NEIC
MULTI-MEDIA
COMPLIANCE AUDIT
INSPECTION PROCEDURES
February 1983
National Enforcement Investigations Center, Denver
U.S. Environmental Protection Agency
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF LEGAL AND ENFORCEMENT COUNSEL
MULTI-MEDIA
COMPLIANCE AUDIT
INSPECTION PROCEDURES
February 1983
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
INTRODUCTION 1
PURPOSE AND SCOPE ......' 1
OBJECTIVES OF INSPECTIONS . . . 2
INSPECTOR RESPONSIBILITIES
PLANNING THE INSPECTION 6
~ REVIEWING BACKGROUND 6
""DEVELOPING A PROJECT PLAN .- 10
NOTIFYING THE FACILITY 12
CONDUCTING THE INSPECTION 15
ENTRY 15
OPENING CONFERENCE 19
INSPECTION 1 . . 21
ELEMENTS OF AN INSPECTION 22
CLOSING CONFERENCE 35
- PREPARING THE INSPECTION. REPORT 36
REFERRALS 36
REFERENCES . . . 38
ACRONYMS 40
Tables
1 Federal Statutes/Regulations for Multi-Media Compliance
Audit Inspections 9
2 Background Review Information Sources 11
3 Inspection Authority Under the Major Environmental Acts .... 17
4 Summary of Federal Environmental Acts Regarding Right of
Entry, Inspections, Sampling, Testing, Etc • 18
APPENDICES
A CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
B EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS
C AIR POLLUTION CHECKLISTS
D WATER POLLUTION CHECKLISTS
E PROCEDURES FOR HANDLING, PRESERVING, AND TRANSPORTING SAMPLES
F SUMMARY OF POLLUTION CONTROL LEGISLATION
G RCRA AND CERCLA CHECKLISTS
H TSCA AND PCB CHECKLISTS
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INTRODUCTION
PURPOSE AND SCOPE
These procedures are a guide for inspectors authorized to conduct
multi-media compliance audit inspections of facilities that discharge, emit,
handle, or dispose of pollutants controlled by Federal environmental laws
and regulations. Investigative techniques are presented which integrate
the enforcement programs in air, water, solid waste, toxic substances, et
al. The procedures focus on generic activities and functions while high-
lighting special features of the specific media.
Enforcement organizations have frequently made decisions on what chem-
icals to control and how to control them, with limited consideration of
tradeoffs between the various environmental media. For instance, pollut-
ants may be unintentionally transferred from one media to another, and al-
though emissions of a chemical in one media have been rigidly controlled,
other major emissions have received little attention. Major source pollut-
ant reductions in one media should not be achieved while creating adverse
effects in another media.
Pollution sources vary in complexity and difficulty to inspect depend-
ing on facility size, process operations, and variety of pollution programs
involved (e.g., air, water, solid waste, toxic substances). The time and
personnel resources required, therefore, vary accordingly. For example, a
large industrial facility with multiple process operations that result in
waste effluents, emissions, waste residues, etc. involves consideration of
pollution problems regulated under several laws, such as Clean Water Act
(CWA), Clean Air Act (CAA), Resource Conservation and Recovery Act (RCRA),
and Toxic Substances Control Act (TSCA). A multi-media compliance audit
inspection of this magnitude requires an inspection team that has suffici-
ent combined experience to effectively audit all the pollution aspects of
the facility.
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The compliance audit inspection approach is intended to more effec-
tively schedule the time of investigatory personnel and reduce multiple
visits to the same facility. In addition, this approach supports a national
system for analyzing the overall compliance status of a particular source
and identifying pollution problems by targeting inspections according to
national compliance priorities. Finally, these procedures discuss the types
of information that inspection teams try to obtain before the compliance
audit inspection commences, and also the information sought and the areas
that are inspected once the team is onsite.
OBJECTIVES OF INSPECTIONS
The overall purpose of this guide is to provide clear and uniform pro-
cedures for multi-media compliance audit inspections. Specific objectives
of such inspections are to:
Document overall facility compliance with pollution control rules,
including emission and effluent limitations; sampling, analytical,
self-reporting, flow measurement, and recordkeeping requirements;
and construction and implementation schedules.
Determine probability of a facility to maintain "continuous com-
pliance" across all environmental program areas, including deter-
mining if process operations and operation and maintenance prac-
tices are minimizing pollutant emissions/discharges.
Assure that valid, acceptable, and defensible information are
collected for potential enforcement needs.
Thus, compliance audit inspections are intended to develop screening
information to determine whether a facility is in compliance or not and, in
the latter case, define the need for potential remedial and/or enforcement
action. It may further trigger followup comprehensive field investigation
and case preparation.
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In performing compliance audit inspections, inspectors follow estab-
lished Agency policies and procedures concerning matters of: chain-of-
custody and document control; receipt and handling of confidential infor-
mation; employee conduct, responsibilities, and ethics; quality assurance
and quality control; and all applicable safety rules. The inspectors have
a responsibility to collect factual and valid information and data which
are supportable and admissible for use in any subsequent enforcement action.
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INSPECTOR RESPONSIBILITIES*
The primary responsibility of inspectors is to gather information that
will be used to determine facility compliance with applicable regulations,
rules, and other requirements. Inspectors represent the agency in dealing
with regulated industry and municipalities and with the public. Inspec-
tions should be conducted to reflect credit on field personnel and the agen-
cy. Cooperation and good working relations should be sought at all times.
The use of diplomacy, tact, and persuasion ensure that all facility person-
nel are treated with courtesy and respect. Inspectors should not speak of
any person, regulatory agency, manufacturer, or product in a derogatory
manner.
Inspectors must adhere to regulations covering EPA employee responsi-
bilities and conduct codified in 40 CFR Part 3 which are described in the
EPA handbook, "Responsibilities and Conduct for EPA Employees." Any act or
failure to act by an inspector motivated by reason of private gain is il-
legal, and any actions which may be construed as influencing the perform-
ance of governmental duties should be avoided. Inspectors should dress
appropriately including the wearing of protective clothing or equipment, as
required. All proper safety provisions and precautions must be rigidly ad-
hered to throughout the inspection.
Inspectors should possess a high level of competence and work ethic
standards. Inspectors should be familiar with agency policies and proce-
dures, have authority to inspect, know techniques for evidence gathering,
and possess skill in collecting information and obtaining statements from
interviewees. Inspectors should inspire respect and confidence, maintain
good will, be able to relate to and communicate with facility operators,
and demonstrate strong interpersonal skills.
* References 1, 2 and 4-6 used in this section.
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Inspectors should possess a good working knowledge of the various en-
vironmental pollution control statutes and understand rules, regulations,
and other provisions including permits, registrations, authorizations,
limitations, monitoring requirements, etc., as they pertain to a specific
facility. The inspector should possess sufficient knowledge of manufactur-
ing and production processes, modern-day pollution control technology, and
the nature of pollution problems and possible solutions, including available
treatment and controls.
Inspectors must properly handle information for which confidentiality
is claimed or requested to prevent disclosure to unauthorized persons. In-
spectors must possess a specific authorization to have access to or handle
Confidential Business Information under TSCA. No confidential information
should be gathered unless absolutely necessary to fulfill inspection
objectives. Procedures for handling Confidential Business Information are
presented in Appendix A.
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PLANNING THE INSPECTION*
REVIEWING BACKGROUND
Collection and analysis of available background information on the
facility are essential to the effective planning and overall success of a
compliance audit inspection. Materials are obtained from files of Federal,
State, and local agencies, technical libraries, and other information
sources. This review will enable inspectors to become familiar with facil-
ity operations; conduct the investigation in a timely manner; minimize in-
convenience to the facility by not requesting data previously provided to
the Federal, State, and/or local agencies; conduct a thorough and efficient
inspection; clarify technical and legal issues before entry; and develop a
sound, factual inspection report.
A properly conducted background review should consider both the legal
and technical information sought and the available information sources.
The following discusses the types of information which should be acquired
by approaching the background review from both directions.
Technical Information Sought
Facility Background
Maps showing facility location and environmental (stacks, dis-
charge pipes, etc.) and geographic features
Names, titles, phone numbers of responsible Company officials
Process flow charts and major production centers
Production levels - past, present and future
Geology/hydrogeology of the area
Changes in plant conditions since previous inspection/permit
application
Available aerial photographs
* References for this section include Nos. 1-7.
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Inspection Reports, Records, and Files
Federal and State compliance files
Correspondence between Company, local, State, and Federal agencies
Citizens' complaints and reports, followup studies, findings
Previous inspection records, reports, correspondence on past inci-
dents or violations
Self-monitoring data and reports
Previous EPA, State, and consultant studies and reports
Annual reports by Company (e.g., PCB reports, §10k reports)
RCRA data including interim status and uncontrolled site inspec-
tion reports, manifest files, etc.
Laboratory capabilities
Reports of previous hazardous substances spills
Waste Generation, Control, Treatment, and Disposal Systems
Description and design data for each appropriate pollution control
system and process operation
Sources and characterization of waste discharge, emissions, and
disposal
Type and amount of waste discharged, emitted, and disposed of
through storage or treatment
Waste storage areas
Waste/spill contingency plans
Available bypasses or diversions and spill containment facilities
Industrial processes, pollution control, treatment and disposal
methods, monitoring systems.
Legal Information Sought
Requirements, Regulations, and Limitations
Copies of permit application, draft, or existing permits, regis-
trations, regulations, and requirements—Federal, State and
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local—and restrictions placed on discharges, emissions, and
disposal practices, compliance schedules, monitoring and reporting
requirements, available monitoring stations, and analytical meth-
ods used by the Company. Permits will reflect whether the "bub-
ble" concept has been applied at the facility.
Special exemptions and waivers, if any
Receiving stream water quality standards, ambient air standards,
protected uses
RCRA Notification and Part A and Part B application data
Previous facility applications for water, air, and solid waste
permits. These files may contain useful data not shown elsewhere.
One example is Form 2C in NPDES water permit applications which
can provide important information on priority pollutant discharges.
Grant applications for publicly-owned treatment works, R&D demon-
stration projects, and progress reports on these projects
Enforcement History
Status of current and pending litigation against Company
Previous deficiency notices issued to facility and responses by
Company
Status of Administrative Orders, Consent Decrees, or other regula-
tory corrective actions, if any, and compliance by Company.
Information Sources
Laws and Regulations - Federal laws and regulations establish proce-
dures, controls, and other requirements applicable to a facility [Table 1].
In addition, complimentary and conflicting State laws and regulations, and
sometimes even local ordinances, are applicable to 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 or
pollutant generation, treatment, control, and disposal practices; contin-
gency plans and emergency procedures; and pollutant characterization—
types, amounts, and points/locations of discharge, emission, or disposal.
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Table 1
FEDERAL STATUTES/REGULATIONS FOR MULTI-MEDIA COMPLIANCE AUDIT INSPECTIONS
Inspection
Authority
Recordkeeping
Authority
Air
CAA
114a, 208., 211a
[80, 86D]
114
[51,57]
58,60,61,
79,85,86]
Water
CWA
308
[122.7]
308, 402
Superfund
CERCLA
104
308
Pesticides
FIFRA
8,9
[169.3]
2,4,8
[169] .
Solid Waste
RCRA
3007
[122.7]
3002,
3003, 3004
[122.11,122.7]
Drinking Water
SDWA
1445
[122.7, 142.34]
1445
[122.11,122.7]
141.31-33]
Toxics
TSCA
11
8
[704,710
761]
Confidential [2.201-2.215] [2.201-2.215]
Information [2.301,53,57,80] [2.302]
[122.19] [122.19]
Emergency
Authority
Employee
Protection
Permits
Basic requirements
includes applications
standard permit con-
ditions, monitoring,
reporting
EPA procedures for
permit issuance
Technical require-
ments
Specific Source
Category-Controls-
Limitations-
Standards-Rules
303
322
[51]
[124]
[52]
NSPS% [60]
NESHAPT [61]
CEM* [60]
SIP [52]
PSDJ [50]
104
[2.201-2.215]
104, 106
110
504
507
[122]
[124]
[129-133,136]
BMP^ [125]
SPOT [112]
Waivers [125,230]
Effluent Guidelines
[400-460]
BMP [125]
SPC [112]
Pretreatment [125,403]
7,10
[2.201-2.215]
[2.307]
[164,166]
[2.201-2.215]
[2.305]
[122.19]
7003
[122.7]
7001
[122]
[124]
[260-266]
[2.201-2.215]
[2.304]
[122.19]
1431
[122.40]
1450
[122]
[124]
[146,264,267]
14
[2.201-2.215]
[2.306]
23
Generators [262]
Transporters [263]
TSD1 [265]
First phase stds
for TSD permits [264]
Interim Stds [265]
Storage <90 days [262]
Exemptions [261]
PCBs [761]
Dioxin [775]
a Statute, e.g., Clean Air Act, Section 114, 208, or 211
b [80,86] = 40 CFR, Parts 80 and 86; CFR refers to Code of Federal Regulations.
c BMP - Best Management Practices.
d SPCC - Spill, Prevention, Containment, and Control.
e NSPS - New Source Performance Standards.
f NESHAP - National Emission Standards for Hazardous Air Pollutants.
g CEM - Continuous Emission Monitoring.
h SIP - State Implementation Plans.
i TSD - Treatment, Storage, and Disposal.
j PSD - Prevention of Significant Deterioration
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Regional and State Files and Contacts - Files or contacts often possess
grants and grant applications, facility self-monitoring data, and inspection
reports, as well as permits and permit applications, applicable to individ-
ual facilities. Files contain or contacts can provide compliance, enforce-
ment, and litigation history; special exemptions and waivers applied for
and granted or denied; citizen complaints and action taken; process opera-
tional problems/solutions; pollution problems/solutions; laboratory capa-
bilities or inabilities; and other proposed or historical remedial actions.
Consultant reports can provide design and operation data and recommendations
for processes, pollutant/waste sources, treatment/control/disposal systems,
and remedial measures.
Technical Reports, Documents, and References - These information sources
provide generic information on industrial process operations, as well as
pertinent specific data on available treatment/control/disposal techniques,
such as their advantages*or drawbacks, limits of application, etc. Such
sources include Effluent Guideline and New Source Performance Standard de-
velopment documents.
Background review information sources for all program areas and those
that apply specifically to the water, air, solid waste, and toxic substances
programs are contained in Table 2.
DEVELOPING A PROJECT PLAN
A project plan is essential to the effective conduct of a compliance
audit inspection. After reviewing the available background information, a
comprehensive plan is prepared to describe why the project is being done,
the tasks required to fulfill the objectives, when the required tasks are
to be accomplished, and when findings and conclusions on the work will be
reported. A project plan generally addresses the following items:
Objectives - The plan defines what the inspection is to accomplish
from an environmental compliance standpoint. An example would be:
"The overall objective is to determine environmental compliance with
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Table 2
BACKGROUND REVIEW INFORMATION SOURCES
Al 1 Program Areas
Water Pollution
CWA
Air Pollution
CAA
Solid Wastes Pollution
RCRA
Toxic Substances Pollution
TSCA
NEIC Information Retrieval
System data on corporate
structure, financial condi-
tion, pollution control
history, environmental and
health impacts of pollut-
ants of interest
EPA Grants (R&D, construct-
ing, planning)
Information available on
process operations, pol-
lutants of interest, exist-
ing treatment, control and
disposal practices, raw
materials, etc.
Administrative Orders is-
sued for environmental non-
compliance
Applicable local ordinances
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 photo-
graphy
NPDES permits/permit ap-
plications
Second-round permit status
Applicable effluent guide-
lines
Compliance inspection re"
ports (Federal/State/Local)
Laboratory performance re-
ports
Self-monitoring requirements
and Self-reporting data
Best Management Practices
Plan
Spill prevention contain-
ments and control plan
Pre-treatment requirements
if facility discharges to
POTW
Applicable Federal/State
regulations related to water
pollution control at facil-
ity
Technical manuals and ref-
erences on pollution treat-
ment/control technology,
process operation, moni-
toring inspection proced-
ures, etc.
Interstate Commission water
quality data (Ohio River
Sanitary Comm.; Delaware River
Basin Comm.; Interstate Com-
mission on the Potomac River,
etc.)
PSD permits and present
status
Self-monitoring require-
ments and self-reported
data
Compliance inspection re-
ports (Federal/State/Local)
Applicable NESHAPS
Applicable NSPS
Applicable air quality stds.
State Implementation Plan
Ambient air quality re-
ports for AQCR
Air pollutants emission
inventories
Continuous monitoring
practices and facility and
applicable performances in-
spections
Available contractor/
consultant erports
Technical manuals and ref-
erences on applicable pol-
lution treatment/control
technology, process opera-
tors, air pollution moni-
toring, inspection proce-
dures, etc.
Part A of Permit for
Sources Designation -
e.g., generators, trans-
porters, etc.
Part B of Permit if avail-
able
Applicable regulations for
source designations
DIG Permit and present
status
Hydrogeologic reports on
local area and relative
to UIC permit
Self-monitoring require-
ments and self-reported
data
Applicable regulation on
manifest requirements
Inspection reports (Feder-
al/State/Local)
Technical manual and ref-
erences on applicable
treatment/control and dis-
posal technology, inspec-
tion and monitoring pro-
cedures and techniques,
etc.
Available information on
chemical substances pro-
duced by facility
Applicable regulations re-
garding manufacture, identi-
fication, self-reporting
requirements, etc. concern-
ing toxic materials - e.g.,
PCB rules
Inspection reports (Federal/
State/Local)
Technical manuals and refer-
ences on applicable treatment/
control and disposal techno-
logy, inspection and monitor-
ing procedures and techniques,
etc.
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the various regulations that apply to the source—water, air, etc.
pollution control." Achieving the objective involves an evaluation of
process operations, pollution control/treatment and disposal practices,
operation and maintenance procedures, self-monitoring and self-reporting
practices, and apparent pollution abatement/control needs.
Tasks - The plan addresses how the objectives will be accomplished
generally by accomplishing various technical tasks. The background
review should have revealed the various data gaps. The plan spells
out procedures for obtaining required/missing information and evaluat-
ing facility compliance.
Procedures - Policies and procedures for document control, chain-of-
custody, quality assurance, handling and processing confidential in-
formation, and safety are well established by EPA and must be followed
by EPA inspection teams. The plan reiterates these facts and any spe-
cific instructions for the particular inspection.
Resources - The plan indicates the personnel needs for the project and
details the particular equipment requirements. Capable and experienced
personnel, knowledgeable of pollution control activities in one or
more of the program areas, form the compliance audit inspection team.
Schedules - A schedule of the milestones for project activities is
necessary for smooth project operations. This information is impor-
tant to the participants as well as those Regional and/or Headquarters
officials who requested the project. It is necessary that the start
and finish points of the field activities, analytical work, and report-
ing dates for the project be firmly established and understood at the
beginning.
NOTIFYING THE FACILITY
Compliance audit inspections can be conducted announced or unannounced.
Except for typically unannounced TSCA inspections, most are announced; that
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is, facility officials are contacted prior to the inspection. Initial con-
tact is usually by phone with followup written confirmation of inspection
dates. The notification letter specifies the authority for the inspection
and provides a general outline of the areas that will be covered by the
inspection. This approach improves the chances that responsible Company
officials will be present and necessary information will be available.
Notification letters which announce an inspection with general time
frames such as "within the next months" or "during the next calendar
year" essentially make the inspection announced. However, this approach
creates difficulties in that responsible Company officials may not be avail-
able, and the information requested in the notification letter may not have
been assembled.
Notification is not desired when illegal discharges or emissions or
improper records are suspected. The concern that physical conditions may
be altered prior to the inspection or that records will be destroyed justi-
fies an unannounced inspection. A written notification could then be pre-
sented at the time of the unannounced inspection.
Typical information requested by a notification letter may include the
following:
Raw materials, products, byproducts, production levels
Facility layout maps identifying process areas, discharge and
emission points, waste disposal sites
Flow diagrams for processes and waste control, treatment and dis-
posal systems showing where wastewater, air emission, and solid
waste sources originate
Description and design of pollution control and treatment systems
and normal operating parameters
O&M problems that may be causing violation of applicable regula-
tions and limitations
Recent self-monitoring reports and inventories for discharges and
emissions
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Self-monitoring equipment in use, normal operating levels, and
available data
Files of required records
Information that is already available should not be requested. How-
ever, it is worthwhile to confirm the validity of such information. The
facility should be informed of its rights to assert a claim of confidential-
ity for any material requested by the Agency and the procedures for doing
so (40CFR§2.203). The facility should also be informed that it waives
this right if it fails to assert the claim and of the requirement that they
support any future claim.
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CONDUCTING THE INSPECTION
ENTRY*
The inspectors, upon arrival at the facility, identify themselves to
the owner, agent in charge, or other responsible person; present their of-
ficial agency credentials to the facility, whether requested or not; and
state the authorities under which the inspection is being conducted. A
written notification may or may not have preceded the inspectors. Arrival
at the facility should be made during normal working hours. A meeting with
the responsible Company officials is requested. The authorized facility
representative should be located as soon as the inspectors arrive on the
premises. Agency policy dictates that inspections be completed in a manner
that is prompt, timely, and reasonable.
If the inspection is of a federal facility that has national security,
restricted areas, or classified areas, special procedures may be required
for entry. For example, a military installation regulation may stipulate
that "inspectors shall be required to show proof of appropriate security
clearance before entry is approved into restricted areas". Inspectors
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 inspectors to sign it. Note however that EPA
employees will 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. The inspector
must not agree to any such unwarranted restrictive conditions. If such a
waiver or release is presented, the inspectors should politely explain they
cannot sign and request a blank sign-in sheet. If the inspectors are re-
fused entry because they do not sign such release, they should leave and
f
* References 1-7 used in this section.
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immediately report all pertinent facts to the appropriate supervisory and/
or legal staff (e.g., Office of Regional Counsel). All events surrounding
the refused entry should be fully documented. Problems should be discussed
cordially and professionally. Company officials must not be subject to
intimidation by the Government's right to inspect.
Various Federal environmental statutes give Agency inspectors the au-
thority to enter facilities, review records, and collect environmental sam-
ples [Tables 3 and 4],
The inspection should be made with the consent of the facility and/or
authorized person. As long as the inspector is allowed to enter, entry is
considered voluntary and consensual by the facility or owner, unless the
inspector is expressly told to leave the premises. Consent to enter can,
however, be revoked by the facility at any time during the inspection. If
this occurs, all information collected during the consensual phase remains
in possession of the inspectors. When withdrawal of consent takes place,
the same procedures apply as for denial of entry.
Because inspections may be considered adversary proceedings, inspectors
may be challenged as to their legal authority, techniques, and competency.
The facility may also display antagonism to agency personnel. In all cases,
the inspectors must cordially explain the authorities and the reasons for
the protocols followed. If explanations are not satisfactory or disagree-
ments are irresolvable, the inspectors should leave and obtain further di-
rection from the appropriate Agency supervisory or legal staff. Profession-
alism and politeness must prevail at all times.
The inspectors may be instructed by agency attorneys, under certain
circumstances, to conduct an inspection under search warrant. A warrant is
a judicial authorization for appropriate persons to enter specifically des-
cribed locations and to perform specific inspection functions. It is pos-
sible that a pre-inspection warrant could be obtained where there is reason
to believe that entry will be denied when the inspector arrives at the fa-
cility or when violations are expected which could be hidden during the
time a search warrant was obtained.
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Table 3
INSPECTION AUTHORITY UNDER THE MAJOR ENVIRONMENTAL ACTS
CAA - § 114(a)(2)
". . .the Administrator or his authorized representative, upon presentation of his credentials - shall have a right
of entry to, upon, or through any premises of such person or in which any records required to be maintained. . .are
located, and may at reasonable times have access to and copy any records, inspect any monitoring equipment and
method. . . and sample any emissions. . ."
CWA - § 308(a)(4)(B)
". . .the Administrator or his authorized representative, upon presentation of his credentials - 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 may at reasonable times have access to and copy any records, inspect any moni-
toring 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 hazard-
ous 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 o-f any containers or labeling for such
wastes."
TSCA - § 11(a)(b)
". . .any duly designated representative of the Administrator, may inspect any establishment. . .in which chemical
substances 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 dis-
tribution 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
". . .officers or employees duly designated by the Administrator are authorized to enter at reasonable times, any
establishment or other place where pesticides or devices are held for distribution or sale for the purpose of in-
specting and obtaining samples of any pesticides or devices, packaged, labeled, and released for shipment, and sam-
ples of any containers or labeling for such pesticides or devices."
". . .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 reason-
able times to have access to, and to copy: (1) all records showing the delivery, movement, or holding of such pes-
ticide or device, including the quantity, the date of shipment and receipt, and the name of the consignor and
consignee. . ."
"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 - § 2445
". . .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, fa-
cility, or other property . . .in 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)(l)
". . .any person who stores, treats, or disposes of . . .where such hazardous substances are located, who generates,
transports, or otherwise handles or has handled hazardous substances shall. . .furnish information relating to such
substances and permit such person at all reasonable times to have access to, and to copy all records relating to
such substances."
". . .such officers, employees, or representatives are authorized. . .to enter at reasonable times any establish-
ment or other places where such hazardous substances are or have been generated, stored, treated, or disposed of,
or transported from."
". . .to inspect and obtain samples from any person of any such substance and samples of any containers or labeling
for such substances."
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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
§308(a)
§8(b)
(Books &
Redords)
§9(a)
(Inspec-
tions of
estab-
1 ishments)
§114(a)
§3007(a)
§1445(b)
§ll(a, b)
Designated Presentation
Representative of Credentials
Yes, auth. by Required
Admn.
