ASTSWMO
INSPECTOR TRAINING
MANUAL
Developed for the
Association of State and Territorial
Solid Waste Management Officials
,by
The School of Natural Resources
The University of Michigan
Ann Arbor, Michigan
with the support of the
U.S. Environmental Protection Agency
February 1988
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ASTSWMO
INSPECTOR TRAINING MANUAL
FEBRUARY 1988
Developed for the
Association of State and Territorial
Solid Waste Management Officials
by
The School of Natural Resources
The University of Michigan
Ann Arbor, Michigan
with the support of the
U.S. Environmental Protection Agency
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ACKNOWLEDGEMENT
TJie University of Michigan project team gratefully acknowledges the
Assistance provided by rnelnbers of the ASTSWMO review committee,
iridudinySteve Baxtei'V Jim Close, Mack Henderson1; Crfi£ltteinhieh4
Khijfht, Sieve Madonria,;!Richard Slein, and Willie Williams.- We als
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INTRODUCTION TO THE INSPECTOR TRAINING COURSE
The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is
a non-profit trade association representing the directors'of solid and hazardous waste
programs in each of the States and territories of the U.S. The Association is .dedicated to
promoting and protecting public health and safety and to preservation of'lhe environment.
° .•.'?.:,.I '•'-• " .>."-: • Xcjf. •'.' '••:•'. . - .-1. , ''
ASTSWMp's^roembeptyg.believes these goals can be ac^iev^d through a hje^archy of
solid and hazardous- •was£eJLmanagement procedures designed.to..reduce the generation of
waste, recycle and reuse much of the waste flow, recoverienergy from as'rnuoh/jo£the
remainderH£S impossible, and finally, landfilling the residual. No single management
procedure will solve the problems of America's tremendous 'waste' flow,:but carefully
planned and regulated efforts will allow safe, efficient management.
A significant feature of ASTSWMO's continuing efforts at achieving better,-"Safer'waste
management depends upon the improved exchange of information among Sta&s'Sacnd in
providing better training opportunities for State employees in all'aspects of waste"
management. These efforts are commonly, referred to AS."technology jtransfer" within the
environmental community and it is under this general program that the Association began
to assess the needs of its member States* OneCarfea that was identified early concerned
the turbulence caused by the turnover of'Stat£lemployees at the entry level within the
hazardous waste regulatory agencies. Effective inspectors are vital in the promotion and
enforcement of good waste management .practice, yet the turnover at the entry level is
significant and unlikely to diminish in the hear future. .What was needed was an effective,
rapid training vehicle to bring new State/ferifployees quickly up to the knowledge levels
required of inspectors operating under the Resource Conservation and Recovery Act.
Based on that identified need, the Associatibrrtleveloped' a grant proposal, to be funded by
the Environmental Protection Agency, and entered into joint planning and implementation
of an entry level inspector training course with the University of Michigan School of
Natural Resources.
A key element of ASTSWMO's efforts at technology transfer is the belief that much of the
training must be Institutionalized in the States themselves. This is especially important
for the entry levels of training. The Association believes strongly, (that States haye the
best perspective to train State employees and should be provided with the too^s to do so.
While the Association recognizes the efficiencies and economies of centralizing some of the
nation's more advanced and specialized waste-'management training, the members believe
that the best forum for most training remains at the State level, and is best supported by
State sponsored educational institutions' and xmiv'ersfties. This concept is central to the
development of the inspector training course and to any future training programs
sponsored by ASTSWMO.
Tom "Kennedy
Executive Director
ASTSWMO"-
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ASTSWMO INSPECTOR TRAINING MANUAL
TABLE OF CONTENTS
CHAPTER 1 - INTRODUCTION 1-1
CHAPTER 2 - RESOURCE CONSERVATION AND RECOVERY ACT 2-1
CHAPTER 3 - SAFETY PROCEDURES 3-1
CHAPTER 4 - PERMITS AND COMPLIANCE MONITORING 4-1
CHAPTER 5 - WORK ETHICS 5-1
CHAPTER 6 - PREPARING FOR THE INSPECTION 6-1
CHAPTER 7 - CONDUCTING THE INSPECTION 7-1
CHAPTER 8 - POST-INSPECTION PROCEDURES 8-1
CHAPTER 9 - SAMPLING PROCEDURES 9-1
CHAPTER 10 - BASIC EVIDENCE COLLECTION 10-1
CHAPTER 11 - SPECIAL PROCEDURES 11-1
CHAPTER 12 - MEDICAL MONITORING PROGRAM 12-1
APPENDIX A - LIST OF VIDEO TAPES A-l
APPENDIX B - KEEPING UP-TO-DATE WITH RCRA B-l
APPENDIX C - SOURCES OF INFORMATION C-l
APPENDIX D - TELEPHONE NUMBERS D-l
APPENDIX E> ELECTROPLATING WASTE STREAM E-1
APPENDIX F - PULP AND PAPER WASTE STREAM F-l
GLOSSARY OF TERMS
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CHAPTER 1 TABLE OF CONTENTS
Chapter 1 INTRODUCTION 1-1
1.1 The Inspection Manual 1-1
1.2 Using this Manual 1-2
1.2.1 Format of the Manual 1-2
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Inspection Manual
INTRODUCTION
Chapter 1
INTRODUCTION
1.1 The Inspection Manual
The purpose of this manual is to instruct entry-level inspectors on the fundamentals of
conducting hazardous waste facility inspections. It is assumed the trainee has no previous
experience with the management of hazardous waste. It is highly recommended that the
reader first review the Glossary of Terms at the very end of this manual. Many terms
and acronyms which are mentioned in passing in the text are defined in detail in this
glossary.
This manual can stand alone as a training tool, but can be enhanced by additional training
efforts of greater depth and specificity. In addition to serving as a part of a training
program, this manual can also be utilized for other purposes:
Onsite Training
Reference Manual
Field Manual
This manual can serve as a supplementary guide during onsite
training.
Professional field staff can use this document for reference in the
performance of field and office activities. It provides guidance for
the handling of field samples, the assessment of necessary safety
requirements, the preparation of reports, etc.
Professional field staff may decide to carry part of this manual into
the field during inspections. The manual is bound in a three-ring
binder to facilitate easy removal of sections and is printed on two
sides to make it compact and more easily transported into the field.
February 1988
Page 1-1
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INTRODUCTION Inspection Manual
In addition to professional staff who will be conducting facility inspections, this manual
may also be useful to other professional groups including:
- State personnel.
- Private contractors.
- Regional EPA personnel.
- Local fire departments.
- City and County health departments.
- Hazardous waste facility owners and operators.
1.2 Using this Manual
This manual focuses on three phases of a hazardous waste facility inspection:
1. Preparing for the inspection.
2. Conducting the inspection.
3. Post-inspection follow-up.
A chapter is devoted to each phase of an inspection and presents an outline of the activities
and procedures required in that phase. Additional chapters of the training manual cover
the federal hazardous waste law, safety procedures, permits, work ethics, sampling
procedures, basic evidence collection, and medical monitoring programs. The binding
facilitates easy updating of the current manual contents and for the inclusion of State-
specific materials (e.g., checklists, telephone numbers).
1.2.1 Format of the Manual
The manual has been designed to present material clearly and concisely, me chapter title
is printed on the top outside of each page. Page numbering is organized by chapter and
appendix, and is printed on the bottom outside of each page. The first digit refers to the
Page 1-2 February 1988
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Inspection Manual INTRODUCTION
chapter; the second, to the specific page within that chapter (e.g., Page 5-20 refers to page
20 of Chapter 5, Page D-14 refers to page 14 of Appendix D).
This training manual is accompanied by video tapes which review key portions of the text.
These video tapes reinforce the material presented in the manual. Appendix A lists the
various sections of the video tapes by name.
This manual is part of an overall State self-sufficiency in training program developed by
the Association of State and Territorial Solid Waste Management Officials in cooperation
with The University of Michigan School of Natural Resources with the support of the U.S.
Environmental Protection Agency.
February 1988 Page 1-3
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INTRODUCTION Inspection Manual
Page 1-4 February 1988
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CHAPTER 2 TABLE OF CONTENTS
Chapter 2 RESOURCE CONSERVATION AND RECOVERY ACT 2-1
2.1 Summary 2-1
2.2 Introduction to RCRA 2-2
2.2.1 Managing Solid Wastes 2-4
2.2.2 The Definition of Solid Waste 2-4
2.2.3 The Definition of Hazardous Waste 2-5
2.2.4 Managing Hazardous Waste 2-6
2.2.5 Characteristics 2-7
2.2.6 Listing of Hazardous Waste 2-8
2.2.7 Mixtures 2-9
2.2.8 Solid Wastes that are Excluded 2-9
2.3 Generation of Hazardous Waste 2-10
2.3.1 Who are the Generators 2-10
2.3.2 The EPA Identification Number 2-10
2.3.3 Pre-Transport Regulations 2-11
2.3.4 The Manifest 2-12
2.3.5 Record Keeping and Reporting 2-13
2.3.6 Additional Requirements 2-14
2.4 Transportation of Hazardous Waste 2-15
2.4.1 Who is a Transporter? 2-15
2.4.2 Requirements for Transporters 2-16
2.5 Treatment, Storage and Disposal 2-17
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2.5.1 What is a TSD? 2-17
2.5.2 TSD Regulatory Requirements 2-18
2.5.3 Administrative Requirements 2-19
2.5.4 Technical Requirements 2-19
2.6 Underground Storage Tanks 2-20
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
Chapter 2
RESOURCE CONSERVATION AND RECOVERY ACT
2.1 Summary
Although the Resource Conservation and Recovery Act (RCRA) was intended to control all
types of solid waste disposal and to promote recycling and alternative energy sources, its
major emphasis is on controlling hazardous waste treatment, storage and disposal. The
law established a system to identify waste and track its generation, treatment, storage,
transport and final disposal. Technical standards for disposal sites and State hazardous
waste programs are also addressed in the Act.
States and the U.S. Environmental Protection Agency (EPA) are jointly responsible for
administering RCRA. State hazardous waste programs vary on the amount of RCRA they
are authorized to administer. In all cases EPA retains oversight responsibility to see that
the objectives of RCRA are met. States hazardous waste programs may impose regulatory
requirements that are more stringent than the Federal program. For instance, State
hazardous waste programs may deal with the handling of used oil and secondary
containment, or may have annual reporting requirements not covered in the Federal rules
and regulations. Readers are referred to appropriate State hazardous waste program
documents for details on how the State program differs from the Federal guidelines.
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
Under RCRA, the Environmental Protection Agency (EPA) identifies what materials are to
be considered hazardous wastes. EPA also identifies characteristics of hazardous waste,
such that any waste exhibiting a characteristic of a hazardous waste also is considered a
hazardous waste. Any generator of hazardous wastes above certain minimum quantities
must notify EPA and comply with hazardous waste generator requirements. There is also
a special program to handle generators of small quantities of hazardous waste, such as dry
cleaning establishments. Transporters of hazardous waste must also notify EPA.
Treatment, storage and disposal (TSD) facilities must both notify EPA and obtain either
an interim status or regular permit in order to receive or store hazardous waste. Interim
status permits are available only to those companies existing prior to November llth,
1984. In most cases, a multi-copy manifest must accompany every batch of hazardous
waste from generator to final disposal. This allows for cradle-to-grave tracking of the
waste and, as part of an operating record helps to identify the contents at each disposal
site. Records of hazardous wastes generated, shipped and disposed must be available to
Federal and State regulator}' authorities. In most states, these records or annual reports
summarizing the amounts of wastes generated and/or handled are submitted on a regular
basis.
2.2 Introduction to RCRA
Several hundred million metric tons of hazardous waste are produced in the United States
each year. This is over 1 ton of hazardous waste generated per person, per year. The
proper transportation, disposal, treatment or storage of this hazardous waste is a major
environmental issue. The Resource Conservation and Recovery Act (RCRA), built on the
foundation of the Solid Waste Disposal Act of 1965 and the Resource Recovery Act of
1970, was passed in 1976 to address this growing issue. The major goals of RCRA are:
1. To protect human health and the environment.
2. To reduce waste and conserve energy and natural resources.
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
3. To reduce or eliminate the generation of hazardous waste as quickly as possible.
This Act requires that EPA identify hazardous wastes, set standards for their
management, and issue guidelines that provide Financial aid to state programs to regulate
such waste. RCRA also requires that persons who treat, store or dispose of large amounts
of hazardous waste apply to EPA for a permit. Permits are not required for on-site waste
water treatment units and elementary neutralization.
To achieve the goals of RCRA, three distinct, interrelated programs were developed.
These are often referred to by the section of the Act in which they are described: Subtitle
D, C, and I.
SUBTITLE D This encourages States to develop a plan for the management of
solid waste, primarily non-hazardous waste such as household
refuse.
SUBTITLE C This section of RCRA establishes a system for the management of
hazardous waste from the time it is generated until its final
disposal.
SUBTITLE I This program regulates certain underground storage tanks. It
establishes performance standards for new tanks and requires leak
detection, prevention and correction at underground tank sites.
It is important to note that while RCRA encourages the proper management of non-
hazardous and hazardous waste, it does not deal with the problems of hazardous waste
found at inactive (unless the facility applies for a permit) or abandoned sites or those
problems resulting from spills that require emergency response. These problems are
addressed, with certain exceptions, by a different Act, the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), better known as Superfund, and
now (SARA).
The three programs which make up RCRA - solid waste, hazardous waste, and
underground storage tanks - are described in more detail below.
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
2.2.1 Managing Solid Wastes
The history of solid waste management at the Federal level is mainly a result of post-
World War II affluence. After the war, the nation's industries began producing enormous
amounts of consumer goods. Many of these goods were designed to be disposed of. During
1971 over 110 million metric tons of solid waste were discarded; by 1980 this figure had
reached 135 million metric tons. Since the 1920s the amount of solid waste has increased
about five times as fast as the population.
By the 1960s it had become apparent that the nation's ability to manage solid waste was
being severely strained. As a result, Congress passed the Solid Waste Disposal Act of
1965. Later amendments to this Act - the Resource Recovery Act of 1970 and RCRA in
1976 - further improved the nation's ability to manage solid waste. The Subtitle D
program under RCRA was specifically aimed at non-hazardous solid waste.
The primary goals of the Subtitle D program (Sections 4001-4010 of RCRA) are to
encourage environmentally appropriate solid waste disposal methods, maximize the reuse
of recoverable resources, and encourage resource conservation.
2.2.2 The Definition of Solid Waste
The term "solid waste" is very broad, including not only traditional non-hazardous waste,
such as municipal garbage, but also hazardous solid waste. The term "solid waste" is a
misnomer in that it may also be liquid, semisolid, or gaseous. Although the definition of
solid waste includes hazardous waste, the Subtitle D program is concerned primarily with
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
non-hazardous waste. Only a few hazardous wastes excluded from regulation under
Subtitle C of RCRA are covered by Subtitle D (e.g., small quantities of hazardous waste
coming from households and generators).
Under RCRA some materials are not considered solid waste, for instance:
- Domestic sewage (defined as untreated sanitary wastes that pass through a sewer
system.
- Industrial wastewater discharges regulated under the Clean Water Act.
- Irrigation system return flows.
- Nuclear materials, or by-products, as defined by the Atomic Energy Act of 1954.
- Mining materials that are not removed from the ground during the extraction
process.
- Pulping liquors.
- Spent sulfuric acid used to produce virgin sulfuric acid.
To achieve the main goals of Subtitle D, EPA established both a voluntary program under
which participating states may develop solid waste management plans and technical
standards for solid waste management facilities. The solid waste management plans
ensures the proper management of solid waste, conservation and, where possible, recovery
of resources and closure or upgrading of open dumps. The technical standards are
mandatory and set minimum technical requirements for environmentally acceptable solid
waste disposal facilities.
2.2.3 The Definition of Hazardous Waste
While Congress defined the term "hazardous waste" in Section 1004(5) of RCRA (see the
Glossary of Terms), EPA was required to develop a specific framework for identifying
those wastes to be managed as hazardous waste under Subtitle C. This framework (found
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
in 40 CFR Part 261) specifies that a solid waste is hazardous if it meets any of the
following conditions:
1. Has been named as a hazardous waste and listed.
2. Exhibits, on analysis, any of the characteristics of a hazardous waste.
3. Is a mixture containing a listed hazardous waste and a non-hazardous solid waste
(unless the mixture is specifically excluded or no longer exhibits any of the
characteristics of hazardous waste).
Furthermore, the residue from treatment of any hazardous waste is also a hazardous
waste unless specifically excluded.
2.2.4 Managing Hazardous Waste
The improper management of hazardous waste is a major environmental issue in the
United States. In 1979, the EPA estimated that only 10 percent of all hazardous waste
was managed in an environmentally appropriate way. The remainder was transported,
treated, stored or disposed of in a manner that potentially threatened human health and
the environment. Since 1979 the amount of hazardous waste generated has risen and
proper management of this waste is still an issue.
The Subtitle C program developed under RCRA (Sections 3001-3019 of the Act) is
designed to promote the proper management of hazardous waste. The management
system sets forth requirements for such things as:
- Identifying hazardous waste.
- Regulating generators of hazardous waste.
- Regulating transporters of hazardous waste.
- Regulating owners and operators of facilities that treat, store, or dispose of
hazardous waste.
- Issuing operating permits to owners or operators of treatment, storage and disposal
(TSD) facilities.
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
To ensure the proper management of hazardous waste, RCRA requires that generators of
large amounts of hazardous waste use a "cradle-to-grave" manifest system. This manifest
system tracks hazardous waste from its point of origin to its final disposal. First, a
generator of solid waste must check to see if the waste is classified as a hazardous waste.
Next, the waste must be appropriately packaged, labeled and transported only to an
authorized hazardous waste treatment, storage or disposal site. Finally, both the
transporter and the waste disposal site owner or operator must sign the manifest and
return a signed copy to the person that generated the waste.
2.2.5 Characteristics
EPA has identified four characteristics of hazardous waste. Any solid waste that exhibits
one or more of them is classified as hazardous under RCRA. The responsibility for
determining if a particular solid waste is hazardous is that of the waste generator. He/she
must either test the waste following methods specified in 40 CFR Part 261 or, using
sufficient knowledge about the waste, assess whether it exhibits any of the characteristics
of a hazardous waste. If the waste does exhibit a hazardous characteristic, then it must
be handled accordingly. These characteristics are described below.
Ignitability A solid waste that exhibits any of the following properties is a
hazardous waste due to its ignitability: (1) a liquid, except aqueous
solutions containing less than 24 percent alcohol, that has a flash
point less than 60 degrees C (140 degrees F); (2) a non-liquid
capable, under normal conditions, of spontaneous and sustained
combustion; (3) an ignitable compressed gas per Department of
Transportation (DOT) regulations; (4) an oxidizer per DOT
regulations. Examples of ignitable wastes include used solvents and
paint thinners.
Corrosivity A solid waste that exhibits any of the following properties is a
hazardous waste due to its corrosivity: (1) an aqueous material with
a pH less than or equal to 2 or greater than or equal to 12.5; (2) a
liquid that corrodes steel at a rate greater than 1/4 inch per year at
a temperature of 55 degree C (130 degrees F). Examples of
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RESOURCE CONSERVATION AND RECOVERY ACT
Inspection Manual
Reactivity
EP Toxicity
corrosive wastes include acidic wastes and used pickle liquor
(employed to clean steel during its manufacture).
A solid waste that exhibits any of the following properties is a
hazardous waste due to its reactivity: (1) normally unstable and
reacts violently without detonating; (2) reacts violently with water;
(3) forms an explosive mixture with water; (4) generates toxic
gases, vapors, or fumes when mixed with water; (5) contains
cyanide or sulfide and generates toxic gases, vapors, or fumes at a
pH of between 2 and 12.5; (6) capable of detonation if heated under
confinement or subjected to strong initiating source; (7) capable of
detonation at standard temperature and pressure (20 degrees C and
760 mm of mercury); (8) listed by DOT as Class A or B explosive.
Examples of reactive wastes include water from TNT operations
and used cyanide solvents.
The term EP toxicity refers both to a characteristic of a waste and
to a test used to determine this characteristic. The test, called the
extraction procedure (EP), is designed to identify wastes likely to
leach hazardous concentrations of particular toxic materials into the
ground water as a result of improper management. During the
procedure, materials are extracted from the waste in a manner
designed to simulate the leaching actions that occur in landfills. The
extract is then analyzed to determine if it has any of 14 listed toxic
materials above certain concentration levels (See 40 CFR 261.24).
If so, then the waste is classified as hazardous.
2.2.6 Listing of Hazardous Waste
A solid waste is a hazardous waste if it is named on one of the three lists kept by EPA:
Non-Specific Source Wastes
Specific Source Wastes
Commercial Chemical Products
These are generic wastes, commonly
produced by manufacturing and industrial
processes. Examples include halogenated
solvents used in decreasing and wastewater
treatment sludges from electroplating
processes. (See 40 CFR Section 261.31).
This list consists of waste from specifically
identified industries such as wood preserving,
petroleum refining and organic chemical
manufacturing. These wastes typically
include sludges, wastewaters, spent catalysts
and residues. (See 40 CFR Section 261.32).
The third list consists of specific commercial
chemical products or manufacturing chemical
intermediates. This lists includes such
chemicals as chloroform, creosote, sulfuric
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February 1988
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
acid, hydrochloric acid, DDT and kepone.
(See 40 CFR Section 261.33 (e) and (f)).
2.2.7 Mixtures
Any waste mixture containing a listed hazardous waste is considered a hazardous waste
and must be managed accordingly. This applies regardless of the percentage of the listed
hazardous waste in the mixture.
There are a few special exceptions to the mixture rule outlined above:
1. If a wastewater discharge subject to regulation by the Clean Water Act is mixed
with low concentrations of a listed waste, as specified in 40 CFR Section 261.3, the
resulting mixture is not considered a listed hazardous waste. Of course, if such a
mixture exhibited one of the characteristics it would be deemed hazardous.
2. Mixtures of non-hazardous waste and characteristic wastes are not considered
hazardous if the mixture no longer exhibits any hazardous characteristics.
2.2.8 Solid Wastes that are Excluded
There are a number of instances of hazardous materials not being considered hazardous
waste under Subtitle C of RCRA. For instance, hazardous materials that are fully
contained within a totally enclosed treatment facility can be excluded. Also excluded are
solid wastes that are recycled under 40 CFR Section 261.2 (e). In addition Congress
decided that certain types of solid waste should not be considered hazardous waste. These
include a number of common wastes that do not present a significant threat to human
health or the environment or are currently managed under other programs in a way that
minimizes such threats. Included are household refuse, municipal resource recovery
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
wastes, agricultural wastes and mining overburden returned to the mine site. EPA
amended Congress' list with certain chromium-containing wastes and laboratory samples
(see 40CFRPart 261).
2.3 Generation of Hazardous Waste
2.3.1 Who are the Generators
To define which group of solid waste generators must comply with the hazardous waste
regulations (Subtitle C of RCRA) it is necessary to distinguish between generators who
produce or handle non-hazardous solid waste and those who generate or handle hazardous
solid waste. Subtitle C separates these two groups by requiring all generators of solid
waste to determine if any of their waste is hazardous using the procedures outlined above.
Once the generator makes such a determination, the generator must comply with Subtitle
C requirements. The Subtitle C regulatory requirements for hazardous waste generators
include:
- Obtaining an EPA ID number.
- Proper handling of hazardous waste before transport.
- Manifesting of hazardous waste.
- Record keeping and reporting.
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
2.3.2 The EPA Identification Number
To monitor hazardous waste generators, each is assigned a unique identification number.
Without this number, generators are barred from treating, storing, disposing of,
transporting or offering for transport any hazardous waste. Furthermore, the generator is
prohibited from offering hazardous waste to any transporter or TSD facility that also does
not have an EPA ID number. The EPA ID number is site specific. It cannot be
transferred with the facility if the location changes. The number must be "closed out" if a
facility no longer exists at the original site. Note that this identification number can be
issued by EPA or States with authorized hazardous waste programs.
2.3.3 Pre-Transport Regulations
EPA has adopted the regulations developed by the Department of Transportation (DOT)
(40 CFR 140) for handling hazardous waste prior to transportation to an off-site TSD
facility. DOT regulations require that a generator:
• Properly package the hazardous waste to prevent leakage during both normal
transport conditions and in potentially dangerous situations (e.g., when a drum
falls from a truck).
- Identify the characteristics and dangers associated with the wastes being
transported by labeling, marking and placarding the vehicles transporting the
packaged waste.
In addition to adopting DOT regulations listed above, EPA also developed pre-transport
regulations that cover the accumulation of waste prior to transport off-site. A generator
may accumulate hazardous waste on-site for 90 days or less as long as the following
requirements are met:
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
Proper Storage The waste must be stored in approved containers or
tanks marked with the words "Hazardous Waste"
and the date on which accumulation began.
Containers must be in good condition with no
releases.
Emergency Plan A contingency plan and emergency procedures to use
in an emergency must be in place.
Personnel Training Facility personnel must be trained in the proper
handling of hazardous waste.
Preparedness/Prevention Personnel must maintain and operate their facility to
minimize the possibility of fire, discharge, etc.
The 90 day accumulation period allows a generator to collect enough waste to make
transportation more cost-effective. Instead of paying to haul several small shipments of
waste, the generator can accumulate enough waste for one large shipment. Small quantity
generators can accumulate as much as 6000 kgs of hazardous waste for 270 days.
If the generator accumulates hazardous waste on-site for more than 90 days or fails to
comply with the temporary accumulation requirement, the generator is considered a
storage facility and must comply with the Subtitle C requirements for such a facility (e.g.,
obtain a permit). Under temporary, unforeseen and uncontrollable circumstances the 90
day period may be extended, for up to 30 days, on a case-by-case basis.
2.3.4 The Manifest
The Uniform Hazardous Waste Manifest is the key to the cradle-to-grave management of
hazardous waste. Using a manifest, generators who ship their waste off-site for
management can track the movement of hazardous waste from the point of generation (the
cradle) to the point of final treatment, storage or disposal (the grave). The manifest
contains the following information:
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Inspection Manual RESOURCE CONSERVATION AND RECOVERY ACT
- Name and EPA ID Number of the generator, the transporter(s), and the facility
where the waste is to be treated, stored or disposed of.
• U.S. DOT description of the waste being transported.
- Quantities of the waste being transported.
- Address of the treatment, storage or disposal facility to which the generator is
sending the hazardous waste (called the designated facility).
- Certification that the generator has in place a program to reduce the volume and
toxicity of the waste to the degree economically practicable, as determined by the
generator.
- Certification that the treatment, storage or disposal method chosen by the
generator is the most practicable method currently available that minimizes the
risk to human health and the environment.
The manifest is part of a controlled, circular tracking system. Each time the waste is
transferred (e.g., from a transporter to the designated facility or from a transporter to
another transporter) the manifest must be signed to acknowledge receipt of the waste. A
copy of the manifest is retained by each link in the transportation chain. Once the waste
is delivered to the designated facility the owner or operator of that facility must send a
copy of the manifest back to the generator. This system ensures that the generator has
documentation that the hazardous waste has arrived at its final destination. Because the
purpose of a manifest is to track hazardous waste off-site, it is not required for generators
who treat, store or dispose of their waste on-site.
2.3.5 Record Keeping and Reporting
The record keeping and reporting requirements for generators provide EPA and states
with a method to track the quantities of waste generated and the movement of hazardous
waste. Subtitle C contains three main record keeping and reporting requirements:
Biennial Reporting Generators of hazardous waste must submit a
biennial report to the EPA Regional Administrator
by March 1st of each even-numbered year. The
report details the generator's activities during the
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RESOURCE CONSERVATION AND RECOVERY ACT
Inspection Manual
Exception Reports
Retention of Documents
previous period including: (1) the EPA ID number
and name of each transporter used throughout the
period; (2) the EPA ED number, name and address of
each off-site treatment, storage or disposal (TSD)
facility to which hazardous waste was sent during
the period; and (3) quantities and nature of the
hazardous waste generated. The Hazardous and
Solid Waste Amendments of 1984 (HSWA) also
require the biennial report to include: (4) efforts
taken to reduce the volume and toxicity of the
wastes generated; and (5) changes in volume and
toxicity that were actually achieved, as compared
with those achieved in previous years. Generators
who treat, store or dispose of their hazardous waste
on-site also must submit a biennial report that
contains a description of the type and quantity of
hazardous waste the facility handles during the
period, and the method(s) of treatment, storage or
disposal used.
Generators who ship hazardous waste off-site must
submit an exception report to the Regional
Administrator if they do not receive a copy of the
manifest signed and dated by the owner or operator
of the designated facility within 45 days from the
date on which the initial transporter accepted the
waste. The exception report must describe efforts
taken to locate the hazardous waste and the results
of such efforts.
Documents the generator must retain for three years
include: each biennial report and any exception
reports; a copy of all manifests (from the date on
which the hazardous waste was accepted by the
initial transporter) and the records of the waste
analyses and determination undertaken by the
generator.
2.3.6 Additional Requirements
There are additional requirements for special situations:
International Shipments
The exporter of hazardous waste is required to notify
the EPA Regional Administrator of the nature of the
shipment (e.g., dates, quantity, description of waste)
at least four weeks prior to shipment. Within 30
days of the receipt of this notification, the State
Department, acting on behalf of the Administrator,
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must inform the receiving country about the export.
The country, in turn, must consent (in writing) to
accept the waste. If an international agreement
exists between the United States and the receiving
country, notice and consent for each shipment are
not required.
Farmer Exclusion Although farmers can be generators of hazardous
waste, they need not comply with the Subtitle C
regulations for generators when the wastes being
disposed of are pesticides used only by them and: (1)
empty pesticide containers are triple rinsed; and (2)
pesticide residues are disposed of on the farm
following the instructions on the pesticide label.
2.4 Transportation of Hazardous Waste
Transporters of hazardous waste are the critical link between the generators and the final
off-site treatment, storage or disposal facility. The transporter regulations were developed
jointly by EPA and DOT to avoid contradictory requirements. Although the regulations
are integrated, they are not contained under the same Act. A transporter must comply
with the Hazardous Materials Transportation Act (see 49 CFR Parts 171-179) as well as
Subtitle C of RCRA (see 40 CFR Part 263). The Subtitle C regulations for transporters
are outlined below.
2.4.1 Who is a Transporter?
A transporter is any person involved in the off-site transportation of hazardous waste
within the United States, if such transportation requires a manifest. This definition covers
transport by air, rail, highway or water. The transport regulations do not apply to either
the on-site transportation of hazardous waste by generators who have their own TSDs or
to TSDs transporting waste within a facility.
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Inspection Manual
Once a transporter accepts hazardous waste from a generator or another transporter, it
can store this waste at a transfer facility for up to 10 days without being subject to TSD
regulations. However, if the storage time exceeds 10 days, the transporter is considered a
storage facility and also must comply with the regulations for such a facility (see next
section). In addition, transporters who bring hazardous waste into the United States or
mix hazardous waste of different DOT shipping descriptions by placing them in the same
container are classified as generators and must comply with the regulations applicable to
generators.
2.4.2 Requirements for Transporters
A transporter is subject to the following regulations:
EPA ID Number
Manifest
Waste Discharges
Each transporter is required to obtain a unique ID
Number from the EPA. Without this ID Number the
transporter is prohibited from transporting any
hazardous waste. Furthermore, a transporter may
not accept hazardous waste which requires a
manifest from a generator unless that generator has
an EPA ID Number.
The transporter is required to deliver the entire
quantity of waste which he/she accepted to the
designated facility on the manifest. If the waste
cannot be delivered as the manifest directs, the
transporter must inform the generator and receive
further instructions (e.g., return the waste or take it
to another facility). Before releasing the waste to a
TSD facility, the transporter must have the owner or
operator of the facility sign and date the manifest.
Multiple copies of the manifest are given to the TSD
facility: one copy remains at the facility, one stays
with the transporter, another must be sent to the
generator. The transporter must retain a copy of the
manifest for three years from the date the
hazardous waste was accepted by the initial
transporter.
In the event of an accident during the transportation
of hazardous waste the transporter is required to
take immediate action to protect human health and
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the environment. This may include notifying local
authorities and/or diking off the discharge area. The
regulations also give certain officials the authority to
deal with transportation accidents. These officials
can authorize the removal of hazardous waste by a
transporter who lacks an EPA ID Number and
without the use of a manifest if the waste poses an
immediate hazard to human health or the
environment.
2.5 Treatment, Storage and Disposal
Treatment, storage and disposal facilities (TSDs) are the last link in the "cradle-to-grave"
hazardous waste management system. RCRA requires all TSDs that receive hazardous
waste off-site to obtain an operating permit (see next section) and comply with treatment,
storage and disposal regulations. Because treatment, storage and disposal involves many
different types of facilities (e.g., landfills, incinerators) the regulations are lengthy. Due to
this length, the present section provides only a summary of the TSD requirements. For
more details see 40 CFR Parts 264 and 265 or the EPA RCRA Orientation Manual (blue
book) Chapter 4.
2.5.1 What is a TSD?
The definition of a TSD, according to 40 CFR Part 260.10, includes three different
functions:
Treatment Any method, technique or process, including neutralization, designed
to change the physical, chemical or biological character or
composition of any hazardous waste so as 1) to neutralize it or
render it non-hazardous or less hazardous; or 2) to recover it, make
it safer to transport, store or dispose of, or amenable for recovery,
storage or volume reduction.
Storage The holding of hazardous waste for 90 days (or 10 days if a
Transporter) at the end of which the hazardous waste is treated,
disposed of or stored elsewhere.
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Disposal The discharge, deposit, injection, dumping, spilling, leaking or
placing of any solid waste or hazardous waste into or on any land or
water so that any constituent contained in the waste may enter the
environment or be emitted into the air or discharged into any water,
including ground waters.
2.5.2 TSD Regulatory Requirements
RCRA established two categories of TSDs based on when the facility went into operation.
The first category is "interim status" facilities. These are TSDs that have not obtained a
Part B permit. The second category includes facilities that have a Part B permit.
Although RCRA is clear on the fact that only permitted TSDs are allowed to operate,
Congress, in developing this requirement, recognized that it would take many years for
EPA to issue all permits. Therefore, it established the "interim status" category which
allows owners and operators of facilities in existence on November 19, 1980 (or brought
under Subtitle C regulation), who meet certain conditions, to continue to operate until their
permit is issued or denied.
RCRA requires EPA to develop regulations for all TSDs. Although only one set was
required, EPA developed two sets of regulations, one for "interim status" TSDs, the other
for "permitted" TSDs. In establishing two sets of requirements, EPA decided that owners
and operators of facilities with "interim status" should meet less stringent requirements
than "permitted" facilities.
The "interim status" standards (40 CFR Part 265) outline practices that owners and
operators must follow to properly manage hazardous waste. The "permitted" facility
standards (40 CFR Part 264) are "design and operating" criteria included in facility-
specific permits (e.g., tanks storing hazardous waste must be designed to industry-
specifications found in 40 CFR Part 264). The "permitted" standards contained in the
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regulations are general and serve as a guideline for permit writers in setting the site-
specific design and operating requirements through "best engineering judgment." Both
"interim status" and "permitted" standards consist of two parts: Administrative and
Technical requirements. Each is briefly discussed below.
2.5.3 Administrative Requirements
Administrative requirements ensure that owners and operators of TSDs establish the
necessary procedures and plans to operate a facility and to manage any emergencies or
accidents. These requirements are in Subparts A through E of 40 CFR Parts 264 and 265
and cover the subject areas shown below:
SUBPART SUBJECT
A Who is subject to the Regulations?
B General Facility Standards:
- Waste analysis
- Security
- Inspection
- Training
- Ignitable, reactive or incompatible wastes
- Location standards ("permitted" facilities only)
C Preparedness and Prevention
D Contingency Plans and Emergency Procedures
E Manifest System, Recordkeeping and Reporting
2.5.4 Technical Requirements
The purpose of the technical requirements is to minimize the potential for threats resulting
from hazardous waste treatment, storage and disposal. The general management
practices detailed in the "permit" standards are more extensive than those in the "interim
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RESOURCE CONSERVATION AND RECOVERY ACT Inspection Manual
status" standards. They require an owner or operator to take corrective action if ground-
water contamination is detected. They also compel the owners and operators of the
different waste management units to design those units to prevent the release of
hazardous waste. The "permit" standards also differ from the "interim status" standards
in that the permit standards are only blueprints for the requirements applied to TSDs.
The specific requirements an owner or operator of a TSD must comply with are developed
for each facility by permit writers, based on their best engineering judgment and the
requirements of 40 CFR Part 264. These requirements are incorporated into the facility
operating permit. For instance, ground-water monitoring requirements are found in 40
CFR Part 264 but the actual parameters that must be monitored for are specified in each
permit.
The technical requirements are further broken into:
- General Standards that apply to several types of facilities, covering:
* Ground-water monitoring.
* Closure/Post-closure.
* Financial requirements.
- Specific Standards that apply to a waste management method, covering:
* Containers.
* Tanks.
* Surface impoundments.
* Waste piles.
* Land Treatment.
* Landfills.
* Incinerators.
* Thermal treatment ("interim status" standards only).
* Chemical, physical, biological treatment ("interim status" standards only).
* Underground injection ("interim status" standards only).
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2.6 Underground Storage Tanks
There are as many as 1.5 million underground storage tanks used to contain hazardous
substances or petroleum products. An estimated 100,000 to 300,000 of these tanks are
presently leaking and polluting underground water supplies. To address this situation,
Congress created a new regulatory program under the Hazardous and Solid Waste
Amendments (HSWA) of 1984 which significantly expanded both the scope and coverage
of RCRA. This new program, referred to as the UST program (Subtitle I), regulates
underground tanks storing petroleum products and any substances defined as hazardous
under Superfund (CERCLA).
An "underground storage tank" is defined as any tank with at least 10 percent of its
volume buried below the ground, including any pipes attached to the tank. Any owner or
operator, including Federal entities, who store petroleum products or any substance
defined as hazardous under Superfund in an underground tank must meet the new UST
requirements. The UST program does not apply to:
- Tanks holding a hazardous waste regulated under the RCRA hazardous waste
program (Subtitle C).
