
B. §8(a) Level A
1. Name of Chemical:
2. CAS Registry Number:
3. Published Reporting Date for PAIR/CAIR:
4. Corporate fiscal year:
5. Was PAIR/CAIR report submitted? _Yes _No
Date of Submission:
6. What information on PAIR/CAIR report was verified?
7. What records were reviewed?
8. Did records agree with submitted report?
9. Remarks:
(06/87)
-------
J-25
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XII. TSCA §8(a) LEVEL A AND 8(d) COMPLIANCE REVIEW (cont.)
C. §8(d)
1. Published reporting date for 8(d):
2. Was 8(d) report submitted? Yes No
Date of Submission:
3. Studies submitted (by title):
4. Remarks:
(06/87)
-------
0-26
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA §8(c) and 8(e) COMPLIANCE REVIEW
A. Interviewees: (1)
(2)
B. §8(c)
1. Did facility have a §8(c) file? _Yes _No
Location of file:
Contents: (1) Allegations: Yes No
If yes, how many?
(Attach list of chemical(s), processes and effects)
(2) Copy of the 8(c) regulations?
_Yes _No
(3) Copy of company or facility 8(c) policy?
_Yes _No
2. If allegations were on file, did they appear to represent
unknown effects? Yes No
Remarks:
3. Were recorded allegations filed correctly and completely?
_Yes _No
Remarks:
4. Other records (OSHA, incident files, lawsuits) reviewed for
allegations and findings?
(06/87)
-------
J-27
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA §8(c) and 8(e) COMPLIANCE REVIEW (cont.)
5. Were company officials generally knowledgeable of 8(c)
requirements? Yes No
Remarks:
6. Had there been any apparent attempts at employee outreach?
_Yes _No
Remarks:
7. Were fact sheets and other information left with plant
officials? _Yes _No
C. §8(e)
1. Did the facility or company have a §8(e) policy?
_Yes _No
Did the facility have an 8(e) file? Yes No
Location of file:
Has the facility or company made any TSCA §8(e) submittals to
the Agency? Yes No
List:
Were all 8(e) submissions filed within 15 days?
_Yes _No
How verified:
(06/87)
-------
0-28
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA §8(c) and 8(e) COMPLIANCE REVIEW (cont.)
2. Were company officials generally knowledgeable of 8(e)
requirements? Yes No
Remarks:
3. Were other spills or releases reported to
EPA State authority or the Coast Guard in
a timely manner? Yes No
Remarks:
4. Have any civil lawsuits been filed against the facility
with respect to health or environmental effects?
_Yes _No
Remarks:
(06/87)
-------
APPENDIX K
PESTICIDE CHECKLIST
-------
K-l
Appendix K
PESTICIDE INSPECTION CHECKLIST
INTERVIEW/RECORDS
1. Are pesticides used at the facility?
a. Circle general types used:
Yes
No
Algacides Insecticides Fungicides Herbicides Rodenticides
Other
2.
3.
4.
Are any restricted use pesticides used
at this facility?
Are pesticides applied by facility personnel?
Are pesticides handlers certified?
a. Circle type of certification:
EPA State DOD Other
b. Are pesticide handlers authorized for
restricted use pesticides? _
c. Are licenses/certificates current (not expired)?
Yes
Yes
Yes
Yes _
Yes
No
No
No
_ No
No
5. Has the facility pesticide program been inspected
before?
a. Circle by whom:
EPA State DOD
b. General results
Other
Yes
No
6. Does the facility have application records?
7. Has the facility filed restricted use pesticide
reports?
8. Does the facility have inventory records?
9. Are target pests indicated on application records?
a. Are the pesticides used registered for use
against the target pest?
Yes
No
Yes
Yes
Yes _
Yes
No
No
_ No
No
(06/87)
-------
K-2
Appendix K (cont.)
10. Are pesticide handlers' training records current? Yes No
a. Types of training
STORAGE
1.
2.
3.
4.
5.
6.
7.
8.
9.
Is the storage area located on a flood plain?
Is the storage area fenced?