Yes, designated Not required
by Admn.
Yes, designated Required
by Admn.
Yes, auth. by Required
Admn.
Yes, designated Not required
by Admn.
Yes, designated Required
by Admn. ,
Yes, designated Required
by Adran.
Notice of
Inspection
Not required
Not required
Written notice
required w/rea-
sons for inspec-
tion
Not required ex-
cept notify state
for SIP sources
Not required
Written notice
required, must
also notify
state w/reasons
for entry if
state has pri-
mary enf. re-
sponsibility
Written notice
required
Receipt
Sampling Inspection Sample for Agency's
Permitted of Records Splits Samples
Yes, (efflu- Yes Not required Not required
ents which
the owner is
required to
sample)
No Yes N/A N/A
Yes See §8 Required, Required
if requested
Yes Yes Not required Not required
Yes Yes Required, Required
If requested
Yes Yes Not required Not required
No? (The Act Yes N/A N/A
does not men-
Return of
Analytical
Results
Not
required
N/A
Required,
promptly
Not
required
Required,
promptly
Not
required
N/A
CERCLA
§104(e)
Yes, designated
by President
Not required
Not required
tion samples
or sampling in
this Sec. It
does state an
inspection shall
extend to all
things within
the premise of
conveyance.)
Yes
Yes
Required,
if requested
Required
Required,
promptly
oo
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OPENING CONFERENCE*
At the opening conference with facility officials, the inspector pre-
sents credentials (if not already done); provides names of the inspectors,
purpose of the inspection, and authorities under which the inspection is
being conducted; and procedures to be followed. Any required notices should
also be presented to facility representatives at this time, if not previ-
ously made.** The agency encourages cooperation between the inspectors and
the facility officials; this will simplify assignments and contribute to
the success of the compliance audit inspection.
Major topics at the opening conference should include: inspection
objectives, the order of inspection, processes and areas to be inspected,
schedules to various areas of the facility, basic types of records to be
inspected, rules as to how the plant will be inspected, safety requirements,
the handling of confidential data (which should be obtained only if abso-
lutely necessary), how to address questions during the course of the inspec-
tion, and the closing conference. Facility officials should be informed of
their right to receive duplicates of any samples taken and, under RCRA and
Superfund, the offer is made to provide the results of analyses. If inspec-
tors desire to take photographs during the inspection, this should also be
discussed.
Photographs may be used to prepare a more thorough and accurate inspec-
tion report, as evidence in enforcement proceedings, and to better 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
* References used in this section include Nos. 2-5.
** Under FIFRA, TSCA and SDwA, written notification is required before
entry. Under TSCA, the inspector presents a TSCA Inspection Confiden-
tiality Notice which informs the facility of their right to claim cer-
tain materials as Confidential Business Information (CBl). The inspec-
tor also shows his authorization for access to CBI. The Company is in-
formed of procedures and requirements which the EPA must follow in
handling these materials.
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acceptable solution cannot be reached and photographs are considered essen-
tial to the inspection, agency supervisory and legal staff should be con-
tacted for advice.
Facility personnel may also request that any photographs taken during
the visitation be considered confidential, which the agency is obliged to
comply with, pending further legal determination. Self-developing film,
although of lower quality, is useful in certain situations. A facility may
refuse permission to take photographs unless they can see the finished print.
Duplicate photographs (one for the inspector and the other for the Company)
should satisfy this need. When taking pictures under TSCA authority, self-
developing film eliminates processing problems, because the film processing
facility must also have TSCA clearance.
Photographs must be carefully documented, following procedures for
handling evidentiary materials [Appendix B].
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INSPECTION*
This section presents inspection procedures following the opening con-
ference. Concurrent activities include reviewing and verifying records;
observing and evaluating equipment, monitors, devices, or activities direct-
ly; and questioning facility personnel. It is, therefore, valuable if not
essential to have a facility representative knowledgeable about operations
accompany the inspectors during this segment of the inspection.
As indicated previously, the purpose of the compliance audit inspection
is to document compliance of the facility with environmental laws, regula-
tions, permits, and other requirements. When noncompliance is detected or
suspected, these situations should also be properly documented. Just as
importantly, those items not suspected of being compliance problems or af-
fecting compliance should be given only limited attention. For the prepon-
derance of items where there is insufficient information to discern whether
an item should be pursued, only the preparedness, knowledge, experience,
and intuition of the inspection team can be relied upon. Products of a
compliance audit inspection can be questions or concerns, as well as an-
swers. The inspection team must continually evaluate and reevaluate the
purpose for reviewing specific records, observing specific equipment or
activities, and pursuing specific lines of questioning. As a result, the
objectives of the inspection may be expanded or narrowed during the course
of the inspection. Such decisions are not to say that certain objectives
are not important, only that they are believed to be less important. The
inspection should try to uncover the most serious continuing environmental
problems and their underlying reasons.
If the inspection includes determining consent decree compliance, the
following procedures are recommended:
During inspections, inspectors should ascertain the names and
functions of individuals familiar with, and responsible for, com-
pliance with their terms of the consent decree.
* References used in this section include Nos. 1-17.
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Inspectors should be thoroughly briefed on contents of the decree,
interim and final deadlines, and any formal or informal modifica-
tions of the decree that have occurred prior to the inspection.
Coordination should occur prior to the inspection (in conjunction
with the Regional office) with the local Assistant United States
Attorney or Justice Department attorney responsible for the civil
case and resulting consent decree.
Where significant cases of noncompliance are discovered during
the inspection, the inspection team and Regional office should
coordinate at the earliest possible date with the appropriate
field office of the Criminal Enforcement Division to discuss the
potential for criminal charges—including criminal contempt—stem-
ming from this noncompliance. Administrative/civil enforcement
(including informal negotiations with the company) should be held
in abeyance, pending a decision on the appropriateness of a crimi-
nal referral or additional field investigation.
ELEMENTS OF AN INSPECTION
This section describes generic elements that are common to all environ-
mental program areas—process operations, pollution control, treatment, and
disposal, and operation and maintenance. Specific elements that complement
the generic elements and that can be used when deemed appropriate are organ-
ized by program area—air, water, solid/hazardous wastes, and toxic sub-
stances; additional checklists are provided in the Appendices.
Process Operations
The inspectors need to have a general understanding of the physical
plant under investigation and the process or processes in use at that faci-
lity. This knowledge is necessary to aid in the determination of substances
present at the facility and where these may be released as pollutants into
the environment. It is not necessary that a compliance audit inspection
team has an in depth understanding of all the intricacies of the industrial
processes; however, a sufficient understanding provides inspectors with
confidence to conduct the inspection.
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23
The compliance audit inspection team should do the following:
Determine the production information necessary to evaluate pollutants
which could be present or discharged. Validate flow diagrams, process
descriptions, raw materials, intermediates, products and byproducts,
and determine whether processes are continuous, batch, and seasonal.
Determine current operating levels, how they compare to design, if any
change is significant, and whether production status is considered
normal or abnormal. Information on production is essential if pollu-
tion control limits are based on production rates or products; infor-
mation on production is desirable at all other times to aid evaluation
of types and possible quantities of pollutants. Process modifications
may have changed the types and loads of pollutants emitted, discharged,
or disposed of. Different production levels may have caused higher
emission mass loadings or gas flow rates. Use of raw materials, in-
cluding fuels, may have increased, affecting emission characteristics.
Process equipment may have deteriorated, or different operating condi-
tions may be creating more difficult pollutant collection and control
problems.
Identify those processes or physical elements of the facility which
may contribute to a source of pollution (air, water, solid/hazardous
waste). Identify feed inputs to the process and the sources, charac-
terization, flow rates, etc. at all points where wastewater, gaseous
emissions, and solid wastes leave each process. Determine the fate of
those wastes (e.g., do they discharge or emit directly to the environ-
ment or do they discharge or emit to a treatment facility). Determine
the types and amount of pollutants present or potentially present.
Determine the types of controls on the process. For example, deter-
mine if process rates remain consistent or are constantly changing, or
if there is a large or small amount of variability in the raw material.
Identify equipment, design and capacity of equipment, peripheral com-
ponents (including instrumentation and monitoring), performance logs
and records, and operating schedules. This type of knowledge will
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24
enable the inspector to evaluate whether variations in the quantity of
wastes can be anticipated, and whether available logs or instruments
record such information.
Determine whether any process or facility modifications are proposed
or planned. Obtain specifics on the proposed or planned modifications,
including schedules, and certainty of the modifications (e.g., is the
change proposed or planned, is money set aside). Obtain any informa-
tion on the facility's estimates regarding wastes generated and/or
discharged.
Pollution Control, Treatment, and Disposal
After the inspectors have determined what type of waste sources are
generated by each process, they should identify the type of treatment pro-
vided and the ultimate fate of wastes. Because the principal purpose of a
compliance audit inspection is to document compliance, the inspectors should
check all terms of each permit with the permittee's records or by observing
the permittee's practices.
The compliance audit inspection team should do the following:
Obtain updated descriptions and schematics of major pollution control
equipment and waste storage/disposal areas. Visually inspect equipment
and storage disposal areas. Locate points of pollutant emission or
discharge and waste disposal or storage, including alternative loca-
tions, such as diversions, bypasses, overflows, etc.
Obtain design data and startup dates for pollution control/treatment
devices and waste disposal areas. Observe equipment or disposal areas.
Observe equipment or disposal practices during operation. Locate and
observe indicating or recording instrumentation available to monitor
control/treatment devices; compare operating levels to design data to
conclude whether devices are operating normally or abnormally. Iden-
tify any operating problems and their causes.
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25
Evaluate sampling locations as to collection of representative samples.
Identify recycle or dilution streams or other flow disturbances and
where they are in reference to sampling locations. Determine if sam-
ples are collected consistent with permit/regulation requirements,
e.g., grab vs composite, and frequency of sample collection. Observe
monitoring procedures such as flow measurement, sample collection and
preservation, calibration procedures, instack monitors, etc. Deter-
mine whether the proper parameters are being monitored, if the records
are consistent with permits and regulations, and if results are pro-
perly calculated and reported.
Determine what plans the facility has to either expand existing treat-
ment facilities or install new treatment units. Obtain copies of any
design criteria, consultants' reports, etc. Based on these data and
first-hand observations, determine what, if any, additional treatment
may be required to meet existing permit limits, regulations, or other
requirements.
In evaluating compliance schedule compliance, look at engineering plans
and equipment design, procurement, fabrication, installation and test-
ing, and startup of equipment. Determine whether the final require-
ments can be achieved on time; verify if structures are in place.
Determine if delays associated with particular construction violations
are valid and perhaps beyond the control of the facility. If schedules
are not being met, determine if the facility has made new arrangements
for getting back on schedule; for example, corporate resolutions, fi-
nancing agreements, contracts, equipment orders, and engineering serv-
ices' documents. Verify dates when documents were completed. As
needed, these documents may be procured through a formal written re-
quest so they can be studied in depth. Determine if recruitment and
training of new personnel for anticipated pollution control activities
have been initiated.
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26
Operation and Maintenance
Knowledge of operation and maintenance of process and control facil-
ities provides the inspector insight into plant management and problems
including frequency of breakdowns, malfunctions, upsets, outages, diver-
sions, bypasses, and waste variability. It is important to know causes and
if these incidents can be corrected. O&M review can include preventative,
routine, and remedial maintenance programs; spare parts inventory; emergency
operating and response programs; training and certification of plant per-
sonnel; alarm systems for power and equipment failures; backup systems; and
regularity of housekeeping throughout the plant. It may also include Com-
pany protocol and schedules for such items as reading and calibrating in-
strumentation, examining recording charts and logs, and updating O&M manu-
als, engineering drawings and specifications, supplier manuals, and data
cards on equipment.
The compliance audit inspection team should do the following:
Determine for each process and control center whether operational main-
tenance conforms to good and acceptable practice. If acceptable levels
of O&M and housekeeping are not being attained and total wasteload
generation and variability are significantly higher than prescribed
for a given operation, determine expected improvements.
Determine major factors which affect process discharge, emissions,
disposal, controls, and changes in operation. Evaluate O&M practices
as to whether they are adequate, and if they minimize pollutant re-
leases. Abnormal releases may be due to production equipment operat-
ing at excessive rates and/or progressive equipment deterioration or
lack of repair. Startup and shutdown of process and control facil-
ities can create problems of surge waste releases which can be allevi-
ated by better plant management.
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27
Air
The listing below of air pollution inspection items is divided into
six groups: operating conditions, compliance and compliance testing, con-.
trol systems, continuous monitoring, review of files and records, and status
of operation and maintenance. Inspectors should be prepared to observe and
document these inspection items so that factual information can later be
evaluated and compliance determined. Prior to the inspection, review of
checklists in Appendix G is encouraged also.
Operating Conditions
Update construction and operating permits.
Update emission inventories.
Construct record of abnormal operations, shutdowns, malfunctions.
Conduct opacity readings of stack emissions if inspector is
certified.
Check continuous monitors downstream of control equipment. Verify
output of continuous opacity monitor and correlate with VEOs and
regulations.
Check velocities in hoods and ducting systems and measure para-
meters on induced draft fans, including total static pressure
across fan, electrical current used, and fan speed; look for change
in gas flow rates. Observe physical condition of the fans.
Observe evidence of air pollution effects on premises but especi-
ally over surrounding areas, e.g., odors, dusting, deposits on
cars, vegetation damage. Fugitive emissions may require special
attention. Odor problems are best characterized outside the plant
because of olfactory fatigue inside the plant.
Compliance and Compliance Testing
Check source for compliance with applicable regulations, espe-
cially NESHAP and NSPS requirements.
Determine if sources are in compliance with mass emission regula-
tions, visible emission regulations, fuel quality regulations,
and if there has been change in flow rate through system, in total
system static pressure drop, in particulate emission levels, emis-
sions temperature, cyclic and intermittent emissions.
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28
Determine if an onsite visible emission inspection is warranted;
an inspector doing CAA inspections must be certified for Visible
Emissions reading, or the information developed may require
duplication.
Check results of compliance tests. The Company should be able to
provide proof that emissions are within desired limits by means
of a compliance test using a specified or reference test method.
The test is usually witnessed by control agency officials. Pro-
cess and emission parameters must be adequately documented during
test.
Control Systems
Determine if there is reasonable probability that problems exist.
Compare observed operating conditions with baseline values
obtained from compliance stack tests or from manufacturer's spe-
cifications. Deviations from baseline values show abnormal
performance.
Conduct control system evaluation. As an example, for an ESP
system, review ESP instrumentation, emission monitors and plant
records. Check agency files on the Company and its ESP, espec-
ially for operating data. From these data, the inspector should
know if the plant can achieve compliance under normal circum-
stances. Check compliance schedules, permits, number of emissions
violations, malfunctions of the ESP, and any complaints since the
Jast inspection.
Continuous Monitoring
Check equipment and records on continuous monitoring, as required
by NSPS, on specific pollutants by certain industries. Available
systems include opacity monitoring for particulates and extract-
ive and in-stack monitoring for gases.
Review of Files and Records
Two examples include: the operating records required by NESHAP regu-
lations and permits and inspection and review of special leak detection
and sampling and analysis programs found at certain industries.
Status of Operation and Maintenance
Examples of O&M inspection for air control systems are cited below:
Air Infiltration. Check process equipment, breaching and ducts, access
doors, panels, and expansion joints.
Induced Draft Fans. Check vibration, bearing temperature and lubri-
cation, coupling lube, V-belt condition, motor bearing lube, founda-
tion bolts, and variable speed drive.
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29
Thermal Insulation. Check integrity and cold spots.
Dampers. Check function and lubrication.
Ventilation System. Check for leaks, fugitive emissions, need for
cleanout.
Fabric Filters. Inspect baghouses, as needed, during scheduled main-
tenance periods in cooperation with plant officials. Check for bag
tears and pinholes; otherwise, if the source has an opacity monitor,
the inspector should examine the opacity chart during a cleaning cycle
to determine where the leak is located.
Wet Scrubbers. Check operation of recirculation pump, pressure on
nozzle to determine possible clogging, temperature and pH of the sump
liquor.
ESPs. Check electrical, gas flow, mechanical, and effluent systems.
Water
The following list of water pollution inspection items is divided into
control and treatment systems, self-monitoring systems including both field
and laboratory areas, operation and maintenance, and the BMP plan. Before
the inspection, the inspectors are encouraged to review the checklists in
Appendix D.
Control and Treatment Systems
Deter/nine efficiency of removal for conventional, nonconventional, and
priority pollutants and toxic and hazardous substances. Assess ability of
wastewater treatment plant to withstand shocksf low temperature, excess
stormflows, peak process flows, and organic loads. Assess impact of storm-
flows, inflow, and infiltration on system operation. Determine if SPCC
plan meets §311 requirements of the CWA.
Self-monitoring Systems
Self-monitoring consists of the field sampling and flow measurement
phase and the laboratory which analyzes water samples required for develop-
ing necessary data under the NPDES water program.
Field
Confirm that acceptable sampling and flow measurement, as specified by
the NPDES permit, are carried out at the correct locations and with the
proper frequency, and that all necessary calibration and O&M are performed.
The inspector may find unpermitted discharges which would be a violation of
the permit. Representative samples must be collected at prescribed loca-
tions. Flow rating and calibration must use standardized techniques. Clean
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 the following: (a) preserva-
tion methods and holding times of samples; (b) determination if approved
analyses are used; (c) adequacy of instrument calibration and state of re-
pair; (d) adequacy of QA/QC program for all analyses; and (e) 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; sign-off proce-
dures used; analysis of spikes, blanks, and reference samples; how the lab
data are transposed into 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 may be out of service and causes; if
there is excess accumulation of solids, scum, grease, and floating materials
in the treatment units; if there is a presence of odors, excessive weed
growths, 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 hazardous substances.
A BMP Plan is indicated if toxics are contributed from ancillary operations,
and reasonable opportunity exists for discharge. BMP, and also SPCC plans,
documents, and facilities should be reviewed.
Solid/Hazardous Wastes
Inspections of uncontrolled hazardous waste disposal sites often re-
quire gathering of information in the following categories: administrative,
site information, field evaluation, storage facilities, incinerators, land-
fill disposal, landfarming, surface impoundments, biological treatment, and
physical/chemical treatment. The inspector should be familiar with CERCLA
(Superfund) provisions as briefly explained in Appendix F. Furthermore,
inspectors are encouraged to use the checklist in Appendix G for details in
each of the 10 aforementioned categories.
Because of the changing nature of RCRA regulations, the listing of
RCRA inspection items below has not been as finely structured as the water,
air, and toxics listings but instead are simply divided into the main areas
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31
of Generators, Transporters, and Treatment/Storage/Disposal Facilities.
For further detail, the inspector is encouraged to use the various RCRA
checklists in Appendix G.
Notification
Determine if the Company which handles hazardous wastes has given the
EPA official notification of these activities under §3010 of RCRA (if it is
required to do so),
Generators
Check generator for its authorized identification number. Check mani-
fests for generator identification, proper waste information, emergency
information, and certification that materials are properly packaged and
labeled for transport. Check for adequacy of containers and leaking and
corroding containers. Check labeling practices. Check transport placards
for compliance with DOT regulations. Establish accumulation time of wastes,
since a generator may not store wastes more than 90 days without a facility
permit. Every container should be properly marked as to initial date of
storage. A generator must keep manifest copies up to 3 years and, like-
wise, copies of annual and exception reports and waste analyses for 3 years.
Transporters
Check transporter for its authorized identification number. Verify
existence and completeness of manifests, transporter number on manifest,
correlation of license number of vehicle with transporter document. Deter-
mine that containers are properly marked and labeled, and vehicles are pro-
perly placarded; look for evidence of leaking or damaged containers, if any.
Facilities that Treat/Store/Dispose of Hazardous Waste
Determine compliance with General Facility Standards. These include
an adequate waste analysis plan, security, general facility inspection plan
and program, adequate operator training, and plans for dealing with ignit-
able, reactive, and incompatible wastes.
Check facility for the following: (l) degree of preparedness and pre-
vention (include precautions against fire, explosion, etc.; presence of
required emergency equipment; testing and maintenance of that equipment;
required aisle space; and arrangements beforehand with local authorities);
(2) availability of contingency plan and emergency procedures; (3) manifest
system and reporting (which includes keeping proper records and copies of
each manifest for up to 3 years, manifest discrepancies, written operating
record, a record of unmanifested wastes, if applicable, and annuaJ report
for facility); (4) closure and post-closure plans (includes disposal or
decontamination of equipment, certification of closure, and period and type
of care in post-closure).
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32
Facility Specific Standards Include the Following:
For Containers: Inspect for leakage and corrosion of containers; waste
must be compatible with containers.
For Tanks: Check for freeboard, proper containment volume, integrity of
tanks, necessary waste analyses, inspection records, closure.
For Surface Impoundments: Check for proper freeboard, protective covering
on dikes, waste analyses, records of inspections made, evidence of leaks or
deterioration, closure and post-closure plans, and groundwater monitoring.
For Waste Piles: Check for proper protection from the elements, waste ana-
lyses, containment around pile, and groundwater monitoring.
For Land Treatment: Check that runoff provisions are met, along with waste
analysis, safety of food chain crops, adequate unsaturated zone groundwater
monitoring program, records on waste application, limited access, closure
and post-closure plans, and groundwater monitoring.
For Landfills: Check that runoff, leachate, and wind dispersal provisions
are met; describe how wastes are stored at site; closure and post-closure
requirements; special requirements for handling ignitable and incompatible
wastes and for disposing of liquids and containers, etc.; check facility
for groundwater monitoring.
For Incinerators: Check that operating requirements are met; analysis of
waste to be burned; record of inspections made; special instrumentation;
presence of leaks, spills, fugitive emissions, closure plan.
For Thermal Treatment: (See requirements for incinerators above.)
For Chemical/Physical/Biological Treatment: Check operating requirements,
waste analyses, record of inspections, monitoring, closure plan.
Toxic Substances
The list of TSCA inspection items (including PCBs) below is divided
into five parts: necessary TSCA forms, files and records, status of PCB
controls, PCB marking, and PCB inventory. The inspector is encouraged to
use the TSCA checklists in Appendix H. PCBs, one of the many chemicals
falling under TSCA, are evaluated by a special PCB inspection generally
covering transformers, capacitors, hydraulic systems, etc. The PCB inspec-
tion is intended to: (1) detect violations in marking, storage, and dis-
posal; (2) assure proper records; and (3) assure proper PCB disposal.
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33
Necessary Forms
Notice of Inspection Form (gives reason, nature, and extent of TSCA
inspection)
TSCA Inspection Confidentiality Notice (enables Company to
claim confidentiality status)
Declaration of CBI Form (TSCA-CBI information is itemized)
Receipt for Samples and Documents Form
Files and Records
Check available records systems:
Verify completeness and accuracy of data, compare with past records
for possible discrepancies or false reports, check that records reten-
tion requirements are met, check that the records compare with field
observations.
Check Company PCB inventory, availability of annual document contain-
ing necessary data, determine that 5-year records retention is being met,
and that items and data in inventory agree with field observations.
Status of PCB Controls
Check for degree of spills, leaks, and improper storage and control to
determine risk of PCB contamination. Improper worker knowledge of hazards
and inadequate protective clothing and equipment can add to this risk.
Spills
Check proper construction and operation of maintenance and repair
facilities.
Determine if written maintenance and repair procedures are avail-
able. Check if spills and leaks are cleaned up immediately.
Determine if decontamination operations are proper and if proce-
dures are written down. Evaluate proper decontamination of drums
and pallets before reuse.
Check for proper handling and transfer procedures for PCBs, pre-
sence of puddles or drips on floors near equipment, containers,
drip pans.
Evaluate general state of housekeeping.
Determine level of care in draining, refilling operations,
disconnection/disassembly areas, material handling systems, trans-
port operations.
Observe provisions for spill containment in work pits, servicing
areas, other areas. Check if facility drainage systems are ade-
quately constructed.
Determine if containers for PCB items are of adequate size and in
good condition.
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34
Leaks
Determine if equipment is in good working order and undamaged.
Check that leaking units are transferred to non-leaking containers
and are routinely checked.
Storage and Disposal
Determine adequacy of rainfall protection at facility, sufficient
containment volume; check if flooring and containment requirements
are met; the site should be above the 100-year flood elevation;
the facility should have written storage procedures.
Check for proper handling and disposal of contaminated and damaged
parts, units, oily rags, filter media, soil, etc.
Check dumps, landfills, pits, scrap areas, abandoned buildings,
construction areas, docks.
Determine if transformers or large capacitors stored outside
on pallets are structurally undamaged, non-leaking, and checked
routinely.
Other
Check compliance with retrofilling requirements.
Observe discoloration of soil in PCS handling areas.
Determine provision of worker protection.
Marking and Identification of PCBs and PCB Items
Check that all required items are properly marked, including storage
areas and items in storage areas, transport vehicles, capacitors, etc.
PCB Inventory
Determine that a PCB inventory has been established for a facility,
where PCBs are present; an inventory checklist is contained in Appendix H.
-------
35
CLOSING CONFERENCE
A post-inspect!on or wrap-up conference should be held with the faci-
lity. This should be limited to specific findings of the inspection, e.g.,
factual observations and measurements. The inspection team's main function
is to observe and evaluate compliance, but it is noted that overall compli-
ance is determined 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 should not be discussed
with the facility or its operating personnel. It is unacceptable to recom-
mend a particular consulting firm if asked, but it is proper to advise that
professional societies be contacted, inspectors should not substitute their
judgment for that of facility personnel regarding their operation.