- Farm and residential tanks with holding capacity of less than 1,100 gallons of
motor fuel.
- On-site tanks storing heating oil.
- Septic tanks.
• Pipelines regulated under other laws.
- Surface impoundments.
- Systems for collecting storm water and wastewater.
- Flow-through process tanks.
- Liquid traps or associated gathering lines related to operations in the oil and
natural gas industry.
The UST program includes the five parts described below. As of late 1987 regulations are
still in the process of being developed by the EPA.
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Inspection Manual
Ban on New Tanks
Notification
Regulatory Program
State Authorization
Inspections and Enforcement
A provision banning underground installation of
unprotected new tanks went into effect on May
7, 1985. Currently, no person may install an
underground storage tank unless: (1) it will
prevent release of the stored substances due to
corrosion or structural failure for the life of the
tank; (2) it is protected against corrosion,
constructed of noncorrosive material or steel-
clad with noncorrosive material, or designed to
prevent the release of the stored substance; and
(3) the material used in the construction or
lining of the tank is compatible with the
substance to be stored.
Subtitle I created a notification program that
affects many tank owners. This program
requires, in part, that owners of existing or
newly installed underground storage tanks
notify the State or local agency of each tank's
age, size, type, location, and use.
Under HSWA, EPA must develop regulations
that specify performance standards for new
underground storage tanks, as well as
regulations covering leak detection, leak
prevention, and corrective action for both new
and existing tanks.
Several States already have or are developing
regulatory programs for underground storage
tanks. The new law is designed to avoid
interfering with those State programs and to
encourage other States to move ahead with
control programs. Beginning in May of 1987
States were expected to begin applying to EPA
for authorization to operate an UST program.
The law allows States to choose whether their
program will cover petroleum or hazardous
substances or both.
HSWA provides authority for Federal and State
personnel to: (1) request relevant information
from tank owners; (2) inspect and sample tanks;
and (3) monitor and test tanks and surrounding
soils, air, surface water, and ground water.
Federal enforcement is also part of the new law.
EPA may issue compliance orders for any
violation of the UST program.
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CHAPTER 3 TABLE OF CONTENTS
Chapter 3 SAFETY PROCEDURES 3-1
3.1 Introduction 3-1
3.2 General Safety Procedures 3-1
3.3 Safety Plan 3-3
3.3.1 Site Assessment 3-4
3.3.2 Level of Protection 3-4
3.4 PERSONAL PROTECTION 3-7
3.4.1 Ingestion Protection 3-8
3.4.2 Absorption Protection 3-8
3.4.3 Respiratory Protection 3-8
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Inspection Manual SAFETY PROCEDURES
Chapter 3
SAFETY PROCEDURES
3.1 Introduction
This chapter outlines procedures for providing safe and healthful working conditions for
inspectors at hazardous waste sites and emergency spills. The inspector is potentially
exposed to a very high risk of incurring illness or injury while investigating a hazardous
waste site or responding to an emergency spill. Inspectors cannot anticipate every safetj'
hazard and must therefore take extraordinary precautions to prevent illness or injury to
themselves, other workers, and the public. Inspectors must never enter a site which calls
for the knowledge and use of safety equipment on which they have not received training.
Since inspectors cannot eliminate risk, they must reduce the risk to the lowest feasible
level. No set of rules, however, can be applied uniformly to every situation. This chapter
is intended to provide a basic framework for inspector safety considerations. All RCRA
field inspectors are required to have a 40 hour safety course before conducting inspections.
This course (e.g., working through the ASTSWMO Inspector Training Manual) does not
satisfy the 40 hour requirement.
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SAFETY PROCEDURES
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3.2 General Safety Procedures
Common sense is a vital element of safe conduct during all inspections. Situations
encountered in the field are such that there will not always be guidance available on the
scene. Materials encountered may be toxic, explosive, flammable, radioactive,
carcinogenic, infectious or any combination of these. Certain safety practices are
applicable to all sites. These include:
Development of a Safetj7 Plan
Use of a Buddy System
Wear Personal Protection
Practice Contamination Avoidance
Avoid Ingestion Hazard
Protect Your Sight
Avoid Skin Reactions
Caution Around Flammable Materials
Caution in Enclosed Areas
A site specific safety plan should be
prepared before entering a facility.
This item is discussed in more detail
later in this chapter.
Never enter a potentially hazardous
site alone. Your buddy should be
either another inspector or a
competent employee associated with
the site.
Individuals must use appropriate
safety equipment and protective
clothing adequate for the inspection.
Never sit or kneel on the ground.
Avoid obvious contamination. Never
climb over barrels or obstacles. Walk
around spills, never through them.
Stay upwind where possible.
Eating, drinking, smoking, etc. are
not allowed in potentially hazardous
areas.
Contact lenses should not be worn in
potentially hazardous areas. Soft
contact lenses are gas permeable.
Cologne, perfume, deodorants and
certain types of jewelry may react
with chemical vapors to produce an
irritation.
Provide for the removal and/or
isolation of all ignition sources (e.g.,
electric sparks, cigarettes,
automobiles, improper grounding of
electrical equipment) when dealing
with flammable substances.
Entering enclosed areas is extremely
dangerous and should never be
undertaken without first testing the
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SAFETY PROCEDURES
Caution with Closed Drums
Decontamination
General Safety Considerations
enclosed atmosphere. Entry should
be attempted only if one has a self-
contained breathing apparatus, full
body protection, communications
equipment, a partner for the
inspection, and backup personnel in
case of an emergency.
Never open a sealed drum. Collect
information written on the drum and
sample any nearby contaminated
wastes or soil. If a drum absolutely
must be opened, do so only in the
presence of professionals experienced
in opening drums and with Level A
protection (described below).
Upon leaving the contaminated area,
inspectors should decontaminate
equipment using appropriate
procedures. Never take hazardous
waste home and never bury or leave
disposable personal equipment on-
site.
Never forget fundamental safety
procedures concerning personal
injury, heat stress, snake bites, etc.
Always take your first aid kit with
you.
3.3 Safety Plan
Before the site visit a site specific safety plan should be developed by the inspector. This
plan will aid in preparation for the actual field work. The safety plan might address the
following issues:
1. Site name.
2. Date of inspection.
3. Site safety officer and telephone number.
4. Objectives of the inspection.
5. Hazardous materials present.
6. Hazard assessment (e.g., toxic effects, reactivity, physical hazards).
7. Possible need for pre-entry monitoring.
8. Level of personal protection required.
9. Decontamination and disposal procedures to be followed.
10. Emergency procedures (for skin contact, inhalation, or ingestion).
11. Emergency telephone numbers (e.g., nearest hospital, ambulance, fire).
12. Directions to nearest hospital.
February 1988
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3.3.1 Site Assessment
Hazards at a hazardous waste facility can be identified by consulting the records on the
site and by literature review (e.g., NIOSH/OSHA Pocket Guide to Chemical Hazards) or by
actual site analysis. Various instruments are available which can be used to provide
insight into the degree of protection needed when entering a potentially hazardous site.
These instruments include:
- Explosimeter
- Oxygen Indicator
- Radiation Instruments
- Organic Vapor Analyzer
- Detection Tubes
- Air Sampling Pump
- Portable Gas Chromatograph/Mass Spectrophotometer
3.3.2 Level of Protection
Once a site is characterized, the required level of protection may be determined. Indicators
such as dead animals or animal skeletons at the site, visible smoke, or fish kills should
alert the inspector of potential danger.
Equipment to protect the body against contact with known or anticipated chemical hazards
has been divided into four categories according to the degree of protection needed:
- Level A: Should be worn when the highest level of respiratory skin, and eye
protection is needed.
- Level B: Should be selected when the highest level of respiratory protection, but a
lower level of skin protection is acceptable.
- Level C: Should be selected when the types(s) of airborne substance(s) is known,
the concentration(s) is measured, and the criteria for using air-purifying respirators
met.
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- Level D: Should not be worn on any site with respiratory or skin hazards. It is
primarily a work uniform providing minimal protection.
The level of protection selected should be based primarily on:
- Type(s) and measured concentration(s) of the chemical substance(s), the ambient
atmosphere, and its toxicity.
• Potential or measured exposure to substances in the air, splashes of liquids, or
other direct contact with material due to work being performed.
In situations where the type(s) of chemical(s), concentrations(s), and possibilities of contact
are not known, the appropriate level of protection must be selected based on professional
experience and judgment until the hazards can be better characterized. Higher levels of
protection are usually reserved for instances which present a greater potential for
accidental exposure. The highest level of protection is usually reserved for spill response
and other extraordinary circumstances.
While protective equipment reduces the potential for contact with harmful substances, safe
work practices, decontamination, site entry protocols, and other safety considerations are
required to insure full protection. It is up to the individual inspector (with the assistance of
safet)' personnel) to determine the appropriate level of protection required. The individual
inspector has the responsibility to avoid direct exposure to hazardous chemicals. All four
levels are described briefly in Table 3-1.
TABLE 3-1
LEVEL OF PROTECTION
I. LEVEL A PROTECTIVE EQUIPMENT
EQUIPMENT
1. Pressure-demand, self-contained breathing apparatus, approved by the Mine
Safety and Health Administration (MSHA) and National Institute of
Occupational Safety and Health (NIOSH).
2. Fully encapsulating chemical-resistant suit.
3. Gloves, puter - chemical resistant.
4. Gloves, inner - chemical resistant.
5. Boots, chemical resistant steel toe and shank.
6. Booties, (outer) chemical resistant, disposable.
7. Coveralls, chemical resistant.
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8. Hard hat - worn under suit (optional).
9. Long cotton underwear (optional).
10. Disposable protective suit, gloves, and boots (optional).
11. 2-Way radio communications (intrinsically safe).
CRITERIA FOR USE
Level A protection should be selected when the type(s)
and the concentration(s) of respirable material is known,
and requires the highest level of protection for skin, eyes,
and respiration system based on: (1) measured (or potential
for) high concentration(s) of atmospheric vapors, gases, or
particulars, or (2) site operations and work functions
involve high potential for splash, immersion, or exposure
to unexpected vapors, gases, or participates.
Level A protection should also be selected if: (3) extremely
hazardous substances (for example dioxin, cyanide compounds,
concentrated pesticides, infectious substances) are known or
suspected to be present and skin contact is possible, (4) the
potential exists For contact with substances that destroy
skin, (5) operations must be conducted in confined, poorly
ventilated areas until the absence of hazards requiring Level
A protection is demonstrated, or (6) total atmospheric readings
on HNU Photoionizer (or similar instruments) indicate
500-1,000 ppm of unidentified substances. Level A is usually
reserved for extreme circumstances and used with supervision.
II. LEVEL B PROTECTIVE EQUIPMENT
EQUIPMENT
1. Pressure-demand, approved, self-contained breathing apparatus (SCBA).
2. Chemical-resistant clothing.
3. Coveralls, chemical resistant.
4. Gloves, (outer) chemical protective.
5. Gloves, (inner) surgical (secondary protection).
6. Boots, chemical resistant, steel toe and shank.
7. Booties, (outer) chemical resistant; disposable (optional).
8. Hard hat (with optional face shield).
9. 2-Way radio communications (intrinsically safe).
CRITERIA FOR USE
Level B equipment provides a high level of protection
to the respiratory tract, but a lower level of protection
to the skin. Level B should be selected when the type(s)
and atmospheric concentration(s) of toxic substances have
been identified and require the highest level of
respiratory protection out a lower level of skin and eye
protection. These atmospheres would be ones which: (1) exceed
the limits of protection afforded by a full-face air-
purifying mask, or (2) contain substances for which air-
purifying canisters do not exist or have U>w removal
efficiency, or (3) contain substances requiring air-supplied
equipment, but substances and/or concentrations do not
represent a serious skin hazard.
Level B should also be selected if the atmosphere contains
less than 19.5% oxygen or site operations make it highly
unlikely that the smalL unprotected area of the head or neck
will be contacted by splashes of extremely hazardous substances.
III. LEVEL C PROTECTIVE EQUIPMENT
EQUIPMENT
1. Full-face, air-purifying, canister-equipped respirator.
2. Chemical-resistant clothing.
3. Coveralls, chemical resistant.
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4. Gloves, (outer) chemical protective.
5. Gloves, (inner) surgical (secondary protection).
6. Boots, chemical resistant, steel toe and shank.
7. Booties, (outer) chemical resistant, disposable (optional).
8. Escape mask.
9. Hard hat (with optional face shield).
10. 2-Way radio communications (intrinsically safe).
CRITERIA FOR USE
Level C protection is distinguished from Level B by the
equipment used to protect the respiratory system, assuming
the same type of chemical resistant clothing is used. The
main selection criterion for Level C is that conditions
permit wearing air-purifying devices. In case of low oxygen
concentrations (less than 19.5%) an air-purifying device is
insufficient. Air-purifying respirators do not provide oxygen.
Level C protection should be selected when the type(s)
and the concentratipn(s) of respirable material is known,
has adequate warning properties, or is reasonably assumed
to be not greater than the protection factors associated
with air purifying respirators and exposure of the few
unprotected areas of the body (e.g., the neck, the back
the head) is unlikely to cause harm. Continuous monitoring
of the site and/or individuals should be established.
IV. LEVEL D PROTECTIVE EQUIPMENT
EQUIPMENT
1. Coveralls, chemically resistant.
2. Boots, chemical resistant, steel toe and shank.
3. Booties, (outer) chemical resistant, disposable (optional).
4. Safety glasses.
5. Hard'hat (with optional face shield).
6. Respirator (kept readily available).
7. Work Gloves.
8. Escape mask (optional).
CRITERIA FOR USE
Level D is primarily a work uniform and should be worn
in areas where only boots can be contaminated or there
are no inhalable toxic substances. Level D protection
should only be selected when sites are positively
identified as having no toxic respiratory hazards
exceeding the limits of the respirator cartridge chosen.
3.4 PERSONAL PROTECTION
Toxic materials can enter the body primarily in one of three ways: 1) by ingestion through
the gastro-intestinal tract, 2) by absorption through the skin or through cuts and
punctures, and 3) by inhalation through the respiratory system.
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3.4.1 Ingestion Protection
As mentioned previously, inspectors should not introduce contaminants into the body by
ingestion. Drinking, eating, smoking, chewing, biting nails, etc. are prohibited at
hazardous waste sites.
3.4.2 Absorption Protection
No one material used in protective gear provides universal protection from chemical
contact. At the end of this chapter are a series of tables on the chemical resistance of
various types of absorption protection materials to aid in selecting the proper gear (see
Tables 3-2, 3-3). Note that the relative protection of the materials shown may change due
to aging, weathering, abrasion, and repeated contact with chemicals. Therefore, inspectors
must routinely check equipment for tears, splits, wear spots, cracks, and leakage prior to
use and discard any degraded equipment. Inspectors are responsible for using and
maintaining personal protection equipment in accordance with the instructions and training
they receive.
3.4.3 Respiratory Protection
Respiratory hazards include vapors or acid mists, gases, particulates (e.g., dust, smoke),
an oxygen deficient atmosphere (under 19.5% oxygen), or an "immediately dangerous to
life and health" (IDLH) atmosphere as determined by OVA/HNU equipment (see Table
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3-4). These hazards may be classified according to physical, chemical, or physiological
characteristics (see Table 3-5). Accordingly, an air purifying respirator or a self contained
breathing apparatus (SCBA) may be required.
In determining the level of protection required, an awareness of respiratory hazards is
fundamental due to the immediate effect they may have. Breathing delivers air to the
lungs with only minor filtering as it passes through the nasal passages. In the lungs, air
fills the small air sacs, called alveoli, where it is directly exposed to the blood stream.
Thus, if air is contaminated, it has a direct path into the blood stream. For this reason,
respiratory protection is essential. Note that in a low oxygen atmosphere a resiprator will
offer essentially no protection.
1. Requirements for respiratory protective devices - It is important to assess the
potential hazards and the degree of control that can be exercised over each
situation. The respiratory protective device selected in each situation will depend
on the information from the qualitative and quantitative assessment of the hazard.
Respiratory protective devices shall be required in the following tjrpes of situations:
a. When there is a high potential for a sudden release of toxic gases or vapors
or there has been such a release.
b. When making entries into environments or locations where it is known or
there is a reasonable belief that toxic airborne contaminants are present
(e.g., entering hazardous waste or spill sites).
c. During infrequent but routine operations. For instance, in a laboratory
situation where engineering controls are not feasible or adequate for the
toxicity of the material involved (e.g., bulk solvent transfers in a remote
storage building).
2. Selection of respiratory protective device - The selection of certified respiratory
protective devices shall be based on the considerations listed below.
February 1988 Page 3-9
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SAFETY PROCEDURES Inspection Manual
a. The nature of the hazardous operation or process.
b. The type of respiratory hazard.
c. The location of the hazardous area in relation to the nearest area having
respirable air.
d. The period of time the respiratory protection will be needed.
e. The employee's activities in the hazardous area.
f. The physical characteristics, functional capabilities, protective factors and
limitations of the respiratory protective devices. Refer to Table 3-6 for
general guidelines on the limitations of respiratory protective devices.
3. Use of respiratory protective devices - For safe use of respiratory protective
devices, it is essential that inspectors be instructed in their selection, use, fit, and
maintenance. Inspectors should use these devices only after they have received
training which includes but is not limited to the following:
a. The nature of hazards, whether acute, chronic, or both, and an honest
appraisal of what may happen if the improper device is worn.
b. An explanation of why respirators are a reasonable requirement when
positive control is not feasible. This should include recognition that every
reasonable effort should be made first to reduce or eliminate the need for
respiratory protection or dependency on it.
c. A discussion of why a given respirator is the proper type of unit for the
particular purpose.
d. A discussion of the device's capabilities and especially its limitations.
e. Instruction and training in actual use, to include fit and seal testing.
Respirators should be fit tested prior to each use. Donning procedures are
listed in Table 3-7.
4. Inspection, Maintenance, Storage, and Repair - Proper inspection,
maintenance, storage, and repair of respiratory protective devices are mandatory
to insure that theses devices protect the health and safety of the inspector when in
use. Consider the following procedures:
a. Inspection - All equipment must be inspected before and after each use (see
Table 3-7).
b. Maintenance - All respiratory protective devices shall be cleaned and
disinfected after each use. Maintenance includes replacement of disposable
elements such as filters and cartridges whenever necessary. All
malfunctions of the respirator should be reported to a supervisor.
c. Repair - Replacement of other than disposable parts and any repair shall be
done only by personnel with proper training and test equipment to insure
the equipment will function properly after the work is accomplished. Only
Page 3-10 February 1988
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Inspection Manual SAFETY PROCEDURES
certified parts supplied by the manufacturer for the product being repaired
shall be used.
d. Storage - Respirators shall be stored in atmospheres that will protect them
from dust, sunlight, extreme heat and cold, and from sources of damaging
chemicals. Do not leave your respirator in a car.
5. Special Considerations
a. Respiratory protective devices should not be worn when any condition
prevents a good face seal. Specific conditions not permitted are as follows:
i. Any facial hair lying between the sealing surface of a respirator
facepiece and the inspector's skin that will prevent a good seal shall
not be allowed. This includes stubble, a moustache, sideburns, or a
beard that extends outward between the face and the sealing
surface of the respirator.
ii. The temple bars or straps of glasses that pass between the sealing
surface of a facepiece and the inspector's face prevent a good seal
and shall not be permitted with a full-face respiratory protective
device. The inspector's department may fund the preparation of
face-plates which have ground into them personal eyeglass
prescriptions. This will allow for good fit, good vision and good
safety.
b. Contact lenses should not be permitted while wearing a respirator.
c. Inspectors with perforated ear drums should not wear respirators.
d. Gum and tobacco chewing should not be permitted while wearing a
respirator.
February 1988 Page 3-11
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SAFETY PROCEDURES
Inspection Manual
CHEMICAL
TABLE 3-2
CHEMICAL RESISTANCE CHART FOR GLOVES
PLASTIC NATURAL
% NEOPRENE NITRILE PVC RUBBER
' /c
\0!~
ACIDS, MINERAL
Chromic
Hydrochloric (HCL) 10%
Hydrochloric (HCL) 36%
Hydrofluoric 10%
Muriatic Acid
Nitric 10%
Nitric
Sulfuric
Sulfuric 20%
ORGANIC ACIDS
Acetic 84%
Citric
Formic
Lactic 88%
Oxalic
ALCOHOLS
Benzyl
Ethvl
Methyl
ALDEHYDES
Acetaldehyde
Benzaldehyde
Formaldehyde
ALIPHATIC SOLVENTS
Mineral Spirits
ALKALIS
Ammonium Hvdroxide 26%
Potassium Hydroxide (KOH) 45%
Sodium Hydroxide (NaOH) 50%
AROMATIC SOLVENTS
Benzene
Stoddards
Toluene
Xylene
CHLORINATED SOLVENTS
Carbon Tetrachloride
Chlorobenzene
Perchloroethylene
Trichloroethylene
ACETATES
Butyl Acetate
Ethyl Acetate
ESTERS
Diethylamine
Methylamine
F
G
F
G
G
G
F
E
E
F
G
G
G
G
G
E
G
G
P
G
G
G
G
P
G
P
P
F
P
P
P
F
F
G
F
F
G
F
G
G
F
F
E
E
F
G
F
E
G
G
E
F
F
G
G
E
E
E
F
G
F
E
F
F
P
P
F
F
G
F
F
G
P
G
G
G
F
E
E
E
G
G
E
G
G
E
F
G
F
E
E
E
G
P
F
P
F
P
P
P
F
P
P
G
F
NR
G
F
F
G
F
P
G
F
G
G
G
E
G
F
G
G
F
P
G
G
G
G
NR
P
NR
NR
NR
NR
NR
NR
P
P
F
F
Page 3-12
February 1988
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Inspection Manual
SAFETY PROCEDURES
CHEMICAL
ETHERS
Ethyl Ether
OILS AND FATS
Airplane Hydraulic Oil
Animal Fats
Cutting Oil
Linseed Oil
Mineral Oil
Vegetable Oil
OXIDES
Carbon Dioxide
Nitrous Oxide
KETONES
Acetone
Methyl Ethyl (MEK)
Methyl Isobutyl
INORGANIC SALTS
Copper Sulfate
TABLE 3-2 CONTINUED
NEOPRENE NITRILE
F
G
F
F
G
F
G
F
F
P
F
F
G
G
G
G
G
G
F
P
NR
P
PLASTIC
PVC
P
G
E
F
F
F
G
G
P
NR
NR
NATURAL
RUBBER
P
P
F
P
P
F
G
F
G
G
G
KEY TO RATINGS:
E = Excellent - Chemical has no apparent effect as tested in a laboratory.
G = Good - Chemical has very little effect.
F = Fair - Chemical has minor or moderate effect.
P = Poor - Chemical has a pronounced effect.
NR = Glove is not recommended for use.
February 1988
Page 3-13
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SAFETY PROCEDURES
Inspection Manual
TABLE 3-3
CHEMICAL RESISTANCE/PHYSICAL PROPERTIES CHART FOR SUITS
TYVEK
CHEMGARD CHEMPRUF FABRIC
CLOTHING CLOTHING CLOTHING
ALCOHOLS
Methanol, Butyl alcohol, Glycerin,
Ethanol, Isopropanol PEE
CAUSTICS
Ammonium hydroxide 38%
Sodium hydroxide 50%
Potassium hydroxide 50% E E E
CHLORINATED SOLVENTS
Carbon tetrachloride,
Perchlorethylene, Trichloroethylene,
Ethylene dibromide F F
KETONES
Methyl ethyl ketone, Methyl
isobutyl ketone, Acetone
PETROLEUM SOVENTS
White gasoline, Naphtha, Mineral
thinner, Kerosene
ORGANIC ACIDS
Citric, Formic, Tannic, Acetic
INORGANIC ACIDS
Hydrochloric 38%, Hydrochloric 10%,
Sulfuric 10%, Nitric 10%, Chromic
Sulfuric 98%, Nitric 70%
HYDROCARBONS
Stoddard solvent, Toluene,
Benzene, Xylene
Coal tar dis'tillate
Styrene
MISCELLANEOUS
Lacquer thinner
Cutting oil
Battery acid
Phenol
Insecticides
Printing ink
Dyesturfs
Pentane
Formaldehyde, Isodecaldehyde
Vegetable oil
Animal fat
Acrylonitrile, Acetonitrile
Steam
Aniline
Hydraulic fluid
Turpentine
Linseed oil
Soya bean oil
Carbon disulfide
Creosote
Paint and varnish remover
NR
G
E
G
G
F
F
G
F
E
E
NR
E
F
E
E
F
E
E
NR
E
F
E
E
G
G
F
G
F
F
E
E
E
P
G
P
F
E
E
E
E
G
E
G
E
G
G
E
E
E
P
F
F
F
F
G
F
G
G
G
E
G
F
F
G
G
F
E
G
E
E
E
E
G
E
E
F
G
G
F
E
G
E
E
F
F
G
Page 3-14
February 1988
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Inspection Manual
SAFETY PROCEDURES
TABLE 3-3 CONTINUED
TYVEK
CHEMGARD CHEMPRUF FABRIC
CLOTHING CLOTHING CLOTHING
PHYSICAL PROPERTIES
Abrasion resistance
Cut resistance
Snag resistance
Heat resistance
Low-temperature resistance
Flexibility
E
G
G
F
G
G
G
E
E
G
E
E
G
F
F
P
G
E
KEY TO RATINGS:
E = Excellent - Chemical has no apparent effect as tested in a laboratory.
G = Good - Chemical has very little effect.
F = Fair - Chemical has minor or moderate effect.
P = Poor - Chemical has a pronounced effect.
NR = Glove is not recommended for use.
February 1988
Page 3-15
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SAFETY PROCEDURES
Inspection Manual
TABLE 3-4
ATMOSPHERIC HAZARD GUIDELINES
MONITORING
EQUIPMENT
Combustible gas
Indicator
(Explosimeter)
HAZARD
Explosive
atmosphere
AMBIENT
LEVEL
ACTION
Oxygen
concentration
meter
Oxygen
Colorimetric
tubes
(Detection tubes)
Photoionizer
Organic and
Inorganic
Vapors/Gases
Organic
Vapors/Gases
10% LEL Continue investigation.
Organic
vapor
analyzer
Organic
10-25%
25% LEL
19.5%
19.5-25%
25%
Depends
on
species
1) Depends
on
species
2) Total
response
mode
1) Depends
on
species
2) Total
response
mode
(Withdraw) with extreme
caution as higher levels
are encountered.
Explosion hazard: withdraw
from area immediately.
Monitor wearing SCBA.
NOTE: Combustible gas
readings are not valid in
atmospheres with > 19.5%
oxygen.
Continue investigation with
caution. SCBA not needed,
based on oxygen content only.
Discontinue inspection: Fire
hazard potential. Consult
specialist.
Consult standard reference
manuals for toxicity data.
Consult standard reference
manuals for air concen-
trations/toxicity data.
Consult EPA Standard
Operating Procedures.
Consult standard reference
manuals for air concen-
trations/toxicity data.
Consult EPA Standard
Operating Procedures.
Page 3-16
February 1988
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Inspection Manual SAFETY PROCEDURES
TABLE 3-5
AIR CONTAMINANTS
A. PHYSICAL CLASSIFICATION
1. Mechanical Dispersoid - A mechanical dispersoid consists of particles of solid or
liquid matter formed and dispersed into the air by mechanical actions.
2. Condensation Dispersoid - A condensation dispersoid consists of particles of solid or
liquid matter formed and dispersed into air by reactions such as combustion.
3. Dust - A dust's dispersed phase is a solid mechanical dispersoid. Dust particles
range from submicroscopic to visible.
4. Spray - A spray's dispersed phase is a liquid mechanical dispersoid. The particles
are generally visible.
5. Fume - A fume's dispersed phase is a solid condensation dispersoid. The particles
are extremely small, generally less than 1 micrometer in diameter.
6. Mist - A mist's dispersed phase is a liquid condensation dispersoid. The particles
vary from submicroscopic to visible.
7. Fog - A fog is a mist dense enough to obscure vision.
8. Smoke - Smoke is defined as the products of incomplete combustion of organic
substances in the form of solid and liquid particles suspended in air and gaseous
products mixed with air. It is usually visible and may obscure vision.
9. Smog - Smog may consist of any combination of dispersoids, solid and/or liquid,
suspended in the air and gas or vapor contaminants dispersed in the air. Smog
sometimes is referred to as a mixture of fog and smoke. It is generally visible and
may obscure vision.
B. CHEMICAL CLASSIFICATION
1. Acidic - Gaseous air contaminants that are acids or react with water to form acids
are called acid vapors and gases. Acids contain hydrogen and produce positively
charged hydrogen ions when dissolved in water (e.g., HC1, Cl, Fl).
2. Alkaline - Gaseous air contaminants that are alkaline or react with water to form
bases are called alkaline or basic vapors and gases. Alkalies produce negatively
charged hydroxyl ions when dissolved in water (e.g., amines, phospine).
3. Organic - Gaseous air contaminants that contain carbon and hydrogen are
classified as organic vapors and gasses. Some of the more common organic
gaseous air contaminants are: saturated hydrocarbons (methane), unsaturated
hydrocarbons (acetylene, methyl alcohol, methyl ether), halides (carbon
tetrachloride), and aromatics (benzene).
4. Qrganometallic - Organometallic compounds are those in which metals are
chemically bonded to organic groups. Some are volatile and can become gaseous
air contaminants (e.g., tetraethyl lead).
5. Hydride - Hydrides are compounds in which hydrogen is chemically bonded to
metals and metalloids (i.e., elements intermediate between metals and nonmetals).
Examples of gaseous hydride air contaminants are diborane, pentaborane, and
decaborane.
6. Inert - Substances that seldom react chemically with other substances are called
inert. Inert gases include helium, neon, argon, and xenon.
February 1988 Page 3-17
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SAFETY PROCEDURES Inspection Manual
TABLE 3-5 CONTINUED
C. PHYSIOLOGICAL CLASSIFICATION
1. Asphyxiants - These are gases that deprive the body tissues of oxygen. Simple
asphyxiants are physiologically inert gases which at high concentrations deplete air
of oxygen leading to suffocation. Examples of simple asphyxiants include nitrogen,
nitrous oxide, carbon dioxide, helium, methane, and ethane. Chemical asphyxiants
are gases that prevent the body from utilizing an adequate oxygen supply.
Cyanide and carbon monoxide are two chemical asphyxiant gases. They bind the
hemoglobin in blood and prevent it from carrying oxygen.
2. Irritants - These are chemicals which irritate the air passages causing constriction
of the airways, which is frequently compounded by edema and infection. Examples
or irritants are the corrosives: chlorine gas, hydrogen fluoride, and ammonia.
3. Anesthetics - These are substances which depress the central nervous system
causing a loss of sensation or intoxication.
4. Systemic Poisons - These are substances which cause disease in various organ
systems.
Page 3-18 February 1988
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Inspection Manual SAFETY PROCEDURES
TABLE 3-6
RESPIRATORY PROTECTIVE DEVICE LIMITATIONS
KEY TO TYPE OF RESPIRATOR
A = Self Contained Breathing Apparatus (atmosphere-supplying, pressure demand)
B = Gas and Vapor Removing - Full Facepiece
C = Particulate Removing - Full Facepiece
TYPE OF RESPIRATOR
LIMITATIONS ABC
Protects against skin
irritation or absorption? No No No
Provides eye protection? Yes Yes Yes
No limit on respirable air supply? No Yes Yes
Movement not restricted? Yes Yes Yes
Can be used in atmospheres
immediately dangerous to
life or health? Yes No No
Protects against all contaminants? No No No
Provides protection against oxygen-
deficient atmospheres? Yes No No
Protection is not dependent on
proper cartridge, or filter? Yes No No
Provides protection regardless of
concentration of contaminant? Yes No No
Provides protection against
paniculate contaminants? Yes No Yes
No discomfort or objectionable
resistance to breathing? No No No
Can use even if contaminant has
no warning properties? Yes No No
Provides protection against
gases and vapors? Yes Yes No
No training required
for maintenance and use? No Yes Yes
Service time independent of
user's respiratory rate No No No
Is light and non-bulky? No Yes Yes
Easily worn by prescription
lense wearers? No No No
February 1988 Page 3-19
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SAFETY PROCEDURES Inspection Manual
TABLE 3-7
USE OF RESPIRATORS
A. DONNING PROCEDURE FOR TYPE A RESPIRATOR
1. Loosen harness strap adjustments.
2. Put chin in facepiece and draw back on adjustment straps evenly (i.e., top two
straps, then bottom two straps, and center strap last).
a. Harness union should be centered on the back of your head.
b. Unevenly adjusted straps will create a leak. They are also very
uncomfortable.
c. Straps should be drawn back no more than necessary.
3. Check for leaks and/or proper facial seal.
a. Cover cartridge air ports with palm of hands and attempt to pull air
through the inhalation ports - mask should collapse slightly on face.
b. Count to eight while holding your breath. The pressure inside of facepiece
should be maintained for the duration of the count.
c. If pressure is not maintained, check and/or adjust straps. (Note: Make sure
that palms are blocking all of the cartridge air ports. This could be the
source of leakage).
B. INSPECTION CHECKLIST PRIOR TO FIELD USE OF RESPIRATOR
1. Exhalation Valve - Pull off plastic cover and check valve for debris or for tears in
the neoprene valve (which could cause leakage).
2. Inhalation Valves (two) - Remove cartridges and visualty inspect neoprene valves
for tears. Make sure that the inhalation valves and cartridge receptacle gaskets
are in place.
3. Make sure a protective cover lens is attached to the lens (full facepiece).
4. Make sure you have the correct type of cartridge.
5. Make sure that the facepiece harness is not damaged. The serrated portion of the
harness can fragment preventing proper face seal adjustment.
6. Make sure the speaking diaphragm retainer ring is hand tight.
Page 3-20 February 1988
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CHAPTER 4 TABLE OF CONTENTS
Chapter 4 PERMITS AND COMPLIANCE MONITORING 4-1
4.1 Permits Under RCRA 4-1
4.1.1 Who Needs a Permit? 4-2
4.1.2 Special Situations 4-3
4.1.3 The Permitting Process 4-5
4.1.4 The Permit Application 4-6
4.1.4.1 Administrative Review of the Application 4-6
4.1.4.2 Preparing the Draft Permit 4-7
4.1.4.3 Finalizing the Permit 4-8
4.1.4.4 Changes to the Permit 4-9
4.1.5 Changes Due to HSWA 4-9
4.1.5.1 Special Permits 4-10
4.1.5.2 Waste Minimization 4-10
4.1.5.3 Corrective Action 4-10
4.1.5.4 Exposure Information 4-11
4.2 The Enforcement Program 4-12
4.2.1 Inspections 4-12
4.2.1.1 Compliance Evaluation Inspection 4-13
4.2.1.2 Comprehensive Groundwater Monitoring
Evaluation 4-14
4.2.1.3 Sampling Inspection 4-14
4.2.1.4 Record Review 4-14
-------
4.2.2 Enforcement Action 4-15
4.3 Responsibility of the Inspector 4-16
4.3.1 Regulatory Development 4-17
4.3.2 Identification Documents 4-18
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Inspection Manual PERMITS AND COMPLIANCE MONITORING
Chapter 4
PERMITS AND COMPLIANCE MONITORING
4.1 Permits Under RCRA
Owners or operators of facilities that treat, store or dispose of hazardous waste (TSDs) are
required to obtain a permit to operate a hazardous waste management facility. Permits
are very detailed statements of operating conditions for a hazardous waste facility. The3r
are issued in response to a permit application by the facility. The permit writing process,
although very detailed and time intensive, is a most valuable tool for regulating hazardous
waste at active facilities.
Closely tied to the permitting of hazardous waste facilities is the inspection of these
facilities. The basic purpose of an inspection is to monitor whether a facility is in
compliance with its permit. At the current time each State has only a limited number of
fully permitted hazardous waste facilities, most facilities are operating and inspected under
an interim status permit.
Although this chapter describes permitting and inspections as though they were federal
programs, the procedures outlined apply equally to permitting and inspection programs
run by authorized States. Readers are referred to appropriate State documents for State-
specific requirements.
February 1988 Page 4-1
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PERMITS AND COMPLIANCE MONITORING Inspection Manual
Inspections also play a key role in the permit writing process. Information gathered by
the inspector during the inspection process can be invaluable to the permit writer. As the
number of Part B permit applications submitted increases, so does the frequency with
which inspections are conducted to support the permit preparation process. Compliance
evaluation inspections conducted for this purpose provide the permit writer and/or
contractor who is writing or reviewing the application with a better understanding of the
facility layout and its operations (e.g., processes, unit design and construction, mass
balance). Inspectors can also feed back information to the permit writers about permit
conditions which are impossible to inspect or enforce. Beyond this reconnaissance-type
inspection, additional inspections are conducted during the permit preparation process (i.e.,
after the application has gone through a number of reviews and revisions). These
inspections usually focus on those facility operations which appear most likely to fail to
meet regulatory requirements. The inspector's role during an inspection in support of the
permitting process is:
- To inform the regulated facility of the requirements of the law,
- To identify those aspects of the facility's operations that do not meet regulatory
requirements, and
- To make suggestions as to alternatives or provide sources of information as to
actions necessary for compliance and for issuance of a permit.
4.1.1 Who Needs a Permit?
Owners or operators of existing or new TSD facilities must obtain an operating permit
under RCRA Subtitle C. Some exclusions to this requirement include:
1. Generators who store waste on-site in tanks or containers for less than 90 days
and comply with accumulation requirements.
2. Farmers who dispose of their own (hazardous) pesticides on-site.
3. Owners or operators of totally enclosed treatment facilities.
Page 4-2 February 1988
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Inspection Manual PERMITS AND COMPLIANCE MONITORING
4. Owners or operators of wastewater treatment units (tanks) and elementary
neutralization units (tanks or containers).
