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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                                                                           11
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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                                                                           13
     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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                                                                                                                 17
                                                           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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                                                                           19
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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                                                                           20
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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                                                                           21
     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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                                                                           22
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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                                                                           23
          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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                                                                 24
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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                                                                           25
          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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                                                                      28
     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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                                                                           29
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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                                                                           30
     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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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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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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                                                                           33
     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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                                                                      37
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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                                                                           38
     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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                                                                           39
     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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                                                                      40
     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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                                                                           41
     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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                                                                           42
     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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                                                                           43
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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                                                                           44
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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                                                                           45
     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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                                                                           47
     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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                                                                           48
     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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                                                                           49
 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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                                                                           50
     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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                                                                 51
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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                                                                           52
          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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                                                                           53
     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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                                                                           54
                    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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                               BIBLIOGRAPHY
 1.   EPA Order 1000.18, Transportation of Hazardous Materials, February 16,
     1979.   Washington, D.C., Environmental  Protection Agency.

 2.   EPA Order 1440.2, Health and Safety Requirements for Employees Engaged
     in Field Activities, July 12,  1981.   Washington, D.C.,  Environmental
     Protection Agency.

 3.   EPA Order 1440.3, Respiratory Protection, July 24, 1981.  Washington,
     D.C.,  Environmental  Protection Agency.

 4.   EPA Order 1440.4, Health and Safety Training Requirements  for Mine
     Safety,  August 17,  1982.  Washington,  D.C.,  Environmental Protection
     Agency.

 5.   EPA Order 1440.6, Motor Vehicle Occupant Restraint Systems,  February 2,
     1984.   Washington, D.C., Environmental  Protection Agency.

 6.   EPA Order 1440.7, Hazard Communication,  May 30,  1986.   Washington, D.C.,
     Environmental  Protection Agency.

 7.   EPA Order 3100.1, Uniforms,  Protective Clothing and Protective Equipment,
     Decembers,  1972.  Washington, D.C., Environmental Protection  Agency.

 8.   EPA Order  3100.3, Authorization  of  Performance of Hazardous  Duty,
     October 31, 1977.  Washington, D.C., Environmental Protection  Agency.

 9.   G. William Frick, October 1981.   Conducting an Environmental  Audit,
     Washington,  D.C., Van Ness, Feldman, Sutcliffe, Curtis and  Levenberg.

10.   Industrial Environmental Research Laboratory, August 1979.  A Handbook
     of Key Federal Regulations  and Criteria for Multimedia Environmental
     Control.   Interagency Energy/Environment R&D Program Report, Research
     Triangle Park, North Carolina,  Environmental  Protection Agency, EPA-
     600/7-79-175.

11.   National  Enforcement Investigations Center,  July 1981.   A Step-fcy-Step
     Approach to Development  of  NPDES and RCRA Permits,  Denver,  Colorado,
     Environmental  Protection Agency, EPA-330/1-81-004.

12.   National  Enforcement Investigations  Center, August 1979.  Enforcement
     Considerations for Evaluation of Uncontrolled Hazardous Waste Disposal
     Sites  by Contractors, Draft Report,  Denver,  Colorado, Environmental
     Protection Agency.

13.   National  Enforcement Investigations  Center, August 1979.  Performance
     Audit  Inspections of Rtestewaster Sources,  Denver, Colorado, Environ-
     mental Protection Agency, EPA-300/1-79-004.

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14.   National Enforcement Investigations Center, March 1981.   NEIC Pesticide
     Sampling Guide, EPA 330/9-81-001.

15.   National Enforcement Investigations Center, (revised) May 1986.  NEIC
     Policies and  Procedures  Manual.   Denver,  Colorado:   Environmental
     Protection Agency, EPA-330/9-78-001-R.

16.   National Enforcement Investigations Center, July 1981, RCRA Inspection
     Manual, Denver, Colorado, Environmental  Protection Agency.

17.   National Institute for Occupational Safety and Health (NIOSH), et al.,
     October 1985,  Occupational  Safety  and  Health Guidance  Manual for
     Hazardous Waste  Site Activities.    Washington,  D.C., United  States
     Government Printing Office.