During the closing conference there can be informal discussion of the
inspection team's findings. Discussion may include observed deviations
from prescribed or recommended procedures. At this meeting, the inspectors
may request additional data, questions may be asked and answered, requested
permit changes and process modifications are noted, and necessary receipts
are given. The inspectors should make a final review of checklists and
field notes before the conclusion of the visit. Field notes taken by the
inspectors at the time of the field investigation should not be turned over
to the company officials. However, the inspectors are free to let the com-
pany officials know that they may request a copy of the final inspection re-
port, and that it may be made available in accordance with the restriction
of the Freedom of Information Act and 40CFR Part 2.
For TSCA, RCRA, and CERCLA activities, written receipts are given for
samples and documents taken. A Declaration of Confidential Business Infor-
mation (TSCA-CBI) shall include a list of items declared confidential by an
authorized facility official, and procedures should be explained if the Com-
pany desires to make any subsequent declaration. Facility officials should
be informed of any leaks, spills, or other problems that require immediate
attention; however, no instructions or orders that repairs be undertaken
should be issued.
-------
36
PREPARING THE INSPECTION REPORT
The inspection report organizes and coordinates all evidence gathered
during the inspection in a highly usable manner. It is the culmination of
factual information and professional judgment resulting from the compliance
audit inspection. Information in the report must be accurate, relevant,
complete, coordinated, objective, clear, and legible. The report serves to
record the procedures used in gathering the data and gives factual observa-
tions and evaluations from the inspection.
Many different formats are possible for the inspection report. A typi-
cal report could be structured into two main sections, the Executive Summary
and the Technical Analysis. The Executive Summary establishes the objec-
tives of the inspection and presents succinct conclusions which are sup-
ported by relevant findings; recommendations are made if appropriate. Top-
ics in the summary may include: overall environmental compliance, adequacy
of pollution control and treatment systems, adequacy of operation and main-
tenance practices, multi-media waste abatement needs, and followup action.
The Technical Analysis section comprehensively describes the inspec-
tion by discussing such topics as facility history, discussions with Com-
pany representatives, records reviewed, recordkeeping procedures, sampling
programs, and specific problem areas. The Technical Analysis section cor-
relates inspection findings with the conclusions contained in the Executive
Summary.
REFERRALS
There are several types of intergovernmental or agency referrals that
may be necessary once an inspection is complete. These must be handled on
a case-by-case basis. Examples could include referrals such as reports to
other EPA programs, OSHA, State or County Health Departments, City or County
waste treatment plants, local fire departments, etc. Referrals should be
-------
37
standard operating procedure; thus, basic knowledge of other regulatory
programs is needed by inspectors.
-------
38
REFERENCES
1. National Enforcement Investigations Center, October 1979. NEIC Poli-
cies and Procedures Manual. Denver, Colorado: Environmental Protec-
tion Agency, EPA-330/9/78/001-R.
2. 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.
3. Pesticides and Toxic Substances Enforcement Division, March 1981.
Toxic Substances Control Act Inspection Manual, Volume Two: PCB In-
spection Manual. Washington, D.C.: Environmental Protection Agency.
4. Office of Water Enforcement, Enforcement Division, January 1981.
NPDES Compliance Evaluation Inspection Manual, MCD-75. Washington,
D.C.: Environmental Protection Agency.
5. Government Institutes, Inc., September 1982. .Resource Conservation
and Keocvery Act Inspection Manual, U.S. Environmental Protection
Agency, Washington, DC.
6. 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.
7. National Enforcement Investigations Center, August 1979. Performance
Audit Inspections of Wastewater Sources. Denver, Colorado: Environ-
mental Protection Agency, EPA-330/1-79-004.
8. National Enforcement Investigations Center, July 1981. A Step-by-Step
Approach to Development of NPDES and RCRA Permits. Denver, Colorado:
Environmental Protection Agency, EPA-330/1-81-004.
9. Office of Water Enforcement, Enforcement Division, 1977. NPDES Com-
pliance Sampling Inspection Manual. Washington, D.C.: Environmental
Protection Agency.
10. 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.
11. Office of General Enforcement, February 1979. Inspection Procedures
for Evaluation of Electrostatic Precipitator Control System Perform-
ance. Washington, D.C.: Environmental Protection Agency, EPA-340/
1-79-007.
-------
39
12. 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.
13. 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.
14. Technology Transfer, 1978. Handbook, Industrial Guide for Air Pollu-
tion Control. Environmental Protection Agency, EPA-625/6-78-004.
15. Thomas H. Truitt, et.al., 1981. Environmental Audit Handbook - Basic
Principles of Environmental Compliance Auditing. Washington, D.C.
Wald, Harkrader & Ross and Resource Planning Corp.
16. G. William Frick, October 1981. Conducting an Environmental Audit.
Washington, D.C.: Van Ness, Feldman, Sutcliffe, Curtis and Levenberg.
17. Industrial Environmental Rsearch Laboratory, August 1979. A Handbook
of Key Federal Regulations and Criteria for Multimedia Environmental
Control. Interagency Engergy/Environment R&D Program Report. Research
Triangle Park, NC: Environmental Protection Agency, EPA-600/7-79-175.
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40
ACRONYMS
AQCR - Air Quality Control Region
BAT - Best Available Technology Economically Achievable
BCT - Best Conventional Technology
BMP - Best Management Practices
BOD - Biochemical Oxygen Demand
BPT - Best Practicable Control Technology
B.T.U. - British Thermal Units
CAA - Clean Air Act aka The Federal Water Pollution Control Act (FWPCA)
CBI - Confidential Business Information
CEM - Continuous Emission Monitoring
CERCLA - Comprehensive Environmental Response Compensation and Liability
Act of 1980 (Superfund)
CFR - Code of Federal Regulations (Federal Register)
COD - Chemical Oxygen Demand
CWA - Clean Water Act
DCO - Document Control Officer
DO - Dissolved Oxygen
DOT - Department of Transporation (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
HW-FW - Half Wave/Full Wave (electrical distribution)
LAER - Lowest Achievable Emission Rate
MLVSS - Mixed Liquor Volatile Suspended Solids
-------
41
N/A - Not Applicable
NAA - Non-Attainment Areas
NAAQS - National Ambient Air Quality Standards
NEIC - National Enforcement Investigations Center
NESHAPS - National Emission Standards for Hazardous Air Pollutants
NPDES - National Pollutant Discharge Elimination System
NSPS - New Source Performance Standards
OE - Office of Enforcement (now Office of Legal and Enforcement Counsel
(OLEC)
0 & M - Operation and Maintenance
ORM - Other Regulated Material
OSHA - Occupational Safety and Health Act
PCB - Polychlorinated Biphenyls
PMN - Premanufacture Notice
POTW - Publically-Owned Treatment Works
PSD - Prevention of Significant Deterioration
QA/QC - Quality Assurance/Quality Control
RCRA - Resource Conservation and Recovery Act (enacted as amendment to the
Solid Waste Disposal Act)
R & D - Research and Development
SDWA - Safe Drinking Water Act (enacted as amendments to the Public Health
Service Act)
SIP - State Implementation Plans
SPCC - Spill, Prevention, Containment, and Countermeasures
SSE - Stationary Source Enforcement
TOC - Total Organic Carbon
T-R - Transformer-Rectifier
TSCA - Toxic Substances Control Act
-------
42
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 Emission Observation
WLA/TMDL - Wasteload Allocation/Total Maximum Daily Load
-------
APPENDICES
A CONFIDENTIAL BUSINESS INFORMATION
PROCEDURES AND FORMS
B EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS
C AIR POLLUTION CHECKLISTS
D WATER POLLUTION CHECKLISTS
E PROCEDURES FOR HANDLING, PRESERVING,
AND TRANSPORTING SAMPLES
F SUMMARY OF POLLUTION CONTROL LEGISLATION
G RCRA AND CERCLA CHECKLISTS
H TSCA AND PCB CHECKLISTS
-------
APPENDIX A
CONFIDENTIAL BUSINESS INFORMATION
PROCEDURES AND FORMS
-------
A-T
CONFIDENTIALITY NOTES AND DISCUSSIONS
The TSCA Inspection Confidentiality Notice [Figure 1] is presented to
the facility owner or agent in charge during the opening conference. This
Notice informs facility officials of their right to claim as confidential
business information any information (documents, physical samples, or other
material) collected by the inspector. The inspector should also show the
facility official his letter from the Deputy Administrator for General
Enforcement certifying that he is authorized for access to confidential
business information.
Authority to Make Confidentiality Claims
The inspector must ascertain whether the facility official to whom the
Notice was given has the authority to make business confidentiality claims
for the company. The facility official's signature must be obtained at the
appropriate place on the Notice certifying that he does or does not have
such authority.
The facility owner is assumed to always have the authority to
make business confidenitality 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 consut with their
attorneys (or superiors in the case of agents in charge) regard-
ing this issue.
If no one at the site has the authroity to make business confi-
dentiality claims, the Notice and declaration form [Figure 2] 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 chier executive officer who should also receive a
-------
A-2
FIGURE 1
TSCA Inspection Confidentiality Notice
1. Enter Inspector's name(l)
and EPA office address(2)
2. Enter the complete,
official name of the
facility being inspected
(3) and its complete
street address (4).
5. Enter the name (5), title
(6), arid complete
address (7) of the chief
executive officer of the
firm.
8. Enter the name (8) and
title (9) of the person
receiving the Notice.
10. Enter the date of the
Notice.
11. Enter the complete
address of the Regional
Document Control Officer
authorized to receive the
statement from the chief
executive officer.
12. Enter the name (12) and
title (13) of the person
. receiving the Notice. Have
this person sign (14) and
date (15) the Notice.
16. Enter the name (16),
title (17), and complete
address (18) of the
company official who, in
addition to the chief
executive officer, should
receive a copy of the
Notice.
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-------
A-3
FIGURE 2
Declaration of Confidential Business Information
1. Enter the complete EPA
Regional Office address.
2. Enter the date of this
declaration.
3. Enter the name(3), title
(4), official firm name
(5), and complete firm
address (6) of the
individual making this
declaration.
7. List by title or descrip-
tion all information
begin designated as
confidential business
information.
8. Have the individual
making the declaration
sign (8) and list his/
her title (9).
10. Enter the name and title
of the Inspector
11. Sign the Declaration
(Inspector).
DECLARATION OF CONFIDENTIAL
BUSINESS INFORMATION
Ack.-.o^ledt}e=!«r.t by Cltia&nc
Th« underlined Acknowledges that th« information described &bev« i» designated as
further aciinow ledges :hat he/fhe is authorized to MXe such claims for hjs^er fira
The undersigned «l»o certifies thac «*ch lt*a described ibov« neets *ll at Lhe
(1) The CBf£*j\y fws taken ne'tures to prot«ct the confidentiality of c-'ie infor
following criteria
nation and it
attainable without cite t:oirp«ny's consent by other p«rs-,r.j (other than oovemrental bodies) by i
of It-jitic-ace gwuu (other tnan dlicovery b**ed on a »ncv:-7 of >p«cial n«»d in a judicial or
qxiaji' judicial procee Jinq) i (1) The tnforru^ ion ts .tot puhl ;cly available t Ise'^eri; and
(4) Disclosure of Uie inrorr'tion would cause substar.tial h^ro to the cor^my't :oap«titiv«
position.
8
10
II
-------
A-4
copy of the Notice and a accompanying forms. Space is provided
on the Notice form to make such a designation
Confidentiality Discussion
Officials should be informed of the procedures and requirements that
EPA must follow in handlign 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 desigantion (or avoidance, if
possible) of confidential business data.
A detailed receipt for all documents, photographs, physical
samples, and other materials collected furing eht 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 Busi-
ness Information form. Each item claimed must meet all foru of
the criteria shown on the Notice and Declaration forms.
If no authorized person is available onsite, a copy of the Notice
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.
-------
A-5
Claims of confidentiality must abe sent by requested
return-receipt-requested mail to the appropriate EPA
office within 7 calendar days of receipt of the Notice.
(The inspector will inert the name and address of the
Regional Document Control Office in the appropriate
place on the Notice.)
All data claimed confidential will be turned to the Document
Control Officer and treated in accordance with the procedures
described in the TSCA-CBI Security Manual. Only authorized
persons will have access to the information.
Data not immediately claimed confidential business information
because no authorized person is availabe onsite will be kept in
locked storage and otherwise accorded confidential treatment(rou-
tine security measures) until the 7-day period has expired. The
information will not be logged in by the Document Control Officer
until an actual business confidentiality claim has been made.
Preparation/Distribution of Confidentiality Forms
When the TSCA Confidentiality Notice is completed, four or five copies
are made and distributed as follows:
Facility owner or agent-in-charge
Company chief executive officer* (if no authorized person is
available)
Other company official* (if designated)
Inspection report
Inspector's files
* If the Notice is to be sent to the chief executive officer (and other
company official, if designated), attach a copy of the completed Receipt
for Samples and Documents and a partially completed Declaration form.
Nail within 2 days of the inspection.
-------
A-6
Three of four copies are made of the Declaration of Confidential
Information form and distributed as follows:
Facility owner or agent in charge
Other company official (if designated)
Document control Officer
Inspection report
-------
APPENDIX B
EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS
-------
B-l
PHOTOGRAPHS
When movies, slides, or photographs are taken which visually show the
effluent or emission source and/or any monitoring locations, they are
numbered to correspond to logbook entries. The name of the photographer,
date, time, site location, and site description are entered sequentally 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 settings and shutter speeds for photographs taken wihtin 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 notations and receipts may be used to account for routine film
porcessing. Once developed, the slides or photographic prints shall be
serially numbered corresponding to the logbook descriptions and may be
labeled.
-------
APPENDIX C
AIR POLLUTION CHECKLISTS
TABLES
C-l NEIC Checklist for Air
C-2 Example of Inspection Checklist
C-3 Example of Maintenance Schedule for
Electrostatic Precipitators
C-4 Incinerator Malfunctions that Affect Emission Rates
C-5 Elements of Corporate Air Pollution Program
FIGURES
C-l Fabric Filter Inspection Flowsheet
C-2 Scrubber Inspection Flowsheet
C-3 Electrostatic Precipitator Inspection Flowsheet
-------
C-l
Table C-l
NEIC CHECKLIST FOR AIR
STATE IMPLEMENTATION PLAN (SIP)*
Sources Covered
Generic emission limits (e.g. all fuel burning equipment limited
to X Ibs S02/106 BTU input)
Specific emission limits (e.g. all Kraft pulp mills limited to
Y Ibs/hr from the black liquor reduction furnace)
Size cutoffs [i.e. sources under a certain emission potential
(e.g. 100 tons/yr of any pollutant) are exempted from regulation]
Pollutants
Criteria pollutants include:
Sulfur dioxide HCs
Particulates Nitrogen oxides
CO Lead
Ozone
Other pollutants regulated under State law or under CAA lll(d)
Permit Requirements
Source Registration
SIP requires sources to simply register with State as a con-
dition to operate
Application contains limited details
Permit to Construct
SIP regulated sources apply to State for permit to construct
Application gives details on plant operation, emissions
estimates, and control technology to be employed
* 40 CFR, Parts 51 & 52, 1980
-------
C-2
Permit to operate
SIP regulated sources apply to State for permit to operate
(if no permit to construct is required); application gives
details on plant operation, emissions estimates and control
technology to be employed
Permit includes emission limits for all regulated pollu-
tants generated by source
Permit may include compliance schedule
Monitoring
State provisions in applicable regulations
Emission testing
Ambient monitoring
Federal regulations require emission limits and continuous
monitoring for the following sources if the state has required
these CEM regulations in its SIP:
Fossil fuel-fired steam generators
Fluid bed catalytic cracking unit catalyst regenerators
Sulfuric acid plants
Nitric acid plants
Kraft pulp mills
If the SIP does not contain a testing method to measure a criteria
pollutant emission rate, the methods are found in reference methods
in 40 CFR Part 60.
Recordkeeping and Reporting
SIP contains recordkeeping and reporting provision
Generic provisions require all sources to maintain records and
periodically (e.g. quarterly) report emissions, malfunctions,
breakdowns, and upsets.
-------
C-3
Specific provisions may also require certain sources to also
maintain records and periodically report continuous emissions
monitoring data, excess emissions reports, actions taken to
maintain continuous compliance.
-------
C-4
NEW SOURCE PERFORMANCE STANDARDS (NSPS)*
Sources Covered
NSPS includes new and modified stationary sources in 28 industrial
categories for which construction started after the standard was proposed.
Requirements
Must Meet Technology Standard
. Standard is in numerical form or alternate approach is used
Notification to Agency
Agency notified before construction, before startup, and before
testing
Emissions Testing
Performance tests of emission control equipment to be conducted
using prescribed reference methods and written results are sent
to Agency
Monitoring
Continuous monitoring to be conducted for ten categories
[Table B-1C]; different monitoring for other categories
Recordkeeping
Shall be kept in permanent form suitable for inspection
Records of continuous monitoring system shall be maintained
including actual data, performance tests, performance
evaluation results, calibration checks, adjustments, and
maintenance
Other information required by law
Quarterly Reports
Agency shall receive reports on data, time, and magnitude of
excess emissions; identification of excess emissions periods
associated with startup, shutdown, and malfunction; and date
and time when control equipment was repaired, adjusted, or was
inoperative.
40 CFR, Parts 60, 1980
-------
C-5
Table C-1A
SOURCES SUBPART (40 CFR Part 60),
EFFECTIVE DATE OF STANDARD
AND POLLUTANTS SUBJECT TO NSPS
Source
Subpart Effective Date
Pollutant
Fossil fuel-fired steam D
generators Da
Municipal incinerators E
Portland cement plants F
Nitric acid plants G
Sulfuric acid plants H
Asphalt concrete plants I
Petroleum refineries J
Storage vessels for K
petroleum liquids Ka
Secondary lead smelters L
Secondary brass and bronze M
ingot production plants
Iron and steel plants N
(basic oxygen furnace)
Sewage treatment plants 0
(incinerators)
Primary copper smelters P
Primary zinc smelters Q
Primary lead smelters R
Primary aluminum reduction
plants
Phosphate fertilizer in-
dustry (listed as five
separate categories)
Coal preparation plants
Ferroalloy production
facilities
Steel plants
(electric arc furnaces)
Kraft pulp mills
Glass plants
Grain elevators
Stationary gas turbines
AA
Lime plants HH
Auto and It.-duty truck MM
Surface-coating operation
Ammonium Sulfate plants PP
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
T October 22, 1974
U
V W X
Y October 24, 1974
Z October 21, 1974
October 21, 1974
BB September 24, 1976
CC June 15, 1979
DD August 3, 1978
GG September 10, 1979
May 3, 1977
October 5, 1979
February 4, 1980
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
Nitrogen oxides, sulfur
dioxide
Particulate matter
VOC
Particulate matter
-------
C-6
Table C-1B
NSPS INDUSTRIES SUBJECT TO CONTINUOUS
EMISSIONS MONITORING REQUIREMENT
Fossil fuel-fired steam generators (>9/18/78) Primary zinc smelters
Nitric acid plants Primary lead smelters
Sulfuric acid plants Ferroalloy production
Petroleum refineries facilities
Primary copper smelters Electric arc furnaces
Kraft pulp mills Lime plants
-------
C-7
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS
AIR POLLUTANTS (NESHAP)*
Sources Covered
Asbestos (final)
Beryllium (final)
Mercury (final)
Vinyl chloride (final)
Benzene (proposed)
Radionuclides (proposed)
Inorganic arsenic (proposed)
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 on line after the publication of standards must achieve immediate
compliance.
Requirements
Compliance Status
Submit to Agency within 90 days of publication of standard ade-
quate information on design, method of operation, weight/month of
hazardous material, and control devices.
Agency Notification
Proper notice before startup and before emissions testing.
Emissions Testing
Regulations give detailed testing procedures to be used for each
industry.
Monitoring and Reporting
Regulations prescribe specific monitoring, sampling, and reporting
requirements for each industry subject to NESHAP.
*40 CFR, Part 61, 1980
-------
C-8
PREVENTION OF SIGNIFICANT DETERIORATION (PSD)*
Coverage
Location and Source
Applicable to clean air areas, i.e., where NAAQS are being met
for any criteria pollutant (most areas). Major sources include:
1. A source in one of 26 industrial categories described in
Table B-1D and which has the potential to emit or does emit
100 tons/year of any pollutant regulated by the CAA
2. A source which has the potential to emit 250 tons/year of
any regulated air pollutant
3. A Major Modification is one where source load is increased
to beyond 100 tons/year or 250 tons/year, respectively, and
modification results in significant net increase in emissions.
Fugitive Emissions
If quantifiable, will be counted for PSD classification (Table B-1D)
and for source subject to NSPS and NESHAP
Significant Net Increase
Net increase is significant if it is greater than "de minimus"
amounts set by EPA for each criteria pollutant (Table B-1E)
Special Rule
For major sources and major modifications located with 10 km of
Class I PSD areas (i.e., pristine air areas where visibility is
especially protected) even if calculations show only "de minimus"
increase, source must still demonstrate impact on Class I area.
If impact is greater than 1 microgram/m3 on an average 24 hr
basis, the source is then subject to PSD.
Requirements
A source subject to PSD cannot be constructed without a permit. Pre-
construction review includes:
1. Installation of Best Available Control Technology (BACT)
2. Pre-construction monitoring and, in some cases, post-
construction monitoring
3. Air quality impact analysis
* 40 CFR, Sec. 52.21, 1980
-------
C-9
Table C-1C
PSD SOURCE CATEGORIES
1. Coal-cleaning plants (with thermal dryers)
2. Kraft pulp mills
3. Portland cement plants
4. Primary zinc smelters
5. Iron and steel mills
6. Primary aluminum ore production plants
7. Primary copper smelters
8. Municipal incinerators capable of charging more than 250 tons
of fuel/day
9. Hydrofluoric, sulfuric, or nitric acid plants
10. Petroleum refineries
11. Lime plants
12. Phosphate rock processing plants
13. Coke oven batteries
14. Sulfur recovery plants
15. Carbon black plants (furnace process)
16. Primary lead smelters
17. Fuel conversion plants
18. Sintering plants
19. Secondary metal production plants
20. Chemical process plants
21. Fossil fuel boilers (or combination thereof) totaling more
than 250 million British thermal units/hr input
22. Petroleum storage and transfer units with a total capacity
exceeding 300,000 barrels
23. Taconite ore processing plants
24. Glass fiber processing plant
25. Charcoal production plants
26. Fossil fuel-fired steam electric plants of more than 250
million British thermal units/hr heat input
-------
C-10
Table C-1D
DE MINIMUS VALUES FOR PSD
De Minimus Design Air Quality
Emission Rate Value (average time)
Pollutant (tons/year) (micrograms/m3)
Carbon monoxide
Nitrogen oxides
Sulfur dioxide
Total suspended particulates
Ozone (volatile organic
compounds)
Lead
Asbestos
Beryllium
Mercury
Vinyl chloride
Fluorides
Sulfuric acid mist
Total reduced sulfur
(including H2S)
Reduced sulfur
(including H2S)
Hydrogen sulfide
100
40
40
25
40
0.6
0.007
0. 0004
0.1
1.0
3
7
10
10
10
2 (annual)
14.6 (24-hr)
10.4 (24-hr)
0.06 (3-mo)
-------
c-n
Table G-2
EXAMPLE OF INSPECTION CHECKLIST*
I. 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
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
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.
-------
C-12
Table C-2 (continued)
Report Number
III. INSPECTION RESULTS
A. Preliminary Conclusions
All sources in compliance with:
Mass Emission Regulations: Yes No N/A
Visible Emission-Regulations: Yes No N/A
Fuel Quality Regulations: Yes No N/A
Continuous Monitoring Regulations: Yes No N/A
Sampling/Testing Requirements: Yes No N/A
Recordkeeping Requirements: Yes No N/A
Permit Stipulations: Yes No N/A
Special Orders: Yes No N/A
O&M Practices: Good Average Poor
Housekeeping: Good Average Poor
B. Specific Conclusions
Compliance questionable due to:
Changes in raw materials and/or fuels
Production rates increases
Operational changes in process
Deterioration of process equipment
Operational Problems in Control Equipment (check appropriate items below)
Electrostatic Fabric Wet
Precipitators Filters Scrubbers
Resistivity Tears/Pinholes Low Liquor Flow
TR Sets Blinding Gas Flow Rate Low
Insulators Bleeding Bed Plugging
Discharge Wires Cleaning System Nozzle Erosion
High Velocity Hopper Overflow Demisters
Gas Distribution Corrosion Throat Adjustment
Rappers Tray Collapse
Solids Handling Corrosion
Plate Warpage
Mass Overload
Other
C. Samples Taken (Describe)
D. Comments/Recommended Action
Inspector Date
-------
Table C-3 C-13
EXAMPLE OF MAINTENANCE SCHEDULE FOR ELECTROSTATIC PRECIPITATORS
Enter on daily log
1. Boiler operating parameters
2. Flue gas analysis
3. Coal characteristics
4. Participate collector control readings
5. Transmissometer calibration
Check daily
1. T-R control set readings
2. Rapper and vibrator control settings
3. Ash removal system
4. T-R control room ventilation system
Check weekly
1. Operation of rappers and vibrators
2. Control sets (for internal dirt)
3. Air filters to control sets and precipitator top housing
Check monthly
1. Pressurization of precipitator top housing
2. Standby fan operation (manually)
Perform quarterly
1. Clean and dress contact surfaces on HW-FW electrical distribution
2. Lubricate pivots
Perform semi annually
1. Clean and lubricate access door hinges and test connections ;
2. Inspect exterior for loose insulation, corrosion, loose joints,
other defects
3. Check for points of gas leakage (in or out)
Perform annually
1. Thorough internal inspection:
Check for possible leaks of oil, gas, or air at gasketed connections
Check for corrosion of any component
Check for broken or misaligned wires, plates, insulators, rappers, etc.