5. Transporters who store manifested wastes at a transfer facility for less than 10
days.
6. Persons adding absorbent material to waste in a container and persons adding
waste to absorbent material in a container, provided that these actions occur at the
time waste is first placed in the container.
7. Owners or operators of State licensed, permitted or registered solid waste disposal
facilities are excluded provided they only handle conditionally exempt small
quantity generator waste.
8. Ocean disposal.
9. Publicly owned treatment works (POTW).
10. UIC permitted facilities.
11. Facilities recycling certain materials (e.g., used oil, lead acid batteries) [See Section
261.6(a)(2)(3)].
Note that if any individual listed above treats, stores or disposes of hazardous waste in a
manner not covered by the exclusion, he/she is subject to permitting for that activity.
Another group exempted from RCRA's permitting regulations are those individuals
involved in an emergency situation (e.g., immediate response to a discharge or accidental
spill). In such situations, there is often insufficient time to obtain a RCRA permit for
treatment or containment activities before taking necessary action. If treatment or
containment activities are continued or initiated after the immediate response is completed,
the person performing these activities is subject to all applicable RCRA Subtitle C
permitting regulations.
4.1.2 Special Situations
Included among the ranks of facility owners and operators required to obtain a permit
under RCRA Subtitle C are the three groups eligible for unique permits described below.
February 1988 Page 4-3
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PERMITS AND COMPLIANCE MONITORING
Inspection Manual
Other Environmental Laws
Emergency Permits
New Facility Permits
EPA issues permits under a number of
different laws. In some instances the
requirements of one statute's permitting
regulations are similar to those in another
statute. To avoid duplication EPA has
simplified the application process for facilities
that need to be permitted under two statutes
with a permit-by-rule concept. A permit-by-
rule eliminates the need for facilities to
submit a full RCRA Subtitle C permit
application when they are permitted under
one of three statutes:
1. SDWA - Safe Drinking Water Act
(Underground Injection Control Permit).
2. CWA - Clean Water Act which requires a
National Pollutant Discharge Elimination
System Permit (NPDES).
3. MPRSA - Marine Protection. Research and
Sanctuaries Act (Ocean Dumping Permit).
Facilities that are in compliance with one of
these three permits must meet only a few
additional RCRA Subtitle C regulatory
requirements to receive a RCRA permit.
In potentially dangerous situations EPA can
forgo the normal permitting process.
Specifically, when there is "imminent and
substantial endangerment to human health
or the environment." a temporary (90 days
or less) emergency permit can be issued to a
(1) non-permitted facility for the storage,
treatment or disposal of hazardous waste, or
(2) permitted facility for the storage,
treatment or disposal of hazardous waste not
covered by the existing permit.
EPA also issues permits to construct and
operate new hazardous waste management
facilities. Such facilities cannot be
constructed until a permit is issued. An
exception to this rule is land treatment
facilities and incinerators which can have a
trial period to test their ability to perform
properly under operating conditions. This
period is called a trial burn for incinerators
and a land treatment demonstration for land
treatment facilities. Owners or operators of
these facilities are required to obtain permits
that are enforced while the facility is being
tested. Once the facility adequately
completes its test the owner or operator can
apply for a modification of the permit to set
final operating conditions using the data
generated from these demonstrations.
Page 4-4
February 1988
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Inspection Manual PERMITS AND COMPLIANCE MONITORING
4.1.3 The Permitting Process
All hazardous waste TSDs which are required to obtain a permit under RCRA Subtitle C
go through the same basic 5-step permitting process (except for those facilities issued a
permit-by-rule, an emergency permit, or a temporary/trial period permit as described
above).
1. Submittal of a permit application, including Parts A and B.
2. Administrative review of a permit application.
3. Preparing a draft permit.
4. Taking public comment and finalizing a permit.
5. Modifying, maintaining and terminating a permit.
There are a number of Federal laws that may affect the permit writing process, including:
- Wild and Scenic Rivers Act.
- National Historic Preservation Act of 1966.
- Endangered Species Act.
- Coastal Zone Management Act.
- Fish and Wildlife Coordination Act.
When any of these laws is applicable, its requirements must be followed. For example, the
Coastal Zone Management Act prohibits EPA from issuing a permit for an activity
affecting land and water use in the coastal zone until the applicant certifies that the
proposed activity complies with the State's Coastal Zone Management Program, and the
State or its designee agrees with the certification. (For more information on these laws
and their potential impacts on the permitting process see 40 CFR Section 270.3.)
February 1988 Page 4-5
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PERMITS AND COMPLIANCE MONITORING Inspection Manual
4.1.4 The Permit Application
Owners or operators of TSD facilities subject to permitting regulations are required to
submit a comprehensive permit application that addresses all aspects of the design,
operation and maintenance of the facility. Through the permit application, EPA or an
authorized State receives information which is used to determine the facility's compliance
with RCRA Subtitle C regulations and for developing a facility-specific permit.
The permit application is divided into two parts, A and B. Part A of the application is a
short standard form that collects general information about the facility (e.g., name of the
applicant, description of the hazardous waste activities conducted at the facility). Part B of
the permit application is more extensive than Part A. It requires the owner or operator to
supply detailed and technical information (e.g., chemical and physical analyses of the
hazardous waste to be handled at the facility). Since there is no standard form for a Part
B, the owner or operator must rely on the regulations (40 CFR Parts 270 and 264) to
determine what to include in this part of the application.
Depending on the situation, Part A and Part B may be submitted at different times.
Existing facilities (ones in operation or under construction prior to November 19, 1980)
submitted their Part A when applying for interim status. Their Part B then either can be
voluntarily submitted or "called in" by EPA.
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4.1.4.1 Administrative Review of the Application
Once the owner or operator of a facility has submitted a complete permit application (both
Parts A and B), it is reviewed and either approved or denied. The first step in reviewing
the permit application is to determine if the owner or operator has submitted all the
required information. If the application is not complete a Notice of Deficiency Letter is
sent to the owner or operator indicating the missing information. Once the owner or
operator submits this information the application is considered complete. Failure to
provide this information can result in denial of the application, enforcement action, or both.
After the owner or operator is informed, by letter, that his/her application is complete, an
in-depth evaluation of the permit application is conducted. A decision then is made to
approve or deny the application. If the permit application is denied, the owner or operator
receives a Notice of Intent to Deny and can, in turn, appeal this decision. If the
application is accepted, a draft permit is prepared.
4.1.4.2 Preparing the Draft Permit
The draft permit incorporates technical requirements and permit conditions pertaining to
the facility's operation. Permit conditions are divided into two categories - those applicable
to all permits and those applied on a case-by-case basis. Among the general permit
conditions are:
- The requirement to comply with all conditions listed in the permit.
- The responsibility to notify the appropriate agency of any planned alterations or
additions to the facility.
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- The requirement to provide, when requested, any relevant information and to allow
inspectors to inspect the facility premises under certain conditions.
- The duty to submit required reports (e.g., Biennial Report, Manifest Discrepancy
Report, Unmanifested Waste Report).
The case-by-case permit conditions include:
- Compliance Schedule - this is used to bring a facility into full compliance.
- Duration of Permit - A permit may be issued for any length of time that is less
than or equal to 10 years. The exception is a land disposal permit which is limited
to 5 years.
- Regulated unit design and operational characteristics.
4.1.4.3 Finalizing the Permit
Once the draft permit (or Notice of Intent to Deny) is completed, the public is notified and
allowed 45 days for written comment (in accordance with 40 CFR Part 25). In certain
cases (e.g., if sufficient public interest is expressed) a public hearing may be held during
this time. Along with the public notice, a fact sheet is often issued. These sheets include
detailed information pertaining to the nature of the facilitj', the contents of the draft
permit (or Notice of Intent to Deny), and the procedures to be used in reaching the final
decision on the permit application. These documents are sent to the applicant and, on
request, to any other interested person. If the information submitted during the initial
comment period "appear(s) to raise substantial new questions concerning the permit" EPA
or the State must re-open or extend the comment period.
After the comment period ends, the final decision on the permit application is issued. This
decision is binding, but may be appealed in the local U.S. Court of Appeals.
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4.1.4.4 Changes to the Permit
Periodically each facility is inspected to determine if it is operating in compliance with
permit standards and if it has altered any operations. Any changes or problems can result
in one of three actions:
- Modification of the permit conditions.
- Revocation and reissuance of the permit.
- Termination of the permit.
The owner or operator can request that any one of these actions be undertaken.
4.1.5 Changes Due to HSWA
The Hazardous Solid Waste Amendments (HSWA) of 1984 (Public Law 98-616)
significantly expanded both the scope and coverage of RCRA. These amendments resulted
in numerous changes to RCRA rules and regulations some of which have been included in
the material discussed above. Other changes are anticipated as a result of the HSWA and
the reader is advised to consult Appendix B for ways of keeping up with these changes.
Some of the changes pertaining to permits include:
1. The issuance of research, development and demonstration permits;
2. Waste minimization;
3. Corrective action at permitted facilities;
4. Exposure information and health assessments; and
5. Surface impoundment retrofits.
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4.1.5.1 Special Permits
EPA encourages the use of alternate treatment technologies. Since there are usually no
precedents for these technologies, HSWA allows the issuance of Research, Development
and Demonstration permits to facilities which employ innovative and experimental
technologies. These permits may be issued even if no permit standards for the activity are
in place (see HSWA Section 3005(G)).
4.1.5.2 Waste Minimization
One of RCRA's goals is to reduce the amount of hazardous waste generated nationwide.
To this end, HSWA requires owners or operators of permitted facilities that treat, store or
dispose of hazardous waste generated on the premises to certify annually that:
- There is a program in place to reduce the volume or quantity and toxicity of waste
to the degree determined by the generator to be economically practicable.
- The proposed method of treatment, storage or disposal used minimizes the present
and future threat to human health and the environment to the greatest extent
possible.
4.1.5.3 Corrective Action
In order to address non-compliance through the permitting process, HSWA provides (in
Section 3004(u)) that any permit issued under Subtitle C of RCRA must require corrective
action for all releases of hazardous waste or constituents, regardless of when the waste
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was placed at the facility. It further stipulates financial assurance for the completion of
corrective actions (e.g., clean up and modification to prevent recurrence.)
4.1.5.4 Exposure Information
Landfills and surface impoundments may pose a greater health risk than other types of
disposal facilities. Therefore, Congress included in HSWA the requirements that
information on the potential for public exposure to hazardous waste or constituents
through releases from the facility must accompany Part B permit applications for these
facilities. Not part of the permit proper, this exposure information is a mechanism to
identify human health problems which may arise.
This exposure information is submitted by EPA or the authorized State to the Agency for
Toxic Substances and Disease Registry (ATSDR) established under CERCLA (Superfund).
If EPA or the authorized State feels that a release would pose a substantial risk to human
health, EPA (or the State with EPA's concurrence) can request that ATSDR perform a
health assessment and take other appropriate actions under CERCLA (e.g., providing
medical care and testing to exposed individuals). At a minimum the exposure information
must address:
1. Reasonably foreseeable potential releases from both normal operations and
accidents at the facility, including releases associated with transportation to and
from the facility.
2. The potential pathways of human exposure to hazardous waste or constituents
resulting from the releases described in number 1 above.
3. The potential magnitude and nature of the human exposure resulting from releases
described in number 1 above.
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4.2 The Enforcement Program
The effective implementation of RCRA's regulatory programs depends on the compliance of
the people and companies regulated under the Act. The goals of the RCRA enforcement
program are to ensure that the regulatory and statutory provisions of RCRA are met and
to compel necessary corrective action. This requires close monitoring of facility activities
and timely legal action where non-compliance is determined. Facility inspections by
Federal/State officials are the primary tool for monitoring compliance. Legal action
following the detection of non-compliance includes the use of administrative orders, civil
law suits, or criminal law suits depending on the nature and severity of the problem. The
combination of effective monitoring and timely legal action is intended to reduce the
number of facilities not complying with RCRA's requirements.
The two essential elements to RCRA's enforcement program - inspections and enforcement
actions are briefly described below.
4.2.1 Inspections
The basic purpose of inspections is to determine whether facilities are in compliance with
State and Federal hazardous waste regulations. The basic inspection activities include site
visits, sampling, and record review. State and Federal law allows duly designated
representatives of the State to enter facilities of hazardous waste handlers, have access to
records, and inspect and obtain samples from these handlers.
Each year, as part of the EPA grant agreement, each State must commit to complete a
specified number and type of hazardous waste inspections. Areas of emphasis within
these compliance monitoring inspections include, but are not limited to groundwater
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monitoring, manifests, financial responsibility, and closure/post-closure planning and
implementation.
Annual inspections are required at all Federal-, State- or local government-operated
facilities and at least once every two years at every RCRA Subtitle C facility. Facilities
may also be inspected any time the State or EPA has reason to suspect that a violation
has occurred or when specific information is needed to support the development of RCRA
regulations.
There are four major categories of inspections as defined by the EPA. Each is briefly
described below.
4.2.1.1 Compliance Evaluation Inspection
A compliance evaluation inspection (CEI) is the primarj7 enforcement mechanism for
detection of RCRA violations. The CEI is an overall review of the hazardous waste
handler's performance. The inspection includes an onsite examination of records and other
documents maintained by the handler and an evaluation of the handler's compliance with
all applicable requirements. All applicable inspection checklists must be completed.
A CEI of a groundwater monitoring facility must address Subpart F requirements, as well
as all other aspects of compliance. Thus, CEI's of these facilities are likely to be more
complex and costly than CEI's of other hazardous waste handlers.
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4.2.1.2 Comprehensive Groundwater Monitoring Evaluation
A comprehensive groundwater monitoring evaluation (CME) is an overall review of a
facilities compliance with all applicable RCRA requirements. It encompasses everything
covered in a CEI for groundwater monitoring facilities, and a more detailed investigation of
the engineering features and effectiveness of the groundwater monitoring system and the
facility's hydrogeological conditions. In many situations, CME's will include sampling and
analysis of groundwater.
Inasmuch as CME's are to be so intensive as to identify any design or operational
deficiencies in the groundwater monitoring system, they generally will be conducted only
once during the interim status period of a facility. Subsequent inspections may be the less
intensive CEI or the Operations and Maintenance inspection. However, a significant
alteration in the facility's monitoring system could necessitate another CME.
4.2.1.3 Sampling Inspection
Sampling inspection is a type of inspection in which samples are collected for laboratory
analysis. A sampling inspection will be conducted as needed in conjunction with a CEI.
Sampling inspections may also be necessary for additional enforcement case development.
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4.2.1.4 Record Review
A record review is a detailed evaluation of (1) closure/post-closure plans and cost
estimates, and/or (2) financial responsibility documents and instruments.
4.2.2 Enforcement Action
The second element of the enforcement program is enforcement action taken to bring
facilities into compliance with RCRA Subtitle C regulations. Enforcement actions also
compel monitoring and corrective action in response to both past and present releases of
hazardous waste, non-hazardous waste or hazardous constituents.
An authorized State or EPA has a broad range of enforcement options including
Administrative actions, civil actions and criminal actions. In each situation requiring
enforcement action, a decision must be made, based on the nature and severity of the
problem at the facility, as to which option is pursued.
Administrative Actions This is a non-judicial enforcement action taken by EPA
or a State under its own authority and includes such
things as warning letters and notice of violation.
Administrative enforcement actions range from informal
notices of non-compliance to issuance of an
administrative order accompanied by a formal public
hearing. These actions tend to be less complicated than
a lawsuit and often can be very effective in forcing a
facility to comply with regulations or to remedy a
potential threat to human health or the environment.
Administrative actions provide for enforcement
responses outside the court system.
Civil Actions This action is a formal lawsuit, filed in court, against a
person who has either failed to comply with some
statutory or regulatory requirement or administrative
order or who has contributed to a release of hazardous
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waste or constituents. Civil actions are generally
employed in cases of repeated or significant violations or
where there are serious environmental concerns. Civil
actions are useful in several situations, such as a person
being sued for not complying with a previously issued
administrative order. In this case, the courts may force
the facility to comply and impose penalties. Civil actions
may be taken when a long-term solution to a problem is
desired and the jurisdiction of the court may be helpful
to ensure proper supervision of the facility's actions. In
addition, civil action may be used to stop conduct that is
too dangerous to risk non-compliance with an
administrative order.
Criminal Actions A criminal action is a prosecutorial action by the United
States Government or a State Government that can
result in the imposition of fines or imprisonment. There
are seven acts identified in Section 3008 of RCRA that
carry criminal penalties. Criminal actions are usually
reserved for only the most serious violations; six of the
seven criminal acts carry a penalty of up to $50,000 per
day or from 2 to 5 years in jail. Stated briefly, these
acts are knowingly and/or recklessly:
1. Transporting waste to a non-permitted facility.
2. Treating, storing or disposing of waste without a
permit or in violation of a material condition of a permit
or interim status standard.
3. Omitting important information from, or making a
false statement in, a label, manifest, report, permit, or
compliance document.
4. Generating, storing, treating or disposing of waste
without complying with RCRA's recordkeeping and
reporting requirements.
5. Transporting waste without a manifest.
6. Exporting a waste without the consent of the
receiving country.
The seventh criminal act is to knowingly transport,
treat, store, dispose or export any hazardous waste in
such a way that another person is placed in imminent
danger of death or serious bodily injury. This act
carries a possible penalty of up to $250,000 or 15 years
in prison for an individual or a $1,000,000 fine for a
corporation.
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4.3 Responsibility of the Inspector
The authority to conduct inspections under RCRA as specifically stated in Section 3007(a)
of the Act is granted to the EPA Administrator and any State having an authorized
hazardous waste program. An inspector is expected to be thoroughly familiar with the
legal basis for his/her actions. An inspector must be knowledgeable with respect to the
RCRA and the regulations developed under the Act. In addition, an inspector should be
familiar with other EPA-administered laws relating to hazardous and toxic materials,
including the Federal Water Pollution Control Act. the Clean Water Act, the Toxic
Substances Control Act and the Safe Drinking Water Act.
A designated inspector is authorized to do the following:
- To enter at reasonable times any establishment or other place where hazardous
wastes are, or have been, generated, stored, treated, disposed of, or transported
from.
- To obtain from any person samples for the inspection of any such waste as well as
samples of any containers or labels for such waste.
Inspections must be conducted in a prescribed manner, which includes the following:
- Presenting appropriate identification to the owner, operator or agent in charge of
the premises to be inspected.
- Entering the establishment at a reasonable time and completing inspection as
promptly as possible.
- Issuing a receipt for any obtained samples.
- Providing a duplicate sample (split sample) if requested.
- Furnishing a copy of all sample analyses, if conducted, to the owner, operator or
agent in charge.
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4.3.1 Regulatory Development
Inspection reports from RCRA-regulated facilities also provide information regarding
commercial trends, common problem areas and process details. This information is used to
devise appropriate regulatory requirements for different facets of hazardous waste
management. The inspector's responsibility in support of regulatory development is:
- To identify any issues or areas that have been inappropriately addressed in the
regulations,
- To obtain from the facility a feeling for the problems involved in meeting
regulatory requirements,
- To assist in developing improved permits, and
- To aid in improving permit enforceability.
4.3.2 Identification Documents
Either EPA or the State issues the official identification documents (e.g., State ID card,
business card) to an inspector to conduct inspections. Only persons with the proper
inspection identification are authorized to conduct facility inspections. Note that in some
States additional identification procedures must be followed. RCRA requires that the
identification documents be presented to appropriate facility personnel during each
inspection. These are valuable documents that should be kept by the inspector and should
not be photocopied.
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CHAPTER 5 TABLE OF CONTENTS
Chapter 5 WORK ETHICS 5-1
5.1 Professionalism 5-1
5.2 Attire 5-1
5.3 Dealing with Bribes and Gifts 5-2
5.4 Dealing with Conflicts of Interest 5-3
5.5 Handling Public Relations 5-3
5.6 Disclosing Information 5-3
5.6.1 Dealing with Confidential Information 5-4
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Chapter 5
WORK ETHICS
5.1 Professionalism
As a representative of a Federal, State or local agency, the inspector is often the initial or
only contact between the Environmental Protection Agency and the regulated industries.
When dealing with industry representatives and employees, inspectors must be dignified,
tactful, courteous, and diplomatic. A firm but responsive attitude helps to establish an
atmosphere of cooperation and to initiate good working relations.
Inspectors are expected to perform their duties in a professional and responsible manner.
This includes:
- Developing and reporting the facts of an investigation completely, accurately and
objectively.
- Conducting themselves at all times in the manner described in detail in their
State's code of ethics.
- Avoiding, in the course of an investigation, any act or failure to act that could be
considered motivated by reason of personal or private gain.
- Making a continued effort to improve their professional knowledge and technical
skill in conducting hazardous waste inspections.
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5.2 Attire
Good public relations and common sense require that personnel dress appropriately for
field inspections. When conducting an off-site reconnaissance where hazards would be
minimal, the inspector will have contact with the public. Therefore he/she should follow
regional policy relative to proper attire. On-site reconnaissance and inspections will
require that personnel be protected from unknown hazards or toxic materials. The
required protective clothing and breathing apparatus are described in Chapter 3.
5.3 Dealing with Bribes and Gifts
Inspectors may receive offers of varying amounts of money from persons whose activities
are being investigated. Such offers can only be interpreted as an attempt to bribe. Such
action ma3' represent blatant attempts to whitewash a serious violation or condition, or to
withhold damaging information or observations. If offered something of value, the
inspector must:
- Ask, "What is this for?"
- Explain politely, if the offer is accepted, that both parties to such transactions are
guilty of violating State statutes.
- Refuse to accept money or goods of any kind.
- Immediately document the incident and report in detail to his/her supervisor.
An inspector may not solicit or accept anything of monetary value (e.g., gifts, gratuities, or
loans) from any person or group that has a contractual or financial relationship with EPA,
the State, or the local agency. Inspectors should generally not accept food or refreshments
during an inspection tour. Instead, inspectors should provide for their own meals. Each
state has specific rules indicating what, if any, gratuities may be accepted, but the safest
policy is to accept nothing.
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5.4 Dealing with Conflicts of Interest
A conflict of interest may exist whenever an inspector has a personal or private interest in
a matter related to his/her official duties and responsibilities. Inspectors must avoid even
the appearance of a conflict of interest because such appearance damages the integrity of
your agency and its employees in the eyes of the public. Therefore, all employees must be
constantly aware of situations that represent, or appear to represent conflicts of interest.
Should there be a conflict of interest, the inspector may wish to remove him/herself from
that situation. For a detailed discussion of situations and/or activities that may result in
conflict of interest, readers are directed to the publication entitled, Responsibilities and
Conduct for EPA Employees. This information can also be found in the Federal Register
(volume 38, number 73), April 17, 1973.
5.5 Handling Public Relations
It is important for inspectors to obtain the cooperation of the public and to develop a good
working relationship with it. This relationship can be established best through diplomacy,
tact, and persuasion. Even a hostile person should be treated with courtesy and respect.
Personnel should not offer opinions concerning any person, other regulatory agency, a
manufacturer, or an industrial product. All information acquired in the course of duty is
for official use only.
5.6 Disclosing Information
Inspectors have a responsibility for making useful educational and safety information
available to the public. This policy, however, does not extend to information related to a
suspected violation, to evidence of possible misconduct or to confidential business
information. When such information is requested, personnel should immediately notify a
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supervisor and/or legal counsel. Inspectors should check whether their State has specific
policy regarding the handling of requests for information. Inspectors may use EPA's
policies on information disclosure as a guide in the absence of formal procedures of their
own.
Inspectors should cooperate with representatives of the press, other communications
media, and interested groups. When an inspection team is present, one member should be
designated as the spokesperson to provide information concerning inspection
responsibilities and investigative activities. Inspectors are not, however, press
spokespersons and are not expected to interrupt their inspection to give out information.
Questions concerning investigation of alleged violations and enforcement policy should be
referred to the appropriate State enforcement staff attorney. In all contacts with the
media, the inspector should be careful not to make careless statements.
5.6.1 Dealing with Confidential Information
All information obtained should be considered confidential until an inspection report is
made final. The inspector should rely upon their agency's policy concerning how and when
information should be released.
All confidential information obtained will be marked as such and placed in a locked filing
cabinet or safe. Only authorized personnel will be allowed access to the file. No copies of
confidential information will be made unless authorized in writing by the document control
officer (States may have other standard operating procedures). Requests for access to
confidential information by any member of the public or by a State, local or Federal
agency will be handled according to the procedure described in the Freedom of Information
Act regulations (40 CFR 2). All requests for information or for access to information will
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be referred to the responsible regional organizational unit. Confidential claims for RCRA
should not be confused with Toxic Substance Control Act (TSCA) confidential claims, which
require specific administrative procedures. Confidential procedures for TSCA are contained
in 40 CFR 2.
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CHAPTER 6 TABLE OF CONTENTS
Chapter 6 PREPARING FOR THE INSPECTION 6-1
6.1 Responsibilities of the Inspector 6-1
6.1.1 Facility File Review 6-2
6.1.2 Other Documents 6-3
6.1.3 Review of Permit 6-4
6.1.4 Coordination with Legal Staff 6-4
6.1.5 Completion of Pre-lnspection Worksheet 6-5
6.1.6 Joint Inspections 6-8
6.2 Notification of the Inspection 6-9
6.3 Site Specific Requirements 6-10
6.3.1 Inspection and Sampling Equipment 6-11
6.3.2 Health and Safety Requirements 6-11
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Chapter 6
PREPARING FOR THE INSPECTION
6.1 Responsibilities of the Inspector
Inspectors are skilled field professionals who represent regulatory agencies dealing with
industry and the public. Inspectors are responsible for conducting facility inspections in a
professional manner that reflects favorably on themselves and the agency that they
represent. Their primary responsibility is to determine facility compliance with RCRA
regulatory requirements.
Preplanning is essential to ensure that an inspection is properly focused and is conducted
smoothly, efficientlj' and in a timely manner. Activities requisite to the preplanning
process include:
- Coordination with other sections/agencies/offices.
- Review of the responsibilities of the inspector.
- Acquisition and review of facility background information.
- Completion of preinspection worksheet, and awareness of other environmental
laws.
- Notification procedures/scheduling with the facility (if appropriate).
- Identification and assembly of inspection equipment.
The objectives of the pre-inspection activities are to:
1. Obtain and review background information necessary for the inspection.
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2. Identify key facts about the facility so the inspector knows what to pay particular
attention to during the inspection.
3. Formalize questions to be addressed to facility personnel.
4. Minimize wasted time and inconvenience to facility owners and operators by not
requesting information already on file (although what is on file must be on-site and
inspected).
5. Effectively follow up on matters outstanding from previous inspections so as to
minimize the need for follow-up inspections.
Ideally, two or more inspectors should be assigned to each facility. Such a practice
facilitates information and sample collection, allows for adequate preparation prior to the
site visit, and ensures a more thorough inspection. Several benefits are associated with
Federal and State agency inspectors performing a joint site investigation. Among the
anticipated benefits are:
- A well-prepared, thorough, yet efficient inspection with no duplication of
effort/activities.
- A more comprehensive understanding of regulatory and permit requirements on
the part of the inspection team.
- A uniform information base for enforcement follow-up.
The principal sources of information the inspector needs to review include: the facility
compliance files; the notification form, Part A of the permit application; Part B of the
permit application, if available; and reports and notices required under Parts 262, 263,
and 265 of the regulations.
6.1.1 Facility File Review
To conduct a facility file review, the inspector should, at a minimum, perform the following
activities:
- Obtain copies of hazardous waste management activities reports both past and
present, and of the RCRA Permit A application and all subsequent amendments.
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PREPARING FOR THE INSPECTION
This information should be available from the appropriate EPA Region or State
office.
For TSD facilities, obtain information on the type, volume and process by which
waste is generated for each waste stream. This can be drawn from the annual
reports, Part A and/or Part B permit applications, or EPA data sheets.
Review in detail all information available in the EPA and State files. Pay careful
attention to discrepancies between prior inspections, correspondence, notifications,
Part A applications and corrective action orders. It is important to identify any
unresolved apparent violations found during previous inspections or cited in
compliance orders.
If the facility has never been inspected before, look up and review technical
documentation for that type of facility.
6.1.2 Other Documents
There are also a number of specific documents to review prior to the inspection. These
documents include:
Notice of Registration
Hazardous Waste Permit
Record-Keeping Requirement
Previous Inspection Reports
Agreements, Orders, Etc.
Financial Assurance and Liability
Obtain and review the most recent update of
the Registration or Notification documents.
Review the facility's hazardous waste permit
if applicable. Make sure that if the permit
has been amended, a copy of the amendment
is available.
Note in the Registration and Permit which
record-keeping requirements are applicable
(including RCRA groundwater monitoring
reports).
Review the most recent inspection reports
noting the violations cited and whether they
have been adequately resolved. If
appropriate, interview inspectors who have
conducted previous inspections at the facility.
Review any compliance agreements,
outstanding enforcement orders, court orders,
compliance schedules, etc. Note any dates,
schedules, special programs, operating
procedures, reporting requirements, etc. not
specified in the Permit or Registration.
If applicable, check with the State, Regional
or Federal financial assurance officer to
confirm that the facility has submitted
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proper RCRA financial assurance
documentation.
Photographs, Maps, Etc. Review maps, photographs and drawings
that describe the facility's layout and
operation. The inspector should become
familiar with the plant's physical layout and
know the location of solid waste units.
Inspectors must allow adequate time to receive information from the State agency or EPA
Region.
6.1.3 Review of Permit
It is essential that inspectors coordinate their efforts with those of personnel in the State
and Federal permitting section during the preinspection preparation phase. Such
interaction facilitates collection of information on permit conditions, applicable EPA and/or
State policies and procedures, and compliance and monitoring data. Permitting staff can
readily assist the inspector in identifying inconsistencies between permit conditions and
compliance files, and help target specific areas at the facility requiring attention.
6.1.4 Coordination with Legal Staff
Interaction between inspectors and the legal staff in enforcement or compliance sections is
strongly encouraged to enable the inspector:
1. To develop a thorough knowledge of applicable EPA and State policies,
2. To be aware of the impact of other environmental legislation on the inspection, and
3. To review the compliance file to identify and evaluate any inconsistencies with
existing regulations and/or permit conditions.
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A compliance inspection is the primary enforcement mechanism used to detect and verify
violations of RCRA. Facilities are selected for inspection either under a neutral
administrative inspection scheme or "for cause" (i.e. where probable violations of RCRA
are observed or brought to the attention of the State Agency by an employee or citizen
complaint or a competitor's tip). The authorized State agencies, EPA Headquarters, or
EPA Regional Offices may select an inspection site.
Evidence obtained during an inspection may result in any of the following actions:
- Thank you letter/no action.
- Issuance of a warning letter/Notice of Violation.
- Issuance of an administrative order.
- Assessment of an administrative civil penalty.
- A permit action.
- Institution of a civil court action.
- Institution of a criminal court investigation.
For details on the procedures for developing cases, inspectors are referred to EPA
guidelines. The EPA is currently working on a document entitled, Technical Case
Development Guidance due to be completed in early 1988 and intended for use by
inspectors, compliance officers and attorneys.
6.1.5 Completion of Pre-Inspection Worksheet
A pre-inspection worksheet serves two purposes:
1. As a check of pre-inspection activities, and
2. As a planning tool to enable the inspector to schedule pre-inspection activities more
effectively.
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Items that might appear on a pre-inspection worksheet are listed below. This list was
designed to ensure that inspectors have identified, assembled and reviewed relevant
materials prior to arrival at a facility. Such preparation will result in a more complete and
efficient inspection. Since State and Regional inspection needs, objectives, and procedures
may vary, this list is intended as a guide and should be modified to incorporate the specific
needs of the inspector.
All equipment should be well-maintained and checked regularly to see that it is in good
condition prior to each inspection. Items that are worn out or missing from the inventory
should be replaced immediately.
PRE-INSPECTION WORKSHEET
IDENTIFY AND OBTAIN ALL RELEVANT INFORMATION ON:
- Part A application.
- Part B application (when available).
- Previous inspection reports.
- Correspondence.
- Confidentiality details.
- Corrective-action orders.
- Annual reports and manifests.
- Information from air and water pollution control agencies.
- Facility's processes (e.g., raw materials, final product).
- Copies of State statute(s) and regulations or Federal laws and regulations.
- Wastes generated at the facility (e.g., characteristics, quantities).
- Talk with previous inspector if possible.
SCHEDULE THE INSPECTION:
- Letters of intent to visit/inspect (unless unannounced).
- Establish date(s) of inspection.
- Follow-up telephone calls to confirm date(s) of inspection.
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DOCUMENTS TO TAKE TO THE INSPECTION:
- Inspection checklist.
- State Agency identification card.
- Correspondence file.
- Notice of inspection (if applicable, since many inspections are unannounced).
- Notice of registration.
- Hazardous waste permit.
- Copj' of regulations.
- Violation forms.
- Chain of custody forms.
- Photographs, maps, drawings.
- Receipt for documents.
- Field notebook (for making notes and sketches).
EQUIPMENT TO TAKE TO THE INSPECTION: (varies by inspection type)
- Clipboard (with a side pocket to protect documents from wind and rain).
- Waterproof pens, pencils, markers.
- Camera with batteries.
- Film.
- Pocket Calculator.
- Compass.
- Tape Measure.
- Ice Chest.
- Watch.
- Stopwatch.
- Tape.
- "Confidential Business Information" stamp.
- Stamp pad.
- Locking briefcase.
- Envelopes preaddressed to Document Control Officer.
- Plain envelopes.
- Polyethylene bags.
- Disposable towels or rags.
- Flashlight with extra bulbs and batteries.
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- Level.
- Rangefinder.
- Wind meter.
- Sampling equipment (list below is abbreviated, see Chapter 9).
* thermometers.
* pond sampler.
* pH meters.
* preservation chemicals.
* well bailers.
* bottles (e.g., sampling jars).
- Safety equipment (list below is abbreviated, see Chapter 3).
* safety goggles or glasses.
* hard hat.
* face shield.
* safety shoes (with steel toe).
* ear plugs.
* liquid-proof gloves (preferably disposable).
* long sleeve shirt.
* long-sleeved coveralls.
* long rubber apron.
* plastic shoe covers.
* proper respiratory protection with spare cartridges.
* protective chemical resistant suits.
* disposable clothing.
6.1.6 Joint Inspections
Even when the State is the approved RCRA authority, EPA may be present during the
inspection. With this in mind, adequate time and notification should always be given to
coordinate and encourage EPA participation. The authorized State agency assumes the
lead role in performing the inspection.
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To ensure that cross-agency concerns are adequately addressed during the inspection, the
inspector should check with staff in appropriate State and Federal air and water pollution
control agencies. Inspectors should discuss problems these staff are having or have had
with the facility. Inspectors are also encouraged to obtain any information which may
assist them in identifying RCRA-regulated activities at the facilit}'.
6.2 Notification of the Inspection
There are advantages and disadvantages to notifying a facility of a routine inspection.
Notification is recommended when it is necessarj' that appropriate staff and materials be
available at the time of the site visit. Where special facility personnel must be spoken
with or particular documents must be made available, notification is essential.
Conversely, when illegal discharges or promiscuous dumping are suspected, or when the
facility has a history of violations, the program supervisor may wish to have the inspector
make an unannounced inspection to prevent the owner or operator from making any last
minute changes to the site conditions. Although such inspections offer the element of
"surprise," valuable time may be lost waiting for facility personnel to escort the inspector
through the facility. Even then, this person may or may not be familiar with
environmental regulations and requirements.
The program supervisor may use one of several methods to notify a facility owner or
operator. The method of notification varies according to the intent of the inspection.
Annual notification An annual letter can be sent establishing inspection
requirements, but not specifying an inspection date.
This letter should be followed by an advance
notification letter or telephone call, described below,
to establish the date of inspection.
Advance notification A letter can be sent to notify a facility owner or
operator of the intent to inspect within 1 month (or
some other predetermined time period). This type of
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notification does not necessarily need to be followed
up with a telephone call.
Telephone notification The program supervisor can telephone the facility's
owner or operator (one day to a week in advance) to
schedule an appointment with personnel responsible
for environmental compliance.
No notification In cases where violations are suspected or cover-up
activities are anticipated, the program supervisor
may want to arrive at the facility unannounced.
When the program supervisor elects to notify the facility, written confirmation of the date
of the site visit and the files and information to be reviewed is encouraged. Information
the inspector should convey during notification includes:
1. The inspector's name,
2. The organization or agency he/she is affiliated with,
3. The purpose of the inspection,
4. The authority under which it is to be conducted,
5. The procedures of the inspection,
6. When it is to be conducted, and
7. The names of those persons with whom the inspector needs to confer.
During the notification process, the inspector should take the opportunity to:
1. Discuss any discrepancies discovered during a review of the compliance file and
permit conditions,
2. Request that the information necessao' for evaluation be compiled or developed,
3. Obtain directions to the facility, and
4. Identify any special personal safety equipment or sampling equipment needed
during the tour of the facility. Prearranged inspections should include plans for
collection and shipping of samples.
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6.3 Site Specific Requirements
6.3.1 Inspection and Sampling Equipment
The kinds of equipment that an inspector carries depend on the type of inspection to be
undertaken, as well as the availability of certain equipment and regional policies and
conditions. The inspector is expected to use sound judgment and rely on training, past
experience, and/or colleagues in deciding which equipment is necessary for a particular
inspection. Before the field inspection, the inspector should review the site-specific
sampling requirements, procure the necessary sampling equipment (see Chapter 9 for a
discussion of sampling procedures), and make transportation and lab analysis
arrangements.
6.3.2 Health and Safety Requirements
All company and agency safety precautions should be observed. Company ID cards, and
safet3* equipment such as hard hats and safety goggles, should be worn as required for
inspection staff. Before beginning the field inspection, the inspector should review these
safety requirements and procure the necessary safety equipment (see Chapter 3 for a
discussion of safety procedures).