Is the storage area kept locked?
Are pesticides stored under cover?
Is the area well ventilated?
Is the area posted with pesticide or chemical warning
signs (i.e., DANGER - POISON)?
Are pesticides separated by type?
Are the pesticides properly labeled?
Are pesticides stored in other than original
containers?
a. Explain, if yes.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
MIXING/LOADING
1.
2.
3.
4.
5.
6.
7.
8.
Is there a mixing/loading area?
Is the mixing/loading equipment functional?
Does the equipment help reduce the handlers exposure
to pesticide?
Are label directions followed?
Is protective clothing worn by handlers?
Does protective clothing look used?
Is there a mechanism for rinsing containers?
How is rinse liquid disposed of?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
(06/87)
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K-3
Appendix K (cont.)
9. Is spray equipment cleaned between applications? Yes No
a. How is rinse liquid disposed?
CONTAINER DISPOSAL
1. Are label directions followed? Yes No
2. Are empty containers triple rinsed? Yes No
3. Are containers offered for scrap or recycle? Yes No
4. Are containers punctured or crushed to help prevent
improper reuse? Yes No
5. Are drums given away for burn barrels, etc.? Yes No
6. Is there a container disposal site at the facility? Yes No
7. Is the site fenced and locked? Yes No
8. Are there pesticide or chemical warning signs posted? Yes No
(06/87)
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APPENDIX L
WATER SUPPLY CHECKLIST
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L-l
2.
3.
4.
Appendix L
WATER SUPPLY CHECKLIST
Community
Basic Information
Supply Name
County
Date of Inspection
Noncommunity
I.D. Number
Phone
Establishment
No. of Service Connections
Period of Operation: 12 month
If Seasonal: From
Pop. Served
Seasonal
To
Surface - Other community system
Other community system name
Wells
Spring surface
Wells (source of information) W(
Year installed Casing Diameter
Distance to potential contamination
Controlled access to well?
If yes, distance
;11 log (attached)
in. Depth
ft. Source
Yes
ft.
No
Comments:
Well Details:
Well house Yes No
Heated, lighted Yes No
Casing above grade Yes No
Subject to flooding Yes No
Pump Details:
Brand and Model
Capacity gpm
Type: (Circle)
Submersible
Vertical turbine
Deep well jet
Shallow well jet
Shallow well centrifugal
Comments
Well seal Yes
Water level
device Yes
Grouted Yes
Casing vent Yes
Horsepower
at ft.
Pump removal provi
Pump to waste pi pi
Capacity adequate
Sample tap
No
No
No
No
head
si on
ng
-------
L-2
Appendix L
Other Source
Spring
Surface source
Security (signs, fences, etc.)
Minimum available flow gpm Measured
Sources of contamination
Estimate
Source area ownership
Springs
Fencing Yes No Screened Overflow
Surface runoff Hatch and curbing
ditch Yes No Bottom drain
Springbox Yes No
Comments:
Yes
Yes
Yes
No
No
No
Surface Source
Impoundment Yes No Spillway
Diversion dam Yes No Intake screens
Infiltration Drain
gallery Yes No
Source name:
Yes
Yes
Yes
No
No
No
Comments:
Storage
General: Volume gallons Type: Reservoir
Separate inlet/ Drain to
outlet Yes No daylight
Hatch Yes No Flap valve
Water level Booster pump
indicator Yes No
Reservoir: Material
Overflow
Screened vent
Covered
Hydro-pneumatic tank: Operating range
Hydro-pneumatic
Yes
Yes
Yes
Yes
Yes
Yes
-
No
No
No
No
No
No
-------
L-3
Appendix L (cont.)
7. Distribution System
Types of piping
Adequate pressure (20) Yes No
Flushing program Yes No
8. Chlorination: Continuous chlorination? Yes No
Sodium hypochlorite Yes No Proportional
Calcium hypochlorite Yes No to flow Yes No
Gas Chlorine Yes No DPD chlorine
test kit Yes No
Booster pump Yes No
Type of chlorinator:
Contact time provided by:
Volume of contact chamber: gallons (A)
Estimated maximum system flow: (B)
Contact time - A/B -: minutes
Commments:
9. Monitoring: Type of system (check)
Groundwater
Surface water
Purchase from other water system
Sampling
Required Current? Met MCL's?