Check high-voltage switchgear and interlocks
Check all insulators and check for hairline cracks or tracking
Check expansion joints on hot precipitators
2. Check for signs of hopper leakage, reentrainment of particulate, and
poor gas distribution
3. Check for dust buildup in inlet and outlet flues
4. Check for dust buildup in hoppers
*From Inspection Procedures for Evaluation of ESP Control System Performance,
Draft, EPA, OE, SSE, EPA-340/1-70-007, Washington, D.C., February 1979.
-------
o
• I
TABLE C -4
INCINERATOR MALFUNCTIONS THAT AFFECT EMISSION RATES
Malfunction
Damage to grate*
Breakdown of flue gas
cooling systems
Excessive air
infiltration
Plugged air ports
Precipitators:
Plugged spray nozzles
Frozen rapping systems
Broken or dirty electrodes
ESP section out
Bag failures
Frequency of
occurrence
Depends upon main-
tenance and care used
in charging
procedures.
Infrequent.
—
Infrequent.
Several times/year
for well-maintained
unit; can be higher
if unit is poorly
designed or main-
tained.
Average occurrence
about once per
month.
Duration
Unit repaired at next
shutdown.
About one hour until
incinerator can be
brought off-line.
Results from poor
maintenance and
will continue until
corrected.
1 or 2 days.
6 to 8 hours.
Minimum of 4 hours.
Varies.
ESP can usually be
repaired in a few
hours.
1 to 4 hours.
Effect on
emission rate
Minor unless severe
damage.
Requires bypassing of
emission controls.
Dependent upon
amount of air and
location.
May be substantial.
Varies but can be
substantial.
Air contaminants will
be uncontrolled in the
gas stream going
through the broken
bags.
Means to minimize
excess emissions
—
Immediately curtail
refuse charging
operations.
Usually results from
long-term negligence
of maintenance.
Air flow redistribution
by dampers.
Reduce gas flow
volume to precipitation
(i.e., reduce charging
rate); have spare parts
available.
Check bags periodically
for minute leaks and
work fabric.
'Reciprocating grates frequently become so clogged that the incinerator will be shut down for grate repair and cleanout.
These shutdowns are usually planned, and arc not considered malfunctions.
[From Handbook, Industrial Guide for Air Pollution Control, EPA, Technology Transfer, 1978].
-------
TABLE £-5
EL-EMENTS OF CORPORATE AIR POLLUTION PROGRAM
Objective
Program elements
Result
Locate and describe atmospheric
emission sources
Assess emissions
Determine compliance with applic-
able regulations
Obtain required operating
permits
Prepare and implement
compliance action
Obtain engineering design data
Determine product losses
Establish surveillance program
Survey all processes
Make estimates and measurements
Review regulations
Determine emissions
Compare values with those cited in
applicable regulations
Determine permit requirements
Obtain data
Complete and submit forms
Assign priorities to noncomplying
sources
Perform control feasibility studies
Allocate resources
Perform source testing
Determine emission factors
Perform source testing
Make engineering estimates
Up-date source inventory
Review new regulations
Renew permits
Monitor emissions
Inventory of all emission sources
and vents
Definition of emission parameters
Listing of sources not in
compliance
Operating permits for all
required sources
Agency-approved compliance
plan and eventual compliance
with regulation
Quantitative data for selecting
new control equipment
Economics of further control
Maintaining compliance with
applicable regulations
[From Handbook, Industrial Guide For Air Pollution Control Technology Transfer, 1978].
o
en
-------
C-16
NO
YES - ENTER UNIT
Check pressure drop across
each compartment; also,
check condition of lines
and pressure gauges. •
Check cleaning systea:
-Pulse jet pressure
-Solenoids
-Reverse air blowers
-Shakers
T
Check condition of bags:
^Bag tears
-Bag deterioration
-Dropped bags
-Oily bags
-Wet bags
-Improper bag tension
-Deposits on floor
ESTER RESULTS IN REPORT.
Check solids removal equip-
ment:
-Screw conveyor
-Pneunatic system
-Heaters
-Vibrators
Are
there any
indications of
nonoptimal per-
formance?
Check clean air chamber for
possible leakage.
Check hoppers
Incoaplete solids removal
Corrosion
ENTER UNIT TO CONFIRM
EVALUATIONS. MAY NEED
TO RESCHEDULE INSPECTION.
END INTERNAL FABRIC FILTER
INSPECTION.
NO - END FABRIC FILTER INSPECTION
Figure C-1
Fabric Filter Insnection Flowsheet
[From Enforcement Workshop on Plant Inspection & Evaluation, Volume II,
Draft, EPA, OE, SSE, February 1979].
-------
C-17
Can
Internal Inspection be
-3*
Reschedule inspection
for a time when unit is
operational
Inspect internal parts:
Sozzle condition
Presense of corrosion
Presense of erosion
Presence of scaling
i
Check integrity of shell
retention grids, and othe
parts.
Check slurry handling
system.
Check pumps on purge,
make-up, and recircula-
tion lines.
Read flow neters if avail
able. Check liquor temp
on inlets and outlets.
Check pressure gauges anc
differential pressure
monitors across the fol-
lowing:
Spray nozzles
Scrubber beds
Venturi throat
Demisters
Check Ciinp and recircu-
lation tanks:
-Liquor tenperature
-Liquor pK
Check inlet conditions:
-Gas temperature
-Presaturator water
flow rate
END SCRUBBER INSPECTION
Figurec -2
Scrubber Inspection Flowsheet
[From Enforcement Workshop on Plant Inspection & Evaluation, Volume II,
Draft, EPA, OE, SSE, February 1979].
-------
C-18
Perforn Internal
Inspection.
NO
Top section, check:
-Rappers
-Drives
-Insulators
-Heaters
-Blowers
Electrical Field section,
check:
-Alignment
-Build-up
-Rappers
-Drives
-Insulators
-Erosion
-Corrosion
Check:
-Hopper section
-Suild-up
-Corrosion
-Kopper baffles
Check:
Gas distribution devices
ESP -Inlet
-Outlet
-Ductwork
-Corrosion
-Erosion
-Plugging
-Rapping systens
End ESP inspection, return
for operational inspection.
Is
Precipitator
Operating?
YES
Identify bus section numbering
system.
Check for bus sections which
are not operating.
Check electrical characteris-
tics of each bus section
that is operating.
-Primary voltage
-Primary current
-Secondary current
-Secondary voltage (if
measured)
-Spark rate
Check rapper sequence and
tining.
Check insulators purge and
heating system.
±
Check operational status
Hopper heaters & vibrators
Solids removal system
Ara
there any in-
dications of
compliance
acation?
Esp j>j_
SPECTION.
YES
Reschedule operational in-
spection. Recommend mainte-
nance work.
ENT ESP INACTION.
Figure C-3
Electrostatic Precipitator Inspection Flowsheet
[From Enforcement Workshop On Plant Inspection & Evaluation,
Volume II, Draft, EPA, OE, SSE, Washington, D.C., February 1979],
-------
APPENDIX D
WATER POLLUTION CHECKLISTS
Table D-l - NEIC Checklist for Water
Table D-2 - NPDES Compliance Inspection Report (form 3560-3)
Table D-3 - NPDES Compliance Inspection Report - National
Data System Coding (draft)
-------
D-l
TABLE D-l
NEIC CHECKLIST FOR WATER
NPDES PERMITS FOR EXISTING AND NEH POINT SOURCES
Coverage
Includes any point source 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 POTW's are
regulated under a separate program.
Requirements
• Permit Application
Adequate information must be submitted including basic facility
description, SIC codes, regulated activities, list of current
environmental permits, description of all outfalls, drawings,
flows, treatment, production, compliance schedules, effluent
characteristics, use of toxics, potential discharges and bio-
assay toxicity tests performed.
* Analytical Testing for Pollutants
Applicant must test for BOD, COD, TOC, TSS, ammonia, temp-
erature andi pH.
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.
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.
NPDES Permit
The permit enforces federal effluent limitations promulgated for
individual industrial categories, NSPS, toxic effluent standards, state
-------
water quality standards under Sec. 303 of the CWA if any are applicable,
and hazardous substances otherwise regulated under Sec. 311 of the CWA
but which may be instead incorporated under the NPDES permit. Permit
elements include the amount of pollutants to be discharged expressed in
terms of average monthly and maximum daily loads; compliance schedules
rf_ applicable standards cannot be met now; and monitoring, testing and
reporting requirements.
Routine Non-compliance Reports - The Discharge Monitoring Form
The DMR gives a summary of the discharger's records on a monthly or
quarterly basis for flow measurement, sample collection and laboratory
analyses. Non-compliance reports must be submitted quarterly on cause of
noncomplying discharges, period of noncompliance, expected return to com-
pliance, and plans to minimize or eliminate recurrence of incident.
Emergency Reporting
• < Health
The EPA shall be notified within 24 hours of noncompliance
.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 permissable
if essential to prevent loss of life or serious property damage.
Upset
Temporary noncompliance due to factors beyond the reasonable
control 'of the permittee shall be promptly reported to the
Agency.
-------
PRETREATMENT STANDARDS FOR INDIRECT DISCHARGES TO POTW'S7
I C*
D-3
Coverage
New and existing industrial users who discharge to POTH's are subject
to general and categorical pretreatment standards. The categorical standards
which are primarily directed to control of toxic pollutants in specific
industries, largely await future publication.
Requirements
General Pretreatment Standards
Prohibit fire or explosion hazards, corrosivity, solid or viscous
s
obstructions, "slug" discharges, and heat sufficient to inhibit
biological activity at POTW's.
Categorical Standards
Expected to be based on BAT:
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.
Reports
Users must provide appropriate agency (EPA, State or POTW's
having approved pretreatment programs) with basic information;
SIC code; average and maximum daily discharge; characteristics
of pollutants; applicable standards; and certification whether
standards are being met and if not, what pretreatment is nec-
essary 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 on a 6 month frequency.
49 CFR, Part 403, 1980.
-------
D- 4
OIL AND HAZARDOUS SUBSTANCES SPILLS*
Coverage
Applies to spills of oil and hazardous substances into navigable
waters from point sources from onshore and offshore facilities and vessels.
Oil spills must be reported. Hazardous substance spills must be reported
if they are included in the list of 299 substances (40 CFR, Part 116) and
they exceed "reportable quantities" (40 CFR, Part 117).
Requirements
Spills of reportable quantity must be made known immediately to the
appropriate Federal agency.
Penalties
Failure to notify is subject to penalties, the discharge of a
reportable quantity is subject to administrative penalty, and the source
is liable for cleanup costs.
SPlLL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLANS**
Coverage
Non-transportation related facilities,,onshore or offshore, which
have the potential to discharge oil in harmful or reportable quantities are
required to have SPCC plans.
Requirements
The SPCC plan shall describe past spills, corrective and preventive
means, shall implement secondary containment measures for storage tanks,
correction of corroded pipes, implement DOT regs for loading and unloading
and initiate training and inspection programs.
* Sec. 311 of CWA, 40 CFR, Parts 110, 113, 114, 116, 117, 1980 and 33 CFR,
Part 153, 1980.
** Sec. 311 of CWA, 40 CFR, Part 112, 1980.
-------
DREDGE AND FILL PERMIT PROGRAM*, D'5
Coverage
Permits are required for discharges of dredged or fill material into
waters of the U. S. Exceptions include non-major sources; presence of a
Sec. 208 State plan for areawide waste management and a Sec. 404 program
with BMP in effect for that activity; and special federal projects.
Requirements
• Nationwide Permits
Certain dredge and fill activities may be covered under nationwide
authorization by the Department of Army.
• General Permits
General authorization may be issued for categories of activities
having minimal adverse effect.
• Individual Permits
Must have application and drawings, proper evaluation information,
environmental assessment or impact statement, public notice and
interagency review. The EPA has the final right to veto the
activity if found to cause unacceptable adverse effects.
SAFE DRINKING HATER ACT (SDI-1A)**
Coverage
The SDWA comprises two major regulatory areas. The first regulate:-.
public water supplies and establishes federal drinking water standards.
The second establishes underground injection control (UIC) programs designed
to protect against contamination of underground sources of drinking
water and ensure that these supplies do not violate the national standards.
Variances and exemptions are incorporated in the SDWA but must be tied to
compliance schedules. The public water supply program essentially is
run by the State agencies.
* Sec. 404 of Cl-JA, 33 CFR, Part 323, 1980.
** 42 U.S.C. ff 300 f et. seq. and 42 U.S.C ff 7410 et. seq. 40 CFR,
Part 146, 1980.
-------
f PA h,r:. i'.:M,V"! Hivl roqs n:i a •. '-'Hir^iM.! injection cunlrol (U!0)
D-6
v.iiir.ii divides inject ion wells into C- c'Ur.sos as follows:
I - wells used for the injection of hazardous, industrial, municipal
and nuclear wastes injecting below the zone of the underground
source of drinking water (USDH) and within 1/4 mile of the
US DM.
II - oil and gas injection wells.
Ill - injection wells used for extraction of minerals and in-situ
gasification.
IV - wells used by generators of hazardous/radioactive wastes
or by facilities which dispose of such wastes into or above
a USDW.
V - all other injection wells.
Requirements for UIC Program
Existing Class IV wells to be phased out; no new Class IV wells.
Class I and IV wells which inject hazardous wastes are subject
to RCRA requirements including notification, Part A form, interim
status, necessary permitting, weekly monitoring on drinking water
wells in vicinity and quarterly reports.
Class I-III wells are subject to construction and disposal stand-
ards to be used in permitting of these wells. Standards include
construction requirements, demonstration of mechanical integrity
on a periodic basis, correction of improperly plugged or completed
wells in defined area of review, periodic or continuous monitoring
of well operation, monitoring of adjacent drinking water supplies,
and routine reports.
The States are encouraged to establish UIC programs as soon as possible;
otherwise the EPA will run the program in that State. Regulatory requirements
*of the State should be consulted when auditing groundwater practices and fac-
tors affecting quality of these waters.
NPDES COMPLIANCE INSPECTION REPORT
Inspection report form 3560-3 (Table C-2) is under revision currently.
The new format will advocate a narrative report. The narrative will be used
in conjunction with a standard cover sheet where descriptive information can
be coded (Table C-3).
-------
Table 0-2
NPDES Compliance Inspection Report (Form 3560-3)
Form Approved D- 7
OMB No. 158-R0073
NPDES COMPLIANCE INSPECTION REPORT (Coding Instructions on back of last page)
RANSACTION
CODE
NPDES
YR MO DA
INSPEC- FAC
TYPE TOR TYPE
U ILJ I I'l I I I M I I I I I I I I I U U U
_LZ_
_L2_
TIME
p.m.
REMARKS
I I I I
_§£
_ZO
ADDITIONAL
ECTION A • Permit Summary
AME AND ADDRESS OF FACILITY (Include County, State and ZIP code)
EXPIRATION DATE
ISSUANCE DATE
RESPONSIBLE OFFICIAL
TITLE
PHONE
ACILITY REPRESENTATIVE
TITLE
PHONE
SECTION B - Effluent Characteristics (Additional sheets attached .
PARAMETER/
OUTFALL
MINIMUM
AVERAGE
MAXIMUM
ADDITIONAL
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SECTION C - Facility Evaluation (S = Satisfactory, U = Unsatisfactory, N/A = Not applicable)
EFFLUEf^T WITHIN PERMIT REQUIREMENTS
OPERATION AND MAINTENANCE
SAMPLING PROCEDURES
RECORDS AND REPORTS
COMPLIANCE SCHEDULE
LABORATORY PRACTICES
PERMIT VERIFICATION
FLOW MEASUREMENTS
OTHER:
SECTION D - Comments
SECTION E - Inspection/Review
SIGNATURES
AGENCY
DATE
ENFORCEMENT
DIVISION
USE ONtV
INSPECTED BY
INSPECTED BY
COMPLIANCE STATUS
DCO»*PUANCE
Q NONCOMfMLt ANCE
REVIEWED BY
EPA FORM 3560-3 (9-77)
REPLACES EPA FORM T-51 (9-76) WHICH IS OBSOLETE.
PAGE 1 OF 4
-------
D-8
Form Approved
OMB No. 158-ROQ73
Sections F thru L: Complete on all inspections, as appropriate. N/A = Not Applicable
PERMIT NO.
SECTION F • Facility and Permit Background
ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY DATE OF LAST PREVIOUS INVESTIGATION BY EPA/STATE
(Including City, County end ZIP code)
FINDINGS
SECTION G - Records and Reports
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. DYES D NO D N/A (Further explanation attached )
DETAILS:
(a) ADEQUATE RECORDS MAINTAINED OF:
(i) SAMPLING DATE, TIME, EXACT LOCATION
(II) ANALYSES DATES. TIMES
(iii) INDIVIDUAL PERFORMING ANALYSIS
(iv) ANALYTICAL METHODS/TECHNIQUES USED
(v) ANALYTICAL RESULTS (e.g., consistent with self-monitoring report data)
(b) MONITORING RECORDS (e.g.,flow, pH, D.O., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS
INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g. continuous monitoring instrumentation,
calibration and maintenance records).
(c) LA3 EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT.
(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT UNIT.
(e) QUALITY ASSURANCE RECORDS KEPT.
(f) RECORDS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their compliance Status) USING
PUBLICLY OWNED TREATMENT WORKS.
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
Q YES D NO
D YES D NO
D YES D NO
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
SECTION H - Permit Verification ~-~-
INSPECTION OBSERVATIONS VERIFY THE PERMIT. DYES (UNO D N/ 'A (Further explanation
DETAILS:
(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE.
(b) FACILITY IS AS DESCRIBED IN PERMIT.
(c) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN PERMIT
APPLICATION.
(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION.
(e) NOTIFICATION GIVEN TO EPA/STATE OF NEW, DIFFERENT OR INCREASED DISCHARGES.
(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED.
(g) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT.
(h) CORRECT NAME AND LOCATION OF RECEIVING WATERS.
(i) ALL DISCHARGES ARE PERMITTED.
attached )
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES P NO
D YES D NO
D YES D NO
D YES D NO
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
SECTION 1 - Operation and Maintenance
TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED. D YES D NO D N/A (Further explanation attached )
DETAILS:
(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED.
(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE.
(c) REPORTS ON ALTERNATE SOURCE OF POWER SENT TO EPA/&TATE AS REQUIRED BY PERMIT.
(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED.
(e) ALL TREATMENT UNITS IN SERVICE.
(f) CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND
MAINTENANCE PROBLEMS.
(g) QUALIFIED OPERATING STAFF PROVIDED.
(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS.
(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND
PARTS AND EQUIPMENT SUPPLIERS.
(j) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR
EQUIPMENT.
(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED.
(1) SPCC PLAN AVAILABLE.
(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Dates )
(n) ANY BY-PASSING SINCE LAST INSPECTION.
(o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED.
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES O NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
D YES D NO
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
EPA FORM 3560-3 (9-77)
PAGE 2 OF 4
-------
Form Approved U~:7
OMB /Vo. 158-R0073
PERMIT
NO.
SECTION J • Compliance Schedules
PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES DNO ON/A (Further explanation attached j
CHECK APPROPRIATE PHASE(S):
D (a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE
AUTHORITIES TO BEGIN CONSTRUCTION.
O (b) PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING (mortgage commitments, grants, L-tc.j.
D (c) CONTRACTS FOR ENGINEERING SERVICES HAVE BEEN EXECUTED.
D (d) DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED.
D (el CONSTRUCTION HAS COMMENCED.
D (f) CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE.
D (g) CONSTRUCTION HAS BEEN COMPLETED.
O (h) START-UP HAS COMMENCED.
D (i) THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME.
SECTION K - Self-Monitoring Program
'art 1 — Flow measurement (Further explanation attached J
PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS:
(a) PRIMARY MEASURING DEVICE PROPERLY INSTALLED.
D YES
O YES
D NO
D NO
TYPE OF DEVICE: OwEIR O PARSHALL FLUME DMAGMETER O VENTURI METER D OTHER (Specify
(b) CALIBRATION FREQUENCY ADEQUATE. (Date of last calibration )
(c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED.
(d)SECO.MDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED.
(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW RATES.
'nft ? ' — .Sampling (Further explanation attarhrd j
PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS:
(a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES.
(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT.
(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT.
IF NO, DGRAB OMANUAL COMPOSITE DAUTOMATIC COMPOSITE FREQUENCY
(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE.
!i) SAMPLES REFRIGERATED DURING COMPOSITING
(ii) PROPER PRESERVATION TECHNIQUES USED
(iii) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT
(iv) SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3
(e) MONITORING AND ANALYSES BEING PERFORMED MORE FREQUENTLY THAN REQUIRED BY
PERMIT.
(f) IF (e) IS YES, RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONITORING REPORT.
3art 3 — Laboratory / 'Further explanation attached )
PERMITTEE LABORATORY PROCEDURES MEET THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS:
(a) EPA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.3)
(b) IF ALTERNATE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED.
(c) PARAMETERS OTHER THAN THOSE REQUIRED BY THE PERMIT ARE ANALYZED.
(d) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT.
(e) QUALITY CONTROL PROCEDURES USED.
(f) nnp| ITATF SAMPI PS ARF ANAI Y7Fr>. % OF TIMF
(9) SPIKFD SAMPI Fq ARE USFD % OF TIMF
(h) COMMERCIAL LABORATORY USED.
(i) COMMERCIAL LABORATORY STATE CERTIFIED.
O YES
D YES
D YES
O YES
D YES
O YES
D YES
D YES
D YES
O YES
D YES
O YES
D YES
D YES
D YES
D YES
D YES
D YES
D YES
O YES
D YES
D YES
D YES
D YES
O YES
O NO
O NO
D NO
O NO
D NO
D NO
O NO
D NO
D NO
D NO
O NO
D NO
D NO
D NO
D NO
O NO
O NO
O NO
D NO
D NO
D NO
O NO
D NO
D NO
D NO
DN/A
ON/A
DN/A
ON/A
DN/A
ON/A
ON/A
DN/A
DN/A
ON/A
ON/A
ON/A
ON/A
ON/A
DN/A
ON/A
DN/A
DN/A
ON/A
ON/A
DN/A
DN/A
ON/A
DN/A
ON/A
DN/A
ON/A
I A B AnnPPS^
EPA FORM 3560-3 (9-77)
PAGE 3 OF A
-------
D-10
Form Approved
OMB No. 1S8-R0073
PERMIT NO.
ECTION L • Effluent/Receiving Water Observations (Further explanation attached.
OUTFALL NO.
OILSHEEN
GREASE
TURBIDITY
VISIBLE
FOAM
VISIBLE
FLOAT SOL
COLOR
OTHER
(Sections M and N: Complete as appropriate for sampling inspections)
SECTION M • Sampling Inspection Procedures and Observations (Further explanation attached )
D GRAB SAMPLES OBTAINED
D COMPOSITE OBTAINED
D FLOW PROPORTIONED SAMPLE
D AUTOMATIC SAMPLER USED
D SAMPLE SPLIT WITH PERMITTEE
D CHAIN OF CUSTODY EMPLOYED
D SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE
COMPOSITING FREQUENCY
PRESERVATION
AMPLE REFRIGERATED DURING COMPOSITING: DYES DNO
SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE —
SECTION N - Analytical Results (Attach report if necessary)
EPA Form 3560-3 (9-77)
PAGE 4 OF 4
-------
TAB LED -
D-ll
K.S Cum'UANCF. IflSfKCTtON KKi'ORT
Section A: NntlonnJL Data Sy.'itcw Coding
Code HOPES Permit
III5! 1
1 2 3
39
No. Yr Mo Da Ty In Fa Total Hours
Pre Insp Post
INI II II III [ i
Ac Cl
III II 1 1 1
11 12 17 18 19 20 21 29 30 31 38
BI QA
72 73 80
Section B: Permit Suaaary
4ame and Address of
Facility Inspected Entry Tine
> AM
Name of On-Site Representative: PM
Nane, Address of Responsible Official Title
Permit Issuance Date
Permit Expiration Date
Phone Contacted
(yes/ no)
Section C: Aceaa Evaluated During Inspection
Permit
Records/Reports
Coopllance Sctu
Effluent/Recei^
Flow Measurement
t . Facility Site Review
-dules Operations and Maintenance
ring Waters Self-Monitoring Audit
Laboratory
Other:
Section D: Sunary of Findings
•• -V: •••'•
Section E: Inspection Review/ Action
Signature of Inspector Agency/Office Date Regulatory Office
Dae Only
Signature of Reviewer - Agency/Office Date Compliance Status
Action Taken/Date
Kon ConpHance
(From Draft NPDES Inspection Manual, EPA Washington, DC September 1982)
-------
D-12
Instructions
Section A: NaCional Data Syatea Coding
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 Che data keypunched.
Column 2: Card Code. Always 5 for this card.
Columns 3-11; 3PDRS Permit No. Insert the facility's NPDES permit number. (Use the "Remarks"
columns to record che Stace permit 'number, if necessary.)