Special circumstances may require equipment such as fireproof clothing or self-contained
breathing units. In conjunction with the facility's owner, operator or plant manager, the
inspector must determine whether such additional safety measures are warranted.
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CHAPTER 7 TABLE OF CONTENTS
Chapter 7 CONDUCTING THE INSPECTION 7-1
7.1 Scope of the Inspection 7-1
7.2 Entry into a Facility 7-2
7.2.1 Arrival 7-2
7.2.2 Consent . . 7-3
7.3 Opening Conference 7-4
7.4 Review of Records at Facility 7-5
7.4.1 Manifest Review/Waste Tracking 7-8
7.4.2 Permit Amendments 7-10
7.4.3 Plant and Facility Maps 7-10
7.4.4 Review of Outstanding Problems 7-11
7.5 General Procedures 7-12
7.5.1 Inspection of Facilities 7-12
7.5.2 Observations 7-13
7.5.3 Dealing with Questions 7-13
7.5.4 Use of Inspection Checklists 7-13
7.5.5 When to Sample 7-15
7.6 Exit Conference 7-16
7.7 Unexpected Problems 7-17
7.7.1 Denied Access 7-17
7.7.2 Dealing with Threats and Assault 7-19
7.7.3 Use of a Search Warrant 7-19
-------
7.7.4 Suspected Criminal Activity 7-20
7.7.5 Suspected Violations in Other Programs 7-21
7.7.6 Confidential Business Information 7-21
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Inspection Manual CONDUCTING THE INSPECTION
Chapter 7
CONDUCTING THE INSPECTION
7.1 Scope of the Inspection
Inspection procedures are usually determined by the scope of the inspection. There are
several types of activities involved in conducting an inspection including:
Record Reviews Examination of facility records to
determine compliance with
recordkeeping and reporting
requirements.
Preliminary survej's An initial visual inspection.
Sampling A site visit for the purpose of
collecting samples.
Comprehensive inspections A thorough visual inspection with
sampling.
Most inspections consist of combinations of the above types. Compliance Evaluation
Inspections (CEI) usually include record reviews, and preliminary surveys.
Comprehensive Groundwater Monitoring Evaluations (CME) usually include
comprehensive inspections and sampling.
While EPA has primary responsibility for inspections at a Federal facility (which includes
Federal, State and locally owned facilities), State employees do make independent
inspections. Any classified information that is necessary before the inspection must be
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gathered by an EPA or State employee with a security clearance. (Usually, at least one
employee in each Regional office has a security clearance.)
7.2 Entry into a Facility
The authority to conduct inspections is contained in Section 3007 (a) of RCRA. This section
grants authority to an inspector to enter the premises and access the records of anyone
who "generates, stores, treats, transports, disposes of, or has handled hazardous wastes."
Whether the inspection is announced or unannounced, the inspector must:
- Present the appropriate identification to the owner, operator, or agent in charge of
the premises.
- Enter the premises at a reasonable time and complete the inspection as promptly
as possible.
- Issue receipts for samples collected.
- Split sample with facility if requested.
- Furnish owner, operator or agent with a copy of any sample analysis conducted.
- Notify the facility of the results of the inspection.
7.2.1 Arrival
All inspections should be conducted at reasonable times or during normal working hours.
Inspections that cannot be completed before the normal close of business for the facility
should be continued the next business day unless the time required for completion is so
short that the management does not object to working past normal closing time. If the
facility runs continuously or the management normally departs before operations stop, the
inspection may continue at the inspector's discretion. It is beneficial to have a facility
contact who has responsibility for environmental compliance. This information may be
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available in previous inspection reports, EPA's RCRA data base, Permit Part A or B
information.
The inspector should arrive at the facility at the appointed time, present proper
identification (State ID card and business card should suffice) and state the purpose of the
inspection. The inspector should allow the person to whom the identification documents
are presented the opportunity to closely scrutinize these identification documents since
thej' indicate that the holder is a lawful representative and authorized to perform
inspections under RCRA and all other applicable statutes. The inspector should then
document the entry in his/her log book and note the date, time and name of the facility
personnel encountered.
7.2.2 Consent
The owner or agent in charge at the time of the inspection gives consent to inspect the
premises. The inspector should be aware, however, that consent to the inspection may be
withdrawn by the facility owner or operator at any time. Any segment of the inspection
completed before the withdrawal of consent remains valid. Withdrawal of consent is
equivalent to a refused entry, and a warrant may have to be secured to complete the
inspection. The inspector should never attempt to make any forceful entry into the
facility. Section 7.7.1 describes the procedures the inspector should follow if site entry is
denied. In most cases, site entry will not be a problem.
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The "right of entry" concept is detailed below:
TABLE 7-1
RIGHT OF ENTRY MATRIX
1. Is there a reasonable (legitimate) expectation of privacy that society is prepared to
recognize?
a. If "open fields" are involved, then the answer is no.
b. If prior abandonment or undifferentiated indication that no privacy
expectations remain (e.g., premises open for all members of the public),
then the answer is no.
2. If privacy expectations generally remain, they can be waived:
a. Implicitly, by entry into a pervasively regulated industry,
b. Expressly, by virtue of permit condition consenting to entry, or
c. Expressly, by consent to specific entries.
3. If privacy expectations have not been waived, overriding lawful authority can be
invoked by:
a. Statutory warrant,
b. Administrative inspection program (probable cause) warrant, or
c. Traditional criminal (probable cause) warrant.
7.3 Opening Conference
Once site entry has been achieved, the opening conference with the company officials
provides an opportunity to improve industry-state relations and sets the tone for the entire
inspection. The inspector should quickly learn the names, job titles, and functions of all
officials participating in the inspection and of the plant manager. It is useful to exchange
business cards. Establishing a mood of cooperation between the inspector and company
officials should make conducting the inspection easier.
This meeting has several purposes:
- To outline inspection objectives. This will inform facility officials of the purpose and
scope of the inspection and may help avoid misunderstandings.
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To provide management personnel with information about RCRA and any new
rules or regulations. During the initial inspection, the inspector may wish to
discuss the provisions of RCRA with the manager and furnish a copy of the Act
and appropriate regulations. The inspector should also discuss any new rules and
regulations that might affect the facility.
To establish the order of the inspection. A well-planned schedule can eliminate
wasted time in waiting for records to be gathered, key facility personnel to be
available and intermittent facility operations to be started. Company officials
usually can make helpful suggestions allowing them to schedule plant personnel
efficiently to specific segments of the inspection.
To establish meeting schedules. If duties regarding hazardous waste handling,
storage, recordkeeping, or disposal have been delegated to various key facility
personnel, the inspector can suggest a schedule for meeting with those responsible
persons if a meeting has not been established already.
To arrange for facility personnel to accompany the inspector. During compliance
inspections, it is helpful if a facility representative accompanies the inspector to
explain operations and answer questions.
To set up a closing conference. A wrap-up meeting should be scheduled with
appropriate officials to provide a final opportunity to gather information, to answer
questions, and to complete administrative duties.
To inform plant manager and facility officials of their right to request and receive
immediately splits of any samples (gaseous, liquid or solid) collected for laboratory
analysis during the inspection, and copies of analysis results later (if an
enforcement case is not pending or being pursued).
The order of the inspection tasks should be outlined in the pre-inspection conference. The
order of these tasks will vary depending on many factors such as the type and size of the
facility, the reason for inspection, suspicion of violations, etc. The inspector may choose to
tour the facilities or to review records first. Determining the appropriate order and detail
of the inspection comes from experience and adequate pre-inspection preparation.
7.4 Review of Records at Facility
Section 3007 of RCRA states that the regulated community will "furnish" or "permit"
inspectors "to have access to and to copy all records relating to such wastes." The
regulated community must address administrative requirements for manifests,
recordkeeping and reporting; and hazardous waste facilities must comply with technical
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requirements mandating plans for waste analysis, training, contingency procedures,
groundwater monitoring and closure.
During the interim status period, RCRA inspectors are responsible for reviewing all
recordkeeping as required by Subsections 262.40, 263.22 and 265.74. Although no
standard format is required, inspectors should check for:
1. The presence of required records or plans,
2. Dates of the documents (whether they are being kept up to date and/or maintained
for the required period), and
3. Any suspected falsifications of data.
The regulatory requirements under subsections 122, 262, 263 and 265 mandate that the
following records be maintained by the regulated parties:
1. PERMIT APPLICANTS
Data used to complete permit application
Records of all monitoring information
Copies of all reports
- Annual report (265.75)
- Unmanifested waste report (265.76)
- Additional reports (265.77)
- Releases, fires, explosions
- Groundwater contamination
- Facility closure
2. GENERATORS
262.34 - Job titles and personnel records
- Agreements with local authorities
- Contingency plan
- Inspection records
262.40 - Manifests
- Annual Reports
- Exception Reports
- Waste analysis and test results (in accordance with 262.11)
3. TRANSPORTERS
263.22 - Manifests
- Shipping papers (bulk shipment by rail or water)
- Manifests for foreign shipments
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4. TREATMENT. STORAGE AND DISPOSAL FACILITIES
A. General facility standards:
265.13 Waste analysis plan
265.15 Inspection schedule
265.16 Job titles and personnel records
265.51/53 Contingency plan
265.71/72 Manifest system (records of manifests)
265.73 Operating record
265.93 Outline of groundwater monitoring plan
265.94 Groundwater monitoring record
265.112 Closure plan
265.118 Post-closure plan
B. Facility-specific standards:
265.279 Land Treatment
- Specific operating record requirements
- Specific requirements for closure plan
265.039 Landfills
- Specific operating record requirements
- Records for contents and organization of cells
- Specific requirements for closure plan
270.30 Permits
- Records of all monitoring information
C. Submittals to the Regional Administrator, see Table 7-2.
Table 7-2 below details the information that must be submitted to the Regional
Administrator or State regulatory agency under RCRA.
While performing a review of the records at the facility in accordance with the respective
generator, transporter and interim status regulation, the inspector may encounter
problems in accurately interpreting the regulations. Therefore, EPA has produced a
number of guidance documents and lists of available background documents that will aid
both the inspector and the regulated community in properly complying with the
recordkeeping requirements of Subtitle C. Consult Appendix C for a list of sources in
which these guidance documents can be found.
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Inspection Manual
TABLE 7-2
REQUIRED SUBMITTALS TO THE DESIGNATED AGENCY
Section 265.11
Section 265.12
Section 265.56
Section 265.72
Section 265.74
Section 265.75
Section 265.76
Section 265.93
Section 265.94
Section 265.115
Section 270.10
EPA identification number.
Notice of date of arrival of hazardous waste from a foreign source.
In cases of releases, fires or explosions, notification by emergency
coordinator that an affected area is adequately cleaned up before
operations are resumed.
Written report by emergency coordinator on emergency incident
within 15 days of incident.
Manifest discrepancy report within 15 days of receipt of waste.
Upon closure, copy of records of waste disposal locations and
quantities.
Annual Report
Unmanifested waste report within 15 days of receipt of waste.
In cases of confirmation of analyses indicating significant pH
increases or decreases in groundwater, a written notice that the
facilitj' may be affecting groundwater quality, within 7 days of date
of such confirmation.
Within 15 days after above notification, specific plan for a
groundwater quality assessment program at the facility.
After determination of the above groundwater quality assessment,
written report containing an assessment of groundwater quality
and/or indicating a reinstatement of the indicator evaluation
program.
Recordkeeping and reporting: groundwater monitoring information
as specified in this section.
Annual reports of Section 265.75 contain results of groundwater
quality assessment program.
Certification of closure.
Permit application and amendments.
7.4.1 Manifest Review/Waste Tracking
The inspector will have to become familiar with the facility's process from the point at
which raw materials enter the process to the point of final production. This means the
inspector must obtain a better understanding of how and when waste materials are
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generated. The inspector should tour the process to determine the points of waste
generation. However, he/she may have a more thorough understanding of the process if it
is First explained to him/her.
The inspector should begin by reviewing the permit documents (i.e., Part A) with company
officials to verify that the wastes and waste management facilities are listed correctly.
The inspector should annotate a copy of the documents. All discrepancies pointed out by
the company should be noted. The inspector should ask for a general overview of the
plant's operational status and on-site emergency procedures. For example:
- Are all manufacturing process units in operation?
- Is the company planning any expansion or shutdown of process units?
- Are all the solid waste facilities in active use?
- Are there any plans to close solid waste facilities?
- Have there been an)' recent spills or fires? How were they handled?
Upon explanation of the process, the inspector should conduct a document review of the
following:
General Facility Requirements:
- Copy of the Permit Part A or applicable permits (i.e., Air Pollution, NPDES, etc.)
- Waste Analysis Plans
- Manifest Discrepancies (record any discrepancies found, include manifest number,
transporter name and ID number, TSD facility name, ID number, waste type,
quantity, units.)
- Unmanifested Waste Reports
- Biennial reports
- Waste inspection logs
- Personnel Training plans and records
- Preparedness and Prevention plans
- Arrangements to familiarize local authorities with the layout and hazardous wastes
handled at the facility
- Contingency plans and Emergency procedures
- Operating Records
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- Groundwater Monitoring (if applicable)
- Closure and Post-closure Plans
- Purchasing orders
7.4.2 Permit Amendments
Non-commercial TSD facilities generally operate under a permit written exclusively for the
specific operation. While the facility's operation may be well-documented, it is advisable to
review the process operation prior to and during the site inspections. In some instances
amendments to permits may have been made without the inspector knowing. It is
recommended that the inspector contact the government agency responsible for the
issuance of the permit to determine if any amendments have been made. The inspector
should make a copy of the permit to refer to during the inspection.
7.4.3 Plant and Facility Maps
It is useful to review a plant map which shows all waste management facilities that are to
be inspected. The map should be studied until the inspector is familiar with the plant
layout and understands where all waste facilities are located as well as any important
topographic features such as drainage routes. Ask the company to review the file map to
make sure that it is current and correct. If it is not, make any necessary corrections or
ask the company to provide an updated map. The inspector should prepare a small map
with all waste facilities indicated on it for reference during the plant site inspection.
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CONDUCTING THE INSPECTION
7.4.4 Review of Outstanding Problems
The inspector should discuss any outstanding administrative or enforcement problems
between the company and the state or any new developments or regulatory changes that
affect the company.
For example:
RCRA Exemption Claims
Previous Violations
Enforcement Compliance Agreements
Changes in Rule Interpretation
Has the company submitted an
Affidavit of Exclusion from
permitting since the last inspection?
The inspector should review any
exclusion claims and assess them for
legitimacy.
Has the company resolved all
violations noted during previous
inspections? Ideally, these violations
would have been checked in a follow-
up inspection. Nevertheless, the
inspector should re-inspect these
units to determine if violations were
corrected.
If the company is under a compliance
agreement with the state, the
inspector should review compliance
status and prepare to inspect the
facilities in the field.
Has the company changed its position
about its status under some aspect of
the regulations? The inspector should
review the changes and discuss
consequences of the rules with the
company. If there is disagreement,
the inspector can call the District or
Central Office for advice or can
simply note the problem for later
resolution.
In summary, the inspector should "pick up all loose ends". Problems that cannot be
resolved should be noted for later review and included in the final inspection report.
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7.5 General Procedures
7.5.1 Inspection of Facilities
Step-by-step inspection procedures will vary with the type of facility being inspected.
Procedures will follow a series of checkpoints outlined in an inspection checklist. The
following are general guidelines:
1. The inspector should always be alert to problems. Ask questions or stop and
investigate any area of the plant which may pose an environmental hazard that
would fall under state jurisdiction.
2. Do not allow officials to hurry the inspection of a particular portion of the facility
or direct your inspection.
3. Do not allow officials to prevent you from talking to or asking questions of plant
operators and technicians.
4. Walk to areas of interest to you (e.g., drainage pathways, diversion ditches, creeks,
etc.) even when plant officials take other routes. Frequently check your map to
make sure that you are oriented to the plant layout. The inspection often covers
the entire facility.
The waste storage areas should be inspected thoroughly. The inspector should not limit
the inspection to known waste storage areas. He/she should be inquisitive about all
materials stored. The inspector should note the following:
- Types of hazardous wastes in storage.
- Wastes segregated according to compatibility and waste type.
- Types of containers (i.e. drums, tanks, above ground, below ground, etc.).
- Container size.
- Container integrity.
- Secondary containment (i.e., dikes, etc.).
- Emergency equipment and its maintenance (i.e. the systems, communication, etc.).
- Container management (e.g., aisle space).
- Any pretreatment prior to disposal.
- Any onsite treatment.
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- Is the facility permitted to discharge to a POTW? If yes, what materials?
- Are containers properly labeled?
- Are containers securely closed?
- Are containers leaking?
Leaks or spills from production areas could be hazardous waste. Such spills could require
RCRA closure/post-closure plans. If the waste is not hazardous, the facility should
probably be referred to another agency for follow-up.
7.5.2 Observations
The inspector may observe potential violations during the inspection. Facility personnel
may be aware that inspectors suspect violations, and may bring the matter up. When this
occurs, the inspector should then tactfully discuss the problems with the facility officials
and offer help and suggestions if possible.
7.5.3 Dealing with Questions
Inspectors should answer questions posed by facility personnel within their ability and
authority to do so. If unable to answer, inspectors should refer questions to other
personnel. These situations should be followed up when possible.
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7.5.4 Use of Inspection Checklists
The inspection checklist is a required item for completion of RCRA Compliance Evaluation
Inspections (CEI), Comprehensive Groundwater Monitoring Evaluations (CME), and other
inspections. The inspector should not limit the inspection to the questions on the checklist
but should use the checklist as a guide to evaluate facility operations and compliance.
The inspector should select the inspection checklists applicable to the facility being
inspected. As much of the checklist as possible should be filled out in the company office
where most of the records are kept. Questions that cannot be answered without visual
inspection should be left blank and filled out in the field.
Examples of checklists include:
Interim Status Checklists
Report Contents Sheet
Inspection Cover Sheet
Generators Checklist
Small Quantity Generators Checklist
Conditionally Exempt Small Quantity Generators Checklist
Facilities Checklist
Tanks Checklist
Surface Impoundments Checklist
Waste Piles Checklist
Land Treatment Checklist
Landfills Checklist
Incinerators Checklist
Thermal Treatment Checklist
Chemical, Physical or Biological Treatment Checklist
Closure and Post Closure Checklist
Closure-in-Progress Checklist
Ground Water Monitoring Checklist
Permitted Facilities Checklists:
Report Contents Sheet
Inspection Cover Sheet
Permit Compliance Checklist
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Facilities Standards Checklist
Closure/Post Closure Checklist
Closure-in-Progress Checklist
Containers Checklist
Tanks Checklist
Surface Impoundments Checklist
Waste Piles Checklist
Land Treatment Checklist
Incinerators Checklist
Transporters Checklist
7.5.5 When to Sample
If samples are to be collected, the inspector should provide the sampling equipment.
Sometimes the inspection tour is conducted by automobile or truck and sampling
equipment can be easily transported. However, leaving samples or sampling equipment
unattended or out-in-the-open can compromise sample integrity. Refer to Chapter 9 for
information on sampling procedures.
Samples should be collected whenever the composition of a particular waste stream is
suspect, or when contamination is discovered which appears to pose a threat of eventual
discharge to either ground or surface waters. In some instances, the inspector may decide
to sample a particular waste stream.
Groundwater samples should be collected and split with the facility at the time of the
annual compliance inspection. Samples should be collected from a downgradient well that
would likely be affected by the waste management facility, or from a well whose previous
samples have shown some evidence of contamination. Continued sampling should be
undertaken following submittal of an enforcement action request in order to document
additional violations and to maintain up-do-date sample data.
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7.6 Exit Conference
Facility officials are usually anxious to discuss the findings of an inspection prior to the
inspector's departure. A closing conference should be held for the presentation and
discussion of preliminary findings. This is an ideal time to answer final questions, prepare
necessary receipts, provide information about RCRA and request the compilation of data
not available at the time of inspection. The exit briefing prevents any surprise reactions
from company officials when they get the final inspection report, and gives them a chance
to challenge any findings of the inspector. It also allows the inspector direct
communication with managers, preventing possible distortion of the inspection findings by
other company officials. The inspector should be prepared to discuss general follow up
procedures, such as preparation of the final report.
The inspector is often the only contact between the State agency and the regulated
industries, and he/she should be keenly aware of opportunities to maintain and improve
State/industry relations. The closing conference provides a chance to offer various kinds of
help to facility officials. Having just completed an inspection, the inspector will have first-
hand knowledge of questions and problems and can suggest available resources to facility
officials to help deal with problems (i.e., EPA outreach materials, technical publications.
special services available to industry, etc.).
It is important for the inspector, as an industry relations representative to follow up on all
referrals and offers of help. A letter, telephone call or repeat visit will indicate to facility
officials a genuine interest on the part of the regulatory agency. Such expression of
interest will aid relations with industry by developing credibility and encourage voluntary
compliance programs.
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Inspection Manual CONDUCTING THE INSPECTION
There will be times when the closing meeting is not so cordial. The exit conference should
be frank, but courteous. Usually the inspector is outnumbered by company officials and it
is easy to become intimidated. The inspector should expect to be vigorously challenged on
any Findings. It is important to state that, except for obvious violations of the rules, all
findings are preliminary until the inspection is reviewed and the inspector has consulted
with supervisory personnel. The inspector should take the following precautions:
- Remember that the inspector's function is to observe and evaluate compliance. The
overall compliance or noncompliance status of the facility is not determined until
after review of the inspection results by supervisory personnel and issuance of the
Inspection Report.
- Realize that it is not an acceptable practice to recommend a particular consultant
or consulting firm even if asked to do so. An ethical and acceptable alternative is
to inform the permittee, operator or agent to contact a professional society
concerning this matter.
- Be careful not to provide any advice or assistance that would prejudice the State's
case in a subsequent enforcement action or that would compromise the State's
authority to require full compliance with rules or permits.
7.7 Unexpected Problems
7.7.1 Denied Access
Consent to site entry is not required for an inspector to observe and report on things in
plain view (i.e., that a member of the public could be in a position to observe). This
includes observations made while on private property in areas not closed to the public (e.g.,
matters observed while the inspector presents identification). However, if the inspector
does not have a warrant, the owner may limit the inspector's access to any portion of the
facility.
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An inspector may be denied entry for several reasons, some of which will be valid. For
instance, the inspector may not have the safety equipment required by the facility (per
OSHA or NIOSH requirements).
Other reasons will not be valid. In this case, a warrant may be obtained to conduct the
inspection. Some invalid reasons for denial include:
- Not allowing the inspector to bring in necessary equipment (e.g., camera).
- Not allowing the inspector access to documents.
- Strikes and/or plant closings.
Procedural steps in response to refused entry into a facility for the purposes of an
inspection may vary with state policy. However, as a guideline the following steps are
recommended:
- Present proper identification to the facility representative authorized to agree to an
inspection. Consent must be given at the time of inspection.
- Thoroughly document the event, noting time, date and facility personnel
encountered.
- If entry is denied, ask the reason for denial.
- Re-explain your purpose for conducting the inspection and cite and explain the
statutory provisions authorizing entry into the site.
- If the problem is beyond the inspector's authority, suggest that the facility official
contact an attorney to obtain legal advice on his/her responsibility under the
inspection statute 3007 of RCRA.
- Under no circumstances discuss potential penalties or do anything that might be
construed as threatening.
- If entry is still denied, leave the premises and document any observations made
pertaining to the denial, particularly any suspicions of violations, and the time,
date, and names and titles of any facility personnel encountered. Fill out a "Denial
of Entry Report."
- Report all aspects of denial of entry to your supervisor to determine appropriate
action, including help in obtaining a search warrant.
- An attorney (i.e., Deputy Attorney General) will assist the inspector in the
preparation of documents necessary to obtain a search warrant and will arrange
for a meeting with the inspector and an attorney. The inspector will bring a copy
of the appropriate draft warrant and affidavits to the meeting.
- The attorney will then secure the warrant and forward it to the inspector, and/or
state or local police or U.S. Marshall. The local district attorney or county judge
may, if requested, volunteer a deputy sheriff to accompany and assist the inspector
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Inspection Manual CONDUCTING THE INSPECTION
in gaining entry to the property. The amount of local assistance varies between
county governments and officials.
7.7.2 Dealing with Threats and Assault
The receptiveness of facility officials will vary from firm to firm. Most inspections will
proceed without difficulty. Whenever difficulty arises in gaining consent to enter,
inspectors should be careful to avoid making threats or inflammatory statements. The
inspector should record the date, time of day, person(s) denying access and other pertinent
facts before exiting the facility and before calling their supervisor. Other specific
procedures may be prescribed by individual agencies.
7.7.3 Use of a Search Warrant
An administrative search warrant needs only to show probable right of entry rather than
probable cause as is required of a criminal search warrant. The following points should be
adhered to when requesting a search warrant:
- Be certain that you are within your statutory jurisdiction.
- The warrant should include the right to obtain samples and photographs.
- The warrant should allow sufficient time to complete the investigation.
- Five completed copies of the warrant should be provided for the signature of the
district judge, county court at law judge, or a justice of the peace. The warrant
should be as broad as possible.
Conducting an inspection under a search warrant will differ from conducting a normal
inspection. If there is high probability that entry will be refused even with a warrant or if
there are threats of violence, the inspector should be accompanied by a U.S. Marshal or a
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CONDUCTING THE INSPECTION Inspection Manual
representative of a local law enforcement agency. The inspector should never
himself/herself attempt to make any forceful entry of the establishment. If entry is
refused to an inspector holding a warrant but not accompanied by an enforcement agent,
the inspector should leave the establishment and inform the enforcement attorney.
The inspection must be conducted strictly in accordance with the warrant. If the warrant
restricts the inspection to certain areas of the premises or to certain records, those
restrictions must be adhered to. If sampling is authorized, all procedures must be
carefully followed including presentation of receipts for all samples taken. The facility
should also be informed of its right to retain a portion of the samples obtained by the
inspector. If taking records or property is authorized, the inspector must provide receipts
and maintain an inventorj' of all items removed from the premises.
When the investigation has been completed, all samples with respective chain of custody
tag numbers, photographs and any other material evidence obtained during the inspection
should be referenced on the copies of the warrant for the peace officer and the department.
The references must be identical on both copies. When the peace officer has signed and
notarized the warrant, he/she is usually responsible for returning the executed warrant to
the issuing judge within three days. Nevertheless, the inspector should verify that a
completed copy of the warrant with pertinent signatures has been received by the judge
within the specified time. Consult departmental procedures for further guidance.
7.7.4 Suspected Criminal Activity
Any suspected criminal activity should be documented as accurately as possible, and
reported to the proper enforcement personnel immediately.
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Inspection Manual CONDUCTING THE INSPECTION
7.7.5 Suspected Violations in Other Programs
If an inspector observes potential violations in programs other than RCRA, he/she should
document and report such observations to the proper authorities immediate!}'.
7.7.6 Confidential Business Information
During the course of the inspection, an inspector may encounter a situation in which the
facility claims that certain information is confidential. When this occurs, the inspector
should pursue the proper channels for obtaining this confidential information.
It is recommended that any confidential business information included in the final
inspection report be referenced in a nonconfidential manner (i.e., by Document Control
Number and a general description of the information contained in the document). An
alternative would be to include the information, but to treat the entire inspection report as
confidential. If the latter alternative is selected, the report would be logged in with the
Document Control Officer to ensure that only persons cleared for access are permitted to
review it.
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CHAPTER 8 TABLE OF CONTENTS
Chapter 8 POST-INSPECTION PROCEDURES 8-1
8.1 Report Preparation 8-1
8.1.1 Objectives 8-1
8.1.2 Report Formats 8-2
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Inspection Manual POST-INSPECTION PROCEDURES
Chapter 8
POST-INSPECTION PROCEDURES
8.1 Report Preparation
The inspection of a hazardous waste facility is not complete until the report is entered into
the official agency files. The adequacy of follow up activities to correct problems or
deficiencies noted during an inspection depends on the completeness and timeliness of the
report the inspector prepares. This report presents the factual basis for: 1) subsequent
enforcement actions against a facility, 2) reports to the legislature and general public
regarding the statewide industrial compliance, and 3) funding received pursuant to the
Federal RCRA grants administered by the EPA.
8.1.1 Objectives
An inspection report must organize and coordinate in a comprehensive and usable manner
all relevant information and evidence gathered during an inspection. Therefore the
information must be:
Accurate All information must be factual and based on sound inspection
practices. Observations should be verifiable first-hand knowledge.
Case proceedings personnel must be able to depend on the accuracy
of all information.
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POST-INSPECTION PROCEDURES
Inspection Manual
Relevant
Comprehensive
Coordinated
Clear
Neat and Legible
Information in an inspection report should be pertinent to the
subject of the report. Irrelevant data clutter a report and can reduce
its clarity and usefulness.
The subject of the report [i.e., suspected violation(s)] should be
substantiated by as much factual, relevant information as possible.
The more comprehensive the evidence, the better and easier the
prosecution task. When gaps in information are discovered, the
inspector should obtain necessary data by means of telephone calls,
or in unusual circumstances, a follow up visit. If appropriate, the
report should also include recommendations.
All information pertinent to the subject should be organized into a
complete package. Documentary evidence (photographs, statements,
sample analyses, etc.) accompanying the report should be clearly
referenced so that anyone reading the report will get a complete and
clear overview of the subject. The narrative section, for example,
might be cross-referenced with the checklists.
The information and language in the report should be well-organized
and understandable by the general public.
Adequate time should be taken to allow for the preparation of a
neat, legible report.
The inspector who prepares the report is responsible for the accuracy of the information
detailed within the report. Inspectors and their supervisors sign and date these reports
attesting to the accuracy of the report and may be called upon to give testimony in court
regarding the inspection findings. All white-outs and handwritten changes should be
initialed and dated. All statements in the report should be supported by appropriate
observations, documents, and/or pictures or otherwise reference the source of information.
8.1.2 Report Formats
Although specific information requirements will vary with the facility, each report
comprises three elements: inspection report forms (checklists), supplementary narrative
information and documentary support. Suspected violations must be documented in these
reports. Compliance enforcement personnel will review the report file to determine the
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Inspection Manual POST-INSPECTION PROCEDURES
adequacy of the evidence, and any information needing clarification should be reviewed
with the inspector.
Most inspections of hazardous waste facilities will be reported on inspection checklists.
These lists represent only one component of a complete report; they should not be
considered sufficient by themselves. In instances where the checklist(s) need clarification
or elaboration, inspectors should make a notation in their field notebooks. The inspection
checklists used and included in reports will vary according to individual State or Regional
procedural requirements.
A supplemental narrative (often an inter-office memorandum (IOM)) accompanies the
checklists to report facts pertinent to the inspection which are not explained by the
checklists, to highlight special problems encountered, or to make recommendations for
follow up actions.
Simplicitj- of presentation should be a primary consideration:
- Use a simple writing style; avoid stilted language.
- Use the active rather than the passive voice.
- Keep paragraphs brief and to the point.
- Avoid repetition.
- Proofread the narrative carefully.
Below is a basic enumerated format for preparing an inspection report:
1. Facility Information: Name, address and telephone.
2. Responsible Official: Name and title.
3. Survey Participants: Name, agency or company.
4. Date of Inspection: Include day and date.
5. Applicable Regulations: 40 CFR Parts 260-265 (Federal
Register February 26 and May
16, 1980).
6. Purpose of Survey: Requested by, inspection of,
sampling of, etc.
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Inspection Manual
7. Facility description:
RCRA related activities.
Include the following information when inspecting hazardous waste generators:
8. General Standards:
9. The Manifest:
10. Pre-transport Requirements:
11. Recordkeeping and Reporting:
12. Special Conditions:
40 CFR Parts 262.10-262.12
(Describe compliance with these
standards).
40 CFR Parts 262.20-262.23
(Establish existence of manifest
records, assess adequacy with
regulatory requirements).
40 CFR Parts 262.30-262.34
(Review packaging, labeling,
marking and placarding
procedures for compliance with
the regulations. Establish
compliance with accumulation
time restrictions).
40 CFR Parts 262.40-262.43
(Establish existence of annual
reports and additional reports).
40 CFR Parts 262.50-262.51
(Inspect for reports of
international shipments of waste,
and proper notification to the
Administrator).
When inspecting hazardous waste transporters include the following information:
13. General:
14. Manifest System, Recordkeeping:
15. Hazardous Waste Discharges:
40 CFR Parts 263.10-263.11
(Ensure that the transporter has
obtained an EPA I.D. number).
40 CFR Parts 263.20-263.22
(Establish existence of manifest
records and compliance with
manifest procedures).
40 CFR Parts 263-30-263.31
(Ensure the transporter is aware
of the responsibilities of this
section. Check to see if any
discharge reports have been
reported to the Department of
Transportation as required by
these regulations).
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POST-INSPECTION PROCEDURES
When inspecting TSD facilities include the following information:
16. General Facility Standards:
17. Preparedness and Prevention:
18. Contingency Plan/Emergency Procedures:
19. Manifest System, Recordkeeping:
20. Groundwater Monitoring:
21. Closure and Post-Closure:
22. Facility Specific Standards:
23. Documentation of Violation:
24. Recommendations:
25. State Coordination:
40 CFR Parts 265.10-165.17
(Describe compliance with these
standards).
40 CFR Parts 265.30-265.37
(Check for required equipment
and arrangements with local
authorities).
40 CFR Parts 265.50-265.69
(Check records and procedures for
adequacy with requirements of
this section).
40 CFR Parts 265.70-265.77
(Establish existence of manifest
records, operating record, annual
report and unmanifested waste
report. Assess adequacy with
regulatory requirements).
40 CFR Parts 265.90-265.94
(Examine groundwater
monitoring plan and review
results of sampling analysis).
40 CFR Parts 265.110-265.120
(Review closure and post closure
plan for adequacy with regulatory
requirements).
40 CFR Parts 265.170-265.430
(Depending on the type of facility
being inspected establish
compliance with the appropriate
regulatory standards).
Summarize violations listed above
with quotes from applicable
regulations.
To bring facility into compliance.
Assisted by, copy of report to,
additional information obtained
from.
There are a few instances (although a very few) where only an inter-office memorandum
(IOM) and Inspection Cover Sheet are sufficient to document an inspection. One example is
the reporting of a facility which has not done a hazardous waste determination and where
no evidence exists such that the inspector can make that determination. Such situations
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are reported detailing the source(s) of waste and quantities involved, an Inspection Cover
Sheet, a copy of the Notice of Violation Letter (NOV) sent to the company detailing the
requirements for notification and waste determination, and a code sheet. Inspections of
inactive hazardous waste registrations may also be reported by IOM if there are no
facilities to inspect.
Documentation intended to provide evidence of suspected violations should be part of the
inspection report. This includes statements, photographs, drawings and maps, printed
matter, mechanical recordings and copies of permits and records.
All inspection reports (except lOM's tabulating sample analytical results) must be received
within 30 calendar days from the first day of the inspection.
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CHAPTER 9 TABLE OF CONTENTS
Chapter 9 SAMPLING PROCEDURES 9-1
9.1 Introduction 9-1
9.2 Preparation for Sampling 9-1
9.2.1 Background Information 9-2
9.2.2 Sampling Plan 9-2
9.2.3 Selection of Sampler 9-3
9.3 Sampling Equipment 9-4
9.3.1 Pond Sampler 9-4
9.3.2 Oil Thief 9-5
9.3.3 Trier 9-5
9.3.4 Bucket Auger 9-6
9.3.5 Scoop and Shovel 9-6
9.3.6 Bailer 9-7
9.3.7 Glass Tubing 9-7
9.3.8 Sample Storage Containers 9-8
9.4 Sampling Procedures 9-8
9.4.1 Number of Samples 9-8
9.4.2 Volume to Sample 9-9
9.4.3 Sampling Safety 9-11
9.4.4 Sampling Various Media 9-11
9.4.5 Analytical Parameter Selection 9-13
9.4.6 Sample Handling 9-15
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9.4.7 Sample Identification 9-15
9.4.8 Field Log Book 9-16
9.5 Chain of Custody 9-17
9.6 Shipping of Samples 9-17
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Inspection Manual __ SAMPLING PROCEDURES
Chapter 9
SAMPLING PROCEDURES
9.1 Introduction
Hazardous wastes are sampled for different purposes. In most instances, sampling is
conducted to determine if a facility is in compliance with existing regulations. In other
cases, sampling is conducted to obtain data for purposes of classifying, treating,
recovering, recycling, or determining compatibility characteristics of the wastes.
Generally, sampling of hazardous waste requires the collection of adequately sized.
representative samples of the waste. Sampling situations vary widely and therefore no
universal sampling procedure can be specified. Rather, several procedures are outlined for
sampling different types of hazardous waste in various physical states and containers.
These sampling procedures require a plan of action to maximize safety of sampling
personnel, minimize sampling time and cost, reduce errors in sampling, and protect the
integrity of the samples after collection.
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9.2 Preparation for Sampling
9.2.1 Background Information
Accurate background information about the waste to be sampled is important in planning
any sampling activity. The information is used to determine the required types of
protective equipment, sampling precautions to be observed, as well as the types of
samplers, sample containers, container closures, and, when needed, preservatives.
Generally, information about the waste determines the kind of sampling scheme to be
used.
Shipping manifests, inspection reports and other documents can provide information on the
wastes to be sampled. When documentation is not available, information may be obtained
from the facility.
9.2.2 Sampling Plan
The main purpose of the sampling program is to obtain representative samples of waste,
soil, water, and media containing or contaminated by hazardous waste. Representative
samples are needed to provide an accurate evaluation of the nature and extent of
hazardous wastes present at each site. The first step in developing a site-specific sampling
plan is to decide what is to be accomplished by the data collected during the sampling
program. Based on this overall goal, specific sampling requirements can be set. The
inspector must decide whether preliminary qualitative or detailed quantitative analysis is
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Inspection Manual SAMPLING PROCEDURES
needed; what type of equipment should be used; and what type of field measurements are
required.