18.   Office of Administration, Occupational  Health and Safety Staff, Eye
     Protection Program Guideline.   Washington, D.C., Environmental Protec-
     tion Agency.

19.   Office of Administration, Occupational  Health  and Safety Staff, May 1987.
     Interim Health  and Safety Guidelines  for EPA  Asbestos Inspectors
     (Revised).   Washington, D.C.,  Environmental Protection Agency.

20.   Office of Administration, Occupational  Health  and Safety Staff, March 18,
     1986.   EPA 1440, Occupational Health and Safety Manual,  1986  Edition.
     Washington,  D.C., Environmental  Protection Agency.

21.   Office of Administration, Occupational  Health and Safety Staff, Eye
     Protection Program Guideline.   Washington, D.C., Environmental Protec-
     tion Agency.

22.   Office of General Enforcement, February 1979.   Enforcement Workshop on
     Plant Inspection and Evaluation -  Volume II,  Inspection Procedures and
     Performance Evaluation,  Washington, D.C., Environmental  Protection
     Agency.

23.   Office of General Enforcement, February 1979.   Enforcement Workshop on
     Plant  Inspection  and Evaluation -  Volume  III,  Process and Control
     Equipment Flow  Charting  Techniques,  Washington, D.C.,  Environmental
     Protection Agency.

24.   Office of General  Enforcement,  February 1979.  Inspection Procedures
     for Evaluation of Electrostatic Precipitator Control System Performance,
     Washington,  D.C.,  Environmental Protection Agency,  EPA-304/1-79-007.

25.   Office of Planning  and Management,  April 1973, EPA Employee Responsi-
     bilities and Conduct, Washington,  D.C. ,  Environmental Protection Agency.

26.   Office of Water  Enforcement,  Enforcement Division,  June 1984.  WPDES
     Compliance Inspection Manual,  Washington,  D.C.,  Environmental Protection
     Agency.

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27.   Office  of  Water  Enforcement,  Enforcement Division,  1977.   NPDES
     Compliance Sampling Inspection Manual,  Washington,  D.C., Environmental
     Protection Agency.

28.   Oregon  State  Health Division, Department of  Human  Resources,  Small
     Public Water Supply Sanitary Survey Report,  33-5 (revised January 1985).

29.   PEDCO Environmental,  Inc.,  1980.   Standards  of Performance  for New
     Stationary Sources - A Compilation as of January 1,  1980.  Cincinnati,
     Ohio, Environmental  Protection Agency,  EPA-340/1-77-015, EPA-340/
     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.
                                                                     (06/87)

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A-2
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
                                                                     (06/87)

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                                                                         A-3
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).
                                                                     (06/87)

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A-4
     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).
                                                                     (06/87)

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                                                                         A-5
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.


                                                                      (06/87)

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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.

                                                                     (06/87)

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                                                                        A-7
     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.
                                                                     (06/87)

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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


                                                                     (06/87)

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                                                                        A-9
          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.


                                                                     (06/87)

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A-10
     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.
                                                                     (06/87)

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                                                                         A-11
     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.
                                                                     (06/87)

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A-12
          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
                                                                     (06/87)

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                                                                        A-13
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.
                                                                     (06/87)

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A-14
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.
                                                                     (06/87)

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                                                                        A-15
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

                                                                     (06/87)

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A-16
          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)

-------
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)

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                                                                         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.

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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)

-------
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)

-------
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)

-------
                                                                         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)

-------
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)

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                                                                         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

-------
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:

-------
  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)

-------
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)

-------
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)

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                                                               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)

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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)

-------
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)

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                                                                         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)

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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)

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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)

-------
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)

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                                                                         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)

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                                                                         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)

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          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)

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                                                                         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)

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                                                                          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)

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                                                                         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)

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                                            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)

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                                                                         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)

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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)

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                                                                         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)

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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)

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                                                                         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)

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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)

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                                                                         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)

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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)

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                                                                         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)

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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)

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                                                                         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)

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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)

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    APPENDIX K



PESTICIDE CHECKLIST

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                                                                         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)

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 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

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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:

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                 APPENDIX M



UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST

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                                                                        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)

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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)

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                                                                   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)

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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)

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                                                                   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)

-------