Columns 12-17; Inspection Date. Enter Che dace of entry 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 che cype of
inspection:
C - Compliance Evaluation B - Biomonicoring
S - Compliance Sampling X - Toxic Sampling
P - Performance Audit *
Coluan 19: Inspector Code. Use one of the codes listed below Co describe che lead agency in che
inspeccion. (Credit for a joint inspection is given Co che lead agency.) Codes are:
R - EPA Regional Inspector •* AV
S - State Inspeccor "'<*«. v:* ^
J -'Joint EPA and Stace Inspeccors - EPA lead ^ v'}.^
T - Joint State and EPA Inspeccors - Stace lead .***&'•'* '''• *
N - NEIC Inspeccors \ V"'-: "
C - Contractor or Ocher Inspectors \?-''';
Column 20: Facility Type. Use one of the codes listed below to describe the type of faclliCy
that was inspecced. Codes are:
1 - Municipal - Publicly-Owned TreatmenC Works (POTWs) wich 1977 Scandard
Industrial Classificacion (SIC) 4952.
2 - Industrial - Other Chan Municipal, Agricultural, and Federal facilities.
3 - Agriculcural - Those facilities classified wich 1977 SIC 0111-0971.
4 - Federal - Those facilities identified as Federal by EPA Regional office.
Columns 21-29; Total Hours. Enter the total hours expended by Che inspeccion Ceaia for pre-
inspeccion accivicies (planning, cravel Co Che site, etc.), for on-sice inspeccion activities,
and pose-inspection accivicies (report preparation, Cravel from Che site, lab support, ecc.)
Include clerical/administrative and laboratory personnel time where applicable.
Column 30; Action Taken. If there is n£ acCion taken, enter an N; if any type of action is being
taken, including an acCion Chat is pending or under review, enter a 7.. The Cype of action should
be explained in the space provided in Section E at the bottom of the form.
Column 31; Close. If no action is being taken enter a 1 Co indicate closure. If some type of
action is being taken leave this space blank; enter a 1 when che case is closed.
Columns 32-71: Keaarka. These columns are reserved for remarks ac the discretion of"the Region.
Column 72: Blomooitorlng Information. Enter D to indicate static testing. Leave this column
blank co indicate flow through casting.
Column 73: Quality Assurance Data Inspection. Enter Q if inspection is based on follow up on
quality assurance sample results. Leave blank otherwise.
Columns 74-80: Reserved.
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D-13
Section B: Permit Sunnary
This section is self explanatory.
_ Section C: Areaa Evaluated During Inspection
Check appropriate boxes. A full explanation of inspection findings should be the subject of the
report which will accompany this form. Use the heading (i.e. Permit) in the report when
describing the areas evaluated during the Inspection. The heading marked "Other" may include
activities such as SFCC, BMP's, multi-media and the like.
_ Section D; Sunaary of
Using the space provided, briefly summarize the Inspection findings. This is not intended to
replace the report but is to be used to abstract the pertinent inspection findings. Include a.
list of attachments. Inspection reports should be completed in accordance with guidelines listed
in the NPDES Manual.
_ Section E: Inspection Review/ Action _ :
In the space marked "Action Taken", describe the initial action (if any) and all subsequent
actions until the case is closed. List the date of each action.
-------
APPENDIX E
PROCEDURES FOR HANDLING, PRESERVING,
AND TRANSPORTING SAMPLES
-------
E-l
PROCEDURES FOR AIR SHIPMENT OF
ENVIRONMENTAL LABORATORY SAMPLES
Many surveys require shipment of environmental samples by air from
field locations to laboratories to meet required holding times. Environ-
mental samples collected during water surveys are categorized as drinking
water, ambient water, effluent, biological sediment, sludge, and other
evnrionmental laboratory samples. Unless noted, the following procedures
comply with Department of Transportation (DOT) regulations for packaging
and shipping.
1. Unpreserved drinking water, ambient water, effluent, biological
V
sediment, and sludge samples.
Normal unpreserved environmental samples collected by inspectors
are not regulated under DOT Hazardous Transportation Regulations
and may be shipped using packaging and handling procedures for
shipment of non-hazardous samples.
2. Preserved drinking water, ambient water, effluent, biological
sediment, and sludge samples.
Table 1 lists the common preservatives and preservation techniques.
Samples preserved in the recommended manner may be shipped using
current packaging and handling procedures for shipment of non-
hazardous samples.
3. Reagents
Reagents which are designated as hazardous by DOTs Hazardous
Material Table, 49 CFR §172.101, shall be shipped pursurant to
the appropriate DOT regulations. The shipper is required to
determine if an individually shipped reagent is likely to be
classified as a hazardous material when it is not listed in the
DOT Table. Nitric acid in any concentration is forbidden on
passenger-carrying aircraft or railcar.
-------
TABLE 1
Standard Preservatives Listed 1n the Hazardous Materials
Table (49 CFR £172.101) used by EPA for Preservation of Water,
Effluent, Biological Sediment and Sludge Samples
ro
Preservative
HC1
j HgCl2
HN03
H2S04
.
NaOH
H2P04
Freezing
. . o°c
(Dry Ice)
Sample Type/
Parameter
Organic Carbon
Nitrogen Species
*Metals, Hardness
Nitrogen Species
COD, Oil & Grease
P (hydrolyzable)
Organic Carbon
Cyanides
Phenol ics
Biological -
Fish & Shellfish
Tissue**
pH Quantity of Weight % of
Recommendation Preservative Added Preservation Hazard Class
<2 (-1.9) . 2 ml of 1:1 0.04%
N.A. 40 mg 0.004%
<2(-1.6) 3 ml of 1:1 0.15%
<2(-1.15) 2 ml of 36N 0.35%
>12 (r!2.3) 2 ml of ION 0.080%
<4 Sufficient to
yield desired .pH
N.A. N.A. N.A.
Corrosive
Material
Poison B
Oxldizer;
Corrosive
Material
Corrosive
Material
Corrosive
Material
Corrosive
Material
ORM-A
Packaging (49 CFR) Specific
Label Exceptions Requirements
Corrosive 173.244
Poison 173.364
Oxidizer and None
Corrosive; 0.
& Poison;
Corrosive
Corrosive 173.244
Corrosive 173.244
Corrosive 173.244
None None
173.263
173. 372
173.268
173.272
173.248
173.245(b)
173.249
173.245
173.615 .
* If sample must be shipped by passenger aircraft or railcar, the sample may be Initially preserved by icing and Immediately shipping it to the
laboratory. Upon receipt in the laboratory, the sample must be acidified with cone, HN03 to pH 2. At time of analysis, sample container should
be thoroughly rinsed with 1:1 HN03; washings should be added to sample.
** Dry Ice 1s classified as a ORM-A hazard by DOT. There is no labeling requirements for samples preserved with dry 1ce, but samples must be
packaged in accordance with the requirements of 49 CFR 173.615 and advance arrangements must be made between the shipper and the air carrier.
-------
E-3
For investigations where nitric acid must be used for metals
preservation, means other than transport by passenger-carrying
aircraft or rail car must abe used to transport the acid to the
site of investigation.
4. Other Samples
Some environmental samples collected by inspectors, cush as
leachates, untreated process materials or samples from spill
investigations, may contain concentration of contaminants in
excess of those normally encountered in preserved drinking water,
ambient water, effluent, biological sediment, and sludge samples.
If such samples are collected and shipped by air, and the techni-
cal name of a sample containment material is known, and if the
contaminant material is designated in the Hazardous Materials
Table, it must be shipped pursurant to applicable DOT Hazardous
Materials regulations. If the technical name of the sample
containment material is not known, the DOT regulations place the
burden on the shipper to determine if the sample meets the defini-
tion of a hazardous material. In the case of samples being
forwarded to a laboratory for analysis, it is assumed that the
shipper would have some information concerning the sample, and
based on that information, be able to make a reasonable determi-
nation whether the sample is likely to be classified a hazardous
material. When a reasonable doubt exists as to whether a sample
is subject to DOT regulations, the shipper should consult the
Hazardous Materials Transportation Coordinator as to the appro-
priate procedures to follow in the shipment of the sample.
When a sample is not listed in DOT's Hazardous Materials Table,
40 CFR §172.101, it is necessary for a shipper to make a reason-
able determination whether the sample is likely to be classified
as a hazardous material. The following classes of hazardous
materials must be considered, and they are listed below in the
order of greatest concern, 40 CFR §173.3.
-------
E-4
Radioactive material
Poison A
Flammable gas
Non-flammabel gas
Flammable liquid
Oxidizer
Flammabel solid
Corrosive material (liquid)
Poison B
Corrosive material (solid)
Irritating materials
Combustible liquid (in containers having capacities exceeding
110 gallons)
ORM-B (other regulated material, ile., barium oxide, calcium
oxide, copper chloride)
ORM-A (i.e., dry ice, carbon tetrachloride, chlorofrom, DDT,
dieldrin, formaldehyde, lindane, malathion, naphthalene,
vinyl acetate)
Combustible liquid (in containers having capacities of 110
gallons or less)
The above hazards likely to be applicable to survey samples as defined
by DOT regulations are as follows:
Poison A (49 CFR §173.326) - Poisonous gases or liquid of such nature that
a very small amount of gas, or vapor of the liquid mixed with air, is
dangerous to life. This class includes the following:
Bromacetone
Cyanogen
Cyanogen chloride containing less than 0.9% water
Diphosgene
Ethyldichlorasine
Hydrocyanic acid
Methyldiclorstsine
Nitrogen peroxide (tetroxide)
Phosgene (diphosgene)
-------
E-5
Nitrogen tetroxide - nitric oxide
Mixtures containing up to 33.2% weight nitric oxide
Flammable liquid [49 CFR §173.115(a)] - "Any liquid having a flash point*
below 100°C (37.8°F) . . ." Some of the flammable liquids listed in DOT's
Hazardous Materials are acetone, alcohol n.o.s. (not otherwise specified),
Benzene cyclopentane, hexane, ink, methyl alcohol, methyl ehtyl ketone,
toluene,
and xylene.
Oxidizer (49 CFR §173.151) - "A substance such as a chlorate, permanganate,
inorganic peroxide, intro carbo nitrate, or a nitrate that yields oxygen
readily to stimulate the combustion of organic matter."
Corrosive materials (49 CFR §174.240) - "A liquid . . . that causes visible
destruction or irreversible alterations in human skin tissue at the site of
contact, or in the case of leakage from its packaging, . . . that has a
severe corrosion rate of steel."
Poison B (49 CFR §173.343) - "Those substances, liquid, or solid (including
pastes and semisolids), other than Class A poisons or Irritating Materials,
which are known to be so toxic to man as to afford a hazard to health
during transporation; or which, in the absence of adequate data on human
toxicity, are presumed to be toxic to man because they fall within any one
of the following categories when tested on laboratory animals:
Oral toxicity . . . Toxicity on inhalation . . . Toxicity by skin
absorption ...
Examples taken from DOT's Hazardous Material Table indlude aldrin, copper
cyanide, mecuric acetate, nitroaniline, thiophosgene, and zinc arsenate.
The foregoing categories shall not apply if the "physical characteristics or
* Flash point means the minimum temperature at which a substance gives off
vapors which, in contact with spark or flame, will ignite [49 CFR §171.8],
-------
E-6
the probable hazard to humans as shown by experience indicate that the
substances will not cause serious sickness or death."
Irritating Material (49 CFR § 173.381) - "A liquid or solid substance
which upon contact with fire or when exposed to air gives off danger-
ous or intensely irritationg fumes, such a bromenzylcynaide, chlorace-
tophenone, diphenylaminechlorarsine, and diphenylchlorasine, but not
including any poisonous material, Class A."
Combustible liquids [49 CFR §173.115(b)] - Any liquid that ... has a
flash point at or above 100°F (37.8°C) and below 200°F (93.3°C) ..."
Examples of combustible liquids include alcohol - n.o.s., benzaldehyde,
camphor oil, chlordane-liquid,-cresosotecoal tar, fuel oil, pine oil,
road oil, and wax-liquid.
Etiological agent (49 CFR §173.386) - a viable microorganism or its
toxin, which causes or may cause human disease. A diagnositc specimen"
means any human or animal meterial including, but not limited to,
excreta, secreta, blood and its components, tissue, and tissue fluids
being shipped for purposes of diagnosis. The list of etiological
agents in the Department of Health, Education and Welfare (HEW) regu-
lations, 42 CFR §72.25(c), includes bacterial, fungal, and viral
agents and would cover organisms found in sewage, human and animal
waste. Diagnostic specimens of etiological agents are expected from
DOT hazardous materials regulations, but HEW requires an etiological
agent label to be affixed to all packages which contain etiological
agents. However, so long as the shipper does not have reason to
believe that viable disease-causing organisms are present in a sample
based on the company's NPDES permit and DRM data, then the sample will
not be considered an etiological agent. Therefore, the sample will
not require a HEW etiological label and may be shipped pursuant to
packaging and handling procedures for shipment of non-hazardous samples.
The Clean Water Act [311(b)(2)] requires the identification of hazard-
ous substances which present an imminent and substantial danger to the
-------
E-7
public health and welfare. DOT has proposed that any substances not previ-
ously listed in the Hazardous Material Table be classified as ORM-E. The
EPA Safety Manual ror Hazardous Waste Site Investigations* details proce-
dures for transporting unknown hazardous waste materials samples.
Packaging and Handling Procedures for
Shipment of Non-Hazardous Samples
The basic guidelines for packaging procedures must meet DOT standard
requirements for all packages as specified in 49 CFR §173.24, e.g.:
Each package . . . shall be so designed and constructed, and its
/
contents so limited, that under conditons normally incident to trans-
portation:
There will be no significant releast of ... materials to the
environment;
the effectiveness of the packaging will not be substantially
reduced; and
there will be no mixture of gases or vapors in the package which
could, through any credible spontaneous increase of heat or
pressure, or through an explosion, signficantly reduce the effec-
tiveness of the packaging.
In addition, shipments by air must meet the requirements at 49 CFR §173.6:
Each package . . . shall be so designed and constructed and its con-
tents so limited, that under conditons normally incident to transpora-
tion,
There will be no significant release of ... materials to the
environment.
In DRAFT circulation at time of this printing.
-------
E-8
Inner containers that are breakable (such as earthenware, glass,
or brittle plastic), must be packaged to prevent breakage and
leakage under conditions normally incident to transportation.
These completed packagings must be capable of withstanding a 4-ft
drop on solid concerete in the position most likely to cause
damage. Cushioning and absorbent materials must not be capable
of reacting dangerously with the contents ....
For any packaging with a capacity of 110 gallons or less contain-
ing liquids, sufficient outage (ullage) must be provided to
prevent liquid contents from completely filling the packaging at
130°F. The primary packaging (which may include composite packag-
ing), for which retention of the liquid is the basic function,
must be capable of withstanding, without leakage, an internal
absolute pressure of no ness than 26 Ib/sq in. or no less than
the sum of the absolute vapor presssures of the contents at 130°F
(55°C) and,
Stoppers, corks, and other such friction-type closures must be
held securely, tightly, and effectively in place with wire, tape,
or other positive means. Each screw-type closure or any inside
plastic packaging must abe secrued to prevent the closure from
loosening due to vibration or substantial changes in temperature.
Most analytical methods recommend that samples be preserved with ice
or below a temperature of 4°C. These must be adhered to in addition to the
following packaging precedures based on the above DOT guidelines.
Samples in quart-size and smaller glass bottles should be enclosed in
sytrofoam packaging and sealed with filament-reinforced tape. In the case
of the 1-gallon bottles used for non-preserved organic samples, carved
sytrofoam sheets at the top and bottom will be used to hold the bottle in
place. A picnic cooler containing plastic 16-oz bottles and ice was dropped
three times from a distance of 4 ft and did not experience any leakage or
damage to the inside bottles. This indicates that it affords the type of
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E-9
sturdy protection which is the goal of 49 CFR §173.24 and 173.6. Therefore,
16-oz polyethylene bottles will be used for samples containing acid preserv-
atives, and the bottles will not require additional sytrofoam enclosures.
The caps will be tightly screwed on before being placed in the cooler.
Small volatile organics glass bottle samples will be placed inside quart
cubic containers to prevent breakage. Plastic containers and quart-size
glass bottles (enclosed in styrofoam containers) will be put into large
heavy-duty plastic bags inside the cooler, ice will be place around the
samples, and the bags will be tightly closed. The cooler drainage hole
must abe secured to prevent leakage. All sides of the cooler will have
arrows which indicate the proper upward position of the cooler, and a "THIS
SIDE UP" sticker will be placed on top. Following these packaging proce-
dures will minimize to the greatest degree presently possible, any harm
which could occur from transportation of environmental samples in commerce.
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APPENDIX F
SUMMARY OF POLLUTION CONTROL LEGISLATION
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APPENDIX A
SUMMARY OF POLLUTION CONTROL LEGISLATION
This appendix gives a short synopsis on the prevailing Federal approach
to environmental regulation, EPA enforcement remedies used today, and then a
summary of each of the major pollution control Acts including the Clean Air
Act (CAA), the Clean Water Act (CWA), the Resource Conservation and Recovery
Act (RCRA), the Comprehensive Environmental Response, Compensation and Liab-
ility Act (Superfund), the Toxics Substances Control Act (TSCA), the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Safe Drinking Water
Act (SDWA), and the Occupational Safety and Heatlh Act (OSHA).
GENERAL FEDERAL APPROACH TO ENVIRONMENTAL REGULATION
The basic approach is to establish National Standards for the handling,
emission, discharge, or disposal of harmful substances. (Waste) sources are
expected to comply with these national standards whether the programs are
implemented directly by the EPA or delegated to the States. In most cases,
the National Standards are applied to sources through permit programs which
control the entry of pollutants into the environment. Meeting the federal
standards is a condition of receiving the permit. The EPA establishes the
federal standards and requirements for permit issuance for an approvable
program. In turn, most permit programs are administered by the States. The
TSCA program is run entirely by the federal government whereas Subtitle D
of RCRA (governing the disposal of nonhazardous solid waste) is run almost
entirely by the States.
Some of the larger programs which have been delegated by the EPA to
the State are the National Emission Standards for Hazardous Air Pollutants
(NESHAP), Prevention of Significant Deterioration (PSD) permits under the
CAA, the water quality standards and the National Pollution Discharge Elimi-
nation System (NPDES) program under the CWA, the hazardous waste program
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under RCRA, and the drinking water and Underground Injection Control (UIC)
programs under the SDWA. Conversely, TSCA is administered entirely by the
federal government.
The States can set stricter standards then those required by federal
law. State regulation of air and water pollution is oftentimes more inclu-
sive than dictated by federal regulation. States can bring a broader group
of sources under regulation or may require more stringent controls, e.g.,
California's stringent air pollution controls on both stationary and mobile
sources. Texas' conditions on hazardous waste handling and disposal are
more stringent than federal standards.
EPA ENFORCEMENT REMEDIES
Some enforcement options include:
1. Issuance of a (administrative) Compliance Order, sometimes pre-
ceded by a "Notice of Violation".* A compliance order will speci-
fy the nature of the violation, and give a reasonable time for
compliance. The Order if violated can lead to civil, or in some
cases, criminal action.
2. EPA may directly go to court without using administrative proce-
dures seeking injunctive relief or civil penalty.
3. EPA may directly go to court without using administrative proce-
dures, seeking criminal sanctions. Criminal penalties are avail-
able for "knowing" or for "willful or negligent" violations.
4. EPA can attempt to obtain an emergency restraining order halting
activity alleged to cause "an imminent and substantial endanger-
ment" to the health of persons.
* A concise written statement with factual basis for alleging a violation
and a specific reference to each Regulation, Act Provision, or Permit
Term allegedly violated
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5. Emergency authority may be used until judicial authority is
granted.
Additionally the EPA can assess administrative penalties. This penalty
will generally attempt to eliminate the economic advantage that would other-
wise be enjoyed by a firm as a result of delaying installation of pollution
control equipment. The penalty calculation will involve comparing the cash
flow which the source would have incurred if it had complied on time with
the cash flow that will result if it does not comply. The EPA can also
"blacklist" a Company or party from entering into Federal contracts, loans,
and grants.
CLEAN AIR ACT*
The Clean Air Act (CAA) calls for the EPA to establish national ambient
air standards as concentrations of designated pollutants called National
Ambient Air Quality Standards (NAAQS). These standards are to be achieved
by the States through State Implementation Plans (SIPs). EPA also sets two
types of national air emission standards: New Source Performance Standards
(NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP).
Special programs have also been developed for Prevention of Significant
Deterioration (PSD) in clean air areas and for stringent controls in Non-
Attainment Areas (NAA's).
The SIP provides emission limitations, schedules and timetables for
compliance by stationary sources. The Act focuses upon "major" stationary
sources or major modifications of existing sources. Major sources are de-
fined as sources which generally emit more than 100 tons/year of a desig-
nated pollutant. The Clean Air Act emphasizes five areas:
National Ambient Air Quality Standards/State Implementation Plans
EPA designates harmful pollutants and publishes criteria documents
which discuss the health and welfare significance of those pollutants. The
42 U.S.C. §§ 7401 et. seg.
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EPA then sets primary and secondary ambient air standards (CAA, Section
109). Primary standards are intended to protect health of the population
whereas secondary standards are meant to protect the public welfare. Seven
pollutants have been established as harmful and standards established.
These pollutants include: sulfur dioxides, particulates, carbon monoxide,
ozone, hydrocarbons, nitrogen oxides, and lead. These standards are imple-
mented through SIP's (CAA, Sec 110).
The 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. SIP's must assure attainment of NAAQS by prescribed dates.
SIP's 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, transportation
plans, preconstruction review of new sources, NAA and PSD permits for con-
struction of new sources, monitoring, and inspection and testing of ve-
hicles. Other measures may include emissions charges, closing and relo-
cation of plants, changes in operations, and ways to reduce vehicular traf-
fic including taxes, staggered work hours, and mass transportation. The
CAA prescribes that any SIP will not be adopted without a public hearing
and sources affected by the SIP are expected to participate.
New Source Performance Standards
NSPS are established for particular 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, the 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 Emission 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
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standards are based on health effects with strong reliance on technological
capabilities. They apply to both existing and new stationary sources. The
four substances on the NESHAP list for which there are effective regula-
tions currently include: beryllium, asbestos, mercury and vinyl chloride.
The NESHAP program can be delegated to any qualifying State. (CAA, Section
112)
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 pol-
lutant 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 3 categories: Class I-only
minor air quality degradation allowed; Class II - moderate degradation; and
Class III - substantial degradation. In no case would PSD allow air quality
to deteriorate below secondary air quality standards.
"Increments" are the maximum amount of deterioration that can occur in
a clean air area over baseline. "Baseline" is the existing air quality for
the area at the time the first PSD is applied for. 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 potential 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. This
process requires that extensive data be assembled. 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)
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Non-Attainment Areas
These areas are those which are not in compliance with national air
quality standards. New construction in a NAA is prohibited unless the SIP
has been amended and approved by the EPA to reflect the following
conditions:
1. total allowable emissions for the area will be less than emis-
sions from existing sources.
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 desig-
nated 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 allow-
ance for the NAA. In these situations, the source would need to obtain
enforceable 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. Rules are yet to be established by the States governing the sale
or trade of these banked offsets. (CAA, Part D)
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CLEAN WATER ACT*
Through the 1950's and 1960's, emphasis was on the States setting am-
bient water quality standards and developing plans to achieve these stan-
dards. 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 crea-
ted and substantial monies were made available for construction of sewage
treatment plants. The Federal Water Pollution Control Act was amended in
1977 and renamed the Clean Water Act. The CWA regulates 5 types of point
sources: direct discharges, indirect discharges, sources which spill oil or
hazardous substances, discharge of dredged or fill material, and sewage
from vessels.
Effluent Guidelines for Direct Discharges
Section 304 of the CWA sets restrictions on the amount of pollutants
discharged at industrial plant outfalls which are usually expressed as
weight per unit of product (i.e., 0.5 lb/1000 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). BPT
was previously intended to be in place by industry in 1977 and BAT in 1983.
Amendments to the CWA modified this schedule whereby a very limited BPT
extension was granted to 1979, and the BAT deadline was extended to between
1984 and 1987. The Amendments divided all pollutants into three categories.
"Conventional" pollutants shall meet BCT limitations by July 1984. "Toxic
pollutants" must meet BAT limitations by July 1984, and "non-conventional
pollutants" shall achieve BAT criteria by July 1987.
33 U.S.C. §§ 1251 et. seq.
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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.
Pretreatment Standards for Discharges to Publicly Owned (Sewage) Treatment
Works (POTW'S)
Industrial discharges to city sewers are indirect discharges and do
not require a permit under the CWA but must comply with pretreatment stan-
dards (Section 307(b)). Pretreatment standards consist of general and
categorical standards designed to prevent interference with the POTW and
avoid pass-through of pollutants at the POTW.
General pretreatment standards applicable to all sources which contri-
bute to POTWs include prohibiting:
1. fire or explosion hazards
2. corrosive discharges
3. viscous obstructions
4. slug discharges
5. heat sufficient to inhibit biological activities
Pretreatment standards must be integrated into NPDES permits issued to
POTWs. EPA regulations provide for local pretreatment programs at many
municipalities; these programs must be in place by July 1983.
Toxic Pollutants
The 1977 Amendments to the CWA defines 129 pollutants as toxic. These
pollutants are required to meet BAT criteria by July 1984 and will also be
controlled by NSPS and categorical pretreatment standards [CWA, Sec-
tion 301(b)(2)(c)].
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F-9
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 for these wa-
ters and accordingly determine effluent limits and compliance schedules
for point sources to meet the maximum daily allowable loads.