9.2.3 Selection of Sampler
Hazardous wastes are often complex, multiphases mixtures of liquids, semisolids, sludges,
or solids. The liquid and semisolid mixtures vary greatly in viscosity, corrosivity,
volatility, explosivity, and flammability. The solid wastes can range from powders to
granules to big lumps. The wastes may be in drums, tanks, surface impoundments, waste
piles, barrels, sacks, bins, vacuum trucks, ponds, or other containers.
Sampling these diverse types of wastes requires different types of samplers. Sampling
devices are described in this chapter. Table 9-1 below is a general guide to the types of
waste that can be sampled by each of the samplers described.
TABLE 9-1
SAMPLING EQUIPMENT FOR VARIOUS WASTE MEDIA
OPEN DRUMS Glass tubing, drum pump, small sample jar.
TANKS, VALVES Oil thief, bucket, glass tubing.
WASTE PILES Plastic scoop, trier, shovel.
SOILS Bucket auger, shovel, plastic scoop.
IMPOUNDMENTS Pond sampler, bucket.
AIR Organic vapor analyzer, explosimeter, TIP,
Detection Tubes, O2 meter.
WELL Hydrocarbon bailer, PVC bailer, stainless steel
bailer, small sample jar, submersible sampling
pump.
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9.3 Sampling Equipment
This section describes EPA-approved equipment and procedures for obtaining
representative samples of a solid waste. The information in this section is general in
nature. Since each specific sampling situation is unique, the equipment and procedures
described must be modified appropriately in an actual use situation to ensure that
representative samples are collected.
9.3.1 Pond Sampler
Scope and Application - The pond sampler consists of a glass or plastic beaker clamped to
the end of a 2 or 3 piece telescoping aluminum or fiberglass pole which serves as the
handle. This instrument samples liquids and free-flowing slurries.
General Comments and Precautions:
- Do not use a nonfluorocarbon plastic beaker to sample wastes containing organic
materials.
- Do not use a glass beaker to sample wastes of high pH or wastes that contain
hydrofluoric acid.
- Paint aluminum pole and clamp with a 2-part epoxy or other chemical-resistant
paint when sampling either alkaline or acidic wastes.
Procedure:
1. Clean beaker, clamp, and handle.
2. Assemble sampler by bolting adjustable clamp to the pole. Place beaker in clamp
and fasten shut.
3. Turn sampler so the mouth of the beaker faces down and insert into waste
material. Turn beaker right side up when at desired depth. Allow beaker to fill
completely (as shown by the cessation of air bubbles).
4. Raise pond sampler and transfer sample to container.
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9.3.2 Oil Thief
Scope and Application - An oil thief is a brass cylindrical sampler with spring activated
upper and lower seals. The brass construction prevents the possibility of creating a spark
when it is operated. It is used to sample oil and sludges which are not high in solids.
Procedure:
1. Clean sampler.
2. Cock the sampler by pulling the upper and lower stoppers until the spring trigger is
held in the open position.
3. Lower the sampler to the desired depth and activate the spring trigger. The
stoppers will then close by the spring action.
4. Raise sampler and transfer sample to container.
9.3.3 Trier
Scope and Application - A trier consists of a tube cut in half lengthwise with a sharpened
tip that allows the sampler to cut into sticky solids and loose soil. A trier can be used to
sample moist or sticky solids with a particle diameter less than one-half the diameter of
the trier.
Procedure:
1. Clean trier.
2. Insert trier into waste material 0 to 45 degrees from horizontal. Rotate trier to cut
a core of the waste. Remove trier with concave side up and transfer sample to
container.
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9.3.4 Bucket Auger
Scope and Application - A bucket auger consists of two dull cutting bits welded to an open
ended cylinder bucket. A central metal T-shaft is attached to the other end of the cylinder.
It is used to pull an undisturbed core of soil.
General Comments and Precautions:
- This type of auger cannot be used on rocky soil.
- It is often difficult to extract the sample from the bucket intact. This will take
some practice to get it right.
Procedure:
1. Clean sampler.
2. Rotate the auger clockwise into the soil with downward pressure. When the
cylinder bucket is full, the auger is lifted and twisted out of the hole.
3. Push the sample from the opening near the shaft. The sample should scrape the
cutting bits slightly as it is extracted. Raise sampler and transfer sample to
container.
9.3.5 Scoop and Shovel
Scope and Application - Scoops are disposable sampling tools used to sample granular
material or surface soils. Shovels are reusable and are used to sample subsurface soils.
Procedure:
1. Clean the shovel.
2. Obtain a full cross section of the waste material using a scoop or shovel that is
large enough to contain the waste collected in one cross section sweep.
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3. Transfer sample to container.
9.3.6 Bailer
Scope and Application - A bailer is a tube made of PVC, stainless steel, teflon, acrylic, or
some other inert material which is open at the top. The bottom is sealed with a ball check
valve. This sampler is used in collecting water from wells.
Procedure:
1. Clean bailer.
2. Lower sampler down the well until it touches the water surface. Lower sampler
another 10 to 12 inches to allow water to enter. Pull up and raise to the surface.
Ball valve will automatically seal the bottom opening.
3. Transfer sample to container.
9.3.7 Glass Tubing
Scope and Application - Glass tubing is used to collect liquid samples. Its advantage is
that representative samples of stratified wastes can be taken and it is simple to use. The
surface tension of the waste across the opening helps to hold the sample in the tubing.
Organic wastes usually have lower surface tension than water and it may be necessary to
taper the end of the tube to prevent the sample from spilling out of the tubing.
Procedure:
1. Use clean tubing.
2. Place a wide mouth jar on the ground near the sampling location.
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3. Vertically lower the tubing to the desired depth. Make certain that at least 6
inches of tubing is kept above the waste.
4. Seal the opening with your thumb. Wearing gloves will help assure a tight seal at
the opening. With a steady and smooth motion lift the tubing and position it above
the wide mouth jar. Carefully release your thumb from the opening and allow the
sample to flow into the jar.
5. Dispose of the tubing when done.
9.3.8 Sample Storage Containers
The most important factors to consider when choosing containers for hazardous waste
samples are compatibility, resistance to breakage, and volume. Containers must not melt,
rupture, or leak as a result of handling or chemical reactions with the samples. Containers
with wide mouths are easiest to work with. The containers must be large enough to
contain the required volume of sample. The inspector should protect against the cross-
contamination of samples at all times.
Plastic containers (e.g., linear polyethylene with a polypropylene cap) can be used to collect
and store aqueous samples which do not contain oily residues, pesticides, or halogenated
hydrocarbons. Glass containers are inert to most chemicals and can be used to collect and
store all hazardous waste samples except those that contain hydrofluoric acid or a strong
alkali.
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9.4 Sampling Procedures
9.4.1 Number of Samples
Collecting one representative sample of a given waste is usually adequate to determine the
average concentration of the hazardous components. This sample can either be collected
from a single sampling point with a composite sampler, or several samples can be collected
from various sampling points and combined into one composite sample.
When gathering evidence for possible legal action (and most inspections should be
conducted with the assumption that legal action will ensue) then multiple samples of a
waste are sometimes collected. Two identical samples are desirable: one sample is given to
the person or entity responsible for the waste for its own analysis; the second sample is
submitted to the State's laboratory for analysis. A third sample can be kept in storage for
possible use as a referee sample if deemed desirable. Subdividing a waste sample is not
recommended unless it is clearly homogeneous.
9.4.2 Volume to Sample
Sufficient volume of sample, representative of the main body of the waste stream, must be
collected. This sample must also be adequate in size for all analytical needs. The
concentration of the contaminant, the type of analysis, and the sample medium determine
the volume requirements. Table 9-2 gives general guidelines for sample volume or mass
requirements.
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TABLE 9-2
RECOMMENDED SAMPLE SIZES
PARAMETER MEDIA TYPE
CONTAINER
MINIMUM SIZE
I. WET CHEMISTRY
Cyanide
Cyanide
Phenol
Phenol
COD (b)
COD (b)
Total Metals
Total Metals
Leachates
Leachates
Liquid
891! or Solid
Liquid
Soil pr Solid
Liquid
Sou or Solid
Liquid
891! or Solid
Liquid
Sou or Solid
II. HAZARDOUS CHARACTERISTIC
Flash Point
Flash Point
Corrosivity
Corrosivity
HI. ORGANICS
GC/MS (c)
GC/MS (c)
GC/MS (c)
GC/MS (c)
VOA (f)
VOA (f)
TOX (i)
TOX (i)
Liquid
Soil 9r Solid
Liquid
Sou or Solid
Liquid (d)
Liquid (e)
SoU or Solid
Soil 9r Solid
Liquid
Solid
Liquid
Solid
liter
liter
liter
liter
liter
liter
liter
liter
liter
liter
container
glass jar
glass jar
glass jar
container
glass jar
container
glass jar
container
glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
1 liter glass jar
VOA vial
1 liter glass jar
500 mlbrown glass jar
1 liter glass jar
liter
kilogram (a)
liter
kilogram (a)
liter
1 kilogram (a)
1 liter
1 kilogram (a)
1 liter
1 kilogram (a)
300-500 ml
1 kilogram (a)
1 liter
1 kilogram (a)
1 liter
40-200 ml
1 kilogram
100-300 grams
40 ml (g)
50 grams (h)
500 ml (g)
1 kilogram (a)
(a) 1 kilogram is approximately a half-filled 1 liter glass jar.
(b) Chemical Oxygen Demand
(c) Gas Chromatography/Mass Spectrophotqmetry
(d) Liquids with low concentrations of organics.
(e) Liquids with high concentrations of organics.
(f) Volatile Organics Analysis.
(g) Leave no headspace when sealing vial.
(h) More difficult than liquid, can also use VOA vial.
(i) Total Organic Halogen
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9.4.3 Sampling Safety
Proper safety precautions must always be observed when sampling hazardous waste. In
all cases, the person collecting a sample must be aware that the waste can be corrosive,
flammable, explosive, toxic, and capable of releasing extremely poisonous gases. The
background information obtained about the waste should be helpful in deciding the extent
of sampling safety precautions to be observed and in choosing protective equipment to be
used. In some situations obtaining a sample using normal sampling procedures may be too
dangerous and should not be attempted. Refer to Chapter 3 for a more detailed discussion
of safety procedures.
The following safety guidelines should be followed whenever sampling:
1. Each sample must be treated and handled as though it were extremely toxic -
sample procedures should minimize the risk of personnel exposure.
2. If special handling of a sample would be appropriate, you must also warn the
laboratory which receives the sample.
3. Approved and appropriate safety equipment, such as eye protection, hard hats,
foot protection, and respirators must be worn in areas where hazardous conditions
are suspected. In addition, eye protection should be worn when handling acidic,
caustic, or other hazardous liquids (including preservative chemicals).
9.4.4 Sampling Various Media
The following procedures are recommended for sampling different types of hazardous
waste in various containers.
Sampling a Drum Drums containing liquid wastes can be under
pressure or vacuum. A bulging drum usually
indicates that it is under high pressure and a heavily
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Sampling a Barrel
Sampling a Pond
Sampling Soil
Sampling a Waste Pile
corroded or rusted drum can readily rupture and
spill its contents when disturbed. Opening the bung
on a drum can produce a spark that might detonate
an explosive mixture in the drum. These situations
are difficult to predict and must be taken into
consideration every time a site is inspected. The
need to leave an unopened drum in an undisturbed
state cannot be overestimated. Inspectors should
exercise extreme caution when opening a sealed
drum.
If a leaking drum is discovered at a site, the
contaminated soil near the drum should be sampled.
If an open drum is discovered at a site, collect a
sample through the opening using a glass tube.
The proper protective respirator (in addition to other
protective gear) must be worn when sampling dry
powdered or granular waste from a barrel,
fiberdrum, can, bag or sack. Dry powdered or
granular wastes tend to generate airborne particles
when the containers are disturbed.
Collect a composite sample from the container with a
trier or scoop.
Storage or evaporation ponds for hazardous waste
vary greatly in size. It is difficult to collect
representative samples from the large ponds without
incurring large expenses and assuming excessive
risks. Note that there are three parts to the waste
stream: the influent, the standing liquid and the
sludge. It is easiest to sample influent, hardest to
sample sludge. An3r samples desired beyond about
11 feet (about 3.5 meters) from the bank may
require the use of a boat, which is very risky, or the
use of a crane or a helicopter, which is very
expensive. The information sought must be weighed
against the risk and expense of collecting the pond
samples. The pond sampler can be used to collect
samples as far as about 11 feet (about 3.5 meters)
from the bank.
Collect a composite sample with pond sampler.
Soil samples are taken in a grid pattern over the
entire site to ensure a uniform coverage.
First divide the area into an imaginary grid. Sample
at each intersection point in the grid and combine the
samples into one. When sampling up to 3 inches
(about 8 centimeters) deep, collect samples with a
scoop. When sampling beyond 3 inches (about 8
centimeters) deep, collect samples with a bucket
auger.
Waste piles can range from small heaps to large
mounds of waste. The waste are predominantly
solid and can be a mixture of powders, granules, and
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Inspection Manual SAMPLING PROCEDURES
chunks. A number of core samples have to be taken
at different angles and composited to obtain a
sample that, on analysis, will give average values
for the hazardous components in the waste pile.
Collect the samples with a waste pile sampler.
Sampling a Storage Tank Sampling a storage tank requires a great deal of
manual dexterity. Usually it requires climbing to
the top of the tank through a narrow vertical or
spiral stairway while wearing protective equipment
and carrying sampling equipment. Therefore, at
least two people should be involved in the sampling:
One to collect the actual samples and the other to
stand back, usually at the head of the stairway, and
observe, ready to assist or call for help. The
inspectors should be accompanied by a
representative of the company, to open any sampling
holes (usually on the tank roof).
Collect one sample each from the upper, middle, and
lower sections of the tank contents with an oil thief
sampler, combine these three samples in one
sampling container, and submit this container as a
composite sample.
9.4.5 Analytical Parameter Selection
Once the sample media and sampling points have been selected, it is necessary to select
the parameters for analysis which will provide the desired information. Those parameters
which are known or suspected to be in the waste will be the primary focus of the analytical
program. Cases where no information about the waste is known present the greatest
challenge for the inspector who must decide which parameters to request for analysis.
It is impossible to make rules for predicting which parameters to request. Each situation
is unique. The final decision is left to the inspector. Table 9-3 is a generalized guideline
which may prove helpful in developing the analysis request.
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TABLE 9-3
POSSIBLE CHEMICAL PARAMETERS TO REQUEST
I. ARE THE COMPONENTS OF THE WASTE KNOWN OR SUSPECTED?
YES - proceed to III. below.
NO - proceed to II. below.
II. IS THE SITE STABLE? (will the material be there in the near future?
YES - In a stable situation, time is on your side. It is possible to collect a
composite sample for a full spectrum of organic or metal analyses or to
collect a minimal number of samples for basic organic parameters. Later,
when specific problem areas are discovered, more samples can be collected
for advanced organic parameters or for the suspected metals. Proceed to
III. below.
NO - In this situation (unknown components at an unstable site) all points
of interest will need to be sampled at once. Since the contaminants are not
known, a balance between the number of samples and the number of
parameters must be developed by the inspector. Consider both organic and
inorganic parameters in III. below.
III. ARE THE CONTAMINANTS ORGANIC, INORGANIC (or both)?
ORGANIC - Basic organic parameters include COD, phenol, and flash
point. Advanced organic parameters include GC, GC/MS, volatile organics
analysis (VOA). Virtually all samples can be analyzed for the basic organic
parameters. Request those parameters which will meet the inspection
objectives and give information on the general type of organic compounds
with a molecular weight less than 105 AMU. Styrene is one of the
heaviest organic compounds which is best analyzed by VOA. GC is
requested for suspected contaminants which include toxaphene, PCBs,
pentachlorophenol, or samples which have few organic components
suspected. GC/MS is best utilized in analyzing complex mixtures of organic
components. There are many organic compounds (e.g., resins, esters,
polymers, monomers) which are of interest to inspectors but which cannot
be analyzed by gas chromatography.
INORGANIC - This will include pH, COD, cyanide, and metals analysis.
Aqueous samples are preserved with approved chemicals but soil and solid
waste samples are not.
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9.4.6 Sample Handling
After a sample is transferred into the proper sample container, the container must be
tightty capped as quickly as possible. The use of a preservative or additive is not usually
recommended for waste samples. However, if only one or two components of a waste are
of interest, and if these components are known to rapidly degrade or deteriorate chemically
or biologically, the sample may be refrigerated at between 39 and 43 degrees F (about 4 to
6 degrees C) or treated with preservatives according to EPA-approved guidelines.
9.4.7 Sample Identification
Each sample must be labeled and sealed properly immediately after collection. Sample
seals (e.g., gummed paper seals) may be used to preserve the integrity of the sample from
the time it is collected until it is opened for analysis in the laboratory. This seal should
carry such information as: (1) the collector's name; and (2) the date the sample was
collected.
The seal should be attached in such a way that it is necessary to break it in order to open
the sample container. The seal should adhere to both the cap and the sample container for
the entire 360 degrees around the mouth of the container.
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9.4.8 Field Log Book
All information about the sampling survey must be recorded in a log book. This must be a
bound book, preferably with consecutively numbered pages. Entries in this log book must
be made in indelible ink and include at least the following:
1. Purpose of sampling (e.g., surveillance).
2. Location and address of sampling (e.g., transporter, disposal site).
3. Name and address of field contact.
4. Generator of waste and their address.
5. Type of process producing the waste.
6. Type of waste (e.g., sludge, waste water).
7. Declared waste components and concentrations.
8. Number and volume of sample taken.
9. Description of sampling point.
10. Date and time of collection.
11. Collector's sample identification number(s).
12. Sample distribution (e.g., laboratory, transporter).
13. References such as maps or photographs of the sampling site.
14. Field observations.
15. Any field measurements made such as pH, flammability, explosivity, etc.
16. Calibration record of field equipment.
Sampling situations vary widely. No general rule can be given as to the extent of
information that must be entered in the log book. A good guideline is to record sufficient
information so that another person can easily reconstruct the sampling situation without
relying on the collector's memory. It is also worth remembering that the log book may
become evidence in a court case. The log book should be maintained in good condition,
protected and kept in a safe place.
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9.5 Chain of Custody
Chain of custody (COC) requires permanent records of all sample handling and shipment.
Chain of custody procedures must be used to ensure sample integrity, and legally and
technically defensible data. One member of the inspection team should be responsible for
initiating chain of custody procedures and documenting the sample source.
The sample should be kept in view or within limited access, locked storage until custody is
relinquished and formal documentation of the transfer is complete. The person collecting a
sample will start the chain of custody procedure.
9.6 Shipping of Samples
Samples should be delivered to the laboratory for analysis as soon as possible - usually
within one day after sampling. The samples must be accompanied by all chain of custody
records and by a sample analysis request sheet. The samples must be delivered to the
person in the laboratory authorized to receive samples (often referred to as the sample
custodian).
When a sample is shipped to the laboratory, it must be packaged in a proper shipping
container to avoid leakage and/or breakage. A cardboard or styrofoam box that will
provide at least 4 inches (about 10 centimeters) of tight packing around the sample
container must be used. Acceptable packing materials include sawdust, vermiculite,
polyurethane chips, or crumpled newspaper. Other samples that require refrigeration
must be packed with reusable plastic packs or cans of freezing gels (e.g., "blue ice packs")
in molded polyurethane boxes with sturdy fiberboard protective cases. The boxes must be
taped closed with masking tape or fiber plastic tape. For additional details contact the
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local Postal Service Office and/or refer to the EPA document SW-846, Test Methods for
the Evaluation oF Solid Waste, Physical/Chemical Methods.
All packages must be accompanied by the chain of custody records. Complete address of
the sender and the receiving laboratory must legibly appear on each package. When sent
by mail, register the package with return receipt requested. When sent by common
carrier, obtain a copy of the bill of lading. Post office receipts and bill of lading copies may
be used as part of the chain of custody documentation.
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CHAPTER 10 TABLE OF CONTENTS
Chapter 10 BASIC EVIDENCE COLLECTION 10-1
10.1 Written Records 10-1
10.1.1 Field Notebooks 10-2
10.1.2 Checklists 10-3
10.1.3 Maps and Drawings 10-4
10.2 Photographic Records 10-5
10.2.1 Precautionary Measures During Evidence Collection .. 10-6
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Inspection Manual BASIC EVIDENCE COLLECTION
Chapter 10
BASIC EVIDENCE COLLECTION
10.1 Written Records
All information pertinent to field activities, including sampling, must be recorded in several
forms: log or field books, checklists, photographs, maps and drawings. Proper
documentation and document control are crucial to enforcement actions since the
government's case in a formal hearing or criminal prosecution often hinges on evidence
gathered by others. Therefore, each inspector must keep detailed records of inspections,
investigations, photographs taken, and thoroughly review all notes before leaving the site.
It is standard practice to use a bound book to keep notes in, loose paper should not be used
in the field to record observations.
The purpose of document control is to assure that all documents for a specific project are
accounted for when the project is completed. Accountable documents include items such as
log books, field data records, correspondence, sample tags, graphs, chain-of-custody
records, analytical records and photographs. Each document should bear a serial number
and should be listed, with the number, in a project document inventor}' assembled at the
project's completion. Waterproof ink must be used in recording all data bearing serial
numbers.
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10.1.1 Field Notebooks
In keeping field notes, each inspector should maintain a legible daily diary containing an
accurate and inclusive documentation of all inspection activities, conversations and
observations. This will include any comments, as well as a record of sampling points,
photograph points, and areas of potential violation.
Because sampling situations vary widely, notes should be as descriptive and inclusive as
possible. Someone reading the entries should be able to reconstruct the sampling situation
from the recorded information. Because the diary will form the basis for later written
reports, it must contain only facts and observations. Language must be objective, factual,
and free of personal feelings or any other inappropriate terminology. The inspection report
is a carefully prepared, comprehensive report that documents any suspected violations.
These data may also serve as an aid to giving testimony. If anyone other than the person
to whom the log book was assigned makes an entry, he/she must date and sign it.
This information must be entered in a bound book with consecutively numbered pages.
Field notes are part of the State agency's files, not the inspector's personal record.
Entries in the log book must include at least the following:
- Date and time of entry.
- Purpose of sampling/inspection.
- Name and address of field contact (Federal, State, local representative).
- Producer of waste and address (if known).
- Type of process producing waste (if known).
- Type of waste (sludge, wastewater, etc.).
- Description of sample.
- Waste components and concentrations (if known).
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- Number and size of sample taken.
- Description of sampling point.
- Date and time of collection of sample.
- Collector's sample identification number(s) and/or name.
- References such as maps/photographs of the sampling site.
- General environmental setting.
- Level of activity at the site.
- Land use near the site.
- Evidence of contamination.
- Ground water seeps.
- Field measurements such as pH, specific conductivity, and dissolved oxygen levels
of wastes, ponded water and leachate (if applicable).
- Erosion and runoff problems.
- Slope instability and differential settling.
- Local bedrock and soil properties.
- Vegetation.
- Animals and animal tracks.
- Evidence of unauthorized use by humans (e.g., dirt bike trail).
- Number and types of buildings nearby.
- Site security.
- Facility design, construction and operation.
- Leachate and gas collection and treatment.
- Site monitoring.
10.1.2 Checklists
Checklists should be used in conjunction with field notes. Checklists are reprinted in
various EPA documents (see Appendix C) and are available from State agencies. These
checklists ensure that all necessary areas of concern are reviewed during the inspection.
These checklists should be used as tools for ensuring a comprehensive review, but they
should not be used as substitutes for judgment.
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10.1.3 Maps and Drawings
Schematic maps, drawings, charts and other graphic records can be useful in supporting
violation documentation. They can provide graphic clarification of a particular site relative
to the overall facility; spill or contamination parameters relative to height or size of
objects; and other information that, in combination with other documentation, can produce
an accurate and complete evidence package. In collecting maps consider such sources as
U.S. Geological Survey topographic maps, Soil Conservation Service aerial photographs,
FHA flood plain maps, etc.
Maps and drawings should be simple and free of extraneous details. Basic measurements
should be included to provide a scale for interpretation, and compass points should be
included.
As mentioned earlier, the inspector should have plant and facility maps provided either by
the facility or in agency files and should prepare a small map with all waste facilities
located on it. In situations when these are not available (e.g., illegal disposal site), a
sketch map is needed.
A sketch map should include the following features:
- Name of site visited.
- Location in relation to major transportation routes.
- Permanent landmarks (e.g., roads, power lines, streams, homes).
- An approximate scale to measure size and distances.
- An arrow indicating north.
- Locations of wastes.
- Locations of important features.
- Locations where photographs were taken.
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- Directions of water drainage.
- The date and preparer's name.
Even minor observations should be noted. For example, a small patch of dead vegetation
could mark the location of a contaminated ground water plume.
After returning to the office, the inspector should redraw the sketch map. Typically field
sketches are crudely drawn and redrawing the map provides inspectors with a good
opportunity to review the visit and clarify technical details. If a later visit is needed for
sampling, note locations on or near the site that would be useful sampling stations. Such
locations might include private wells belonging to nearby residents, waste piles, ground
water seeps, adjacent surface waters, and leachate streams. Note these sampling
possibilities on the sketch map.
10.2 Photographic Records
Although the camera is not a substitute for good field notes, photographs are the most
accurate record of the field inspector's observations. They can be significant during future
inspections, informal meetings and hearings. Documentation of a photograph is crucial to
its validity as a representation of an existing situation.
Good photos convey information which might otherwise be missed during the site visit;
poor photographs contribute little. Consequently, investigators should:
- Before entering the site, load the camera with film appropriate for light conditions.
- Be sure the film advances properly after each photo.
- Do not try to get too much into each picture.
- Stand close to the feature being photographed to ensure maximum resolution.
- Frame the picture in the view finder to avoid having to crop photos later.
- Be sure to account for special conditions which might affect light metering, such as
especially cold weather or highly reflective surfaces (e.g., snow, sand, stainless
steel pipes).
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- Use a camera-lens system with a perspective similar to that afforded by the naked
eye (telephoto or wide-angle shots cannot be used in enforcement proceedings).
- Take too many rather than too few photos.
• Include in a photo identifiable landmarks, such as a corner of a building.
- Develop the film as soon as possible after the survey.
After taking each picture, record the feature being photographed on a site sketch map.
For each photo, note the numbers of the film roll and the exposure, the weather, and the
direction from which the photo was taken. Once the film is developed, record above
information and a brief introduction of the picture on the back of prints or on a separate
piece of paper for slides.
A photograph must be documented if it is to be a valid representation of an existing
situation. Therefore, for each photograph taken, several items should be recorded in the
field log book.
- Day, date and time.
- Signature of photographer.
- Name and identification of site.
- General direction faced and description of the subject.
- Location on site.
- Sequential number of the photograph and the roll number.
Comments should be limited to the photograph's location because any remarks about its
contents could jeopardize its value as legal evidence.
10.2.1 Precautionary Measures During Evidence Collection
Special care needs to be taken around explosive hazards. As a precaution, don't get any
closer than necessary to take a good photo and don't use a flash or strobe. Fortunately,
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some organic chemicals will create an extremely uncomfortable breathing environment at
their lower explosive limit (> 10,000 ppm). But this will not always be the case. Some of
the more dangerous organics include natural methane (found in landfills and sewers) and
hydrogen (from acids, cylinders, and electrolysis).
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CHAPTER 11 TABLE OF CONTENTS
Chapter 11 SPECIAL PROCEDURES 11-1
11.1 Discharge Responses Investigations 11-1
11.1.1 Introduction 11-1
11.1.2 Notification Requirements 11-2
11.1.3 Initial Response to a Spill 11-2
11.1.4 On-The-Scene Response 11-4
11.1.5 Safety Considerations 11-5
11.2 Courtroom Testimony 11-5
11.2.1 Before You Testify 11-6
11.2.2 On Your Day in Court 11-6
11.2.3 While on the Witness Stand 11-7
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Inspection Manual SPECIAL PROCEDURES
Chapter 11
SPECIAL PROCEDURES
11.1 Discharge Responses Investigations
11.1.1 Introduction
A discharge is usually defined as an act or omission by which hazardous substances in
harmful quantities are spilled, leaked, pumped, poured, emitted, entered, or dumped onto
or into waters or by which those substances are deposited where, unless controlled or
removed, they may drain, seep, run, or otherwise enter bodies of water. A body of water
includes groundwater as well as all surface waters - therefore, any hazardous substance
that comes into contact with the ground is a threat to water and should be considered a
discharge. A "hazardous substance" is not limited to the RCRA definition of a hazardous
waste but may include substances that will cause pollution if they enter water.
Discharge response is a field in itself and is quite separate from a RCRA inspector's
normal duties. Discharge response personnel are potentially at great risk. For this reason
they receive specialized training and have special equipment available for their use. This
section is included in this manual because of the content overlap of RCRA inspections and
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discharge response investigations. Inspectors are advised to consult with their supervisors
concerning their State's discharge response procedures.
11.1.2 Notification Requirements
accidental discharge which causes or threatens to cause pollution must be reported.
Most States have a 24-hour emergency telephone number that should be contacted as soon
as possible. In addition, one can contact:
SUPERFUND/RCRA HOTLINE
DOT EMERGENCY NUMBER
CENTER FOR DISEASE CONTROL
CHEMTREC
800-424-9346 (202-382-3000 in Washington,
D.C.). This number is staffed by EPA's
Office of Solid Waste and Emergency
Response. The hotline staff have up-to-date
understanding of the RCRA regulatory
requirements and can provide details on
changes in procedural requirements.
800-424-8802. This is the National
Emergency Response Center for
transportation emergencies staffed by the
U.S. Department of Transportation 24 hours
per day.
404-633-5313.
800-424-9300. This is the Chemical
Transportation Emergency Center, a public
service of the Chemical Manufacturers
Association. Chemtrec operates around the
clock to provide immediate advice for those at
the scene of transportation emergencies.
11.1.3 Initial Response to a Spill
Because spills often do not lend themselves to standard water pollution control and
abatement techniques, it is necessary for personnel to be trained in special emergency
procedures. Most States have established discharge response teams. Such persons should
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coordinate the emergency response and be capable of assessing a spill emergency to
determine if the response is effective and if not, what action should occur. These
coordinators should proceed through the following three steps:
1. Gather as much information as possible from the notifier and maintain contact
with a person with up-to-date knowledge of on-scene activities (if not the notifier).
Below is a list of questions the coordinator should have answers to:
a. Date and time of the spill.
b. Type of material(s) spilled (i.e., incompatibility of chemicals).
c. Estimate of the quantity spilled.
d. Exact location of the spill.
e. Extent of any injuries.
f. Hazards to human health and the environment (i.e., are waters
threatened?)
g. Weather conditions.
h. Name, address and, telephone number of responsible party.
i. Party at spill site in charge of operations and their telephone number.
j. Steps taken or proposed for response.
k. Source of spill.
2. Verify notifier s information, if necessary, with the company or locally involved
authorities (e.g., Sheriffs office).
3. Thoroughly review the characteristics of the spilled material(s) using available
references. If in doubt, do not hesitate to contact the Superfund Hotline at
800-424-9346 (202-382-3000 in Washington, D.C.), CHEMTREC at
800-424-9300, or the DOT Emergency Number at 800-424-8802. Determine the
following:
a. Health hazards involved and the personal safety equipment necessary to
provide appropriate protection.
b. If incompatible chemicals are involved which might represent a
substantially greater hazard.
c. If the material(s) spilled was a product or a waste before the spillage event
occurred (this information may influence subsequent decisions regarding
cleanup and disposal actions).
d. Determine the adequacy of the on-going response (if any) and if other
groups should be present at the scene.
e. Determine if crowd control measures need to be taken.
f. If appropriate, notify and coordinate with other State and federal agencies
who should be informed and/or involved.
g. If going to the scene of the spill, determine the number of personnel
necessary to safely investigate the spill and assemble appropriate sampling
and monitoring equipment, spill response maps, and references.
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11.1.4 On-The-Scene Response
Determine the exact location of the spill and approach it from upwind upon arrival at the
scene. Personnel with spill response training and who participate in a health monitoring
program are the best qualified to investigate a spill where personal safety protection is
required. The following are general guidelines for responding to the scene of a spill:
1. Take appropriate personal protection safety gear, a camera and film, reference
guides, and sampling and monitoring equipment.
2. Park your automobile upwind, a safe distance from the spill, in an area that can be
easily evacuated.
3. If competent response personnel are on the scene, locate the on-scene coordinator.
Identify yourself and ascertain the current status of the response. Do not enter
potentially hazardous areas without adequate personal protection and never enter
areas where hazards are likely but unknown.
4. If an adequate response has not been initiated, direct the responsible party as to
what appropriate action should be taken (local authorities are generally cooperative
in providing support). If the response and/or cooperation of the responsible party
remain inadequate, contact your supervisor.
5. If there are no responsible persons at the scene, then notify the proper authorities
and make an initial survey of the scene (from a safe distance), determining:
a. The location of threatened or potentially threatened people (i.e., is there a
need for evacuation?, is a public water supply threatened?).
b. The presence of hazardous materials (i.e., possible identification through
placards, shipping papers).
c. Potential environmental threats (e.g., via runoff).
d. Are the proper safety procedures being followed?
e. Methods of arresting the source of the spill.
f. Even when there are persons at the scene responding to the spill, do not
hesitate to make recommendations such as diking, runoff control, booming a
waterway, not washing the spill into a drain, or wearing greater safety
protection.
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11.1.5 Safety Considerations
The following safety precautions are to be observed during any on-scene spill investigation.
Refer to Chapter 3 for more information of safety procedures.
1. Avoid direct contact with spilled materials.
2. Remain upwind and avoid inhalation of gases, vapors, or smoke. Do not depend on
your nose - some chemicals are odorless or inhibit your sense of smell and may
overpower you before escape is possible. Do not enter potentially hazardous areas
without adequate personal protection and never enter areas where hazards are
likely but unknown.
3. Stay out of low-lying areas where heavy vapors may concentrate unless the area
has been adequately monitored and deemed safe.
4. Provide for the removal and/or isolation of all ignition sources (e.g., electric sparks,
cigarettes, automobiles, improper grounding) when dealing with flammable or
unknown substances.
5. If the response requires that vehicles be moved (e.g., tank truck, equipment
involved in the spill), retreat to a position safe from splashing or possible ignition.
6. Upon leaving a contaminated area, dispose of or decontaminate protective clothing
and other gear.
11.2 Courtroom Testimony
The following guidelines are made for prospective witnesses in order to lessen the
apprehensions which many people have when first testifying before a Board, Commission,
Hearing Officer, or in Court. It is of utmost importance that the witness be thoroughly
prepared as to the subject matter of his or her testimony. Only the witness can recall
what occurred in the field and/or the laboratory and why. Since many cases are tried
substantially later than the field or laboratory activities occur, it is important that
adequate documentation be originally prepared in order that a witness' memory may be
refreshed, through the use of original notes. A thorough and detailed review of all relevant
documents is the only way prospective witnesses can be adequately prepared.
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In order to assist witnesses on how they should conduct themselves, the following
suggestions are given:
11.2.1 Before You Testify
1. If you are going to testify concerning records, review them. You should know what
is contained in the records, and you should be able to locate such information
easily. If you are not familiar with the particular records about which you will
testify, study them. You may be asked, among other things, to authenticate them
as records made and kept in the regular course of your work.
2. If you are going to testify about an event that happened in the distant past, try to
refresh your memory. You can, for example, return to the scene where the event
took place. Try to picture the exact scene: remember dates, times, the location of
physical objects, approximate distances, the weather, and locations of people.
Talking to other people who were there may help recall details that you had
forgotten.
3. If you have previously given a written statement, ask to see it. If you testified
before about the same matter, review the transcript of your earlier testimony.
4. If you have never done so, visit a court trial or board hearing and listen to other
witnesses testifying. This will make you familiar with such surroundings and will
help you to understand some of the things you will come up against when you
testify.
11.2.2 On Your Day in Court
1. Dress neatly and conservatively - your normal business attire is probably about
right. Remember that your appearance and attitude have an effect on the outcome
of a case.
2. If you have received a subpoena, take it with you. It may be helpful, for example,
it tells you what the case number is.
3. Be on time. When you arrive at the courtroom, if you do not know the attorney
who subpoenaed you, ask for him or her and introduce yourself. If the trial is in
progress and you must wait for a break, it is usually best to remain outside the
courtroom.
4. The attorney will probably want to discuss your testimony with you - this is a
proper thing to do. If you are producing records in response to a subpoena from
the opposing party, do not turn them over to an attorney until the judge orders you
to do so, unless you were told in advance by your own lawyer to give them to
someone.
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5. Avoid undignified behavior, such as load laughing, while you are in the courtroom.
Smoking, gum chewing, and reading are usually permitted in the corridors but not
in the courtroom itself.
11.2.3 While on the Witness Stand
1. When you are called to testify, stand upright while taking the oath. Pajr attention
and say "I do" clearly, so everyone can hear you.
2. You are sworn to tell the truth: Tell it! There are two ways to tell the truth - one
is a halting, stumbling, hesitant manner, which makes Board members, Hearing
Officers, judge, or jury doubt that the witness is telling all the facts in a
straightforward manner; and the other way is in a confident, straightforward
manner, which inspires faith in what is being said. It is most important that the
witness testify in the latter way.
3. During your testimony, every material truth should be readily admitted by you,
even if not to the advantage of the party for whom you are testifying. Do not stop
to figure out whether your answer will help or hurt your side. Just answer the
question to the best of your ability. Candor is a quality that makes you more
believable to the jury. If you attempt to be an advocate while on the witness stand,
you will appear biased and your testimony will not be credible.
4. While you are on the witness stand, direct your answers to the people in the jury,
or, if there is no jury, to the judge. Look at them most of the time and speak to
them as you would to a friend or a neighbor. Do not cover your mouth with your
hand. Try to speak loudly enough so that the farthest juror and the court reporter
can hear you. Do not slouch in the witness chair, and avoid constant shifting
around in the chair.
5. There is no need to memorize your testimony beforehand, in fact, if you memorize
your testimony, it will sound untruthful. Speak in your own words and try to be
prepared, but do not testify as though you are a recorded message.