Parameter Frequency Yes No Yes No
Coliform bacteria
Turbidity
Inorganics (nitrate)
Radiologic
contaminants
Organics
Other
Comments:
-------
APPENDIX M
UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
-------
M-l
Appendix M
UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
Regulatory Authority to Conduct Inspections
Safe Drinking Water Act §1445
40 CFR §144.l(c)
40 CFR §144.51(i)
RCRA §3007(a) (Class I wells only)
I. Type of UIC Program
EPA Administered (40 CFR Parts 146 & 147 applicable)
State Administered (Applicable State Regulations)
II. Type of Well (40 CFR 146.5)
Class I (see Parts IV, VA)
Class II (see Parts IV, VB)
Class III (see Parts IV, VC)
Class IV (see Parts IV, VD)
Class V (see Parts IV, VE)
III. Operation Authority
' Rule
Permit
IV. General Requirements
Construction
(1) Depth to base of USDW
(2) Depth to injection zone
(3) If injecting into USDW, has formation
been exempted? Yes No
(4) Adequate confining zone between USDW and
injection zone? Yes No
(5) Surface casing length, type
volume, type of cement
(6) Long string casing length, type
volume, type of cement
(7) Intermediate casing(s) length type a)
volume, type of cement
b)
(06/87)
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M-2
Appendix M (cont.)
(8) Injection tubing length, type ,
packer Yes No
volume, type of cement on packer ._
(9) Injection fluid
Corrosive Noncorrosive
(10) Injection pressure
(11) Field verification of injection pressure Yes No
Pressure
(12) Injection pressure limit?
(13) Annular pressure
(14) Annular fluid
Types of logs run, date and interval tested:
(15) Formation data:
Fluid pressure
Temperature (Class I)
Fracture pressure
Physical characteristics
Chemical characteristics
(16) Construction complies with
Permit or Rule Yes No
If not, specify
(17) Facility operations match permit/rule
requirements Yes No
If not, specify
(06/87)
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M-3
Appendix M (cont.)
(18) EPA notified of any discrepancies in
operations Yes No
(19) Emergency procedures adequate Yes No
(20) High and low pressure shutoffs on both pumps
and source tanks Yes No
(21) Number and location of injection wells are as
described in inventory and/or permit conditions Yes No
(22) All information required is available and current Yes No
(23) Information is retained for required period Yes No
(24) Sampling and analysis data are complete Yes No
(25) EPA notified of any well failures and/or
corrective actions Yes No
(26) Plugging and abandonment plan on file Yes No
(27) Financial assurance current and on file Yes No
V. Operating, Monitoring, Reporting Requirements
A. Class I Requirements:
(1) Injection pressure exceeds maximum Yes No
(2) Injection between outermost casing
and well bore Yes No
(3) Continuous monitoring of:
a. Injection pressure Yes No
b. Flow rate Yes No
c. Volume Yes No
d. Annulus pressure Yes No
e. All monitoring equipment operational Yes No
(4) Sample injected fluid frequently
enough to be representative Yes No
(5) Mechanical Integrity test
a. Within the last 5 years Yes No
b. Pass Fail
(06/87)
-------
M-4
Appendix M (cont.)
If fail, were workovers completed
(6)
(7)
Class
and well retested?
Wells within area of review (AOR)
a. Type, number, location of wells within
used to monitor USDW (attach map if
necessary)
b. Are required parameters monitored
1. physical (pressure)
2. chemical
Quarterly Reports to Director containing:
a. Physical, chemical characterization of
injected fluid
b. Monthly average, maximum and minimum
values for:
1. injection pressure
2. flow rate
3. volume
4. annular pressure
5. results from monitoring wells
6. mechanical integrity test
7. well workovers
8. any other tests
(specify)
II Requirements:
Yes
Yes
AOR
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
B.