The 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 source discharges. In 1979-1980, 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 toxic and
hazardous substances into surface waters. BMP's are industry practices
used to reduce secondary pollution (e.g., raw material storage piles shall
be covered and protected against rain and runoff). BMP's do not have nu-
merical limits and therefore are different from effluent limits.
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.
Dredge or Fill Discharge Permit Program
Section 404 of the CWA regulates the discharge of dredged or fill ma-
terial into waters of the United States. Dredged material is excavated or
dredged from a water body. Fill material is that used to replace water
with dry land. The Section 404 permit program is administered by the U. S.
Army Corps of Engineers. The EPA provides guidelines for the issuance of
permits by the Corps of Engineers. States may assume responsibility for
portions of the program.
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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 U. S. The ap-
propriate federal agency must be immediately notified of any spill of a
"reportable quantity". Section 311 provides for cleanup of spills and re-
quires plans for preparation of Spill Prevention, Controls and Countermea-
sures (SPCC).
Approximately 300 substances have been defined as hazardous under Sec-
tion 311 and each of these substances has a "reportable quantity" defined
for it (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 type of facility and spill. These limits do not apply if
the discharge resulted from willful negligence or willful misconduct of the
owner.
Certain discharge of oil and hazardous material that flows from a point
source may be excluded from Section 311 liability if, during preparation of
the NPDES permit covering that facility, conditions are added to the permit
to avoid the occurrence of a spill.
RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA)*
RCRA was signed in October 21, 1976 and subsequently amended in 1980.
Subtitle C of the Statute authorizes a comprehensive federal program to
regulate hazardous wastes from generation to ultimate disposal. Subtitle D
42 U.S.C. §§ 6901 et. seq. and Solid Waste Disposal Act Amendments
of 1980, P.L. No. 96-482, 94 Stat. 2334.
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of the Statute deals with the disposal of non-hazardous wastes. These Sub-
titles deal with waste activities now and in the future. Only one section
of the Act, i.e., Section 7003, addresses problems which may have arisen
prior to 1976. The 7003 provision allows EPA to take action against persons
conducting past and current activities that may present "an imminent or
substantial endangerment to health or to the environment".
The term "solid waste" is defined broadly to include garbage, refuse,
and other discarded material, and includes liquids and gaseous materials
together with solids.
"Hazardous waste" is defined in broad terms. Congress delegated to
the EPA the responsibility to define as "hazardous" those solid wastes which
may cause or significantly contribute to an increase in mortality or serious
illness, or which may cause a substantial hazard to human health or the en-
vironment when improperly managed.
SUBTITLE C can be divided into five parts:
Identification of Hazardous Waste
Section 3001 of the Act calls for the EPA to establish criteria for
identifying characteristics of hazardous waste and for listing hazardous
wastes. The EPA on May 19, 1980 promulgated an initial set of regulations,
and a number of amendments have been subsequently made. The EPA has listed
certain wastes as hazardous and established four characteristics, i.e.,
corrosivity, reactivity, ignitability, and toxicity, by which the hazardous-
ness of solid wastes is rated. This determination is given in 40 CFR, Parts
260 and 261, 1980.
Small quantities of acutely hazardous waste may require a management
program; however, most wastes generated in small quantities (< 1,000 kg/mo)
or reused, are excluded from requirements of the hazardous waste program.
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Hazardous Waste Generators
Section 3002 of the Act calls for the EPA to establish regulations on
generators of hazardous wastes. Regulations were implemented Feb 26, 1980,
revised May 19, 1980, and subsequently amended several times. The regula-
tions appear in 40 CFR, Part 262, 1980.
Generators must identify all hazardous wastes they produce. They must
also obtain an I. D. number and store wastes in accordance with standards.
If wastes are shipped offsite, each shipment must be manifested and packaged
and labeled in accordance with DOT specs. Generators must report on an
annual basis to the EPA the types and quantities of wastes transported and
disposed of, and records must be kept for a minimum of 3 years.
Generators are allowed to accumulate hazardous wastes onsite up to 90
days without a storage permit. When the 90 day period is exceeded, the
generator must obtain a permit for storage of hazardous wastes (40 CFR Sec-
tion 262.34 revised Nov. 19, 1980).
Generators who are not Treatment, Storage, and Disposal Facilities
(see below) will not need to obtain a RCRA permit. However they are respon-
sible for assuring that hazardous wastes transported offsite reach designa-
ted treatment, storage or disposal facilities. The generator must also use
a manifest system.
Hazardous Waste Transporters
Section 3003 of the Act calls for regulations on transporters of haz-
ardous wastes. These were promulgated February 26, 1980, revised May 19,
1980, and subsequently amended several times. The regulations appear in 40
CFR, Part 263, 1980. The regulations essentially require that transporters
comply with DOT specifications and use the hazardous waste manifest system.
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Hazardous Waste Treatment, Storage and Disposal Facilities (TSDF)
These facilities are regulated under Sections 3004 and 3005 of the
Act. The initial regulations were issued May 10, 1980 with additional regu-
lations issued at numerous times. The regulations give standards for which
permits may be granted to new and existing TSDFs.
RCRA requires that TSDFs obtain a permit with the important exception
that facilities in existence as of November 1980 may need only to obtain
"interim status". The latter facilities do not require a site-specific
permit until final permitting standards become effective. In contrast, new
facilities must obtain a permit. The regulations establish performance
standards for various types of facilities, i.e., waste piles, tanks, con-
tainers, surface impoundments, etc., which are to be implemented with permit
provisions (40 CFR, Parts 264 and 266). The regulations giving procedures
for obtaining a RCRA permit were promulgated May 19, 1980 (40 CFR, Parts
122-124).
State Programs
At present, States may be delegated responsibility to operate all as-
pects of the federal program except the permitting of land disposal facili-
ties for which the EPA is Detaining authority. There are two stages of
delegation. First, states which had a hazardous waste program at the time
the RCRA regulations were promulgated may receive temporary interim authori
zation to manage the program if the State activities were substantially
equivalent to the federal program. Full authorization may be obtained for
qualifying States with or without interim authorization. Procedures on
delegation of authority were published May 19, 1980 (40 CFR, Part 123, 1980).
SUBTITLE D deals with solid wastes that are non-hazardous and concern
only the disposal, not the generation nor transportation of these wastes.
No permit system is called for under Subtitle D. The regulations call for
minimum standards to be met under State waste management plans. These reg-
ulations define what constitutes a Sanitary Landfill (40 CFR, Part 257, 1980).
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Section 4005 prohibits open dumping of waste unless these are upgraded to a
sanitary landfill within a specified period of time, and compliance sche-
dules are established.
COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION. AND LIABILITY ACT OF
1980 (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
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, that the parties who operated the vessel or fa-
cility which created the hazardous substances are liable for the contain-
ment, removal, remedial action, response, and injury damages to natural re-
sources under Section 107(a). The Act also establishes limitations on
liability.
If claims are presented to the liable parties but are not satified,
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 un-
less the release is in accordance with an established permit. A spill of
one pound or any "reportable quantity" established pursuant to Section 311
(b)(4) of the CWA must be reported. It is expected that this reportable
quantity will be changed in the future.
Public Law 96-510, 94 Stat. 2767
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All owners or operators of any facility handling and disposing of haz-
ardous substances or that have handled hazardous substances in the past
(including previous owners and operators) are 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 notification
is a crime and if the party unknowingly fails to provide these data, they
are not entitled to the prescribed limits and defenses of liability.
TOXIC SUBSTANCES CONTROL ACT (TSCA)*
TSCA regulates existing and new chemical substances. TSCA applies
primarily to manufacturers, distributors, processors, and importers of
chemicals. TSCA can be divided into five parts as follows.
Inventory and Premanufacture Notification
EPA has published an inventory of existing chemicals. A substance
that is not on this list is considered "new" and requires Premanufacture
Notification (PMN) to the EPA at least 90 days before the chemical can be
manufactured, 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. Conversely, the EPA
may decide to limit or completely ban the product from the market.
Testing
Under TSCA Section 4, the EPA can require product testing of any sub-
stance which "may present an unreasonable risk of injury to health or to
the environment". Some testing standards are proposed, but no test require-
ments for specific chemicals are yet in effect.
15 U.S.C. §§ 2601 et. seq.
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Reporting and Recordkeeping
TSCA, Section 8(a) deals wi.th general reporting. The "first tier"
rule now in effect is a short form seeking production and exposure 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 on significant adverse effects 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 submit to the EPA lists of health
and safety studies conducted by, known to, or ascertainable by them. At
present, there is no final rule implementing collection of this data.
Section 8(e) requires action upon discovery of certain data. Any per-
son who manufacturers, processes or distributes a chemical substance or
mixture, and 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 the EPA immediately. Personal liability
can only be limited if the Company has a response plan in effect.
Regulation Under Section 6
The 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.
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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 en-
vironment. When such a condition prevails, the 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)*
FIFRA requires registration of all pesticides, restricts use of certain
pesticides, grants experimental use permits, and recommends standards for
pesticide applicators, and the disposal and transportation of pesticides.
A pesticide is defined as any substance intended to prevent, destroy, repel,
or mitigate pests.
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 num-
ber, 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
* 7 u.s.c., § 136.
** 42 U.S.C. §§ 300(£) et. seg. and 42 U.S.C. §§ 7410 et. seg.
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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. Proposed regulations for tri-
bal omethanes were prepared in 1978. Secondary regulations were proposed in
1977 as guidelines to States to protect the non-health related qualities of
drinking water.
The SDWA also provides for protection of underground sources of drink-
ing water. Final regulations have been issued whereby States are to es-
tablish Underground Injection Control (UIC) waste disposal programs to en-
sure 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 5 classes for regulatory
handling. Construction and disposal standards are established for the per-
mitting of Class I to III wells. Class I and Class IV and some Class I
wells are subject to RCRA requirements. Class IV wells are those used by
generators of hazardous or radioactive wastes into and above an underground
source of drinking water. New Class IV wells are prohibited, and existing
Class IV wells may be phased out in 6 months. There are numerous State
regulatory requirements affecting groundwater which should be consulted by
multi-media compliance inspectors.
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APPENDIX G
RCRA AND CERCLA CHECKLISTS
RCRA
Table G-l - NEIC Checklist for Solid and Hazardous Wastes
Table G-2 - Inspection Procedures for Non-Notifiers
Table G-3 - Generators Checklist
Table G-4 - Transporters Checklist
Table G-5 - General Site Inspection Checklist
Table G-6 - Tanks Checklist
Table G-7 - Surface Impoundments Checklist
Table G-8 - Waste Piles Checklist
Table G-9 - Land Treatment Checklist
Table G-10 - Landfills Checklist
Table G-ll - Incinerators Checklist
Table G-12 - Thermal Treatment Checklist
Table G-13 - Chemical, Physical, and Biological Treatment Checklist
Table G-14 - Containers Storage Checklist
Table G-15 - Groundwater Monitoring Checklist
CERCLA
Table G-16 - Uncontrolled Hazardous Waste Disposal Site Checklist
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G-l
Table G-l
NEIC CHECKLIST FOR SOLID AND HAZARDOUS WASTES (RCRA)
COVERAGE
Solid Waste is regulated through State programs under Subtitle D of
RCRA, if land disposed. Hazardous Solid Waste is subject to regulation in
its generation, transport, treatment, storage, and disposal under Subtitle C
of RCRA. A waste is hazardous under Subtitle C if it is listed by the EPA
as hazardous, it exhibits hazardous characteristics, (corrosivity, reactiv-
ity, ignitability, and extraction procedure toxicity), and if not delisted
or excluded from regulation. There are special management provision for
hazardous wastes created by small generators and hazardous waste that is
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 intended purpose, or is a mining or manufacturing byproduct. Most
industrial and commercial byproducts can quality as a solid waste. Exclu-
sions from solid waste include domestic sewage, irrigation return flows,
materials defined by the Atomic Energy Act, insitu mining waste, and NPDES
point sources.
Solid wastes excluded from regulation as hazardous solid wastes com-
prise: houhold waste; crop or animal waste; mining overburden and wastes
from processing and benefication of ores and minerals; fly ask, 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. Materials intened to be
reused or recycled are not regulated as hazardous wastes unless they are
sludges, listed wastes, or mixtures containing listed wastes.
Listing of Hazardous Wastes
Includes hazardous waste streams from specific major industry groups and
some generic sources (40 CFR, Part 261, Subpart D, § 261.21 and 261.32).
* 40 CFR, Parts 260-261, 1980
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6-2
and toxic commercial chemical wastes which is a list of over 200 commercial
chemical products and chemical intermediates by generic name. Substances
become hazardous wastes when discarded. If a commercial chemical substance
is on the list, its off-spec species and spill residues are also considered
hazardous (40 CFR, Sec. 261.33(f)).
The overall listing further includes acutely toxic commercial chemical wastes-,
which is a list of 122 commercial chemical products and manufacturing
chemical intermediates by generic name which are classified as hazardous waste
when discarded. If a substance is on this list, its off-spec species,
spill residues and containers and inner liners (unless triple rinsed and
effectively cleaned) are also considered hazardous (40 CFR, Sec. 261.33(e)).
Special Management Provisions
Small Generators
Small generators are defined as producing less than:
1,000 kg/month of hazardous waste. '
Or in the case of acutely toxic wastes:
1 kg/month of waste
10 kg/month inner liners
100 kg/month spill residues
It is noted that the cut-off applies to the generator, not to
each waste. Small generators must however still comply with two
requirements:
identify hazardous waste by list, testing or experience
dispose of their hazardous waste in a RCRA authorized TSDF
facility either off-site or on-site.
Reuse or Recycling
See above
Requirements For Generators*
Identification
Hazardous wastes must be identified by list, .testing or experience
and assigned waste I.D. numbers.
40 CFR, Part 267, 1980
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G-3
Notification
By August 18, 1980, generator must file separate 3010 notices to
the EPA for all hazardous waste generation, treatment, storage
and disposal (including Class I and IV UIC wells. Generator
receives an EPA identification number.
Manifest System
By November 19, 1980, implement manifest system and follow
procedures for tracking and reporting shipments.
Packing
Implement packaging, labelling, marking and placarding requirements
prescribed by DOT regs (49 CFR, Parts 172, 173, 178 and 179).
Transport Wastes Only to RCRA - authorized TSDF
Annual Report
Required of transporters and identified wastes each March 1 on
EPA Form.
Exception Reports
When generator does not receive signed copy of Manifest from
designated TSPF within 45 days, the generator sends Exception
Report to EPA including copy of manifest and letter describing
efforts made to locate waste and findings.
Storage
When waste is stored less than 90 days, generator shall comply
with special requirements including contingency plan, prevention
plan and staff training (40 CFR, Part 265, Subparts C, D, J and
265.16).
Permit for Storage More Than 90 Days
If hazardous waste is retained onsite more than 90 days, generator
is subject to all requirements of TSDF's including need for
RCRA permit.
Requirements for Transporters*
Notification
By August 18, 1980, transporters must file notice with EPA of
hazardous waste activity. Transporter receives an EPA identifi-
cation number.
40 CFR, Part 263, 1980
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6-4
Manifest System
By November 19, 1980, the transporter must fully implement the
manifest 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 a RCRA-authorized TSDF
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.
Requirements for Treatment, Storage and Disposal Facilities (TDSF's)*
Notification
Separate 3010 notices shall be filed with EPA for all hazardous
waste treatment, storage and disposal activities (including Class I
and IV underground injection wells) and also for wastes stored
onsite more than 90 days.. The facility receives an EPA identifica-
tion number.
Interim Status for Facilities in Existence as of November 19, 1980
These facilities include TSPF's; onsite hazardous waste disposal;
onsite storage for more than 90 days; and the transportation and
storage of hazardous sludges, Listed wastes, or mixtures contain-
ing listed wastes intended for reuse.
Interim Status is achieved by:
Notification (see above)
Filing Part A of RCRA permit application by November 19, 1980.
40 CFR, Parts 264-265, 1980
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G-5
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)
Groundwater Monitoring
To be effective November, 1981. (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).
Permi t
In order to obtain permit:
Facilities with interim status must file Part B of RCRA
permit application when directed to do so by EPA, and final
facility standards must be met.
Facilities which do not qualify for interim status in order
to obtain permit must apply to EPA or approved State. It is noted
that facilities which do not qualify for interim status must
. cease operations and transfer waste inventory to RCRA-authorized
facility. Operations can resume only after the permit has
been granted.
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G-6
TABLE G-2
INSPECTION PROCEDURES FOR NON-NOTIFIERS
Inspections may be conducted to determine whether handlers of hazardous
waste who have not notified under §3010 of RCRA should have done so. Steps
that should be taken by the inspector to make this determination include the
following:
1. Request proof of a non-hazardous determination (this applies
to generators) via written notice or site visit.
2. If the generator is .unable to satisfactorily demonstrate how
such a determination was made, ask the generator to present
data or records indicating the following:
materials used and their quantity
processes used
product output and quantity of output
wastestream produced and quantity
by-products created and quantity
3. Evaluate the data to determine whether or not the generator
produces hazardous waste in quantities regulated by the Act.
4. If doubt still exists concerning the nature of the waste-
stream, take a representative sample of the wastestream and
submit it for analysis.
(From RCRA Inspection Manual, Fred C. Hart and EPA, Washington, D.C., 1980)
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••"•R-evisstf 7/82
^ %t
6-7
RCRA COMPLIANCE INSPECTION REPORT
GENERATORS CHECKLIST
Note: On multiple part questions, circle those not in compliance.
Section A - EPA Identification No.
1. Does Generator have EPA 1.0. No.? (262.12 - EPA I.D-. No.) Yes No
a. If yes, EPA I.D. No.
Section B - Hazardous Waste Determination
1. Does generator generate hazardous waste(s) listed in Subpart D
(261.30 - 251.33 - List of Hazardous Waste)? Yes No
a. If yes, list wastes and quantities on attachment
(Include EPA Hazardous V/aste*No.)
(Provide waste name and description.)
2. Does generator generate sol id waste(s) that exhibit hazardous
characteristics? (corrosovity, ignitability, reactivity, EP
toxicity) (261.20 - 251.24 - Characteristics of Hazardous waste.)
__. Yes No
a. If yes, list wastes and quantities on attachment. (Include EPA
Hazardous Waste No.) (Provide waste name and description)
b. Does generator determine characteristics by testing or by
applying knowledge of processes?
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 .
equivalent methods used.
Are there any other solid wastes deemed non-hazardous generated
by generators? i.e.(process waste streams, collected matter from
air pollution control equipment, water treatment sludge, etc.)
Yes No
a. If yes, did generator determine non-hazardous characteristics
by testing or knowledge of process?
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
equivalent methods used.
b. List wastes and quantities deemed non-hazardous or processes
from which non-hazardous wastes were produced. (Use narrative
explanations sheet.)
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-2-
6-8
Section C - Manifest
1. Does generator ship hazardous waste off-site?
(Subpart B - The Manifest) Yes No
a. If no, do not fill out Section-C and D.
b. If. yes, identify primary off-site facility(s)! Use
narrative explanations sheet.)
2. Has generator shipped hazardous waste off-site since
November 19, 1980? Yes No
3. Is generator exempted from regulation because of:
Small quantity generator (261.5 - Special requirements)
i Yes Mo
OR
Produces non-hazardous waste at this time Yes No
(261.4 - Exclusions)
4. If not exempted does generator use manifest?
(262.20 - General requirements) Yes No
a. If yes, does manifest include the following
information (262.21 - Required information)
(Break up items or circle ones not on manifest)
1. Manifest Document No. " Yes No
2. Generators Name, Mailing Address, Tele. No. Yes . No
3. Generator EPA I.D. No. Yes No
4. Transporter(s) Name and EPA I.D. No. Yes No
5. a. Facility Name, Address and EPA
I.D. No. Yes No
6. DOT description of the waste . Yes No.
7. a. Quantity (weight or volume) Yes No
b. Containers (type and number) Yes No
8. Emergency Information (optional)
(special handling instructions, Phone No.) Yes _No
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3
9. Is the following certification on each
manifest form? Yes No
This is to certify that the above named
materials are properly classified, described,
packaged, marked and labeled and are in pro-
per condition for transportation according to
the applicable regulations of the Department
of Transportation and the EPA.
5. Does generator retain copies of manifests? Yes No
(Check completed manifests at random. Indicate how many
manifests were inspected, how many violations were noted
and the type of violation.)
<,
If yes, complete a through e. If questions contain more than one
item, circle those not in compliance. (263.23 Use of the Manifest)
a. (1) Did generator sign and date all manifests
inspected? Yes No
(2) Who signed for generator? Name Title
b. (1) Did generator obtain handwritten signature and
date of acceptance from initial transporter? Yes No
(2) Who signed and dated for transporter? Name Title
c. Does generator retain one copy of manifest signed by
generator and transporter? Yes No
d. Do returned copies of manifest include facility
owner/operator signature and date of acceptance? Yes Mo
e. If copy of manifest from facility was not returned within
45 days, did generator file an exception report?
(262.42 - Exception reporting) Yes No
(1) If yes, did it contain the following information
Legible copy of manifest Yes No
AND
Cover letter explaining generators efforts to - -
locate waste. Yes No
f. Does (will) generator retain copies for 3 years? Yes No
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4
6-10
Section D - Pre-Transport Requirements
1. Does generator package waste? Yes No
If no, skip the rest of Section D.
If yes, complete the following questions.
2. Does generator package waste in accordance with 49 CFR 173
178, and 179? (DOT requirements) (262.30 - Packaging) Yes ' No
3. Inspect containers to be shipped.
a. Are containers to be shipped leaking or corroding
or bulging? Yes No
b. Use narrative explanations sheet to describe containers
and condition.
c. Is there evidence of heat generation from incom-
patible wastes in the containers? Yes No
4. Does the generator use DOT labeling requirements in
accordance with 49 CFR 172? (252.31 - Labeling) • Yes No
5. Does the generator mark each package in accordance
with 49 CFR 172? (262.32 - Marking) . Yes No
6. Is each container of 110 gallons or less marked with
the following label? (262.32 - Marking) Yes No
Label saying: HAZARDOUS WASTE - Federal Law
Prohibits Improper Disposal. If found, con-
tact the nearest police or public safety au-
thority or the U.S. Environmental Protection
Agency.
Generator's Name and Address
Manifest Document Number
7. If there are any vehicles present on site loading or unloading hazardous
waste, inspect for presence of placards. Note this instance on narrative
explanation sheet.
8. Accumulation Time (262.34 - Accumulation Time)
a. Is facility a permitted storage facility? . Yes No
If yes, skip to question £9.
If no, answer rest of question £8.
b. Is hazardous waste shipped offsite within 90 days? Yes No
c. . Are containers used to store waste? Yes No
(1) Is the beginning date of accumulation time
clearly indicated? Yes No
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5
c. (1) Does generator inspect containers for G-ll
leakage or corrosion? (265.174 - Inspections) Yes No
(2) If yes, with what frequency?
d. (1) Does generator handle ignitable or reactive
waste? Yes No
(2) If yes, does generator locate containers
holding ignitable or reactive waste at least
15 meters (50 feet) inside facility's property
line? (265.175 - Special Requirements for
Ignitable or Reactive Wastes) Yes No
NOTE: If generator accumulates waste on-site for less than
90 days:, fill out Facilities Checklist Section A-£9
Personnel Training; Section B - Preparedness and Pre-
vention; and Section C - Contingency Plan and Emer-
gency Procedures. >
9. Describe storage area. Use photos and narrative explanation sheet.
Section E - Recordkeeplng and Records
1. Is generator keeping the following reports? (262.40 -
Recordkeeping) (Note: The following must be kept for a
minimum of three (3) years.)
a. Manifests and signed copies from designated
facilities? " Yes No
b. Annual reports (Not applicable until March 1982]
Yes No
c. Exception Reports Yes No
d. Test results where applicable. Yes No
2. Where are records kept (at facility or elsewhere)?
3. Who is in charge of keeping the records? Name Title
Section F - Special Condition
1. Has generator received from or transported to a
• foreign source any hazardous waste? (262.50 -
International Shipments) Yes No
If yes, . -
a. Has he filed a notice with the R.A.? Yes No
b. Is this waste manifested and signed
by Foreign Consignee? Yes No
c. If generator transported wastes out of the
country has he received confirmation of
delivered shipment? Yes No
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G-12
RCRA Compliance Inspection Report
Transporter(s) and Vehicle Checklist
A. General Transporter Information
1. Does transporter have EPA Identification Number? Yes No
a. If yes, EPA No.
2. Does more than one location use this identification number? Yes ^ No
a. If yes, how many?
3. Identify the mode(s) of transportation used by transporter.
Air Rail Highway Water other (Specify)
Specification: Yes NQ
4. Does transporter have all necessary permits? Yes No
a. If yes, identify state permit number
identify federal permit number
5. Does transporter ship hazardous waste out of the U.S.? Yes No
a. If yes, (see C.4)
6. Does transporter ship hazardous waste into the U.S.? Yes No
7. Does transporter mix hazardous wastes of different D.O.T.
shipping descriptions by placing them into a single container?
Yes No
a. 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 off-site within 10 days or less? Yes No
a. If not, complete "RCRA Facility Checklist."