6. Your role is as a communicator while on the witness stand. You may know
something to be true, but unless you can convey it to the judge, Hearing Officer, or
jury, it is worthless. Paint a complete picture by explaining all important details.
Make the events about which you testify stand out as living facts.
7. Listen very carefully to each question and do not answer it unless you are sure you
understand it. Ask for the question to be repeated, if necessary. If you still do not
understand it, say so, Never answer a question you do not fully understand.
8. Never rush into an answer. After listening to the question, pause for a brief
moment to reflect, then answer. This will allow you to collect your thoughts and
avoid being goaded into answers that are not fully accurate. It will also help
defuse an opposing counsel's "rapid fire" questioning tactic which is usually
designed to confuse you. However, don't take so much time on each question that
it might appear that you are making up answers.
9. Answer the question that is asked - not the question you think the lawyer
(particularly the cross-examiner) intended to ask. The printed record shows only
the question asked, not what is in the lawyer's or witness' mind, and a non-
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responsive answer may be very detrimental to your side's case. This situation
exists when the witness thinks "I know what he is after, but he hasn't asked for
it." Answer only what is asked.
10. "Direct" examination refers to the questioning of a witness by the attorney who
subpoenaed that witness to testify. "Cross-examination" is the questioning of a
witness by the other lawyer (i.e., the lawyer who did not request the witness'
presence in court). Note that sometimes a State employee is subpoenaed by the
adverse party to testify - in such instances, the State employee appears as a
witness for the adverse party, and the "direct examination" is conducted by the
adverse party's lawyer.
11. During your direct examination, you may elaborate and respond more fully than is
advisable in cross-examination (unless you are testifying as a witness for an
opposing party, in which case brevity is as important during direct examination as
it ordinarily is in cross-examination). Ordinarily, the cardinal rule is to be brief
and to answer directly, with a "yes" or "no" if possible, then stop. Do not
volunteer any information during cross-examination or during interrogation by an
opposing lawyer. If you do so, this may cause you to appear biased. Answer the
question fully, but using only as many words as necessary to respond, and no
more. State your answers as precisely and succinctly as possible. If an
explanation to your answer is necessary, say so.
12. Sometimes a lawyer will try to limit your answer to yes or no. If that happens,
and you cannot answer the question yes or no, say so. Usually the judge will let
you explain your answer.
13. The court and jury only want the facts that you have seen or personally know, not
what somebody else told you. Normally, you will not be allowed to state your
conclusions or opinions or what someone else told you.
14. When possible, give positive, definite answers. Avoid saying "I think," "I believe,"
or "in my opinion." If you do not know or are not sure of an answer, say so.
There is absolutely nothing wrong with saying "I don't know." It is quite
understandable that you can feel certain about important things without
remembering details. If you are asked about little details that you have forgotten,
just answer that you do not remember. Do not venture a guess about anything.
Stick to the facts, as you know them.
15. Do not exaggerate. Be careful about broad generalizations. Be careful of
statements like "nothing happened," or "that's everything." You can safely say
"that's all that I recall," or "that's all that I remember seeing."
16. If the question is about distances or time and your answer is only an estimate, be
certain that you say that it is only an estimate. Unless you have exact knowledge,
use the term "approximately."
17. Be particularly careful in responding to questions that begin "wouldn't you agree
that" or "isn't it true that." This is typical cross-examination, but make sure that
you are in complete agreement with the substance of such a question before
responding in the affirmative.
18. Avoid mannerisms of speech, like prefacing your replies with such things as, "I can
truthfully say."
19. If any answer you give was wrong or unclear, correct it immediately. It is better
for you to correct your mistake than for the opposing lawyer to discover the error.
At any time you may ask, "May I correct something I said earlier?", or "I made a
mistake earlier in my testimony."
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20. Stop instantly when a judge interrupts you or when an attorney objects to what
you say. Do not try to sneak in an answer.
21. Always be polite and courteous, even if a lawyer is not. Accept insults as part of
the game. Ignore mispronunciations of your name - they may be a deliberate
tactic. Do not argue or try to be sarcastic or "fence" with a lawyer. Don't get
irritated. Don't make wise cracks or take sides. Don't get irritated. Don't be a
smart aleck or act cocky. Don't lose your temper. Remember, the attorney has a
big advantage - he or she can ask the questions. It is your responsibility as a
witness to answer. Your only duty as a witness is to answer the questions as they
are asked.
22. Remember that your testimony is either recorded or is being written down by a
court reporter. Thus, do not nod your head for a "yes or "no" answer. If
illustrating a point by reference to a photograph or other exhibit, don't say. for
example, "I saw the leaking barrel right there"; rather, say "I saw the leaking
barrel at this location, which is about one inch to the right of the blue truck
depicted on Exhibit 15."
23. Speak out clearly so the court reporter can record your answer. At all times make
certain that the reporter is able to hear you and record what you actually say.
Speak slowly enough to be understood, and remember that chemical or technical
terminology may cause the court reporter some difficulty. The case will be decided
entirely on the words that are finally reported as having been the testimony given
at the hearing or trial. Make sure that where possible you give complete
statements using complete sentences. Half statements or incomplete sentences
may convey your thoughts in the context of the hearing, but they may be
unintelligible when read from the cold record many months later.
24. You are allowed to take your notes and written reports with you to the witness
stand. However, before doing so, consult with your lawyer. Be aware that any
notes or papers which you bring with you to the witness stand can be examined by
the lawyer for the opposite side. It is far better that you do not have to constantly
look down at such written materials during your testimony. Do not appear to be
shuffling papers. It is perfectly appropriate, however, to look at written materials
during 3'our testimony to refresh your memory about a detail of which you are
unsure and about which you are asked. The proper etiquette, however, is to first
request permission.
25. An honest witness has nothing to fear on cross-examination. Some of the advice
above make more sense if you understand what an attorney is trying to do in
cross-examination. If your testimony is not harmful to his or her case, or
questioning will not help the case, he or she may skip cross-examination. On the
other hand, if your testimony has been damaging, the other lawyer will want to be
able to tell the jury at the end of the case that they should not believe you. In
order to tell the jury that, he or she wants to make it appear that you do not know
what you are talking about or that you are lying. Usually, the lawyer will try to
get you to say things that are not completely true. If you say something which is
not completely true, the lawyer can then tell the jury, "Since the witness lied on
this point or is wrong on that point, you should disbelieve everything the witness
said."
26. A couple of trick questions may be used by the opposing lawyer on cross-
examination:
a. "Have you talked to anybody about this case?" If you say no, the jury will
think that you are not telling the truth, because a good lawyer always talks
to a witness before the witness testifies. If you say "yes," the lawyer may
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try to imply that you were told what to say. A good way to answer is
simply to acknowledge that you talked to whomever you talked - a lawyer,
the police, or anyone and that you were just asked what the facts were.
There is a big difference, however, between acknowledging that you talked
to someone beforehand about your testimony (which is perfectly ok) and
responding to the likely follow-up question, "And did he tell you what to
say?" Hopefully, you will always he able to answer "no" to the latter
question, or you can answer, "Yes, he or she told me to tell the truth."
b. "Are you being paid to testify this case?" The lawyer hopes that your
answer will be yes, suggesting that you have been paid-off to say what you
have said. A good way to answer the question is, "No, I am not getting
paid to testify, all I have received is the subpoena witness fee."
27. Pay attention to the objections which your lawyer makes while you are being
interrogated by the opposing lawyer. Sometimes such objections are made as a
way of communicating with you while on the witness stand. For example, if your
lawyer says, "Objection, Your Honor; the witness has already answered that
question," it may be the lawyer's way of telling you, "You've already answered a
similar question; make sure your answer this time is consistent with your prior
answer."
28. Testifying for a long period of time is surprisingly tiring and can cause fatigue,
nervousness, anger, careless answers, and a willingness to say anything in order to
leave the witness stand. If you feel tired, try to overcome the tiredness, or ask for
a five-minute break or a glass of water. Remember that some attorneys in cross-
examination are trying to wear you out so you will lose your temper, get rattled, or
say things that are incorrect.
29. Sometimes opposing lawyers use a different tactic such as praise, flattery, or
friendliness, in order to lull you into a sense of security. Be careful of this
approach, and do not become unduly talkative in such a situation. Again, answer
all questions, but never volunteer information, and use as few words as possible.
30. If you do not want to answer a question, do not ask the judge, Hearing Officer, or
Board member whether you must answer it. If it is an improper question, your
attorney will object for you. Do not ask the presiding Officer, judge, or Board
member for advice.
31. Do not look to your attorney or to the judge, Hearing Officer, or Board member for
help in answering a question. You are on your own. If the question is an improper
one, your attorney will object. If the judge, Hearing Officer, or Board member then
says to answer it, do so.
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CHAPTER 12 TABLE OF CONTENTS
Chapter 12 HEALTH MONITORING PROGRAM 12-1
12.1 Introduction 12-1
12.2 Examinations 12-2
12.2.1 Components of the Examination 12-3
12.2.2 Physician's Evaluation 12-4
12.3 Review of Records 12-5
12.4 Confidentiality of Records 12-5
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Inspection Manual HEALTH MONITORING PROGRAM
Chapter 12
HEALTH MONITORING PROGRAM
12.1 Introduction
An occupational health monitoring program is surveillance, or a watch, over the health
status of selected employees by means of periodic medical examinations. A health
monitoring program is designed basically for laboratory and field investigators whose work
regularly poses the possibility of exposure to toxic materials. Those job categories that
should have health monitoring made available are laboratory, solid and hazardous waste,
spill response, and the technical personnel who support these disciplines. Other employees
who collect samples should be included if the sampling requires exposure to pollutants
significantly in excess of ambient concentrations. Generally, administrative, secretarial,
and other support personnel who are exposed to toxic materials indirectly, infrequently, or
inconsequentially are not included.
Employees whose positions justify inclusion in the program might be required to
participate as a condition of employment. A written record of those deferring or declining
participation might be required and kept in the employee's personnel file to document that
the program was made available. Declining employees might be reassigned to non-
exposure duties where possible.
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Occupational health monitoring assists in the prevention and early detection of adverse
effects of occupational exposure and stresses. Specifically, the program aids in the
following:
1. Early recognition of unsuspected risks;
2. Monitoring the effectiveness of protective measures taken for known risks;
3. Prompt initiation of corrective action and appropriate medical care when indicated;
4. Evaluation of health status with respect to work assignments;
5. Compliance with health and safety regulations; and
6. Possible study of long-term subtle effects of occupational exposures.
Participants should be advised that a program of health monitoring examinations is not a
substitute for "general checkups" or other periodic examinations designed to monitor or
promote general health. An occupational health monitoring program is designed to screen
for evidence of adverse effects of occupational exposure, particularly exposure to toxic
substances. The examinations do not provide a comprehensive health evaluation; nor do
they provide screening for many of the common non-occupational chronic disorders.
12.2 Examinations
In order to obtain an accurate health profile from the examination, employees are advised
to refrain from drinking alcoholic beverages and taking non-prescribed medications the day
before the exam. Ideallj', the employee should not smoke in the morning as this could
effect the results of the EKG. The employee may also need to fast starting at midnight
the night before the exam.
The morning session is often reserved for the chemical and physical work-ups. After the
preliminary testing (blood tests, urinalysis, etc.) is completed in the morning, the employee
is often allowed time for lunch.
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During the afternoon session, the hospital usually schedules physical examinations. Most
of the results of the morning work-up will be available to the examining physician.
12.2.1 Components of the Examination
The first, or baseline, examination offered to each participant will usually consist of a
complete medical examination. This examination will be useful in providing reference
information for evaluating the findings of subsequent periodic examinations which will be
of more limited scope.
Health monitoring usually includes, at a minimum, a medical and occupational history
review, a screening physical examination, basic blood and urine laboratory tests and a
physician's evaluation. The monitoring examination will be supplemented by procedures
and special tests only as warranted by exposure to specific significant hazards or stresses
and on the recommendation of the examining physician.
Medical history" The medical history will be obtained by having each
participant initially fill out an occupational history and
family history form before seeing a physician. The
occupational exposure information will be reviewed b3'
occupational health and safety personnel to assist the
examining physician in performing an examination of
appropriate scope. When completed, the form should be
turned over to the physician or physician's designee in a
manner safeguarding privacy and confidentiality of the
participant. Any changes to the information on the form
should be brought to the attention of the examining
physician during the next annual examination.
Pulmonary function Pulmonary function testing is desirable as a part of the
baseline examination. It may be indicated periodically
for employees at respiratory system risk, such as those
with significant exposure to toxic dusts and irritants and
for those employees over 35 years of age. At a
minimum, it should consist of simple tests of lung
ventilation: forced expiratory volume in one second
(FEV) and forced vital capacity (FVC).
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Inspection Manual
X-Ray
Electrocardiogram
Blood counts and chemistry
Audiometry
Physical examination
A baseline chest x-ray should be a standard 14 x 17-inch
P-A (posterior-anterior) exposure. The lateral view is
not necessary for routine screening purposes. Chest x-
rays are required for a thorough occupational
evaluation. This test is one of the best tools for
diagnosing occupational illness. Subsequent testing will
be required every five years or at the recommendation of
the examining physician.
An electrocardiogram should be included in the baseline
examination. It ordinarily should be of the standard 12-
lead resting type and interpreted by an internist or
cardiologist. Subsequent periodic electrocardiograms
should be obtained when recommended by the examining
physician or for those employees older than 35 years of
age.
Each individual should receive a basic panel of blood
counts and chemistries to evaluate bloodforming organs,
kidney, liver, and endocrine/metabolic function.
Audiometry is required for all employees regularly
exposed to high noise levels (i.e., over 85 dB) and is
indicated for employees inspecting industrial and
municipal facilities with high noise level equipment.
A comprehensive physical examination is usually
performed giving special consideration to the particular
job function of the employee. The examining physician
will discuss the results of the tests conducted in the
morning.
12.2.2 Physician's Evaluation
Usually within 90 days, the examining physician and occupational physician will review
the medical information obtained during the examination. From this data, the physicians
will:
1. Evaluate the employee's physical capability of performing work while wearing a
respiratory protective device,
2. Evaluate the employee's physical ability to perform his/her designated job function,
3. Evaluate any medical conditions which would place the employee at risk and
recommend limitations upon his/her assigned work, and
4. Document and report the results of the examination by Letter of Transmittal.
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12.3 Review of Records
Usually an agency coordinator responsible for safety and health will process the incoming
reports as follows:
1. Copies of the Letter of Transmittal without physician comments will be filed,
2. Ccpies of the Letter of Transmittal with physician comments will be mailed to the
employee under a confidential stamp, and
3. Copies of the five-year written evaluation will be mailed to the employee under a
confidential cover.
12.4 Confidentiality of Records
The purpose of requesting personal information is to enable the examining physician and
other health personnel to provide an occupational health program directed primarily to
protecting the employee and fellow workers from potential hazards in the work
environment and the reduction of these hazards. The records will document health status,
changes in physical conditions through the years, and provide an account of any care
rendered, advice given, and consultations that are recommended.
This information may be used to determine unusual susceptibility to illness or injury from
exposures in the work environment, to determine suitability for assignments, to permit
medical surveillance for potential harmful effects of toxicants, and to provide medical
treatment and advice. It may be used to plan, implement and evaluate occupational and
preventative health programs, conduct epidemiologic research, teach, and compile
statistical data. It may be used to adjudicate claims and determine benefits, and report
medical conditions required by law to Federal, State, and local agencies. It may be used
for other lawful purposes including litigation.
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The information contained in these medical files may be open to reviews and use by the
examining physician or duly authorized physicians of the performing agency. The basic
records will normally be in the local custody of the examining physician and are always
maintained in a secure manner. It is normal procedure that, at any time, the employee
may request copies of medical records. Medical information about an employee are
normally never made available to the public.
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APPENDIX A
LIST OF VIDEO TAPES
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Inspection Manual
LIST OF VIDEO TAPES
Appendix A
LIST OF VIDEO TAPES
CHAPTER NAME OF VIDEO SEGMENT
1
2
3
4
5
6
7
8
9
10
11
12
Introduction
Resource Conservation and Recovery Act
Safety Procedures
Permits and Compliance Monitoring
Work Ethics
Preparing for the Inspection
Conducting the Inspection
Post-inspection Procedures
Sampling Procedures
Basic Evidence Collection
Special Procedures
Medical Monitoring Program
February 1988
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APPENDIX B
KEEPING UP-TO-DATE WITH RCRA
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APPENDIX B TABLE OF CONTENTS
Appendix B KEEPING UP-TO-DATE WITH RCRA B-l
B. 1 Internal EPA Network B-l
B.2 Federal Interagency Cooperation B-3
B.3 EPA Hotline B-3
B.4 EPA Headquarters B-3
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Inspection Manual KEEPING UP-TO-DATE WITH RCRA
Appendix B
KEEPING UP-TO-DATE WITH RCRA
Congress passed the Resource Conservation and Recovery Act (RCRA) in 1976 as the
primary statute for the regulation of solid and hazardous waste. Regulations promulgated
pursuant to the Act are found in 40 CFR Parts 240 to 271 and Part 124 and were
subsequently amended on November 8, 1984. Both RCRA and its amendments are
designed to provide for the safe disposal of discarded materials and to regulate the
management of hazardous waste. The four specific goals of RCRA are as follows:
1. To create a "cradle to grave" system for regulating hazardous waste (i.e.. a system
of controlling all aspects of hazardous waste management from the time a waste is
generated until it is properly disposed of). This system is to be administered by the
Federal Government except where a State has chosen to operate an "equivalent"
program.
2. To encourage States to establish solid waste control plans that include provisions
for closing open dumps.
3. To encourage research and development in the field of recycling recovered
materials.
4. To establish an Office of Solid Waste within EPA.
B.I Internal EPA Network
The EPA provides an extensive network for the exchange and dissemination of
information. EPA's program offices can serve as clearinghouses for specific types of
information. A brief summary of the responsibilities for each of these offices is presented
below so inspectors can determine which office to contact.
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KEEPING UP-TO-DATE WITH RCRA Inspection Manual
I. EPA Office of Waste Programs Management
- Manages the national program for compliance and enforcement under RCRA.
- Provides policy direction to the Regions and the States.
• Provides technical support to compliance and enforcement activities.
- Identifies, assesses and recommends action on general and specific RCRA
compliance and enforcement issues.
- Assumes responsibility for direct management of RCRA enforcement actions that
are multiregional or of national significance.
- Formulates strategies and plans, and develops program guidance for issuance to
the Regional Offices and the States.
- Concurs in settlements of enforcement cases.
- Develops accountability measures for the enforcement/compliance program.
- Develops and delivers training programs on new regulations, initiatives, and
policies.
II. EPA Office of Enforcement and Compliance Monitoring
- Provides legal advice regarding RCRA enforcement matters to the Assistant
Administrator for Solid Waste and Emergency Response, Regional Program
Offices, and Regional Counsel Offices.
- Acts as lead counsel on cases of national significance.
- Develops enforcement policies and guidances in conjunction with the Office of
Waste Programs Enforcement.
- Confers with the Department of Justice on the potential impact of enforcement
policy on litigation matters.
- Approves all settlements of enforcement cases.
- Evaluates and analyzes strategies and program accomplishments as national
manager of EPA's enforcement and compliance monitoring functions.
- Reviews all case referral packages, litigation reports, and supporting
documentation prior to referral to the Department of Justice.
- Assists and supports the Regional Counsel lead attorneys and Department of
Justice attorneys by coordinating legal activity and contributing case information to
the development process.
III. EPA Office of General Counsel
- Provides legal interpretations of applicable statutes and regulations to support the
RCRA enforcement programs.
- Has lead responsibility for defensive litigation arising out of enforcement actions
(e.g., Federal Court challenges to EPA's civil penalty proceedings.)
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B.2 Federal Interagency Cooperation
The Resource Conservation and Recovery Act charges EPA with the responsibility of
protecting human health and the environment by ensuring the proper management of
hazardous wastes. To fulfill this responsibility, EPA has developed cooperative
mechanisms to foster working relationships with appropriate State and Federal agencies.
A few of these external agencies are:
1. NATIONAL ENFORCEMENT INVESTIGATION CENTER (NEIC) - A
national technical resource and investigative unit in Denver, Colorado.
2. U.S. DEPARTMENT OF JUSTICE (DOJ) - In accordance with a memorandum
of understanding dated June 1977.
3. U.S. DEPARTMENT OF TRANSPORTATION (DOT) - In accordance with a
1980 memorandum of understanding.
4. STATE HAZARDOUS WASTE PROGRAMS - States authorized under RCRA to
administer and enforce their own hazardous waste management programs.
B.3 EPA Hotline
The EPA's Office of Solid Waste and Emergency Response set up a telephone call-in
service to answer any questions regarding RCRA and Superfund (CERCLA). The phone
number is 202-382-3000 (in Washington, D.C.) or toll-free 800-424-9346 (outside of the
District). The hotline staff have an up-to-date understanding of the RCRA regulatory
requirements and can provide details on changes in procedural requirements. They can
also refer inspectors to the appropriate EPA contact or reference document for further
information on any issue.
B.4 EPA Headquarters
The headquarters of EPA serves as the hub from which administrative, policy and
technical information is disseminated. Regardless of the status of inspectors (Federal,
February 1988 Page B-3
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KEEPING UP-TO-DATE WITH RCRA Inspection Manual
State, or local),they should not hesitate to contact EPA to obtain information that would
enable them to perform their duties more efficiently. The following is a list of important
telephone numbers at the EPA headquarters where inspectors can obtain information not
presented in this manual.
EPA Personnel Locator 202-382-2090
EPA Library 202-382-5921
EPA Public Information Center 202-646-6410
Hazardous Waste Ombudsman 202-475-9361
RCRA/Superfund Hotline 202-382-3000
Page B-4 February 1988
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APPENDIX C
SOURCES OF INFORMATION
-------
APPENDIX C TABLE OF CONTENTS
Appendix C SOURCES OF INFORMATION C-l
C. 1 References C-l
C.2 Background Documents C-3
C.3 Reference Manuals C-4
C.4 Video Sources C-5
C.5 Additional Sources C-6
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Inspection Manual SOURCES OF INFORMATION
Appendix C
SOURCES OF INFORMATION
This appendix lists most of the documents consulted during the preparation of this manual.
The inspector is advised to consult these sources to gain additional insight on RCRA
inspections. As noted below, several of the sources themselves contain reference lists.
C.I References
1. COMPLIANCE/ENFORCEMENT GUIDANCE MANUAL - POLICY
COMPENDIUM.
This document provides information and detailed guidance on the
substantive and procedural requirements necessary for ensuring
compliance with RCRA and the inspector's role in the preparation of
enforcement cases.
2. DRAFT GUIDANCE FOR SUSP ART G OF THE INTERIM STATUS
STANDARDS (1980).
This document was prepared for owners and operators of hazardous
waste treatment, storage and disposal facilities. It was prepared by
International Research and Technology Corporation for US EPA.
The document has sections which covers closure and post-closure
plans.
3. EMERGENCY RESPONSE GUIDEBOOK (1984)
This is a guidebook for hazardous materials incidents prepared for
the U.S. Department of Transportation. It was developed for use
by fire fighters, police and other emergency services personnel as a
guide for initial actions to be taken to protect themselves and the
public when they are called to handle incidents involving hazardous
materials. Copies are available from the U.S. DOT, Materials
Transportation Bureau, Attention: DMT-11, Washington, D.C.
20590.
February 1988 Page C-l
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SOURCES OF INFORMATION Inspection Manual
4. EPA REPORT TO CONGRESS (Fiscal Years 1980 to 1985).
This document's full title is "Report to Congress - EPA Activities
and Accomplishments Under the Resource Conservation and
Recovery Act: Fiscal Years 1980 to 1985." This document is a
summary of the accomplishments of EPA's program in response to
RCRA and HSWA, the priorities that EPA's hazardous waste
program has set for the near term, and the challenge EPA will face
in implementing HSWA. This document contains a listing of EPA
guidance documents prepared during the 1983-1985 period.
5. FEDERAL REGULATION OF HAZARDOUS WASTES: A GUIDE TO RCRA
(1982).
A book written by John Quarles and published by the
Environmental Law Institute. It provides an overview of Subtitle C
of RCRA, outlining the regulations and their impact on the
regulated community. This text is available for purchase from the
Hazardous Waste Report, P.O. Box 3645, Harrisburg, PA 17105.
6. HAZARDOUS WASTE MANAGEMENT - A GUIDE TO THE REGULATIONS
(1980).
Prepared by the Office of Solid Waste, US EPA. This document is a
guide to hazardous waste regulations promulgated on February 26
and May 19, 1980. Consolidates 300 commonly asked questions and
answers concerning the application of the regulations to specific
situations.
7. HAZARDOUS WASTE MANAGEMENT INSTITUTE MANUAL (1985).
A textbook for a model curriculum on hazardous waste technology
edited by Jey K. Jeyapalan and Daniel R. Viste. This text is
published by The Wisconsin Hazardous Waste Management Center.
The Universit3' of Wisconsin - Madison, 2304 Engineering Building,
1415 Johnson Drive, Madison, WI 53706.
8. LEGAL MANUAL OF THE EPA "BASIC TRAINING" PROGRAM FOR FIELD
INSPECTOR PERSONNEL (1987)
A draft of a manual that covers the legal issues involved in
inspection activity for non-legal personnel. Prepared for the Office
of Enforcement and Compliance Monitoring, U.S. Environmental
Protection Agency by Chelsea International Corporation, 718 P
Street, N.W., Suite T-200, Washington, D.C. 20036.
9. NEW YORK STATE HAZARDOUS WASTE COMPLIANCE INSPECTION
GUIDANCE MANUAL (1987)
Copies are available from the New York State Department of
Environmental Conservation, Division of Solid and Hazardous
Waste, 50 Wolf Road, Albany, New York 12233.
Page C-2 February 1988
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Inspection Manual SOURCES OF INFORMATION
10. RCRA COMPLIANCE AND EVALUATION: INSPECTION GUIDANCE
DOCUMENT (1987).
The purpose of this guidance document is to provide guidance to
inspection personnel on the substantive and procedural
requirements of conducting compliance evaluation inspections (CEI)
at both interim-status and permitted hazardous waste generator,
transportation, treatment, storage, and disposal facilities. This
document contains a number of lists of available documents
including: (1) a list of health and safety guidance documents, (2)
industry profile publications, and (3) chemical information sources.
11. RCRA ORIENTATION MANUAL (1986).
A manual prepared for EPA and State staff introducing the solid
waste management program established under the Resource
Conservation and Recovery Act (RCRA). The manual is designed as
a self-administered course for those persons unfamiliar with RCRA
to use in learning about the Act and the agency's program to meet
the Act's requirements.
This document is available from Robert Knox at the Office of Solid
Waste (WH 562), U.S. EPA, 401 M Street S.W., Washington, D.C.
20460 (EPA/530-SW-86-001).
12. REGIONAL GUIDANCE MANUAL FOR SELECTED INTERIM STATUS
REQUIREMENTS (1980).
Prepared by the Office of Solid Waste, US EPA, September 22,
19SO. This document includes sections on plans and recordkeeping,
sample wa'ste analysis plan, contingency plan, ground-water
assessment plans and operating record.
13. TEXAS SOLID WASTE INSPECTION MANUAL (1985)
Copies are available from the Hazardous and Solid Waste Division
of the Texas Water Commission, Stephen F. Austin Building, 1700
North Congress Avenue, Austin, Texas 78711-3087.
C.2 Background Documents
Listed below are 18 background documents developed by the EPA to explain and respond
to comments on the RCRA Phase I rules. These documents can be obtained from EPA
Regional Office libraries or from Solid Waste Information, US EPA, 26 West St. Clair St.,
Cincinnati, OH 45268.
February 1988 Page C-3
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SOURCES OF INFORMATION Inspection Manual
The list is as follows:
Purpose, Scope and Applicability
General Waste Analysis Requirements
Security
General Inspection Requirements
Personnel Training
Preparedness and Prevention, Contingency Plans and Emergency Procedures
Manifest System, Recordkeeping and Reporting
Interim Status Standards for Ground-water Monitoring
Interim Status Standards for Closure and Post-Closure Care
Interim Status Standards for Financial Requirements
Interim Status Standards for Containers and Piles
Interim Status Standards for Tanks
Interim Status Standards for Surface Impoundments
Interim Status Standards for Land Treatment
Interim Status Standards for Landfills
Interim Status Standards for Incinerators
Interim Status Standards for Thermal Treatment
Interim Status Standards for Chemical, Physical and Biological Treatment
C.3 Reference Manuals
These are a series of design and operation manuals being prepared by the EPA to assist
facility owners and operators and regulatory officials. These documents will be available
through Solid Waste Information, US EPA, 26 West St. Clair St., Cincinnati, OH 45268
or through EPA Regional libraries.
The following manuals will be completed by the EPA:
Training
Ground-water Monitoring
Air Monitoring
Financial Responsibility
Containers
Tanks
Surface Impoundments
Waste Piles
Land Treatment
Landfilling
Incineration
Thermal Treatment
Chemical, Physical and Biological Treatment
Page C-4 February 1988
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Inspection Manual SOURCES OF INFORMATION
C.4 Video Sources
1. CHEMSAFE
A videotape providing a basic overview of chemical safety and
training in such categories as corrosives, solvents, oxidizers,
poisons, gases, explosives, and carcinogens. This material is
available in soundslide, 3/4 inch video, VHS and Beta format as
item CSF-000 from BNA Communications, Inc. 9439 Key West
Avenue, Rockville, MD 20850-3396, (800) 233-6067 or (301)
948-0540.
2. HAZARDOUS AND SOLID WASTE AMENDMENTS.
A videotape produced by EPA technical experts who that explains
the Hazardous and Solid Waste Amendments of 1984. This is
available for purchase from the National Audio-Visual Center,
National Archives and Records Administration, Customer Services
Section NR, 8700 Edgewood Drive, Capitol Heights, MD
20743-3701.
3. HAZARDOUS WASTE TRAINING.
This is a seven-part video series. Comprehensive in scope, the
series follows hazardous waste management procedures from
generation at the source through transport and eventual disposal as
a hazardous waste facility. Included are videos covering an
introduction to hazardous waste, the packaging hazardous waste,
the transporter's checklist, the uniform hazardous waste manifest,
the disposal facility and liquid hazardous waste. This material is
available in 3/4 inch video, VHS and Beta format as item HWH-000
from BNA Communications, Inc. 9439 Key West Avenue, Rockville,
MD 20850-3396, (800) 233-6067 or (301) 948-0540.
4. PERSONAL SAFETY PROTECTION
This is a multi-part video series designed to instruct employees on
the various aspects of personal protection from workplace hazards.
Included are modules on respirators (AEB-101), personal protection
gear (AEB-102), respiratory protection (AEB-110) and respirators
for health and safety (TAB-100). This material is available in 3/4
inch video, VHS and Beta format from BNA Communications, Inc.
9439 Key West Avenue, Rockville, MD 20850-3396, (800)
233-6067 or (301) 948-0540.
February 1988 Page C-5
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SOURCES OF INFORMATION Inspection Manual
C.5 Additional Sources
A listing of additional documents is available from the U.S. Environmental Protection
Agency, Office of Solid Waste (WH-562), 401 M Street, S.W., Washington, B.C. 20460.
A collection of visual format material (e.g., soundslide, 3/4 inch video tape, VHS format
video tape and Beta format video tape) is available from BNA Communications, Inc. a
subsidiary of The Bureau of National Affairs, Inc., 9439 Key West Avenue, Rockville, MD
20850-3396, (800) 233-6067 or (301) 948-0540.
Another collection of visual format material is available from the National Audiovisual
Center, National Archives and Records Administration, 8700 Edgeworth Drive, Capitol
Heights, MD 20743-3701, (800) 638-1300.
And a special thanks to: US Ecology - An American Ecology Company for their
cooperation and contribution of video footage for this training program.
Page C-6 February 1988
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APPENDIX D
TELEPHONE NUMBERS
-------
APPENDIX D TABLE OF CONTENTS
Appendix D TELEPHONE NUMBERS D-l
D. 1 Emergency Telephone Numbers D-l
D.2 The ASTSWMO Office D-l
D.3 ASTSWMO Training Coordinators D-2
D.4 ASTSWMO - State Telephone Numbers D-8
D.5 EFA Telephone Numbers D-24
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Inspection Manual TELEPHONE NUMBERS
Appendix D
TELEPHONE NUMBERS
D.I Emergency Telephone Numbers
CHEMTREC 800/424-9300
Center for Disease Control 404/633-5313
DOT Emergency Number 800/424-8802
National Emergency Response Center 800/424-8802
Superfund/RCRA Hot Line 800/424-9346 or
202/382-3000
D.2 The ASTSWMO Office
The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) is
a nonprofit national organization of the directors of State solid and hazardous waste
management programs and their staffs.
ASTSWMO
444 N. Capitol Street, N.W.
Suite 388
Washington, DC 20001
202/624-5828
February 1988 Page D-l
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TELEPHONE NUMBERS Inspection Manual
D.3 ASTSWMO Training Coordinators
The following are the addresses and telephone numbers of the ASTSWMO State Training
Coordinators for the 1987 fiscal year.
Steve Maurer 205/271-7728
Alabama Department of Environmental Management
Land Division
1751 Federal Drive
Montgomery, AL 36130
Doug Toland 907/465-2666
Alaska Department of Environmental Conservation
Environmental Quality Operations
Air and Solid Waste Management
Pouch O
Juneau, AK 99811
Pati Faiai 663-4141
Environmental Quality Commission (Overseas Operator)
American Samoan Government
Pago Pago, American Samoa
Juanita Copeland 602/257-2297
Arizona Department of Health Services
Division of Environmental Services
2005 N. Central Avenue
Phoenix, AZ 85004
Ed Dunn/Dennis Green 501/562-7444
Arkansas Department of Pollution
Control and Ecology
8001 National Drive
P.O. Box 9583
Little Rock, AR 72219
Joyce Law 916/322-1314 or
California Dept. of Health Services 916/322-6372
1219 K Street, 3rd Floor
Sacramento, CA 95814
Pam Harley 303/320-8333
Colorado Department of Health
Waste Management Division
4210 E. llth Avenue
Denver, CO 80220
Patrick Bowe 203/566-8843
Connecticut Department of Environmental Protection
Hazardous Materials Management Unit
165 Capitol Ave
Hartford, CT 06106
Page D-2 February 1988
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Inspection Manual TELEPHONE NUMBERS
Mr. Falmbee 302/736-4781
Delaware Department of Natural Resources and
Environmental Control
Division of Air and Waste Management
Solid Waste Management Branch
89 Kings Highway, P.O. Box 1401
Dover, DE 19901
Angelo Tompros 202/767-8422
Department of Consumer and Regulatory Affairs
Pesticides and Hazardous Waste Management Branch
5010 Overlook Ave, SW, Room 114
Washington, DC 20032
Roger Menendez 904/487-4967
Florida Department of Environmental Regulation
Solid and Hazardous Waste Section
2600 Blair Stone Road
Tallahassee, FL 32301
Moses McCall 404/656-2833
Georgia Department of Natural Resources
Industrial and Hazardous Waste Management Program
Floyd Towers East, Room 1154
205 Butler St, SE
Atlanta, GA 30334
Jose Techaira 646-08863-5
Guam Environmental Protection Agency (Oversees Operator)
Post Office Box 2999
Agana, Guam 96910
Albert Dung 808/548-6410
Hawaii Department of Health
Environmental Protection and Health
Services Division
P.O. Box 3378
Honolulu, HI 96801
John Brueck 208/334-5879
Department of Health and Welfare
Division of Environment
Hazardous Materials Bureau
450 West State St.
Boise, ID 83720
Bill Child/Tom Cavanaugh/Pat McCarthy 217/782-6760
Illinois Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
Springfield, IL 62706
Mike Dalton 317/232-8884
Indiana Department of Environmental Management
105 S. Meridian
Indianapolis, IN 46206
February 1988 Page D-3
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TELEPHONE NUMBERS Inspection Manual
Mr. Hamblin, Department of Natural Resources 515/281-6807
Iowa Department of Water, Air and Waste Management
900 East Grant St.
Henry A. Wallace Building
Des Moines, IA 50319
Tom Gross/Ron Smith 913/296-1603
Kansas Department of Health and Environment (Ext. 292/324)
Forbes Field
Topeka, KA 66620
CarlMillante 502/564-6716
Department for Environmental Protection (Ext. 223/238)
Division of Waste Management
18 Reilly Road
Frankfort, KY 40601
Jim Brent 504/342-1216
Louisiana Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804-4307
Paula Clark or Hank Ako 207/289-8111
Maine Department of Environmental Protection
Bureau of Land Quality
State House - Station 17
Augusta, ME 04333
Bernie Bigham/Doug Johns 301/225-5731
Office of Environmental Programs
Waste Management Administration
201 West Preston St.
Baltimore, Maryland 21201
Dick Slein/Susan Fessenden 617/292-5630
Department of Environmental Quality Engineering
Division of Solid and Hazardous Waste
One Winter St., 5th Floor
Boston, MA 02108
Marta Fisher 517/373-2730
Department of Natural Resources
Hazardous Waste Division
P.O. Box 30038
Lansing, MI 48909
Tom Gries 612/296-7039
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Rd.
St. Paul, MN 55113
LeRoy Dee 601/961-5171
Department of Natural Resources
Bureau of Pollution Control
Division of Solid Waste Management
P.O. Box 10358
Jackson, Mississippi 39209
Page D-4 February 1988
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Inspection Manual TELEPHONE NUMBERS
Keith Schardein 314/751-3176
Department of Natural Resources
Division of Environmental Quality
Waste Management Program
117E. Dunklin St.