(1) Injection pressure exceeds maximum Yes No
(2) Injection pressure exceeds confining
zone maximum adjacent to USDW Yes No
(3) If operating above fracture pressure:
pressure, location and number of
wells affected by injection (attach
map)
(4) Injection between outermost casing and
well bore Yes No
(5) Representative sample of injection fluid Yes No
(06/87)
-------
M-5
Appendix M (cont.)
(6) Observation of pressure, flow rate
and cummulative volume at the
following frequency:
a. Brine disposal (IID) weekly Yes No
b. Enhanced recovery (IIR) monthly Yes No
c. Hydrocarbon (IIH) daily Yes No
d. Cyclic steam daily Yes No
(7) Recording of one observation of pressure,
flow rate and cummulative volume at
least once every 30 days Yes No
(8) Mechanical integrity test every 5 years Yes No
(9) Manifold monitoring (for IIR or IIH)? Yes No
If yes, demonstration approval by
Director for alternate monitoring Yes No
(10) Maintain records until next permit
review Yes No
(11) All monitoring equipment operational Yes No
C. Class III Requirements:
(1) Formation data (Substitute for IV 15)
a. If naturally water-bearing:
1. Fluid pressure
2. Fracture pressure
3. Physical characteristics
4. Chemical characteristics
b. If non water-bearing:
1. Fracture pressure
If formation is a USDW, monitoring wells must be located
in the injection formation and in any USDW's above the
injection formation to detect migration of injected
fluids, process by-products or formation fluids outside
the injection zone
1. Are appropriate wells located to
monitor injection operation Yes No
(06/87)
-------
M-6
Appendix M (cont.)
2. If area is subject to subsidence
or catestrophic collapse, are
wells located so they will not
be physically affected? Yes No
d. If injection wells penetrate a USDW
and in an area subject to subsidence
or catastrophic collapse:
1. Are these monitoring wells com-
pleted into the USDW? Yes No
2. Are the monitoring wells capable
of detecting the movement of
injected fluids and by-products
into the USDW? Yes No
3. Are the wells located outside the
physical influence of subsidence
or catastrophic collapse? Yes No
e. What is the frequency of monitoring wells
under c and d above?
f. Were the following points evaluated in the determination
of monitoring frequency?
I. Population relying on USDW Yes No
2. population affected by
injection Yes No
3. Proximity of injection to points
of drinking water withdrawal Yes No
4. Operating pressures Yes No
5. Nature and volume of injected
fluid Yes No
6. Injection well density Yes No
(2) Injection pressure exceeds maximum Yes No
(3) Injection between outermost casing and
and well bore Yes No
(4) Injection fluid sampled frequently
enough to be representative Yes No
(06/87)
-------
M-7
Appendix M (cont.)
(5) Mentoring of injection pressure
semimonthly and either: Yes No
a. Flow rate Yes No
b. Volume Yes No
c. Metering and daily recording of:
1. injected volume Yes No
2. produced fluid Yes No
(6) MIT at least once every 5 years for salt
solution mining Yes No
(7) Monitoring the fluid volume in the
injection zone semimonthly Yes No
(8) Monitoring the appropriate parameters
chosen to measure water quality in the
monitoring wells semimonthly (see 12c
above) Yes No
(9) Quarterly monitoring of wells (see 12d
above)
(10) Manifold monitoring?
(11) Individual well monitoring?
(12) Facility received approval for manifold
monitoring?
(13) Quarterly reports to Director?
including:
a. MIT
b. Other tests (specify below)
c. Reported by project/field
d. Individual wells
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
D. Class IV Requirements:
Class IV wells are banned and have no inspection requirements
other than plugging and abandonment or continued monitoring accord-
ing to individual State/EPA requirements
(1) Date plugged and abandoned
(06/87)
-------
M-8
Appendix M (cont.)
(2) Other available information
E. Class V Requirements:
No monitoring requirements unless permit has been issued by a
delegated State.
If State issued permit, specify requirements and compliance/
noncompliance
(06/87)
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