C. Manifest & Recordkeeping Requirements
1. Are all shipments of hazardous wastes accompanied by an
approved manifest? Yes No
2. Does all the following information appear on the manifest(s)? Yes No
v
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G-13
a. Manifest document number
b. Generator's name
c. Generator EPA ID number
d. Generator's address
e. Generator's telephone number
f. Generator's signature
g. Date of receipt for shipment
H. Transporter's Name
i. EPA ID number of transporter
j. Transporter's signature
k. Secondary transporter information (if applicable)
1. Disposal Facility Name
m. Disposal Facility EPA i.d. number
n. Disposal facility address
o. Alternate facility information (if any)
p. Date of receipt by disposal facility
q. Disposal facility signature .
r. D.O.T. description of waste(s')
s. Total quantity of each hazardous waste by units of weight
or volume, and the type, number of containers as loaded
into or onto vehicle, (list in narrative)
t. Does the certification appear on the manifest?
"This is to certify that the above named materials
are properly classified, described, packaged, marked,
and labeled and are in proper condition for transportation
according to the applicable regulations of the Department
of Transportation and the EPA."
3. Identify number of manifests inspected and give narrative explanation
of deficiencies.
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 copies of shipping papers for three years Yes No
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G-14
b. If transportation occurs by rail, does the transporter:
1. sign, 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
4. retain one copy of manifest and rail shipping
papers Yes No
5. assure 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 keep copies of manifests and shipping
papers for the required three year period? Yes No
D. Manifest Compliance
t
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?
(Narrative explanation.)
E. Pretransport review
1. Does the transporter check to assure that the generator
has complied with the following requirements:
a. Has the generator packaged wastes in accordance with
D.O.T. requirements? Yes No
b. Has the generator packaged wastes in repacks? Yes No
c. Has the generator labeled wastes in accordance with
D.O.T. requirements _. Yes No
d. Has the generator marked wastes in accordance with
D.O.T. requirements? Yes No
e. Has generator marked each container of 110 gallons or
less used in such transportation with the following
words and information displayed in accordance with
the requirements of 49 CFR 172.304: Yes No
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G-15
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal.
If found, contact the nearest police or public safety
authority or the U.S. Environmental Protection Agency.
Generator's Name & Address
Manifest Document Number
f. Did generator placard or offer the initial transporter
the appropriate placards according to D.O.T. (49 CFR 172. Yes No
Subpart F)?
F. Emergency Action
1. Has transporter ever been involved in a discharge 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 the U.S. D.O.T.
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 clean-up 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); amt. (i.e., 30 drums)
portable tanks-number volume(ea)
gondola
tanker-type ; volume
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G-16
5. Narrative explanation of condition of containerization, (leak-
ing, corroded, fuming, damaged, improperly sealed, poor condition,
improper lining, etc.)
6. Is truck properly placarded and marked? Yes No
7. Complete portions on A, B, and C Parts as apply. Yes No
8. Did generator have to repackage wastes by truck
driver's request? Yes No
9. Is truck driver aware of*any special handling of
•materials? Yes No
10. Does truck driver has accessible the National
Response Center Phone number? Yes No
COMMENTS:
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Revised 7/32
RCRA COMPLIANCE INSPECTION REPORT G-17
TSD FACILITIES CHECKLIST
Section A - General Facility Standards
1. Does facility have EPA Identification No.? (265.11 - Identi-
fication Number) Yes No
A. If yes, EPA I.D. No. . .-
If no, explain •
2. Has facility received hazardous waste from a foreign
source? (265.12 - Required notices) Yes No
A. If yes, has he filed a notice with the Reg. Admin. Yes No
Haste Analysis
3. Does the facility have a written waste analysis plan?
(255.13 - General Waste Analysis) Yes No
A. If yes, is a copy maintained at the facility? Yes No
3. If no, question £4 not applicable.
4. If yes, does it include:
A. Parameters for which each waste will be analyzed? Yes No
B. Test methods used to test for these parameters? Yes No
C. Sampling method used to obtain sample? Yes No
D. 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
E. (For off-site facilities) Waste analyses that gener-
ators have agreed to supply? Yes No
F. (For off-site 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
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G-18
-2-
5. Does the facility provide adequate security to minimize
the possibility for the unauthorized entry of persons or
livestock onto the active portions of the facility?
(265.14 - Security) __ Yes _ Mo
If no, describe inadequacies. (Use narrative explanations sheet.)
If yes, is security provided through:
A. 24-hour surveillance system? (e.g. television moni-
toring or guards) . _ Yes _ No
3. 1. Artificial or natural barrier around facility
(e.g. fence or fence and \;1 iff)? _ 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 typa of security.
Include a drawing indicating any inadequacies in the facility's
security system. .
6. Is a sign with the legend, "Danger-Unauthorized Personnel Keep Out,"
posted at the entrance to the active portion of the facility?
(265.14 - Security) _ Yes _ No
Is it written in English and legible from at least 25 feet? _ Yes _ No
(NOTE: The sign must be written in any other language predominant in the
area surrounding the facility (e.g. In New Mexico and Texas areas bordering
Mexico, the sign must be in Spanish).
If an existing sign 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: (265.25 - General Inspection Requirements)
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G-19
-3-
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
V '"
b. Operator error Yes No
c. Discharges (e.g. leaks from valves or pipes
joint breaks, etc.) Yes No
3. Is a written scheaule for these inspections iTiaintained at
the facility? Yes No
1. Are these inspections conducted? Yes No
a. Is a record of these inspections maintained
in the inspection log? Yes No
8. Does the owner/operator have an inspection log?
(255.15 - General Inspection Requirements) Yes Mo
A. If yes, does it include:
1. Date and time of inspection? . Yes No
2. Name of inspector? Yes No
3. Notation of observations? Yes No
4. Date and nature of repairs.or remedial action? Yes No
S. Are there any malfunctions or other deficiencies noted in
the inspection log that remain unconnected? (Use narri-
tive explanation sheet). Yes No
C. Are records of the inspection log maintained at the
facility for three (3) years? Yes No
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-4- ...
G-20 ., . '
Personnel Training
9. Does the owner/operator maintain a personnel training program?
(265.15 - Personnel Training) Yes No
A. If yes,
1. Is the program directed by a person trained in hazardous
waste management 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
B. Does the owner/operator keep the following records:
1. job title and written job description of each
position? ._ Yes No
V
2. description of the type and amount of introductory
and continuing training? Yes Mo
3. documentation that training has been given to
employees? Yes No
C. Are these records maintained at the facility? Yes No
Requirements for Ignitable, Reactive or Incompatible Haste
10. Does facility handle ignitable or reactive wastes?
(265.17 - Ignitable, Reactive, Incompatible Wastes) Yes No
(Circle appropriate type(s) of waste(s).
A. If yes, is waste separated and confined from
sources of ignition or reaction, (open flames,
smoking, cutting and welding, hot surfaces,
fractional heat) sparks (static, electrical or
mechanical), spontaneous ignition (e.g. from
heat producing chemical reactions) and radiant
heat?
Yes ___. No
B. Are smoking and open flame confined to specifically
designated locations? Yes No
C. Are "No Smoking" signs posted in hazardous areas where
ignitable or reactive wastes are handled? Yes No
11. Check containers (265.17 - Ignitable, Reactive, Incom-
patible Wastes)
A. Are containers leaking or corroding or bulging? Yes No
(Use narrative explanation sheet to explain
containers in this condition.)
v
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
qeneration, bulqina containers, etc.)
-------
•°- G-21
Section B - Preparedness and Prevention
1. Is there evidence of fire, explosion or contamination of
tne environment? (265.31 - Maintenance and operation of
facility) Yes No
If yes, use narrative explanations sheet to explain.
2. Is the facility equipped with (265.32 - Required equipment)
A. Internal communications or alarm system? Yes No
.1. Is it easily accessible in case of emergency? Yes No
8. Telephone or two-way radio to call emergency
response personnel? Yes No
V
C. Portable fire extinguishers, fire control equip-
ment spill control equipment and decontamination
D.
equipment?
1. Is this equipment tested to assure its
proper operation?
Water of adequate volume for hoses, sprinklers or
water spray system?
1. Describe source of water
Yes
Yes
Yes
No
No
No
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? (e.g. adequate
aisle space in between barrels to check for leakage,
corrosion and proper labeling, etc.) (265.35 - Required
aisle space)
Yes No
4. Has the owner/operator made arrangements with the local
authorities to familiarize them with characteristics of
the facility? (layout of facility, properties of hazard-
ous waste handled and associated hazards, places where
facility personnel would normally be working, entrances
to roads inside facility, possible evacuation routes.)
(265.37 - Arrangements with local authorities) Yes No
If no, has the owner/operator attempted to make such
arrangements? Yes No
-------
-6-
G-22
5. In the case that more than one police or fire
department might respond, is there a designated
primary authority? (255.37 - Arrangements with local
authorities) Yes No
If yes, indicate primary authority .
A. Is the fire department a city or volunteer
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 Mo
Are they readily available to the emergency coordinator?
Yes '_ No
(265.37 - Arrangements with local authorities)
v>
7. Has the owner/operator arranged to familiarize local
hospitals with the properties of hazardous waste
handled and types 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? Yes No
(265.37 - Arrangements with local authorities)
8. If the State, or local authorities decline to enter into
the above referenced agreements, has this situation been
entered in the operating record? (265.37 - Arrangements
with local authorities) Yes No
Section C - Contingency Plan and Emergency Procedures
1. Does the facility have a contingency plan?
(265.52 Content of Contingency Plan) 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 per-
sons qualified to act as emergency coordinator? • Yes No
4. list of all emergency equipment at the facility? Yes No
5. evacuation plan for facility personnel? Yes No
2. Is a copy of the contingency plan maintained at the facility?
(265.53 - copies of contingency plan) Yes No
3. Has a copy been supplied local police and fire depts.?
(265.53 - Copies of contingency plan) Yes No
-------
4. Is tha plan a revKco-SPCC Plan? (265.52 - content*-or-
ccntingency plan) '- Yes No
5. Is there an emergency coordinator on-site or within short
driving distance of the plant at all timee? Yes No
If yes, list primary emergency coordinator:
Section D - Manifest System, Recordkeeping and Reporting
1. Has facility received hazardous waste from off-site
since November 19, 1980? (265.71 - Use of manifest system) ___ Yes No
a. If no, questions 1, 2 and 3 not applicable.
b. If yes, does the facility retain copies of all
manifests? Yes No
1. Are the manifests signed and dated and
returned to the generatpr? Yes No
2. Is a signed copy given to the transporter? Yes No
2. Has the facility received any hazardous waste from a
rail or water (bulk shipment) transporter since Nov. 19,
1980? (265.71 - Use of manifest system) Yes No
a. If yes, is it accompanied by a shipping paper Yes ' No
1. Does the owner/operator sign and date the
shipping paper and return a copy to the
generator? Yes Mo
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 - Manifest discrepancies) Yes No
a. If yes, has he resolved the discrepancy
with the generator and transporter? Yes No
1. 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 - Unrnanifested waste report) Yes No
a. If yes, has he submitted an unmanifested waste report
to the Regional Administrator? Yes No
5. Does the facility have a written operating record?
(265.73 - Operating record) Yes No
a. Is a copy maintained, at the facility? Yes No
-------
G-24
-8-
5. 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 wasteof
at each location? . . ' Yes No
a. Is this information cross-referenced with
specific manifest document numbers, if
applicable? Yes No
3. (for disposal facilities only) Is the loca-
tion and quantity of each hazardous waste
recorded on a map or diagram of each cell or
disposal area? Yes No
4. Record and results of waste analyses? Yes No
5. Reports of incidents involving implementation
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 disposal facili-
ties, post-closure cost estimates?
Yes Mo
Section E - Plans and Reports
1. Have all plans and reports been visually inspected and
/or been made available for inspection? (265.74 - Availa-
bility, retention and disposition of records) 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
a. If yes, please indicate which are hazardous waste
facilities on the drawing.
Is-
-------
G-25
3. Indicate types of hazardous waste facilities.
Containers
Tanks
Surface Impoundments
Waste Piles
Land Treatment
Landfill
Incinerator
Thermal Treatment
Chemical, Physical and Biological Treatment
Groundwater Monitoring Program
-------
Revised 8/2/82
G OS TANKS CHECKLIST
(Subpart J - Tanks, 265.190) !
NOTE: If multiple tanks exist, list each tank and specify compliance or non-
compliance. Complete an individual checklist for each tank not in com-
pliance and a collective checklist for those in compliance.
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 resi-
due been removed from these tanks, discharge control equip-
ment, 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, check tanks.
• v.
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 narra-
tive explanations sheet.)
4. Are there any uncovered tanks? . Yes No
a. If no, do not complete 4b.-e.
b. If yes, do they have 2 feet (60cm) freeboard? Yes No
or
c. A containment structure? (e.g. dike or trench) or Yes No
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.
If the answers to 4b.-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 inflow (e.g. waste
feed cutoff or by-pass to a stand-by tank)? Yes No
-------
2
P-?7
Haste 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 explanations sheet).
1. Are waste analyses and trail tests conducted on these ::
wastes Yes No
_OR
Does the owner/operator have written documented infor-
mation on similar treatment of similar wastes under
similar operating conditions? Yes No
2. Is this information retained in the operating record? . Yes No
• *
Inspections (Note: This section does not exclude underground tanks)
7. Does the owner/operator inspect the following at least daily,
where present? Yes No
(Indicate which items are present in 7 and 8.)
a. Discharge control'equipment (e.g. waste feed cut-off, by pass
and/or drainage systems)? Yes No
b. 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? Yes No
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
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
-------
G-28 -, 3
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 ignition or
reaction? Yes No
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.)
13. If a waste is to be placed in a tank that previously held an in-
compatible 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.)
-------
Revised 8/2/82
G-29
SURFACE IMPOUNDMENTS CHECKLIST
Subpart K - Surface Impoundments 255.220
NOTE: Check all surface impoundments. Fill out one checklist for any
impoundment in violation. Fill out one checklist for all other
impoundments in compliance. Indicate number of surface impound-
ments at the facility.
1. 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
i
3. Does the impoundment appear to maintain at least 2 feet
(60 cm) of freeboard? Yes No
a. If no, what was the freeboard? _^
4. Is there evidence of overtopping of the dike? Yes No
If yes, please describe.
5. Does the impoundment have a containment system? Yes No
a. Does the earthen dike have adequate protective cover
(e.g. grass, shale, rock) to minimize wind and water
erosion? (Use narrative explanation sheet to explain Yes No
deficiencies.)
b. Provide description of containment.
6. What wastes are treated or stored in the impoundment? (Use narrative
explanations sheet).
7. Are hazardous wastes chemically treated in the impoundment? Yes No
a. If yes, are
1. Waste analyses and trial tests conducted on
these wastes or Yes No
2. Does the owner/operator have written documented
information on similar treatment of similar
wastes under similar operating conditions? Yes No
b. Is this information retained in the operating record? Yes No
-------
G-30
8. Is the impoundment inspected daily to check freeboard level? Yes No
9. Is the impoundment, dike and vegetation surrounding the
dike inspected to detect leaks, deterioration or failures
ai least once a week? (255.225 - Inspections) Yes No
10. Does the facility maintain a record of the closure plan
on site? Yes No
11. Are ignitable or reactive wastes placed in the impoundment? Yes No
a. If no, do not complete b and c.
b. If yes, are they treated, rendered or mixed before
or immediately after placement in the impoundment
so it no longer meets the definition of ignitable
or reactive? V Yes No
OR
c. Is the impoundment used solely for emergencies? Yes No
1. If yes, has further treatment, storage or disposal
been conducted on these wastes? Describe this situa-
tion.
12. 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.)
13. What is the impoundment lined with? .
-------
6-31
WASTE PILES CHECKLIST
(Subpart L - Waste Piles, 265.250)
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 run-off from the pile considered a hazard-
ous waste? ^
a. If yes, is the pile managed with the following?
1. An impermeable base compatible with the waste? _ Yes _ No
2. Run-on diversion? _ Yes _ No
3. Leachate and run-off collection? Yes No
b. Is the pile protected from precipitation and run-on by
some other means? _ Yes _ No
OR "
c. Are liquids or wastes containing free liquids placed in
the pile? . _ Yes _ No
4. 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
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.
-------
G-32
5. Is there evidence of fire, explosion, gaseous emissions, leaching
or other discharge from the hazardous waste pile? (use narrative
explanation sheet). Yes Mo
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 in-
spection of the devices for controlling precipitation and
run-on and run-off? Yes Noi
c. Is the waste pile periodically-removed for inspection of
the base? Yes No
5. Have incompatible wastes ever bee.n placed together in the waste
pile? * Yes No
If yes, what was the result?
7. 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 in-
compatible wastes or materials were previously piled? Yes No
b. If yes, was the area decontaminated? (Use narrative explana-
tion sheet.)
-------
G-33
Revised 8/82
LAND TREATMENT CHECKLIST
(Subpart M - Land Treatment 265.270)
1. Is run-on diverted away from the land treatment facility? Yes No
2. Is run-off from the land treatment facility collected? Yes No
3. Is the run-off analyzed to see if it is a hazardous waste? Yes No
a. If the run-off is considered hazardous, how is it
handled? {Use narrative explanation sheet.)
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. What hazardous wastes are treated at the land treatment
facility? (Use narrative explanation sheet).
Subpart D Listed Wastes Characteristic Wastes
A. For those listed wastes, were analyses done to deter-
mine 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 toxic because of
the extraction procedure, what are the concentrations of the
following?
Concentration Waste
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4 D
2,4,5-TP Silvex
-------
G-34 5. Obtain a copy of the land treatment process and include
it with the report.
6. Are food chain crops grown? Yes No
a. 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? Yes No
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? Yes No
b. Is the following information used for making this above demonstration
and is it kept at the facility?
1. Tests for the specific wastes and application
rates being used at the facility? Yes No
2. Crop characteristics? Yes No
3. Soil characteristics? Yes No
4. Sample selection criteria? Yes No
5. Sample size determination? Yes No
6. Analytical methods used? Yes No
7. Statistical procedures? Yes No
8. Was the Regional Administrator notified bv January 19, 1981,
that food chain crops had been or would be grown at the
facility? Yes No
9. Does the facility treat wastes that contain cadmium? Yes No
a. If no, go to question 10.
b. If yes, list these wastes. (Use narrative explanation
sheet).
c. Was the pH of the soil and waste mixture 6.5 or greater
at the time of each waste application? ___ Yes No
1. If the pH was less than 6.5, did the waste con-
tain cadmium concentrations of 2mg/kg or less? Yes No
-------
G-35
d. Is the annual application rate of cadmium less than 0.5
kg/ha (hilograms per hectare) for the following:
tobacco, leafy vegetables, or root crops grown for
human consumption? Yes No
1. For all other food chain crops, is the annual
cadmium application rate less than 2.0 kg/ha
(Until 6/30/84?) - Yes No
10. Is an unsaturated zone monitoring plan kept at the
faci 1 ity? Yes No
11. Does the plan include:
a. Soil monitoring Yes No
b. Soil pore water monitoring (water above the saturated
zone) v Yes No
c. Sample depths below wastev incorporation Yes No
d. Number of samples to be taken Yes No
e. Frequency and time of sampling Yes No
f. Analysis of samples Yes No
12. Is the following information (for each hazardous waste)
kept at the facility? Yes No
a. Application dates Yes No
b. Application rates Yes No
c. Quantities . Yes No
d. Waste location Yes No
13. Does the facility have a closure/post-closure plan? ' Yes No
a. If yes, where is it kept?
14. 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.
15. Are incompatible wastes placed in the facility? Yes No
a. Are the incompatible waste placed in different loca-
tions in the facility? Yes No
1. If no, look for signs of fire, heat generation,
toxic mists, etc. (Use narrative explanation sheet).
-------
8/82
LANDFILLS CHECKLIST
(Subpart N - Landfills, 255.300)
1. Is run-on diverted from the landfill?
Yes No
2. Is run-off from the landfill collected?
Yes No
a. Is the waste from the collected run-off analyzed to
determine if it is a hazardous waste? Yes No
1. If it is a hazardous waste, how is it managed?
(Use narrative explanations sheet)
2. Is the collected run-of.f discharged through a
point source to surface-waters? Yes No
a. If yes, list NPDES Permit Number
3. Is the landfill managed so that wind dispersal is con-
trolled? (Note blowing debris) Yes No
4. Is the following information maintained in the operating
record?
a. On a map, the exact.location and dimensions, including
depth of each cell with respect to permanently surveyed
benchmarks? • Yes No
AND
b. Contents of each cell and the approximate location of each
hazardous waste type within each cell? Yes No
5. Are reactive or ignitable wastes placed in the landfill? Yes No
a. If yes, is it treated, rendered or mixed before or
immediately after placement in the landfill so it is
no longer reactive or ignitable? Yes No
b. Describe treatment, etc., or attach a copy of treatment.
6. Are incompatible wastes placed in the same landfill cell? 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.)
Describe how it is possible for incompatible wastes to be placed
in the same landfill cell. (Use narrative explanation sheet.)
-------
-2-
7. Are bulk or non-containerized liquid wastes or wastes containing
free liquids placed in the landfill? g_37
Yes No
a. If yes, does the landfill have
1. A liner which is chemically and physically resis-
tant to the added liquid? Yes No
2. A functioning leachate collection and adequate
removal system? Yes No
OR
b. Is the liquid waste treated chemically or physically
so that free liquids are no longer present? Yes No
8. Are containers holding liquid wastes placed in the landfill? . Yes No
V
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
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
9. Are empty containers placed in the landfill? Yes No
a. If yes, are they reduced in volume (e.g. shredded,
crushed)? Yes No
10. Is there evidence of site instability? (e.g., erosion,
settling)? (Use narrative explanations sheet) Yes No
11. Is there evidence of ponding of water on-site?
(Use Narrative explanation sheet.) Yes No
12. Is there any indication of improper or inadequate
drainage? (Use narrative explanations sheet.) Yes No
13. Does the facility have closure and 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
-------
Kevisea
[INCINERATORS CHECKLIST
B (Subpart 0: 265.340 - 265.369)
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 pre-
viously 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
o
Concentration of mercury Yes No
f. Is the above information documented in the
operating record? ' Yes No
(NOTE: d and e not required, if facility has written documented data that
show the elements are not present.)
4. Does the owner/operator monitor the following when incinerating hazard-
ous waste? Are any of the following instruments existing on the in-
cinerator. Check under applicable column.
a. Does the owner/operator monitor the following at least every
15 minutes? .
Existing Monitored
1. Waste feed Yes No Yes No
2. Auxiliary fuel feed Yes No Yes No
3. Air flow Yes No Yes No
4. Incinerator temperature Yes No Yes No
5. Scrubber flow Yes No Yes ~^_ No
6. Scrubber pH Yes No Yes No
7. Relevant level controls Yes No Yes No
(e.g. after burner and temperature, Op, and CO meters are examples
of relevant level controls.)
b. Does the owner/operator monitor the Stack plume (emissions) at least
hourly for:
1. Color (normal) Yes No
2.. Opacity Yes No
-------
_2- G-39
c. 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 emissions (Use narrative explanation
sheet.) . Yes No
2. Emergency shutdown controls Yes No
3. System alarms Yes No
d. Are these inspections referenced in the inspection log?
Review inspection plan, note deficiencies in narrative. Yes No
5. Is a closure plan maintained for the incinerator? Yes No
If yes, is it kept at the facility? • Yes No
6. What wastes are incinerated on site?
EPA Hazardous Description Weight or volume
Waste No. Incinerated daily
-------
.Revised-8/82
G-40 THERMAL TREATMENT CHECKLIST
(Subpart P - 255.370-265.399)
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:
k,"
1. Heating value • Yes No
2. Halogen content Yes No
3. Sulfur content Yes No
4. Concentration of lead Yes Mo
5. Concentration of mercury Yes No
b. Is this information documented in the operating record? Yes No
NOTE: 4 and 5 not required if 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
b. Auxiliary fuel feed Yes No
c. Treatment process temperature Yes No
d. Relevant process flow Yes No
e. Relevant controls (e.g., after-
burner, and temperature con-
trols, Op & CO meters) Yes No
4. Are stack plume (emissions) monitored at least hourly:
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)
a. Pumps, valves, conveyors, pipes, etc. (for leaks,
spills and fugitive emissions?) ^ Yes No
-------
_2- G-41
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 explosives Minimum distance from open burning
or propellants or detonation to the property of others.
0-100 .. 204m(670 ft)
101-1,000 380m(l,250 ft)
1,001-10,000 530m(l,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 decribe details).
-------
Revised 8/22/82
CHECKLIST
.42 (Subpart Q - Chemical, Physical and Biological Treatment, 265.400)
NOTE: Applies to treatment in other than tanks, surface impoundments, and
land treatment facilities.
1. Describe treatment process (Include information on wastes treated.)
2. Check 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 cut-off system or by-pass?) Yes \ No
4. If a 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 facility is to be used to chemically
treat hazardous wastes, are the following obtained?
a. Waste analyses and trial treatment tests
(e.g. bench scale)? Yes No
OR
b. Written documented information on similar
treatment of similar wastes? Yes No
5. Does the owner/operator inspect the following, where present? Yes No
(Indicate which items are present).
a. At least daily.
1. Discharge control and safety equipment (e.g. waste
feed cut-off, by-pass, drainage or pressure relief
systems)? • ' Yes No
2. Data gathered from monitoring equipment (e.g.
pressure and temperature gauges)? Yes No
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
v ^B*^™** ^™^^«^«
7. Where- is the plan maintained?
-------
- -2-
G-43
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 re-
active? Yes No
(Describe or attach a copy of the treatment.)
9. Has the facility treated in compatible 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 tljat 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 narra-
tive explanations sheet.)
-------
Revised 3/22/82 G'14 , "
G-44 CONTAINERS STORAGE CHECKLIST
(Subpart I - Use and Management of Containers 265.170)
1. Does the facility store hazardous waste in
containers? Yes No
If no, do not complete this form.