P.O. Box 1368
Jefferson City, MO 65102
Bill Potts 406/444-2821
Department of Health and Environmental Sciences
Solid Waste Management Bureau
Room B-201, Cogswell Building
Helena, MT 59620
Mike Steffcnsmeier 402/471-2186
Department of Environmental Control
Land Quality Division
P.O. Box 94877
Statehouse Station
301 Centennial Mall South
Lincoln, NE 68509
Vern Rosse 702/885-4670
Department of Conservation and Natural Resources
Division of Environmental Protection
Capitol Complex
Carson City, NV 89710
Wendy Waskin 603/271-4623
Department of Health and Welfare
Division of Public Health Services
Health and Welfare Building
Hazen Drive
Concord, NH 03301
Carmin Hutchinson 609/984-3118
Department of Environmental Protection
Division of Waste Management
P.O. Box CN028
32 E. Hanover Street
Trenton, NJ 08625
Susan Hill 505/827-2779
Health and Environment Department
Solid and Hazardous Waste Management Program
P.O. Box 968
Santa Fe, NM 87504
Janakrai Desai 518/457-7110
Division of Hazardous Substance Regulation
Department of Environmental Conservation
50 Wolf Road
Albany, NY 12233
Chuck Hayes 919/733-2188
Department of Human Resources
Solid and Hazardous Waste Management Branch
P.O. Box 2091
Raleigh, NC 27602
February 1988 Page D-5
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TELEPHONE NUMBERS Inspection Manual
Neil Knatterud 701/224-2366
State Department of Health
-Division of Hazardous Waste Management
1200 Missouri Ave.
Box 5520
Bismarck, ND 58502-5520
William B. Lopp 633-6984
Department of Public Health and (Overseas Operator)
Environmental Services
Commonwealth of Northern Mariana Islands
Saipan, Mariana Islands 96950
Vacant, Contact Martha Gibbons, Supervisior 614/481-7220
Ohio EPA
Division of Solid and Hazardous Waste Management
P.O. Box 1049, 1800 Watermark Drive
Columbus, OH 43266-0149
Lynne Doty 405/271-5338
Oklahoma State Department of Health
Waste Management Service
P.O. Box 53551
1000 N.E. 10th St.
Oklahoma City, OK 73152
Jim Vilindre 503/229-6165
Department of Environmental Quality
Hazardous and Solid Waste Division
Executive Building
811 S.W. Sixth Avenue
Portland, OR 97204
Bob Orwan 717/826-2516
Department of Environmental Resources
Bureau of Solid Waste Management
P.O. Box 2063
Harrisburg, PA 17120
Carlos Vazquez 809/722-0439
Environmental Quality Board
204 Bumarada St.
Santurce, PR 00910
Tom Getz 401-277-2808
Department of Environmental Management
Solid Waste Management Program
204 Cannon Building
75 Davis St.
Providence, RI 02901
Allan Tinsley 803/734-5200
Department of Health and Environmental Control
Bureau of Solid and Hazardous Waste Management
J. Marion Sims Building
2600 Bull St.
Columbia, SC 29201
Page D-6 February 1988
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Inspection Manual TELEPHONE NUMBERS
Kevin Tveidt 605/773-3153
Department of Water Natural Resources
Office of Air Quality and Solid Waste
Room 217, Foss Building
523 E. Capital
Pierre, SD 57501
Ed "Willie" Williams 615/741-3424
Division of Solid Waste Management
Customs House, 4th Floor
701 Broadway
Nashville, TN 37219-5403
Allen Kenroy 512/463-7761
Texas Water Commission
Hazardous and Solid Waste Division
P.O. Box 13087, Capital Station
1700 N. Congress
Austin, TX 78711
Kent Gray 801/533-4145
Bureau of Solid and Hazardous Waste
Division of Environmental Health
288 N. 1460 West
P.O. Box 16700
Salt Lake City, UT 84116-0700
John Malter 802/828-3395
Agency of Environmental Conservation
Department of Water Resources and
Environmental Engineering
Waste Management Division
State Office Building
Montpelier, VT 05602
Carol Akens 804/225-2723
Department of Health
Division of Solid and Hazardous Waste Management
Monroe Building, llth Floor
101 N. 14th St.
Richmond, VA 23219
Francine Lang 809/774-6420
Department of Natural Resources Management
Government of the Virgin Islands
Natural Resources Management Building
Second Floor, Sub-Basement
St. Thomas, VI 00801
Wyn Hoffman 206/459-6276
Department of Ecology
Office of Land Programs
Mail Stop PV-11
Olympia, WA 98504
February 1988 Page D-7
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TELEPHONE NUMBERS Inspection Manual
Pam Hays/Rebecca Robertson 304/348-5935
Department of Natural Resource
Division of Water Resources
1201 Greenbrier St., 2nd Floor
Charleston, WV 25312
Lakshmi Sridharan 608/266-8804
Department of Natural Resources
Bureau of Solid Waste Management
P.O. Box 7921
Madison, WI 53707
Rob Gronewald 307/777-7752
Department of Environmental Quality
Solid Waste Management Program
122 W. 25th Street
Herschler Building
Cheyenne, WY 82002
D.4 ASTSWMO - State Telephone Numbers
Below are the addresses and telephone numbers of the primary ASTSWMO contact in
each State and U.S. Territory.
ALABAMA
Alabama Department of Environmental Management
Land Division
1751 Federal Drive
Montgomery, Alabama
36130
Daniel E. Cooper Chief, 205/271-7730
Land Division
Telecopy Number: 205-271-7950
ALASKA
Alaska Department of Environmental Conservation
Environmental Quality Operations
P.O. Box O
Juneau, Alaska
99811
David Ditraglia Program Manager, 907/465-2666
Hazardous Waste and
Superfund Programs
Telecopy Number: 46-311 HXRE
Page D-8 February 1988
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Inspection Manual TELEPHONE NUMBERS
AMERICAN SAMOA
Environmental Quality Commission
American Samoan Government
Pago Pago, American Samoa
Pati Faiai Director, Solid 633-2034
Waste Division (Overseas Operator)
ARIZONA
Arizona Department of Health Services
Division of Environmental Health Services
1740 W. Adams Street
Phoenix, AZ 85007
Ronald Miller Manager, Office 602/257-2304
of Waste and Water
Quality Management
Telecopy Number: 602/255-1272
ARKANSAS
Arkansas Department of Pollution Control and Ecology
Solid and Hazardous Waste Division
8001 National Drive
P.O. Box 9583
Little Rock, Arkansas
72219
John Ward Chief, Solid 501/562-7444
and Hazardous (Ext. 504)
Waste Superfund
Telecopy Number: 501/562-7444 (Ext. 619)
CALIFORNIA
Department of Health Services
1219 K Street, 3rd Floor
Sacramento, CA
95814
Jack Kearns Division Chief, Toxic 916/324-1826
Substances Division
Telecopy Number: 916/445-5289
California Waste Management Board
1020 Ninth Street, Suite 300
Sacramento, CA
95814
Sherman Roodzant Chairman, Waste 916/322-3330
Management Board
Telecopy Number: 916/322-1445
February 1988 Page D-9
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TELEPHONE NUMBERS Inspection Manual
COLORADO
Colorado Department of Health
Waste Management Division
4210 East llth Avenue
Denver, Colorado
80220
David Shelton Director, 303/320-8333
Waste Management (Ext. 4364)
Division
CONNECTICUT
Connecticut Department of Environmental Protection
Hazardous Materials Management Unit
165 Capital Avenue
Hartford, Connecticut
06106
Stephen Hitchcock, Ph.D. Director, 203/566-4924
Hazardous Materials
Management Unit
Connecticut Department of Environmental Protection
Solid Waste Management Unit
165 Capital Avenue
Hartford, Connecticut
06106
Charles Kurker Director, Solid 203/566-3672
Waste Management Unit
DELAWARE
Delaware Department of Natural Resources and
Environmental Control
Division of Air and Waste Management
Solid Waste Management Branch
89 Kings Highway, P.O. Box 1401
Dover, Delaware
19903
William G. Razor Supervisor, 302/736-4781
Solid and Hazardous
Waste Management
Branch/Superfund
Telecopy Number: 302/736-3497
Page D-10 February 1988
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Inspection Manual TELEPHONE NUMBERS
DISTRICT OF COLUMBIA
Department of Consumer and Regulatory Affairs
Pesticides and Hazardous Waste Management Branch
5010 Overlook Avenue, SW, Room 114
Washington, D.C.
20032
Angelo C. Tompros Chief, Pesticides 202/767-8422
and Hazardous Waste
Management Branch/Superfund
FLORIDA
Florida Department of Environmental Regulation
Solid and Hazardous Waste Section
2600 Blair Stone Road
Tallahassee, Florida
32301
Robert McVety Administrator, Solid 904/488-0300
Waste, Underground
Storage Tanks (UST)
GEORGIA
Georgia Department of Natural Resources
Land Protection Branch
Industrial and Hazardous Waste Management Program
205 Butler Street, SE, Room 1154
Atlanta, Georgia 30334
John D. Taylor, Jr. Chief, Land 404/656-2833
Protection Branch
Telecopy Number: 404/656-4813
GUAM
Guam Environmental Protection Agency
Post Office Box 2999
Agana, Guam
96910
Jose L. G. Techaira Director, 646/8863-5
Solid/Hazardous Waste
Management Program
February 1988 Page D-11
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TELEPHONE NUMBERS Inspection Manual
HAWAII
Hawaii Department of Health
Environmental Protection and Health Services Division
P.O. Box 3378
Honolulu, Hawaii
96801
James K.Ikeda Deputy Director 808/548-4139
IDAHO
Department of Health and Welfare
Division of Environment
Hazardous Materials Bureau
450 West State Street
Boise, Idaho
83720
Cheryl R. Koshuta Bureau Chief, 208/334-5876
Hazardous Materials
ILLINOIS
Illinois Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
Springfield, Illinois
62706
William Child Manager, Division of 217/782-6760
Land Pollution Control
Telecopy Number: 217/782-6408
INDIANA
Department of Environmental Management
Solid and Hazardous Waste Management
105 S. Merdian Street
Indianapolis, Indiana
46225
David D. Lamm Assistant Commissioner 317/232-8839
for Solid and Hazardous
Waste Management
Telecopy Number: 317/243-5117
Page D-12 February 1988
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Inspection Manual TELEPHONE NUMBERS
IOWA
Iowa Department of Water, Air and Waste Management
900 East Grand Street
Henry A. Wallace Building
Des Moines, Iowa
50319
Peter Hamlin Chief, Air Quality and 515/281-8690
Waste Protection Bureau
KANSAS
Kansas Department of Health and Environment
Bureau of Waste Management
Forbes Field
Topeka, Kansas
66620
Dennis Murphey Acting Manager, Bureau 913/862-9360
of Management (Ext. 290)
KENTUCKY
Department for Environmental Protection
Division of Waste Management
18 Reilly Road
Frankfort, Kentucky
40601
J. Alex Barber Director. Division 502/564-6716
of Waste Management (Ext. 214)
Telecopy Number: 502/564-2150 (Ext. 126)
LOUISIANA
Louisiana Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44066
Baton Rouge, Louisiana
70804
John Koury Assistant Secretary, 504/342-1216
Department of
Environmental Quality
February 1988 Page D-13
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TELEPHONE NUMBERS Inspection Manual
MAINE
Maine Department of Environmental Protection
Bureau of Oil and Hazardous Materials Control
State House - Station 17
Augusta, Maine
04333
Alan Prysunka Director, Bureau 207/289-2651
of Oil and Hazardous
Materials Control
Telecopy Number: 207/289-3628
Maine Department of Environmental Protection
Bureau of Land Quality
State House - Station 17
Augusta, Maine
04333
Paula Clark Director, Bureau 207/289-2111
of Land Quality
MARYLAND
Office of Environmental Programs
Waste Management Administration
201 West Preston Street
Baltimore, Maryland
21201
Ron Nelson . Director, Waste 301/225-5647
Management Administration
Telecopy Number: 301/225-5728
MASSACHUSETTS
Department of Environmental Quality Engineering
Division of Solid and Hazardous Waste
One Winter Street, 5th Floor
Boston, Massachusetts
02108
William F. Cass Director, Division 617/292-5589
of Hazardous Waste
Telecopy Number: 617/292-5593
Page D-14 February 1988
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Inspection Manual TELEPHONE NUMBERS
MICHIGAN
Department of Natural Resources
Hazardous Waste Division
P.O. Box 30028
Lansing, Michigan
48909
Al Howard Chief, Hazardous 517/373-2730
Waste Division
Telecopy Number: 517/373-4797
Department of Natural Resources
Groundwater Quality Division
P.O. Box 30028
Lansing, Michigan
48909
Richard Johns Chief, Groundwater 517/373-4823
Quality Division,
Superfund, Solid Waste
MINNESOTA
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road North
St. Paul, Minnesota
55155
Richard Svanda Director, Division 612/296-7282
of Solid and
Hazardous Waste
Telecopy Number: 612/297-1456
MISSISSIPPI
Department of Natural Resources
Bureau of Pollution Control
Division of Solid Waste Management
P.O. Box 10385
Jackson, Mississippi
39209
Sam Mabry Director, Division 601/961-5062
of Solid Management,
Superfund
February 1988 Page D-15
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TELEPHONE NUMBERS Inspection Manual
MISSOURI
Department of Natural Resources
Waste Management Program
P.O. Box 176
205 Jefferson Street
Jefferson Building
Jefferson City, Missouri
65102
R. Stan Jorgensen Program 314/751-3176
Director, Waste
Management
MONTANA
Department of Health and Environmental Sciences
Solid Waste Management Bureau
Room B-201, Cogswell Building
Helena, Montana
59620
Duana L. Robertson Chief, Solid 406/444-2821
and Hazardous Waste
Bureau
NEBRASKA
Department of Environmental Control
Land Quality Division
P.O. Box 94877
Statehouse Station
301 Centennial Mall South
Lincoln, Nebraska
68509
Jack Sukovaty Division Chief, 402/471-2186
Land Quality Division
NEVADA
Department of Conservation and Natural Resources
Division of Environmental Protection
Capitol Complex
Carson City, Nevada
89710
Lewis Dodgion, P.E. Administrator, 702/885-4670
Division of Environmental
Protection
Page D-16 February 1988
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Inspection Manual TELEPHONE NUMBERS
NEW HAMPSHIRE
Department of Health and Welfare
Division of Public Health Services
Health and Welfare Building
Hazen Drive
Concord, New Hampshire
03301
John A. Minichiello Assistant Director, 603/271-4611
Public Health
NEW JERSEY
Department of Environmental Protection
Division of Waste Management
P.O. Box Cn027
401 East State Street
Trenton, New Jersey
08625
John Gaston Assistant 609/292-1250
Commissioner of
Waste Management
NEW MEXICO
Health and Environment Department
Solid and Hazardous Waste Management Program
P.O. Box 968
Santa Fe, New Mexico
87504
Phillip Westen Environmental 505/827-2779
Scientist. Division
of Solid Waste
Telecopy Number: 505/827-9808
NEW YORK
Division of Hazardous Substance Regulation
Department of Environmental Conservation
50 Wolf Road
Albany, New York
12233 .
N.G. Kaul, P.E. Director, 518/457-5768
Division of Hazardous
Substance Regulation
Telecopy Number: 518/457-1088
February 1988 Page D-17
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TELEPHONE NUMBERS Inspection Manual
NORTH CAROLINA
Department of Human Resources
Solid and Hazardous Waste Management Branch
P.O. Box 2091
Raleigh, North Carolina
27602
William Meyer Head, Solid 919/733-2178
and Hazardous Waste
Management Branch
NORTH DAKOTA
State Department of Health
Division of Hazardous Waste Management and Special Studies
1200 Missouri Avenue, Room 302
Box 5520
Bismarck, North Dakota
58502-5520
Martin Schock Director, Division 701/224-2366
of Environmental Waste
Management and Special
Studies Superfund
NORTHERN MARIANA ISLANDS
Department of Public Health and Environmental
Services
Commonwealth of Northern Mariana Islands
Saipan, Mariana Islands
96950
William B. Lopp Chief, Division 663-6984 or
of Environmental Quality 633-6114
(Overseas Operator)
OHIO
Ohio Environmental Protection Agency
Division of Solid and Hazardous Waste Management
P.O. Box 0149, 1800 Watermark Drive
Columbus, Ohio
43266-0149
Chuck Taylor Chief, Division 614/481-7203
of Solid and Hazardous
Waste Management
Telecopy Number: 614/481-2181
Page D-18 February 1988
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Inspection Manual TELEPHONE NUMBERS
OKLAHOMA
Oklahoma State Department of Health
Waste Management Service
P.O. Box 53551
1000 N.E. 10th Street
Oklahoma City, Oklahoma
73152
Dwain Farley, Ph.D. Chief, Waste 405/271-5338
Management Service
OREGON
Department of Environmental Quality
Hazardous and Solid Waste Division
811 S.W. Sixth
Portland, Oregon
97207
Michael Downs Administrator, 503/229-5356
Solid Waste Division
PENNSYLVANIA
Department of Environmental Resources
Bureau of Solid Waste Management
P.O. Box 2063
Harrisburg, Pennsylvania
17120
Donald A. Lazarchik, P.E. Director, 717/787-9870
Bureau of Solid
Waste Management
Telecopy Number: 717/783-2802
PUERTO RICO
Environmental Quality Board
P.O. Box 11488
San Juan, Puerto Rico
00910
Santos Rohena Director, 809/722-1175
Environmental Quality
Board
February 1988 Page D-19
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TELEPHONE NUMBERS Inspection Manual
RHODE ISLAND
Department of Environmental Management
Solid Waste Management Program
204 Cannon Building
75 Davis Street
Providence, Rhode Island
02908
Tom Getz Chief, Division of Air 401/277-2808
and Hazardous Waste
Management
SOUTH CAROLINA
Department of Health and Environmental Control
Bureau of Solid and Hazardous Waste Management
J. Marion Sims Building
2600 Bull Street
Columbia, South Carolina
29201
Robert W. King, Jr., P.E. Chief, 803/758-5677
Bureau of Solid and
Hazardous Waste Management
SOUTH DAKOTA
Department of Water and Natural Resources
Office of Air Quality and Solid Waste
Room 217, Foss Building
523 E. Capital
Pierre, South Dakota
57501
Joel C. Smith Administrator, 605/773-3153
Office of Air Quality
and Solid Waste
TENNESSEE
Division of Solid Waste Management
Customs House, 4th Floor
701 Broadway
Nashville, Tennessee
37219-5403
Tom Tiesler Director, Division 615/741-3424
of Solid Waste
Management
Page D-20 February 1988
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Inspection Manual TELEPHONE NUMBERS
TEXAS
Texas Water Commission
Hazardous and Solid Waste Division
P.O. Box 13087, Capital Station
Austin, Texas
78711
Bryan W. Dixon, P.E. Director, 512/463-7760
Hazardous and Solid
Waste Division
Department of Health (Municipal)
Division of Solid Waste Management
1100 West 49th Street
Austin, Texas
78756
Hector Mendieta, P.E. Director, 512/458-7271
Division of Solid
Waste Management
Telecopy Number: 512/458-7407 (Verify: 512/458-7770)
UTAH
Bureau of Solid and Hazardous Waste
Division of Environmental Health
288 North 1460 West
P.O. Box 16700
Salt Lake City, Utah
84140
Dale Parker, Ph.D. Assistant Director, 801/538-6121
Division of
Environmental Health
VERMONT
Agency of Environmental Conservation
Department of Water Resources and Environmental Engineering
Waste Management Division
103 S. Main Street - 15
Waterbury, Vermont
05676
Reginald LaRosa, P.E. Chief of 802/244-8755
Operations
February 1988 Page D-21
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TELEPHONE NUMBERS Inspection Manual
VIRGIN ISLANDS
Department of Natural Resources Management
Government of the Virgin Islands
Natural Resources Management Building
Second Floor, Sub Basement
St. Thomas, Virgin Islands
00801
Francine Lang Director, 809/774-6420
Department of Natural
Resources Management
VIRGINIA
Department of Health
Division of Solid and Hazardous Waste Management
Monroe Building, llth Floor
101 North 14th Street
Richmond, Virginia
23219
Cynthia Bailey Executive 804/225-2667
Director, Division of
Solid and Hazardous
Waste Management
WASHINGTON
Department of Ecology
Office of Land Programs
Solid and Hazardous Waste Management Division
Mail Stop PV-11
Olympia, Washington
98504
Earl Tower Special Assistant 206/459-6690
to DOE Director
Telecopy Number: 206/459-6007
WEST VIRGINIA
Department of Natural Resources
Division of Waste Management
1260 Greenbrier Street
Charleston, West Virginia
25311
B. Douglas Steele Acting Chief, 304/348-5935
Division of Waste
Management
Telecopy Number: 304/348-0256
Page D-22 February 1988
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Inspection Manual TELEPHONE NUMBERS
WISCONSIN
Department of Natural Resources
Bureau of Solid Waste Management
101 S. Webster Street
Madison, Wisconsin
53703
Paul Didier Director, Bureau 608/266-1327
of Solid Waste
Management
Telecopy Number: 608/267-3579
WYOMING
Department of Environmental Quality
Solid Waste Management Program
122 West 25th Street
Herschler Building
Cheyenne, Wyoming
82002
Charles A. Porter Supervisor, 307/777-7752
Solid Waste Management
Regulation
February 1988 Page D-23
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TELEPHONE NUMBERS
Inspection Manual
D.5 EPA Telephone Numbers
EPA Library
EPA Personnel Locator
EPA Region 1
EPA Region 2
EPA Region 3
EPA Region 4
EPA Region 5
EPA Region 6
EPA Region 7
EPA Region 8
EPA Region 9
EPA Region 10
202/382-5921
202/382-2090
617/223-7210
212/264-2525
215/597-9800
404/881-4727
312/353-2000
214/767-2600
913/236-2800
303/293-1603
415/974-8153
206/442-5810
Page D-24
February 1988
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APPENDIX E
ELECTROPLATING WASTE STREAM
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APPENDIX E TABLE OF CONTENTS
Appendix E ELECTROPLATING WASTE STREAM E-l
E.I Background E-l
E.2 Pretreatment E-3
E.3 Treatment E-7
E.4 Posttreatment E-9
E.5 In-House Waste Treatment E-9
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Inspection Manual ELECTROPLATING WASTE STREAM
Appendix E
ELECTROPLATING WASTE STREAM
Each type of production facility has specific processes and specific complexities. In order
to inspect a facility effectively, it is important to understand the nature of the processes
that take place at a particular facility. It is also necessary to understand the types of
wastes that the particular type of facility handles. Hence, this appendix is designed to
summarize a case example of one type of facility: electroplating. The material is not
sufficiently detailed to allow you to effectively inspect an electroplating facility without
further training. Rather, its purpose is to summarize the major aspects of the industry so
you will understand its complexity.
This appendix is divided into five major sections. First, background material about the
industry is provided. Second, the pretreatment stage of electroplating process is
summarized. Third, the treatment stage itself is discussed. Fourth, posttreatment is
summarized. Finally, various methods that electroplating facilities use to treat their
wastes are described (For more detail see Cherry, 1982; Cushnie, 1985; Dawson and
Mercer, 1986; and Sittig, 1978).
E.I Background
Electroplating is one of several metal finishing processes used to improve the surface or
other areas of a material. Essentially, electroplating involves plating a metal or series of
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ELECTROPLATING WASTE STREAM Inspection Manual
metals onto another metal or similar surface. The process consists of three major steps:
cleaning (pretreatment), electroplating (treatment), and rinsing and drying
(posttreatment). Electroplating and related metal finishing processes, along with primary
metals, organic chemical, and pesticides and explosives industries, generate approximate!}'
83 percent of all potentially hazardous waste.
The basic chemistry of the electroplating process may be summarized as follows: In the
electroplating solutions, metal ions, in either acid, alkaline or neutral solutions are reduced
on cathode surfaces. These cathode surfaces are the work pieces being plated. The metal
ions in solution are usually replenished by dissolving metal from an anode surface. This
anode surface may be in bar form, or in small pieces contained in inert wire, or in
expanded metal baskets.
The electroplating industry is diverse in many ways. It consists of three major segments:
large captive shops, small captive shops, and job shops. Facilities vary in size and
character, including processes performed at facility, volume of plating or processing
solutions, area of metals being plated, and power consumed. The number of employees
varies. Also, the amount of waste varies from facility to facilitj'. For instance, the initial
conditions of substrate material affect the amount of waste generated. Yet, the nature of
the electroplating process is the same in all facilities regardless of size and age. Hence, the
characteristics of the waste are same for plants of all ages and sizes. Only the quantity
of waste per unit time differ (Sittig, 1978).
Wastes in the electroplating process occur in two major ways: from the processes
themselves, and from accidents or inappropriate management. Inappropriate management
includes: dumping, accidental discharge, and leaks in equipment. Dumping has a severe
pollution effect. It can occur as a batch, or continuously. Accidental discharges have the
next most severe threat. For instance, plants could have slow leaks in plating solution
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Inspection Manual ELECTROPLATING WASTE STREAM
tanks that might go undetected for months. Finally, equipment may be faulty. Filter
hoses, heat-exchanger connections and pumped process lines are all prone to leaks, and
hoses deteriorate.
To help reduce the environmental impact, several environmental laws regulate wastes
from the electroplating industry. These laws include Toxic Substance Control Act, RCRA,
and Clean Water Act (CWA). RCRA regulations differ from those concerned with water
pollution. With CWA, water regulations vary according to the specific industrj' to which
they are directed. With RCRA, all industries that generate, store, transport or dispose of
hazardous waste must comply with the same set of rules. Several electroplating wastes
are specifically listed as hazardous. These are wastewater treatment sludge, used (spent)
plating bath solutions, plating bath sludge from the bottom of plating baths, spent
stripping, and cleaning bath solutions.
At an electroplating facility, the electroplating process consists of three major stages:
pretreatment, treatment and posttreatment. These three stages are briefly discussed
below.
E.2 Pretreatment
Before metals are electroplated, they must be cleaned. Cleaning consists of removing oil,
grease, dirt and oxides from surface of material to be plated. The main purpose of
cleaning is to insure that the electroplate adheres well. Various cleaning methods are
used. Minimally included in this cleaning process are sequential treatments in alkaline
and acid solutions. Types of treatments include: acid cleaning, solvent cleaning, alkaline
cleaning (both non-electrolytic and electrolytic alkaline cleaning), emulsion cleaning,
ultrasonic cleaning, salt bath descaling, pickling, and polishing, barrel finishing or
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ELECTROPLATING WASTE STREAM
Inspection Manual
tumbling. The specific process used depends on the type of material to be plated. Table
E. 1 summarizes various types of pretreatment cleaning used in electroplating.
Acid Cleaning
Table E.I Summary of Pretreatment Cleaning Processes
Acid cleaning is used to remove oxides or to neutralize
residual alkali films. One special type is bright dipping acid
cleaning, which is used to remove oxides and tarnish from
ferrous and nonferrous materials. Phosphoric-nitric-acetic
acid solutions are used. Pickling acid cleaning is another
type which involves the dissolution of oxide scale in an acid.
Acid solutions include: hydrochloric acid, chromic acid,
sulfuric acid and phosphoric acid.
Alkaline Cleaning
Emulsion Cleaning
Mechanical Cleaning
Salt Bath Descaling
Solvent Cleaning
Alkaline cleaning is used to remove oil soils ar solid soil from
work pieces. Three basic types of alkaline cleaners: soak,
spray, electrolytic. Effective alkaline or soak cleaner must
be soluble in water, must wet the surface of the basis
material, must wet and penetrate any soil, must saponify or
dissolve all oil and greases or must emulsify insoluble or
nonsaponifiable oils and greases. The process must also
prevent calcium and magnesium deposits to form from hard
water, prevent tarnish and corrosion of basis material, rinse
freely and minimize foaming. Cleaners may be made up of
one or more of the following chemicals: Sodium hydroxide,
Sodium-carbonate, Sodium-metalsilicate, Sodium-phosphate,
Sodium-silicate, Sodium-tetraphosphate, and a wetting
agent. This process is best for such metals as brass,
chromium, copper, gold, lead, nickel, silver, and zinc.
Emulsion cleaning consists of common cleaning organic
solvents dispersed in an aqueous medium by an emulsifying
agent.
Mechanical cleaning removes impurities through tumbling,
burnishing, dry rolling, buffing, defurring, polishing, and
blasting.
Salt bath cleaning includes the sequence of salt bath, water
bath, and acid dip to clean hard-to-remove oxides from
stainless steels and other corrosion-resistant alloys.
Solvent cleaning can involve either a hot or a cold cleaning
bath.
Different wastes are generated with each type of pretreatment process. For example
different wastes are produced during acid cleaning than with alkaline cleaning. Table E.2
below lists wastes that are classified as hazardous for the electroplating process. Since
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Inspection Manual ELECTROPLATING WASTE STREAM
various wastes are generated in the cleaning stage of the plating process, inspectors should
inspect, and perhaps sample the pretreatment area of the plant.
Furthermore, all pieces of equipment should be inspected for leaks, contamination from one
tank to another, corrosion, etc. Cleaning often occurs in tanks, vats, or barrels. In
addition, various pipes, hoses, and electrical work may connect the tanks. Raw wastes
may be found in rinse waters. Spills, dumps of concentrated solutions, wash waters from
air-exhaust ducts, leaky heating and cooling coils and heat exchangers are other sources
where waste may be found.
After the material to be plated is cleaned, it is usually rinsed and dried. Like the
pretreatment cleaning stage, the certain wastes are generated in pretreatment rinsing
stage. Inspectors should trace and sample where these rinses are stored or disposed of.
Table E.2 Wastes Listed as Hazardous in Electroplating.
This table lists the Industry and EPA hazardous waste number, a description of the waste
and the specific hazard the waste presents. [Source: Federal Register (261.31) 40 CFR
(Chapter 1) (7-1-86 Edition).]
FOO1 The following spent halogenated solvents used in degreasing:
Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all
spent solvent mixtures/blends used in degreasing containing, before use, a
total of ten percent or more (by volume) of one or more of the above
halogenated solvents or those solvents listed in F002, F004, and F005; and
still bottoms from the recovery of these spent solvents and spent solvent
mixtures. (Toxic).
F002 The following spent halogenated solvents: Tetrachloroethylene, methylene
chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-
trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene,
trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent
mixtures/blends containing, before use, a total of ten percent or more (by
volume) of one or more of the above halogenated solvents or those listed in
F001, F004, or F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures. (Toxic)
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Inspection Manual
F003
F004
F005
F006
FOOT
F008
F009
F010
F011
F012
F019
The following spent non-halogenated solvents: Xylene, acetone, ethyl
acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol,
cyclohexanone, and methanol; all spent solvent mixtures/blends containing,
before use, only the above spent non-halogenated solvents; and all spent
solvent mixtures/blends containing, before use, one or more of the above
non-halogenated solvents, and, a total of ten percent or more (by volume) of
one or more of those solvents listed in F001, F002, F004, and F005; and
still bottoms from the recovery of these spent solvents and spent solvent
mixtures. (Ignitable)
The following spent nori-halogenated solvents: Cresols and cresylic acid, and
nitrobenzene; all spent solvent mixtures/blends containing, before use, a
total of ten percent or more (by volume) of one or more of the above non-
halogenated solvents or those solvents listed in F001, F002, and F005; and
still bottoms from the recovery of these spent solvents and spent solvent
mixtures. (Toxic)
The following spent non-halogenated solvents: Toluene, methylethyl
ketone, carbon disulfide, isobutanol pyridine, benzene, 2-ethoxyethanolc and
2-nitropropane; all spent solvent mixtures/blends containing, before use, a
total of ten percent or more (by volume) of one or more of the above non-
halogenated solvents or those solvents listed in F001, F002, or F004; and
still bottoms from the recovery of these spent solvents and spent solvent
mixtures. (Ignitable, Toxic)
Wastewater treatment sludges from electroplating operations except from
the following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin
plating on carbon steel; (3) zinc plating (segregated basis) on carbon steel;
(4) aluminum or zinc-aluminum plating on carbon steel; (5)
cleaning/stripping associated with tin, zinc and aluminum plating on carbon
steel; and (6) chemical etching and milling of aluminum. (Toxic)
Spent cyanide plating bath solutions from electroplating operations.
(Reactive, Toxic)
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process. (Reactive, Toxic)
Spent stripping and cleaning bath solutions from electroplating operations
where cyanides are used in the process. (Reactive, Toxic)
Quenching bath residues from oil baths from metal heat treating operations
where cyanides are used in the process. (Reactive, Toxic)
Spent cj'anide solutions from salt bath pot cleaning from metal heat
treating operations. (Reactive, Toxic)
Quenching waste water treatment sludges from metal heat treating
operations where cyanides are used in the process. (Toxic)
Wastewater treatment sludges from the chemical conversion coating of
aluminum. (Toxic)
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Inspection Manual ELECTROPLATING WASTE STREAM
E.3 Treatment
The electroplating process itself consists of a series of steps carried out in a series of
stations. Within a station may be several units or substations. At each station (or
substation) are various plating baths. Some states require that most toxic solutions, such
as cyanide and chromic acid plating solutions, be contained by a double-walled container to
help reduce the possibility of accidental discharge. Furthermore, these stations must be
arranged so one plating bath does not contaminate the next.
The steps in the electroplating process may be very simple (e.g. cleaning, rinsing, plating,
rinsing, drying) or very complex. Complexities in the electroplating process result from the
nature of the materials, as well as from other factors. For instance, cleaners, acid dips
and strikes vary in composition and concentration, depending upon particular basis
material. Some materials require more intense activation steps than others. Time for
each step varies with the number of stations in each cycle. Also, the transfer time from
station to station, the type of basis material process and the coating(s) deposited varies
depending on the material to be electroplated, and the chemicals being used for the
electroplating.
Another aspect which complicates the process is the type of plating. Electroplating may be
done in either barrel operations or rack plating. Barrel operations are used for small parts
that tumble freely in rotating barrels. Rack plating is used when a large percentage of the
surface area is processed commercially. The choice of methods is based on size and
quantity of parts to be processed per unit time. The same salts, acids, etc. are used in the
process. Hence, the waste characteristics remain unchanged.
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ELECTROPLATING WASTE STREAM Inspection Manual
Many hundreds of electroplating solutions have been commercially adopted. However,
only two to three types are widely used for a single metal or alloy. For example, cyanide
is used for copper, zinc, brass, silver and gold.
Usually, the entire processing area drains onto the floor. Often, the floor is only an
extension of the sewer system leaving the area. So, within the treatment area, (as well as
the facility totally) inspectors should look for corroded plating tanks, piping and treatment
tanks. They should check floors, steel supports and wall, electrical switch gear, duct work
and fans, valves such as ball valves, and plug valves for leaks, corrosion, etc.
Waste from Electroplating Process
Most electroplating solutions can be maintained in working order by periodically or
continuously filtering, purifying or adding various chemicals. However, some solutions
cannot be purified, or it is not economical to do so. These solutions must be treated as
wastes. Refer back to Table E.2 for a list of the hazardous wastes from the electroplating
process.
Wastes from the electroplating process may be liquids, sludges, or solids such as residue
from bottom of tanks. They may be treated or stored in several different ways. These
including filtering the sludge, then storing it and eventually shipping it off site, directly
recycling the plating baths, and storing waste water in surface impoundments.
The wastes contain diverse compounds. Plating baths at each station contain metal salts,
acids, alkalis, and various compounds used for bath control. Common plating metals
include copper, nickel, chromium, cadmium, lead, and iron, plus gold, silver, palladium,
platinum, and rhodium. Common cationic constituents include ammonia, sodium, and
potassium. Common ions include: borate, cyanide, carbonate, fluoride, fiuoborate,
phosphates, chloride, sulfate, sulfide, sulfamate, tartrate. Also, many plating solutions
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Inspection Manual ELECTROPLATING WASTE STREAM
contain metallic, metallo-organic and organic additives. These additives are used to induce
grain refining, level paint surfaces, and deposit and brighten the various plating surfaces.
E.4 Posttreatment
After the base material has been electroplated, sometimes additional coatings are applied.
These additional coating are used to improve surface for painting, to improve lubricity, to
enhance anti-corrosion properties, or to apply a colored finish. One type of additional
finishing procedure is to apply a chromate coating (chromating). Chromating applies a
protective film to the electroplated material. Metal coloring is another posttreatment
process.
Similar to the pretreatment and treatment stages, wastes are generated with the
posttreatment stage. Inspectors may need to sample from the stations in the
posttreatment area.
E.5 In-House Waste Treatment
In addition to pretreatment, treatment, and posttreatment areas in an electroplating
facility, many of larger plants have areas where they treat wastes "in-house". Generally,
these areas are used to treat wastes which cause air and water pollution. Inspectors may
need to inspect these areas, as the waste treatment processes themselves may generate or
result in waste production.
Some small installations have insufficient space for accommodating effective in-process
controls to minimize water use, and to conventionally treat chemical waste. Hence, the
chemicals from these smaller facilities must be transported to an appropriate disposal
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ELECTROPLATING WASTE STREAM Inspection Manual
facility. Inspectors may need to check that the waste to be transported is packaged
appropriately.
In-House Waste Treatment for Air Pollution
In-house treatment for air pollution may be divided into two primary components: exhaust
system, and air pollution control devices.
An exhaust system contains a ventilation system and system for removing contaminants
from exhaust stream. The ventilation system must be carefully designed for several
reasons. First, toxic contaminants may flow into other areas whenever windows or doors
open. Second, chemicals may corrode or inflame. Hence, materials should be corrosion-
resistant and fire retardant. Third, fumes disperse throughout the area. Hoods should be
designed to capture fumes generated from tanks. Also, pick-up points must be arranged to
capture fumes in the areas. For example, if fumes tend to rise, then pickup points should
be at maximum height of where work occurs. Fumes should also be kept in the tank area
until they can be picked up thoroughly by the exhaust hood. Fourth, exhaust systems
may become contaminated. Hence, to reduce contamination, separate exhaust systems are
often used. For instance, exhaust systems for cyanide should be kept separate from other
systems, and ammonia should be kept separate from exhaust system that handles
hydrochloric acid. Finally, cross drafts may occur. Therefore, hoods should be placed
carefully to minimize contaminants dispersal in cross drafts. Inspectors may need to check
for cross drafts, corrosion, etc.