2. Are the containers in good condition?
(check for leaks, corrosion, bulges, etc.) Yes No
If no, explain in narrative and document with photograph.
3. If a container is found to be leaking, does the
operator transfer the hazardous waste from the
leaking container? Yes No
4. Is the waste compatible with the containers and/or
its liner? Yes No
If no, explain in narrative.
5. Are the stored containers closed? Yes No
If no, explain in narrative.
6. Are containers holding hazardous waste opened,
handled or stored in such a manner as to cause
the container to rupture or leak? Yes No
If yes, explain in narrative.
f
7. Are each of the containers inspected at least
weekly? - Yes No
If no, explain in the narrative the frequency of inspection.
8. 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.
9. Are incompatible wastes stored in the same containers? Yes No
If yes, explain in narrative.
10. Are containers holding incompatible wastes kept apart
by physical barrier or sufficient distance? Yes No
If no, explain in narrative.
-------
Table Q-15
GROUNDU'ATER MONITORING CHECKLIST ' G~45
The owner or operator of a surface impoundment, landfill, or land treatment
facility which is used to management hazardous waste must implement a ground-
water monitoring program. (Part 265, Subpart F)
1. Specify the site(s) for which a ground water monitoring system (has) or
(should have) been installed:
2. What date was the monitoring program initiated (date of first sampling)?
3. Indicate by a map or sketch locations of each monitoring well and distance
from active site(s) (attach).^, Also list depths, diameter and completion
data on each well (or include well drilling and completion report). Indi-
cate whether the wells are hydraulically upgradient or downgradient and
the direction of flow of the groundwater.
4. If no ground water monitoring system has been installed, include a copy of
Low Potential Ground Water Demonstration used to document a low potential
for migration of hazardous waste or constituents. Also describe briefly
what basis was used to justify the waiver of monitoring requirements:
5. If a ground water monitoring system has been installed, attach a copy of
the ground water sampling and analysis plan. Briefly describe sample
collection technique for obtaining samples and the method 'used to estab-.
lish elevation of ground water for ground water monitoring wells:\
6. Is a Ground Water Quality Assessment Plan maintained at the facility?
„ %
Yes NO N/A
7. Indicate the name and address of the facility conducting the analyses,
- What- quality assurances procedures are followed?
-------
G-46
TABLE G- 16
UNCONTROLLED HAZARDOUS WASTE DISPOSAL SITE CHECKLIST
I. ADMINISTRATIVE
1. Facility Name:
2. Facility FIPs No:
3. Address: (include county, state and zip code):
4. Location (Latitude, Longitude:' attach map if available)_
5. Owner or Responsible Official
Name
Business Address
Phone No. AC /
6. Owner of Realty
Name
Business Address
Phone No. AC • /
7. Facility Representative Interviewed
Name
Title
Phone No. AC_
8. Inspector
Name
Title/Division_
Phone No. AC
9, Inspection Participants (names, affiliations, phone nos..)
10. Date and Time of Inspection_
11. Weather Conditions
12. Credentials Shown: Yes ( ) No ( )
13. Entry Denied: Yes ( ) No ( ) By Whom.
Reason(s) for denial __
14. Photographs Allowed: Yes ( ) Mo ( )
Reason(s) for denying photographs
(From Enforcement Considerations For Evaluation of Uncontrolled Waste
Disposal Sites By Contractor, EPA, NEIC, Denver, Colorado, 1980)
-------
G-47
II. SITE INFORMATION
2.
Type of Operation
Generator:
a) On-site disposal ( )
b) Off-site disposal ( ):
Location
Storage: Describe_
Treatment/Disposal:
a) Incineration: ( )
b) Landfill: ( )
c) Landfarm: ( )
d) Biological Treatment: ( )
e) Chemical Treatment: ( )
f) Deep Well Injection: ( )
g) Surface Impoundment: ( )
h) Other: ( )
Percent of Waste
Site Active? Yes ( )
% Active
No ( ) Partially ( )
Authorization •
a) NPDES Permit No..
b) SPCC Plan
c)
d)
e)
State Permits
Air Permits
Other
Records Available
Yes ( ) No ( )
-------
G-48
5. Types of Wastes and Amounts at site (record the source of
information_)
6. Area of site (include dimensions)
7. Depth to groundwater (if known)
8. Distance to surface water from site, name, directions and use:
9. Access Controlled: Yes ( ) No ( ) How
10. "Buildings and uses
11. Geology of Area
a) Known Fault Zone ( )
b) Karst Zone ( )
c) 100-year Flood Plain ( )
d) Regulated Floodway ( )
e) Wetland ( )
f) Critical Habitat ( )
g) Recharge Zone ( )
-------
III. FIELD EVALUATION' FACTORS (REQUIRES NARRATIVE RESPONSE)
1. Evidence of Soil Contamination
2. Evidence of Spills
3. Evidence of Runoff
4. Potential of or Actual Air Emissions
5. Existing or Potential Erosion Problems
6. ' Ponding_
G-49
7. Evidence of Environmental Damage (vegetation, wildlife, fish,
etc.)
8. Evidence of charred areas, smoke, etc.
9. Potential for Groundwater Contamination
10. Adequate Maintenance and Operation of Runoff Collection and
Control Systems
-------
G-50
11. Sewers or drains and terminus of flow
12. Placarding of Trucks Comply with DOT Regs_
13. Contingency and Emergency Plan
14. Fire and Safety Plans
15. Evidence of Pumps, Hoses and other Equipment for Potential
Bypassing
16. Conditions which Required Immediate-.Notification of'Regional
Office for Action
17. Distance to Nearest Water Supply Well:
18. Proximity to Public Buildings and/or Residences
19. Remarks
-------
G-51
IV. STORAGE FACILITIES
1. Storage Area has Continuous Impervious Base: Yes ( ) No ( )
2. Storage Areas has a Confinement Structure: Yes ( ) No ( )
3. Evidence of Leakage or Overflow
4. Estimate of number of barrels/containers
5. Inventory of contents on barrels/containers
6. Number of Storage Tanks and Contents
7. Evidence of Leakage, Corrosion or Bulging of Barrels/Containers/
Storage Tanks
8. Storage Tanks Diked Adequately
9. Venting Method of Storage Tanks_
10. Storage of Incompatible Wastes
-------
G-52
11. Container Washina and Reuse Practices
12. Disposal Methods for Empty Storage Containers
13. Types and Amounts of Wastes Stored
-------
G-53
V. INCINERATORS
1.. Records of Waste Received Verified v/ith Trial Burn Records:
Yes ( ) No ( ). List Chemicals Incinerated
2. Monitoring Equipment Functioning Properly: Yes ( ) No ( )
3. Maintenance of Emission Control Equipment Adequate: Yes ( )
No ( )
4. Records of Maintenance Kept: Yes ( ) No ( ) '
5. Combustion Efficiency Monitored: Yes ( ) No ( ) Explain:
6. Temperature, Gas Flow Rate, Retention Time Calculations, Volume
of Combustion Zone Monitored: Yes ( ) No ( )
7. Waste Flow Rate Monitored: Yes ( ) No
8. Waste Feed Cut-Off Device Functioning Properly: Yes ( )
No ( )
9. Stack Test Conducted: Yes ( ) No ( ). Agency or Con-
tractor
EPA Method
Results
Compliance: Yes ( ) No ( )
10. Disposal Method of Scrubber Liquor
-------
G-54 '
11. Disposal Method of Fly Ash Quenching Wastewater_
12. Disposal Method of Fly Ash_
13. Scrubbing Media (e.g. water, caustic, lime)
14. Type of Scrubber (e.g. spray chamber, packed bed)
15. Mist Eliminator
16. Opacity of Stack During Inspection (Wet or Dry Stack)
17. Opacity Limitations, Regulating Agency
18. Stack Construction, Height, Diameter
19. Acceptable and Accessible Monitoring Ports, Platform, Safety
Rails
20. Electricity Available: Yes ( ) No ( ) 110V
220V
21. Type of Incinerator: Single Chamber ( ) Multiple Chamber
( ) Other
22. Auxilliary Fuel Type Rated Fuel Capacity_
Rated Waste Flow Rate
23. Type of Burner
24. Combustion Temperature Monitored: Yes ( ) No ( )
-------
G-35
25. Permit Limitations and Regulatory.Agency
26. Equipment Manufacture, Age and Appearance of Equipment
27. Other Emission Control Equipment Description
28. Remarks
-------
G-56
VI. LANDFILL DISPOSAL
1. Evidence of Site Instability (Erosion, Settling, Sink Holes,
etc.) '
2. Evidence of Improper Disposal of Ignitable, Reactive, or
Volatile Wastes • •
3. Evidence of Improper Disposal of Bulk Liquids,-Semi-Solids,
and Sludges
4. Records of Burial Cells, Contents and Survey Benchmark
5. Hastes Surrounded by Sorbent Material
6. Evidence of Ponding of Water
7. Runoff Diversion Structures Effectively Constructed and Main-
tained
8. Evidence of Improper and/or Inadequate Draining
9. Type of Leachate Collection System_
10. Leachate Monitored (Analyses)
11. Leachate Collection System Adequately Maintained
12. Gas Production in Landfill: Yes ( ) No ( )_
13. Method of Gas Venting
-------
G-57
14. Gas Monitored: Yes ( ) t!o ( ) Regulations and Regula-
tory Agency
15. Adequate Closure of Inactive Portion of Landfill: Yes ( )
No ( ) Describe '
16. Groundwater Monitoring Wells: Yes ( ) No ( )
17. Record of Groundv/ater Contamination
18. Depth to Groundwater Table and Flow Direction
19. Depth of Landfill
20. Containment Liners, Construction Methods
21. Pretreatment (Volume Reduction, Chemical Fixation, Blending,
Detoxification)
22. Waste Volumes
23. Earth Moving Equipment
24. Backcover Procedures
25. Co-disposal Practices
26. Odors
-------
5-58
27. Citizen Acceptance
23. Remarks
-------
G-59
VII. LAf.'DFARMING •
1. Area and Dimensions and Number of Cells for Disposal Site
2. Depth of Soil/17aste Material_
3. Underlying Contaminated Material and Thickness
4. Depth to Groundwater and Flow Direction
5. Leachate Collection
6. Waste Application Rate_
7. Type of Waste Applied_
8. Discing Frequency
9. Reuse Period
10. Contaminated Runoff Disposal/Treatment Method
11. Uncontaminated Runoff Disposal Method
12. Runoff Diversion Structures Effectively Constructed and
Maintained
13. Remarks
-------
G-60
VIII. SURFACE IMPOUNDMENTS
1. Stability and/or Condition of I.T.bankmant:
2. Evidence of Instability (Erosion, Settling, etc.)_
3. Evidence of Disposal of Ignitable or Reactive Wastes_'_';
4. Waste Compatible with Impoundment_
5. Records Checked for the Contents and Location of Each Impound-
ment
6. Estimated Freeboard
7. Integrity of Liner System_
8. Soil Type for Banks, Berms and Bottom
9. Monitoring Wells and Analysis of Groundv/ater
-------
fi
i-61
10. Death to Groundv.'ater and Flow Direction
11. Volatile Organ.ic Disposal
12. Amount or Volume of Wastes Discharged to Impoundment_
13. Size of Impoundment(s) (height, width, depth)
14. Evidence of Solids Deposition and/or Buildup
15. Evidence of Solid Material (Drums, etc.) in Impoundment
16. Impoundment Aerobic ( ) Anaerobic ( )
17. Spray System for Aeration or Accelerated Evaporation
18. Access Around Impoundments Controlled
19. Remarks
-------
G-62
IX. BIOLOGICAL TREATMENT
1. Types of Treatment: Activated Sludge ( ) Trickling Filter
( ) Lagoon ( ) Other
2. Types of Treatment Units Employed and Sizes (Attach Flow
Diagram) ^ •
3. Wastes Treated and Volumes
4. Design Capacity (Avg & Max) Flow_
5. Wasteload (BOD, Solids, etc.)_
6. Treatment Efficiency^
7. Operation Characteristics (F/M, MLVSS, % Recycle, etc.)_
8. Effluent Discharge Location_
9. NPDES Permit No. Issuina Agency_
Conditions
-------
G-53
10. HPDES Compliance ( ) Non-Compliance ( }
11. Discharge Monitoring Reports on File
12. Laboratory Conducting Self-Monitoring Analyses
13. Self-Monitoring Procedures Correct
14. Bypassing Evident
15. Remarks
-------
G-64
X. PHYSICAL-CHEMICAL TREATMENT
1. Types of Treatment (Describe)_
2. Types of Treatment Units Employed and Sizes (Attach Flov/
Diagram) ; ; ' •
3. Wastes Treated and Volumes'
4. Design Capacity (Avg and Max) Flow
5. Waste Loading Rate_
6. Treatment Efficiency
7. Operation Characteristics
8. Effluent Discharge Location
9. NPDES Permit No. Issuing Agency_
Conditions
-------
10. NPDES Compliance ( ) Hon-Compliance ( )_
11. Discharge Monitoring Reports on File
13. Self-Monitoring Procedures Correct
14. By-passing Evident_
15. Remarks
G-65
12. Laboratory Conducting Self-Monitoring Analysis
-------
APPENDIX H
TSCA AND PCB CHECKLISTS
Table H-l - NEIC Checklist for TSCA
Table H-2 - PCB Field Report Checklist
-------
TABLE H-l
H-l
NEIC CHECKLIST FOR TSCA
PREMANUFACTURE NOTIFICATION*
Coverage
Any new chemical substance that is proposed to be manufactured,
processed or imported and which is not on EPA's Inventory of existing
chemicals.
Requirements
Premanufacture notice of the subject chemical must be made to the
EPA at least 90 days prior to manufacture. The notice shall contain
name and complete chemical identity of chemical, proposed uses, esti-
mated production levels, number of individuals to be exposed and nature
of exposure, description of byproducts, methods of disposal, and testing
required under Sec. 4 of TSCA (none yet developed) and other data
showing that the subject chemical does not cause unreasonable risk of
injury to health or the environment. Any other data regarding environ-
mental and health effects shall also be given to the EPA.
The EPA in response may reject PMN for insufficient data, negotiate
for suitable data, prohibit manufacture or distribution until risk data
are available or pending development of a Sec. 6 rule, or may review the
product data for an additional 90 days. No review action by the EPA
allows the manufacturer to enter the subject chemical into the EPA
Inventory.
**
REPORTING AND RECORDKEEPING REQUIREMENTS
Requirements
* General Reporting Under Sec. 8(a)
Covers 2,300 listed chemicals
Report form seeks general data on production, exposure,
processing, use.
* Records of Significant Adverse Reactions Under Sec. 8(c)
Proposed rule requires that records be kept of significant
adverse reaction alleged from the chemical substance or
* TSCA, Sec. 5
** TSCA, Sec. 8, 40 CFR, Part 710, 1980
-------
H-2
mixture (i.e., long-lasting or irreversible damage to health or the
environment). This data shall be submitted to the EPA upon request and
be retained 5-30 years depending upon nature of data.
• Health and Safety Studies Under Sec. 8(d)
Proposed rule requires that distributors of certain
chemicals submit lists of studies known to them and
copies of studies in their possession. Studies include
individual files, medical records, daily monitoring
reports.
These chemicals have been designated under 40 CFR, Sec.
716.13.
• Notice of Substantial Risk Under Sec. 8(e)
Immediate notice by the manufacturer, processer or distri-
butor to the EPA is required when there is information
which supports the conclusion that the chemical presents
a substantial risk of injury to health or the environ-
ment.
Individual responsibility to report is minimized if the
Company establishes and implements procedures for employee
reporting and the corporate processing of substantial
risk information.
The report to the EPA shall summarize adverse effect,
describe nature and extent of risk, and identify source
of information and supporting data.
-------
PCS COMPLIANCE INSPECTION REPORT
(40 CFR Part 761)
SECTION A. FACILITY SUMMARY
S.
Name and address of facility (include county, state & zip code)
H-3
(Responsible Official)
(Title)
(Phone)
(Facility Representative
(Title)
(Phone)
Type of facility (utility, salvage yard, etc.)
SECTION B. INSPECTION/REVIEW
Inspected by: .
(Signature)
Reviewed by:
COMMENTS:
(Signature)
(Agency and Date)
(Agency and Date)
N/A (Not applicable)
C/A (Comments attached)
(1/81)
-------
H-4
SECTION C. INVENTORY
1. As of July 2, 1973, did facility contain in service, stored for future
use, or disposal:
a. 50 or more large high- or low-voltage
PCB capacitors?
b. One or more PCB transformers?
c. 45 Kgs (99.4 Ibs) or more PCB chemicals,
substances, or mixtures?
2. Disposition of PCB items at time of inspection:
Yes_No_N/A_C/A_
Yes_No_N/A_C/A_
Yes No N/A C/A
a. No. of PCB transformers
b. Kgs of PCBs in transformers
c. No. of low-voltage PCB capacitors
d. No. of high-voltage PCB capacitors
e. No. of PCB containers
f. Kgs of PCBs in containers
g. Contents of containers
Remaining
in Service
Removed
from Serivce
In Storage
for Disposal
In Storage for
Future Use
Sent to
Disposal
Properly
Marked
Identify source of the above information (company records, manufacturer's
labels, etc.)
* If any PCB items are not properly marked, describe deficiencies below.
Description must include information on amount of PCBs involved.
-------
H-5
,--j. 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. i) Were there observations of leaks or spills or any sign of
improper disposal of PCB substances or mixtures?
YES' NO N/A C/A
ii) If yes, document, sample and describe below. Description
must include information on amount of PCBs involved.
6. i) Was there any indication that waterways in the vicinity have
been contaminated by spills, leaks, or improper disposal?
YES NO N/A C/A
ii) If yes, document, sample and Describe below. Description
must include information on the amount of PCBs involved and the name
of the waterway.
7. i) Were samples collected for analysis of PCB residual
concentration?
YES NO N/A C/A
ii) If yes, describe below.
-------
• H-6 ' . ' '
SECTION D. STORAGE AND HANDLING
1. Location:
a. Does the facility have its own storage site for P
YES NO N/A C/A
b. If the storage site is not within the boundry of the
facility, give the site's name and address.
2. Physical requirements: Does storage site meet requirements?
(761.42(a))
Y E S N 0 N / A C / A
a. Provide protection from
rainfall? YES NO N/A C/A
b. Meet floor requirements
with six inch continuous
curbing? YES NO N/A C/A
c. Meet containment volume
requirements? YES NO N/A C/A
i) What is total containment volume of storage site?
(Length x Width x Height)
ii) What is the internal volume of the largest PCB article
or container stored within?
iii) What is the total internal volume of all PCB articles
and containers within the storage site?
Is item i_ greater than
two times item ii? YES NO N/A C/A_
or 25% of item iii? YES NO N/A C/A
-------
H-7
d. i) Is the area within the curbed area void of drains,
valves, expansion joints, or other openings?
* YES NO N/A C/A
ii) If no, document location of opening, drainage path, and
ultimate disposal location in log book 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 PCS items which are located within .storage areas
dated? (761. 42 (.c) (8) )
YES NO N/A C/A
b. Do PCS containers comply with DOT specifications except as
noted in 3c and 3d below? (76 1 .42 ( c) (J6) )
YES NO N/A C/A
c. Are any non-liquid PCBs being stored in containers larger than
those specified in DOT regulations? (761.42(c)(6))
YES NO N / A C/A
i) Do these containers provide as much protection and have
the same strength as DOT containers?
YES NO N/A C/A
-------
H-8
d. Are any liquid PCBs being stored in containers larger than
those specified in DOT regulations? (761. 42(c)(7))
YES NO N/A C/A
i) Do containers comply with OSHA specifications?
Y E S N 0 N / A C / A
ii) Is SPCC plan available pertaining to PCB storage?
(761.42(c)(7))
YES NO N/A C/A
e. Any container deficiencies noted in 3a_ thru d_ must be
documented with photographs and described below. Description
must include amount of PCBs involved.
4. Storage Site Operations:
a. Are all PCB items arranged so they can be located by date?
(761.42(c)(8))
YES NO N/A C/A
b. Do observations indicate good housekeeping 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 accidential breakage or damage?
Y E S N 0 N / A C / A
5. Other Storage Areas:
a. Are any of the following temporarily being stored outside the
prescribed area: (761-42(c)(1))
i) 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 S/A C/A ^_
Have they been there
fewer than 30 days? YES NO N/A C/A
-------
H-9
.ii) Leaking PCB articles and PCS 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
iii) Containers of non-liquid PCBs?
YE 5 NO N / A C / A
Is the date removed from service noted on the containers?
YES NO N/A C/A
Have they been there fewer than 30 days?
Y E S N 0 N / A C / A
iv) Containers of liquid PCBs at concentrations 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 .^0 N/A C/A
Have containers been there fewer than 3o days?
YES NO N/A C/A
b. Are there any- large high voltage capacitors or PCB contaminated
transformers next'to the storage site? (761. 42(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 defied.ncies in temporary s toraglt Jius t be document's^!
with photographs and described below. Description must include N.
information 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 disposal
or decontaminate movable equipment?
YES NO N/A C/A
2. Does the facility claim to have an exception?
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 surrounding
area and waterways?
YES NO N/A C/A
4. Do solvents to be used for removing PCBs contain less than
50 ppa PCBs? (761.43(a))
YES NO N/A C/A
5. Was a sample of the solvent which was used for PCB removal
ob tained?
YES NO N/A C/A
6. Was the rinse volume of the dilutant approximetely equal to 10%
the container's total volume?
(761. 43 (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 .10(b)(1))
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 decontami-B
nation procedures?
YES NO N/A C/A
11. Does facility have written decontamination procedures?
YES NO N/A C/A
-------
H-ll
12. Any deficiencies in the decontamination procedures must be
described below.
SECTION F. RECORD KEEPING
1. Do records indicate the date 'PCBs:
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
2. Do records indicate the quantity of the above items as follows:
a. The weights of PC3s and
PCB items iff containers? YES NO N/A C/A
• b. The contents of PCB
containers? YES NO N/A C/A
c. The number of PCB
transformers? YES NO N/A C/A
d. The weight of PCBs in
PCB transformers? YES NO N/A C/A
e. The number of PCB large V
high and low voltage
capacitors? YES NO N/A C/A
3. Do records indicate the. quantities of PCBs remaining in service
broken down as follows:
a. The weight of PCBs and PCB items in PCB containers?
YES NO N/A 1C/A
b. The identification of the contents in PCB containers?
YES NO N/A C/A
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LI I p
c. The number of PCB transformers?
YES NO N / A. C / A
d. The weight of PCBs in PCB transformers?
YES NO N/A C/A
e. The number of PCB large high and low.voltage capacitors?
YES N 0 N / A C / A
f
4. i) Is the information requested in paragraph 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 NO N/A C/A
ii) List years for which ^annual documents are available.
5. Any deficiencies in record keeping must be described below
including information on amount of PCBs involved.
6. If owners or operators maintain more than one facility that
contains PCBs in the quantities prescribed in paragraph C 1, are
records and documents kept at a single location?
(If yes, list location.) YES NO N/A C/A
7. Do records provide information on a PCB disposal facility?
YES NO N/A C/A
(If yes, please list name, location and type of facility, i.e.,
incinerator, boiler, landfill, etc.)
10
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INSPECTION CHECKLIST FOR PCB INCINERATORS
H-13
Company Name_
Incinerator Plant_
Location
Date of
Type of Waste Burned_
Parameters
Requirement
Actual
Combustion Criteria
> 3% excess oxygen, and
2-sec. dwell @ 1200°C (+100°C)
lor 1% sec. dwell P 1600°C
Dwell
Temp =
sec.
°C
Combustion Efficiency -
-.--x HJO
_ro, -i- GO
Rate and quantity of PCBs
fed to incinerator.
Temperatures of the
incineration process
at least 99.9% .
Recorded at regular interval
at least every 15 minutes
Time oft measurement;—••:-•
co2 = %
CO =
CE =
Feed rate =
Ib./l
PCB cone =
PCB feed rate = > l Ib./h
Continuously measured and
recorded. . .-.
Minimum temperature of
previous 48 hrs.
Flow of PCBs to inciner-
ator.
Stops automatically when
temperature fcrops below
that required under combustion
criteria.
Cut-off at following:
Temp = " °F
CO =
ppm
Excess 0? Monitor
Calibration
Must be calibrated every 24 hrs
when burning PCB's.
. Calibration:
Date
Time
Concentration
Carbon Monoxide
Monitor Calibration
i Must be calibrated every
24 hrs. when burning PCB's
Calibration:
Date
Time
Concentration
Pi
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H-14
Parameter
Requirement
Actual
Draft of Incinerator
Negative
Where measured:
Draft =
inches H00
'Particulate Emissions
State Permit or
0.08 gr/dscf @ 12% C02
Particulate Emissions
Ib/hr
gr/dscf
@ 12% C00
Maintenance of
Records
761.45
(b) dates and amts. of PCB's
rec'd, disposed, & stored.
(c) dates, amts., combustion
criteria.
(f) Documents & corres.-from
..state and local agencies.
Opacity of Stack
Emissions
V .; State Permit (Method 9)
Water Scrubbers for
HC1 Control
99.% (state-of-art)
Results of Last Test:
Date
removal eff = v %
HC1 emissions = Ib/h
Storage,
Decontamination
and marking
••- 761.42 - Storage and Disp,
J. 761,43 -Decontamination.
. 761.44 - Marking Formats [
NPDES Requirements
(only during PCB
incineration)
r
RCRA Requirements
Interim Status - Steady State
prior to introducing wastes. .
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