Ducts and fans in the exhaust system may need to be checked. Liquids may condense on
the duct work. Hence, these ducts should slope, and drainage points should be provided so
condensation can be controlled. Inspectors may need to check for leaks and check the
drains by the fans. Fans should have drains nearby them, as in many cases, the exhaust
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stream coining from the metal finishing operations is saturated heavily with liquid
droplets. These liquids can build up with in the fan housing very rapidly.
The second component of the system for treating air pollution are air pollution control
devices. These devices are used to monitor gases and liquid particulate, and rarely rnists.
The control devices include scrubbers, evaporators, and miscellaneous pipes. Like the
exhaust system, the air control pollution devices need to be carefully designed. The type of
scrubber depends on the nature of the emissions. For instance, in electroplating, wet
scrubbers, as opposed to mechanical or electrical ones, are often used. Often a wet
scrubber is combined with an evaporator. Evaporators are recommended to use when
removing contaminants from a metal Finishing operation is economical, such as with nickel
and chrome plating.
In-House Treatment for Water Pollution
Many of the wastes from the electroplating industry are in solution, or in the form of
wastewater. This wastewater comes from cleaning, pickling, plating, etching, etc. It
includes constituents coming from the base material being finished, as well as constituents
coming from the components in the processing solution. Major wastewater constituents
are metal cations and anions used in cleaning, pickling, and processing baths.
The purpose of in-plant treatment is to reduce or eliminate the waste load which requires
end-of-pipe treatment. This treatment is especially important since approximately 80
percent of all plants discharge to publicly owned treatment works (POTW).
Like the pretreatment, treatment and posttreatment stages of the electroplating process
itself, the waste treatment area consists of tanks, barrels, pipes, etc. This waste
treatment area must be effectively engineered so it is able to handle stream condensate
which may be accidentally contaminated. This is particularly important since the
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Inspection Manual
environmental impact from contaminated rinse water effluent can be a potentially large
problem, due to the volume of wastewater discharged.
Three major types of treatment systems may be used to chemically treat wastewaters
before they are discharged: continuous, batch, and integrated. These three types of
treatments are briefly described in Table E.3.
Table E.3 Summary of Three Types of Treatment System
Continuous Treatment
Batch Treatment
Integrated Treatment
With continuous treatment, wastes are processed on an on-
going basis. Wastes are continuously recirculated and their
chemical characteristics are continuously monitored and
adjusted to assure optimum conditions for promoting desired
chemical reactions for destroying toxic constituents. The
sizing and baffling of treatment tanks provide sufficient hold
times to complete the chemical reactions. In addition, pH
and oxidation-reduction potential are continuously
monitored. There is also a continuous overflow settling tank
that allows sludge to be pumped off periodically thorough
the tank bottom.
Batch treatment systems collect wastewater, especially
concentrated solutions, in holding tanks. These tanks must
be sufficiently large to provide ample time to treat, test and
drain solutions, and to hold materials while another tank is
being filled. This type of treatment is most appropriate for
small or medium plants.
Integrated treatment systems use a reservoir in conjunction
with rinse tanks for each type of plating bath. In this type
of treatment, effluent is constantly recycled. The major
advantage of this technology is the reduces the amount of
chemicals that go into rinse tanks. It also allows metals to
be recovered. Integrated treatment occurs in proximity to
plating room.
Regardless of the type of treatment used, various methods are available for treating
wastes from the electroplating process. Since these wastewater treatment techniques are
more or less economically and technically feasible, differences exist in the extent to which
they are currently used. In addition, all techniques have ecological aspects which must be
considered. Many processes, such as those for zinc, copper, and cadmium, are not yet
amenable to problem-free, closed-loop reclamation. Furthermore, the particular method
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used to treat the wastes depends on specific chemical composition and chemical properties
of the wastes.
Types of Conservation
Various methods of altering the electroplating process are used to reduce the amount of
waste generated, increase unit process efficiency, or both. Methods are used during
treatment itself. These include modifying processes, substituting materials, and reducing
amount of water used. These processes are summarized in Table E.4.
Table E.4 Summary of Types of Electroplating Modifying Processes
Modifying Processes Modifying processes entails substituting low concentrations
of electroplating solutions for high concentrations. This
procedure then requires less water for rinsing when
electroplating parts are transferred to rinse tanks.
Substituting Materials Substituting materials entails using less toxic and
environmentally detrimental substances for materials which
are more toxic and environmentally detrimental. This
procedure has not been used to a large degree because the
chemicals traditionally used have been profitable and
efficient. However, zinc has been substituted for cyanide in
some cases.
Reducing Water Used Reducing the amount of water used during the electroplating
process is another way to reduce the amount of wastewater.
Techniques include installing counterfiow rinse tanks,
freezing, electrodialysis, electrolytic stripping, carbon
adsorption, liquid-liquid extraction, ion exchange,
evaporative recovery, or reverse osmosis.
Techniques are also used after the electroplating process has occurred. These include
recovering and reusing materials, separating streams, and removing solids. Table E.5
summarizes these techniques.
Table E.5 Summary of Techniques for Reducing Waste Loads
Recovering/Re-Using Materials Recovering and/or re-using materials entails
reclaiming or regenerating constituents
which would otherwise be lost in the
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wastewater or discarded. These constituents
include plating baths, plating solutions, and
etching solutions. Specific techniques for re-
using materials include evaporation, ion
exchange, electrolytic recovery,
electrodialysis, reverse osmosis.
Separating Streams Separating waste streams entails separating
or combining plating baths and rinse baths
according to their chemical composition to
reduce the amount of waste. For instance, in
general, cyanide and hexavalent chromium
are treated separately from each other, and
all other chemicals. Yet after initially
treating them separately, these wastes may
be combined with metal ions to treat further.
Removing Solids Removing solids involves removing or
separating metals and other pollutants from
wastewaters. Specific methods include
hydroxide and sulfide precipitation.
sedimentation, diatomaceous earth filtration,
membrane filtration, granular bed Filtration,
sedimentation, peat adsorption, insoluble
starch xanthate treatment and flotation, and
sludge disposal.
LITERATURE CITED
Cherry, K. (1982) Plating Waste Treatment. Ann Arbor, MI: Ann Arbor Science
Publisher, Inc.
Cushnie, G. Jr. (1985) Electroplating Wastewater Pollution Control Technology. NJ: Noyes
Publications.
Dawson, G. and Mercer, B. (1986) Hazardous Waste Management. NY: John Wiley and
Sons.
Sittig, M. (1978) Electroplating and Related Metal Finishing: Pollutants and Toxic
Materials Control. NJ: Noyes Data Corporation.
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APPENDIX F
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APPENDIX F TABLE OF CONTENTS
Appendix F PULP AND PAPER WASTE STREAM F-l
F.I Overview of Pulping Process F-l
F.2 Pulp Bleaching F-4
F.3 Overview of the Paper Making Process F-5
F.4 Overview of Pulp and Paper Wastes F-9
F.5 Methods of Managing Pulp and Paper Wastes F-ll
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Appendix F
PULP AND PAPER WASTE STREAM
Pulp and paper industries have specific processes and complexities. In order to inspect this
type of facility effectively, inspectors should have a general idea the mill processes and its
associated wastes. Hence, this appendix is designed to briefly describe the major processes
associated with pulp and paper production. The material is not sufficiently detailed to
allow you to effectively inspect a pulp and/or paper facility without further training.
Rather, its purpose is to summarize the major aspects of the industry so you will
understand its complexity.
The appendix is divided into five major sections. The first section describes the basic
pulping process. The second section summarizes pulp bleaching. The third section briefly
describes the papermaking process. The fourth section summarizes the types of wastes
associated with producing pulp and paper. Finally, in the fifth section, methods of
managing pulp and paper wastes are discussed. (For more detail, see Libby, 1962a;
Libby, 1962b; and Springer, 1986).
The pulp and paper industry involves processing wood into pulp and then making pulp into
paper. There are five major steps in the process: preparing the wood, pulping, bleaching
the pulp, making paper, and finishing the paper.
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F.I Overview of Pulping Process
Pulping is the process by which wood is prepared for making paper. It essentially consists
of three stages: preparing wood in the wood yard, pulping, and bleaching the pulp.
Several types of pulping procedures are commercially used. These procedures may be
grouped into three major categories: mechanical, chemical and mechanical/chemical
combinations. Chemical pulping includes such processes as Kraft, sulfite, and caustic
soda. Examples of mechanical/chemical combinations include chemimechanical and
semichemical pulping. Each process has advantages and disadvantages.
Several properties of the wood determine the most appropriate pulping process to use for a
given paper product. Perhaps the most important property is the tree species. Different
species require different pulping treatment. Related to tree species, are such significant
properties as morphology of the wood fiber, amount and distribution of chemical
constituents in pulp fibers, and the shape, size, distribution and physical condition of pulp
fibers.
The first stage of the pulping process is preparing the wood. It is prepared by washing the
logs and debarking them. While this stage of the process rarely produces hazardous
waste, inspectors might check this area for effluent leaks. Effluent arises from three
sources: hydraulic conveyance of logs, log washing, and wet debarking.
In the second stage of pulping, wood is made into pulp by treating it mechanically or
chemically. This procedure prepares the pulp for being formed into a sheet or board on the
paper machine. Pulping may be done in either batch mode or continuous mode. Table F. 1
summaries various pulping processes.
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Table F. 1 Summary of Various Pulping Processes
Mechanical Pulping
Chemical Pulping
Mechanical/Chemical Pulping
Mechanical pulping is a process which forces pulp
wood against a rapidly revolving grindstone. It is
used mainly in manufacturing newsprint,
toweling, tissue, wall paper, and coated specialty
papers. It utilizes both the lignin and cellulose in
the wood. Mechanical pulping can be divided into
two types, depending whether pulp is produced
from round wood or chips.
As its name implies, chemical pulping uses
chemicals to make wood into pulp. This process
dissolves the lignin to varying degrees. Various
types of chemical pulping processes are
commercially used. These include: sulfite,
alkaline, caustic soda, and Kraft. Sulfite pulping
separates the cellulose from wood by solubilizing
the lignin layer around the surrounding fibers.
Ammonia sulfite. and magnesium sulfite are
commonly used. Alkaline pulping uses a cooking
liquor consisting mostly of caustic soda to break
down the wood fibers. In Kraft pulping, the
cooking liquor is a mixture of sodium hydroxide
and sodium sulfide.
In chemical puiping, equipment is used to prepare
and handle fibrous materials, and to prepare the
pulping liquor. Also, digestion equipment, or
refiners are used to "cook" or treat the wood
chemically. Refiners perform substantially the
same function as beaters do on the fibers, but
they do it faster and more efficiently.
Semichemical and chemimechanical pulping
procedures fall between classic mechanical and
chemical pulping methods. These procedures
entail a two-stage process. First, wood is treated
with mild chemicals to remove or degrade the
fibrous raw material. Second, wood is defibered
or fiberized to separate the fibers. In
semichemical pulping, this second stage functions
to weaken the lignin-carbohydrate complex of the
fiber bind. Neutral sulfite semichemical pulping,
used for products such as corrugated board,
typifies this two stage process. First, wood chips
are softened by briefly cooking them with either
neutral sodium or ammonium sulfite solution.
They are then defiberated in a refiner.
No standard equipment is utilized in semichemical
and chemimechanical pulping. Generally, the
equipment for the chemical stage is similar to
that equipment used in full chemical pulping.
Equipment used in mechanical stage is frequently
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some type of deliquoring screen press or fiberizing
machine.
Thermomechanical Pulping Thermomechanical pulping uses a presteaming or
reaction vessel to break the wood apart before it
is treated in the primary refiner. In this way, it
is similar to chemimechanical pulping processes.
Specific pieces of equipment are used for each
type of pulping. In mechanical pulping these
include beaters, consistency proportioners, chests,
agitators and pumps. Both continuous beaters
and batch beaters are used to treat the wood.
Pumps are used to distribute process water
throughout the pulp and paper mill, and to
transport stock in slurry from place to place.
Inspectors should check all equipment for corrosion and for leaks around the equipment,
and its associated problems. These problems include: slime deposits, calcium scaling,
buildup of contaminants from waste paper used in the furnish, high water temperatures,
and high levels of dissolved solids. Inspectors should also check the spill collection system
for the pulp washing and screening area, check overflow from heavy to weak liquor tanks,
check extra equipment capacity to handle spills and upsets, and check the ability of the
system to return heavy liquor from the evaporator to the weak liquor tanks instead of
discharging it.
Inspectors should also check the areas in the equipment where effluent arises. With
mechanical pulping, effluent arises from gland seals, spills, screening of rejects, screening
of decker filtrate. In Kraft pulping, effluent may arise from the decker filtrate,
evaporators, intermittent uncontrolled losses. In neutral sulfite semichemical pulping
inspectors should check equipment such as showers, consistency regulators, and wash-up
hoses.
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F.2 Pulp Bleaching
The third stage of pulping is bleaching. It occurs after the pulped wood is washed and
cleaned. This washing procedure and its associated equipment are highly variable.
Bleaching is usually a multistage process, consisting of two to ten stages. Steps in the
bleaching process include may chlorination, alkaline extraction, hypochlorite, chlorine
dioxide and peroxide stages. And, the chemicals most commonly used in bleaching include:
chlorine, sodium hypochlorite and calcium hypochlorite, and chlorine dioxide or peroxide.
Two major types of bleaching are used. First is bleaching that destroys at least part of the
chromophoric groups without being materially consumed by the bulk of the lignin. This
process is used for pulps with a high lignin content, such as groundwood,
chemigroundwood, cold-soda, and semichemical pulps. Second, is bleaching which removes,
all or nearly all, the lignin. This type of bleaching is used with sulfite, Kraft, and soda
pulps that contain relatively small amounts of residual lignin.
Like the pulping process itself, various equipment is used for bleaching. Inspectors should
check this equipment for spills, corrosion, leaks and so forth. It is especially important to
check the first two stages of bleaching because these stages have the most effluent.
F.3 Overview of the Paper Making Process
After pulp is prepared, it is ready to be made into paper. The paper making process
consists of essentially four major stages. First pulp is made into sheets. During the sheet
forming stage, or after sheets are formed, various materials such as color or adhesives
may be added. Next, these sheets are pressed and dried. Finally, the paper is smoothed,
using calenders, and supercalenders.
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Two major types of machines are used to make paper: fourdrinier machines, and cylinder
machines. Although, the details of the equipment vary considerably from one machine to
next, the basic purpose of the machines is to form sheets.
The fourdrinier paper machine has two basic sections. Each section has a particular
function. The first section is where the sheets are formed, and is called the wet end. This
sheetforming process essentially involves depositing diluted, aqueous, Fiber suspensions
onto a relatively fine woven screen. With this deposition, over 95 percent of the water is
removed by draining through wire. The second section is the stock distributor. It
functions to blend flows from individual screens when more than one screen used, to
distribute stock uniformly across whole width of the machine, and to maintain uniformly
dispersed fibers.
A cylinder machine wet end is also used to make paper. It is best for sheets which are
bulky or thick sheets in relation to their weight stock, such as chipboard or some boxboard.
Like the fourdrinier machine, the cylinder machine wet end has several sections. In
addition, there are both multivat and single vat machines. Multivat machines are an
assembly of single vats. These machines consist of vats, whippers (felt cleaners), showers
to remove stock and dirt from the face of the mold, suction boxes to help consolidate the
heat and to help prevent drop-offs between couches, rolls, and presses. Inspectors should
check these machines for leaks, spills, and corrosion.
Special Additives
After the paper has been made into a sheet, or as a paper stock, it may be treated to give
it specific properties. This section briefly describes additives that are applied at either of
these stages.
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One type of additive is a filler or loader. It is an inorganic material which is sometimes
incorporated into the fibrous web to improve the quality of paper or boards.
Various noncellulosic materials are added to improve the paper properties. These special
additives include starches, vegetable gums, latices and other synthetic polymers, wet-
strength resins, foam-control chemicals. They also include surface-sizing agents, and
slime-control chemicals. Surface-sizing agents are applied to paper so it resists penetration
of liquids, specifically water and water solutions.
Each additive has specific a function. For example, starches are added to improve
strength, to improve erasure qualities, and to improve abrasion resistance. They also
serve to reduce surface fuzz and to prevent filler dusting. Gums help improve fiber
bonding to decrease tearing. Various additives are also used to reduce foams, or gas
bubbles.
Another type of additive is color. Two types of colors are used: soluble dyes, and
pigments. And, three principle methods of dying are used. The most important of these
dying methods is stock dyingfaeater dying. With this method, fibers are dyed before sheet
of paper is formed. However, soluble dyes may be added at different stages of process.
For example, optical whiteners may be added to pulp when it is in beaters or it may be
applied to the paper surface.
Pressing
Once the sheet is formed, and appropriate additives are applied to the formed web, it must
be pressed and then dried. Pressing helps remove water from the sheet and supports the
sheets.
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A standard press consists of two rolls, one fixed, and one movable. The movable roll is
arranged to press against the first. Presses consist of either two solid rolls (a plain press)
or one solid and one perforated with an inside suction box (a suction press). Presses may
or may not have felts on them, depending on the function of the press, and the type of
paper desired. For instance, paper machine wet presses are usually provided with felts.
On the other hand, grooved presses on pulp-drying machines are run without felts.
Inspectors should check these presses for leaks, corrosion, etc.
Drying
After a sheet is pressed, it is dried. Wet paper from the press section, which contains
65-85 percent water, is passed through a series of steam-heated rolls and dried to about 6
percent water. The number of driers needed is determined by the amount of water to be
removed. Driers also vary across types of paper. For example, driers for heavy boards
are standard-size steam driers with no felt.
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Smoothers and Surface Treatment
Dried paper is often smoothed using calenders, supercalenders and embossers. These
machines function to reorient surface fibers in the base sheet of paper by either
compression, friction, or combination of compression and friction. Many types of calenders
are used for smoothing the paper. These include: breaker calenders, smoothing calenders,
machine calenders, and supercalenders. Mechanical!}', though, there is little difference
with each type of calender. Each usually stands vertically, and has a complement of rolls,
bearings, pressure systems, and electric controls, and winders.
Other types of materials are often applied to the paper (wet or dry web). This process is
called surface treatment or coating. Surface treatment includes applying adhesives,
functional products, pigment, and their combination to the already formed fibrous web.
F.4 Overview of Pulp and Paper Wastes
The pulp and paper industry produces several wastes. These wastes differ for each
pulping process, for each paper making process, and for each of the various additives that
are used to make the paper have desirable qualities, such as coloring.
The pulp and paper industry produces numerous liquid or effluent wastes. These liquid
wastes consists of water, and some fraction of the chemicals used in producing pulp and
paper. Water is used in nearly every phase of pulp and paper-making processes. It is
used transport the wood and additives. It is used to wash and debark raw materials. It is
also used to process pulp. It is used to dissolve or is mixed with various loading, sizing,
and coloring ingredients. It carries fibers through screens, and refiners. In fact, the
largest single source of wastewater in a fully integrated operation is the paper machine.
In addition, water is used to carry off by-products and undesirable wastes.
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Diverse types of materials are contained within the effluent. It may contain organic
matter, detergents, slimicides, oils and greases, heavy metals, colors, industrial chemicals,
and increased temperatures. Detergents are used to keep the system free of deposits and
certain cleaning applications such as felt-washing. Slimicides (a particular category of
pesticide) such as chlorine, chlorinated phenols, amines, quaternary ammonium
compounds, organo-sulfurs, are used to minimize biological growth. Oils and greases are
common when fuel oil is used as boiler fuel. Heavy metal ions include: aluminum,
chromium, copper, nickel, titanium, iron, mercury, zinc. They are from one of three
sources: chemicals used in pulping process, additives in paper making, and equipment
corrosion.
In addition to effluents, the pulp and paper industry produces various air pollutants
including gaseous wastes such as sulfur dioxide, and particulates. Wood waste boilers are
a source of particulates, nitrogen oxides, sulphur dioxides, carbon monoxides, and
hydrocarbons volatilized from the wood. Particulates include solid and liquid fuels which
contain traces of heavy metals such as beryllium, mercury, lead, cadmium, zinc, arsenic,
selenium, plus nonmetals such as chlorine, fluorine, phosphorus.
Kraft pulping illustrates another example of a source of various air pollution producing
gases and particulates. Particulates are emitted from recovery furnaces, lime kilns, and
smelt dissolving tanks. Reduced sulfur compounds come from pieces of equipment such as
the digester, vacuum washer hood and seal tank vents, multiple-effect evaporation hot well
vents, smelt-dissolving tanks, black liquor (i.e., chemicals from cooking process, wood
residues) oxidation tanks vents, lime kiln exit vents, and wastewater treatment operations.
Black liquor evaporation from evaporators is one major source of gaseous odorous
emissions. Various nonsulfur organic compounds are also emitted from different points in
Kraft pulping. These include turpenes, and fatty and rosin acids, as well as materials
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used in processing and converting operations such as defoamers, pitch control agents,
bleach plant chemicals.
F.5 Methods of Managing Pulp and Paper Wastes
Wastes generated by the pulp and paper industry can be managed by a series of
techniques such as recycling and incineration. They can also be reduced by modifying the
various pulping and paper making procedures.
Recycling Water
Water recycling is commonly used to reduce wastes. Water from all phases of the pulp
and paper processes may be recycled to some degree. For example, debarking water from
the wood yard may be recycled. Details of the recycling process differ depending on the
procedures used in the wood yard. If a mechanical conveyor is used to move the wood,
then the wood must be washed before it is debarked to reduce equipment abrasion. On the
other hand, if an hydraulic debarker is used, a large proportion of solids must be removed
to prevent abrasions in pumps and barker nozzles. Effluent from debarking is normally
sent to a separate sedimentation clarification system before it is combined with pulp mill
effluent and sent to mill's treatment system. Water may also be recycled at the paper
making stage. Complex systems have been developed to recycle water from this stage.
Even though recycling water is helpful to reduce pollution loads, several potential problems
arise from recycling. Problems arise when suspended solids build up. However, dissolved
and colloidal materials cause more trouble than suspended solids. Dissolved salts build up
as effluent volume is reduced and increased amounts of paper machine white water are
recirculated throughout the mill. These buildups can cause increased corrosion, and may
result in plugging of some equipment. Plugs may form in shower nozzles, small lines,
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wires and felts. Corrosion is also often prevalent, especially in the cast iron Nash vacuum
pumps. Slime and odor may become a problem. This problem generally results from poor
housekeeping, lack of effective biocide and/or stagnant areas in the water or stock
preparation system. Finally, the recycled water may become colored. Inspectors should
check for these problems in the mills.
Removing Suspended Solids
Suspended solids are present in the water at various stages of the pulp and paper process.
These solids include bark particles, fiber, fiber debris, filler and coating material such as
clajr, calcium carbonate, titanium dioxide, and sometimes oils and greases. The type and
amount of suspended solids depends on the process used, and the specific waste stream
being considered. For example, suspended solids from mechanical pulping are usually
greater than those from chemical pulping.
Several methods are employed to remove suspended solids from the effluent. Three
common methods are sedimentation, flotation, screening. Sedimentation clarification is
most commonly utilized, followed by froth flotation. Screening is rarely used. Also,
several types of clarifying equipment such as sedimentation clarifiers may be used. Oils
and greases are usually treated by filtration, and then hexane extraction. Like the
equipment from pulping, and paper making, inspectors should check equipment to make
sure it is meeting appropriate regulations.
Treating Wastes Biologically
Many wastes in the paper industry are treated biologically. This treatment serves several
functions. It helps reduce amount of biochemical oxygen demand (BOD). It also helps
destroy materials that are toxic to aquatic life. Furthermore, it reduces foaming and
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reduces dispersed turbidity due to inorganic coating additives. Finally, it eliminates slime
production in the receiving waters.
Several methods of biological treatment are used. These include: large storage oxidation
basins, aerated stabilization basins, various modifications of the activated sludge process
and land disposal. Innovative techniques are being developed to further reduce the
pollution load, yet, as of 1985, few were commercially installed. These innovative
techniques include: rotating biological reactors, high-rate fixed-Film activated sludge,
aerated activated carbon filter, and deep tank aeration.
Managing Solid Wastes
Various solid wastes come from debarking the wood. These wastes may be disposed by
burning the bark in special bark furnaces or in combination furnaces. They are also
commonly disposed of in landfills.
Another type of waste are sludges from wastewater treatment. There are two types of
sludge from wastewater: primary sludge from the primary clarifier, and secondary sludge
from biological treatment. The nature of sludges differs with the type of pulp and paper
manufacturing. And, the more difficult a sludge is to dewater, the larger the volume of
waste there is to handle. For example, primary sludges, which are high in fiber and low in
ash, are easiest to dewater. High-rate biological treatment systems and alum sludges are
most difficult to dewater. Common dewatering equipment includes rotary vacuum filters,
centrifuges, filter presses, twin-wire presses, and screw presses. Although there are
several alternative methods for disposing of the sludge, landfilling is still most widely used.
Managing Air Pollutants
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In many stages of pulp and paper production air pollutants are emitted. Specialized
equipment is available to control and reduce these emissions. This equipment includes:
scrubbers, inertial separators (also known as cyclone collectors or centrifugal separators),
mist pads, dry scrubbers, fabric filters, and electrostatic precipitators. Inspectors should
become familiar with the equipment at the facilities they are inspecting and examine it
during their inspection.
Removing Color and Toxicity
Color comes from three operations in pulp and paper production: chemical pulping, pulp
bleaching, and colored paper production. The majority of this colored wastewater arises
from pulping and bleaching. Some of the processes such as chemical pulping contain toxic
materials.
Colors and toxics are generally removed using physicochemical treatment since secondary
biological treatment is generally ineffective for reducing color and toxics. Physicochemical
treatment is also useful when biological treatment cannot achieve the needed purity.
These physicochemical treatment processes include: resin separation and ion exchange,
alum coagulation and precipitation, lime precipitation or coagulation, enzyme
pretreatment, membrane separation, activated carbon, and ozone treatment. Another
commonly used treatment is MYCOR processing. It is a biological treatment which uses
white rot fungus to remove color. Electrochemical processes may also be used, such as
electrochemically converting chloride to chlorate, hypochlorite, and chlorine.
Some methods remove nearly all toxics and colors as well as other pollutants from the
effluent, such as reverse osmosis and activated carbon systems. Yet these highly effective
systems are also costly.
Modifying Processes
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Inspection Manual PULP AND PAPER WASTE STREAM
Traditional pulping and paper making processes may be modified or new ones may be used
to significantly reduce pollution loads. For example, process modifications significantly
reduce color and toxicity.
Several pulping modifications are available. These include: hydrotrophic pulping, alcohol
pulping, holopulping, nitric acid pulping, phenol pulping, soda anthroquinone pulping, and
oxygen pulping. Each of these processes has advantages and disadvantages as well as
relative levels of effectiveness.
In addition to modifying pulping processes, bleaching processes may be modified to reduce
the amount of pollution. Modified bleaching processes include replacing the chlorination
stage with oxygen and ozone, recycling the chlorination water, re-using water from the
counter current washing system in the chlorination stage, and performing hi-consistency
gas phase chlorination. Each of these processes has advantages and disadvantage as well
as relative levels of effectiveness. For example, direct counter current washing procedures
produce the least effluent, but have serious corrosion problems.
February 1988 Page F-15
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PULP AND PAPER WASTE STREAM Inspection Manual
LITERATURE CITED
Libby, C.E. [ed] (1962a) Pulp and Paper Science Technology. Volume I Pulp NY:
McGraw-Hill Book Co.
Libby, C.E. [ed] (1962b) Pulp and Paper Science Technology. Volume II Paper. NY:
McGraw-Hill Book Co.
Springer, A.M. (1986) Industrial Environmental Control: Pulp and Paper Industry. NY:
John Wiley and Sons.
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GLOSSARY OF TERMS
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Inspection Manual GLOSSARY OF TERMS
GLOSSARY OF TERMS
ADMINISTRATOR - The Administrator of the U.S. Environmental Protection Agency, or
designee.
ADMINISTRATIVE ACTION - A nonjudicial enforcement action taken by the
Administrator (or designee) or a State.
ADMINISTRATIVE ORDER - An order issued by the Administrator (or designee) to a
violator of RCRA provisions that imposes enforceable legal duties (e.g., forcing a
facility to comply with specific regulations). There are four types of RCRA
orders: Compliance orders: Corrective Action orders; Monitoring and Analysis
orders; and Imminent Hazard Orders.
AQUIFER - Rock or sediment in a formation, group of formations, or part of a formation
that is saturated and sufficiently permeable to transmit significant quantities of
water to wells and springs.
ARTESIAN AQUIFER - An aquifer which is under pressure. When accessed, the water
will rise above the water table to the piezometric surface.
BEJ - An acronym for best engineering judgment. The specific requirements an owner or
operator of a TSD must comply with are developed for each specific facility by
permit writers, based on their best engineering judgment and the requirements
of 40 CFR Part 264. Such requirements are then incorporated into the facilit3r's
operating permit.
BIENNIAL REPORT - A report (EPA Form 8700 - ISA) submitted by generators of
hazardous waste to the Regional Administrator due March 1 of each even-
numbered year. The report includes information on the generator's activities
during the previous calendar year. The owner or operator of a treatment,
storage, and disposal facility must also prepare and submit a biennial report
using EPA Form 8700-1313.
CAA - The Clean Air Act. This act contains regulations for the prevention and control of
discharges into the air of substances that may harm public health or natural
resources. Included are both stationary sources of pollution (e.g., factories) and
mobile sources (e.g., cars, trucks, aircraft). See 40 CFR 50-80.
CALIFORNIA WASTES - A category of wastes specified in Section 3004(d)(2) of HSWA.
CEI - An acronym for compliance evaluation inspection. This is an overall review of the
hazardous waste handler's performance. The inspection includes an onsite
examination of records and other documents maintained by the handler and an
evaluation of the handler's compliance with all applicable requirements. All
applicable inspection checklists must be completed,
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GLOSSARY OF TERMS Inspection Manual
CERCLA - The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), passed in 1980 and commonly known as "SUPERFUND." CERCLA
gives the Federal government the power to respond to releases, or threatened
release, of any hazardous substance into the environment as well as to a release
of a pollutant or contaminant that may present an imminent and substantial
danger to public health or welfare. CERCLA established a Hazardous Substance
Trust Fund (Superfund), which is available to finance responses taken by the
Federal Government. Spills or other releases of significant quantities of a
substance listed as hazardous must be reported at once to the National Response
Center at (800) 424-8802. See 40 CFR 300.
CFR - The Code of Federal Regulations, a document containing all finalized federal
regulations. Normally the CFR is referenced as: 40 CFR Section 261.
CHARACTERISTICS - EPA has identified four characteristics of a hazardous waste:
Ignitability; Corrosivity; Reactivity; and EP Toxicity. Any solid waste that
exhibits one or more of these characteristics is classified as a hazardous waste
under RCRA.
CIVIL ACTION - A law suit filed in court against a person who has either failed to comply
with statutory or regulatory requirements or an administrative order or has
contributed to a release of hazardous wastes or constituents. There are four
types of civil action: compliance; corrective; monitoring and anatysis; and
imminent hazard.
CLOSURE - The act of securing a hazardous waste management facility or unit pursuant
to the requirements of 40 CFR Part 264. The owner or operator of a hazardous
waste facility is expected to close the facility in a manner that minimizes the
need for further maintenance, and controls, minimizes or eliminates, to the
extent necessary to prevent threats to human health and the environment,
postclosure escape of hazardous waste. A written closure plan must be
submitted and approved.
CME - An acronym for comprehensive groundwater monitoring evaluation. This is an
overall review of a facility's compliance with all applicable RCRA requirements.
It includes everything covered in a CEI for groundwater monitoring facilities,
and a more detailed investigation of the engineering features and effectiveness of
the groundwater monitoring system and the facility's hydrogeological conditions.
In many situations, CME's will include sampling and analysis of groundwater.
COMPATIBILITY - The ability of materials to exist together without adverse
environmental effects or health risks. Primarily applied to waste fluid
combinations and liner materials.
COMPLIANCE ORDER/ACTION - An order or action issued under Section 3008 (a) of
RCRA, requires any person who is not complying with a requirement of RCRA
to take steps to come into compliance.
CONFINED AQUIFER - An aquifer which is overlain by impermeable strata (confining
beds).
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Inspection Manual GLOSSARY OF TERMS
CONTAINER - Any portable device in which material is stored, transported, treated,
disposed of, or otherwise handled.
CONTAINMENT - Any method or technology that prevents migration of hazardous waste
into the environment.
CONTAMINANT - Any solute that enters the hydrologic cycle through human action
(limited definition for use in context of this manual).
CONTINGENCY PLAN - A document setting out an organized, planned, and coordinated
course of action to be followed in case of a fire or explosion or a release of
hazardous waste or hazardous constituents from a treatment, storage, or
disposal facility that could threaten human health or the environment.
CORRECTIVE ORDER/ACTION - An order EPA issues that requires corrective action
under RCRA Section 3008(h) at a facility when there has been a release of
hazardous waste or constituents into the environment. Corrective action may be
required beyond the facility boundary and can be required regardless of when
the waste was placed at the facility.
CRIMINAL ACTION - A prosecuting action taken by the U.S. Government or a State
towards any person(s) who has knowingly and willfully not complied with the
law. Such an action can result in the imposition of fines or imprisonment.
CWA - The Clean Water Act. This act provides the legislative vehicle for regulating the
discharge of non-hazardous waste into surface waters by municipal sources,
industrial sources and other specific and non-specific sources. The act's ultimate
goal is to eliminate all discharges into surface waters. Its interim goal is to
make all surface waters usable for fishing and swimming. See 40 CFR 100-140,
40 CFR 400-470.
DEEP-WELL INJECTION - The subsurface implacement of fluids through a bored, drilled
or driven well, or through a dug well whose depth is greater than the largest
surface dimension.
DESIGNATED FACILITY - A hazardous waste treatment, storage, or disposal facility
which has received an EPA, or state, permit (or has interim status) and has
been designated on the manifest by the generator as the facility to which the
generator's waste should be delivered.
DISCHARGE - The accidental or intentional spilling, leaking, pumping, pouring, emitting,
or dumping of hazardous waste onto any land or into any water.
DISPOSAL - The discharge, deposit, injection, dumping, spilling, leaking, or placing of any
solid waste or hazardous waste into or on any land or water so that any of its
constituents may enter the environment or be emitted into the air or discharged
into waters, including ground waters.
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GLOSSARY OF TERMS Inspection Manual
DISPOSAL FACILITY - A facility or part of a facility at which hazardous waste is
intentionally placed into or on any land or water, and at which waste will
remain after closure.
ENDANGERED AND THREATENED SPECIES - Species whose populations are so
reduced in number or whose range is so limited in geographic extent that further
reduction in numbers or in size of available habitat could inalterably reduce the
breeding success of the species and lead to subsequent extinction. These species
are listed in Section 4 of the Endangered Species Act.
EPA IDENTIFICATION NUMBER - The unique number assigned by EPA to each
generator or transporter of hazardous waste, and each treatment, storage, or
disposal facility.
EP TOXICITY - A test, called the extraction procedure (EP), that is designed to identify
wastes likely to leach hazardous concentrations of a particular toxic constituent
into the ground water as a result of improper management. It is a characteristic
of hazardous waste.
EXCEPTION REPORT - A report that generators who transport waste off-site must
submit to the Regional Administrator if they do not receive a copy of the
manifest signed and dated by the owner or operator of the designated facility to
which their waste was shipped within 45 days from the date on which the initial
transporter accepted the waste.
EXISTING FACILITY - A facility which was in operation or for which construction began
on or before November 19, 1980.
EXPOSURE PATHWAYS - The environmental routes through which living organisms can
be exposed to hazardous waste.
FACILITY - All contiguous land, structures, other appurtenances, and improvements on
the land, used for the treating, storing, or disposal of hazardous waste. A
facility may consist of several treatment, storage, or disposal operational units
(e.g., one or more landfills, surface impoundments, or a combination of them).
FAULT - A break in earth materials along which a measurable amount of movement has
taken place.
FEDERAL REGISTER - A document published daily by the Federal government that
contains either proposed or final regulations.
FEEDSTOCK - A raw material used during production processes.
FHSA - The Federal Hazardous Substances Act. This act allows the Consumer Product
Safety Commission to ban or regulate hazardous materials produced for use by
consumers. Under the act, the commission has labeling authority over consumer
products that are toxic, corrosive, flammable, irritant or radioactive. See 16
CFR 1500-1512.
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Inspection Manual GLOSSARY OF TERMS
FIFRA - The Federal Insecticide, Fungicide, and Rodenticide Act. This act provides
regulatory authority for registration and use of pesticides and similar products
intended to kill or control insects, rodents, weeds and other living organisms.
See 40 CFR 162-180.
FINAL STATUS - A TSD facility that has interim status acquires final status when final
administrative disposition has been made of its permit application.
FLASH POINT - The lowest temperature at which a liquid will give off enough flammable
vapor at or near its surface so that a spark or flame will ignite it in air.
FLOODPLAIN - The flat areas adjacent to stream channels and covered by water during
periods of flooding.
FOOD-CHAIN CROPS - Crops grown for human consumption and crops grown to feed
animals.
FREEBOARD The vertical distance between the top of a tank or surface impoundment
dike, and the surface of the waste it contains.
GENERATOR - Any person who first creates a hazardous waste, or any person who first
makes the waste subject to the Subtitle C regulations (e.g., imports a hazardous
waste, initiates a shipment of a hazardous waste from a treatment, storage or
disposal facility (TSD) or mixes hazardous wastes of different Department of
Transportation (DOT) shipping descriptions by placing them into a single
container).
GROUND-WATER - Water below the land surface in a zone of saturation.
GROUND-WATER FLOW - The direction of ground-water movement and of any
contaminants it contains; governed primarily by the hydraulic gradient.
GROUND-WATER QUALITY - The ambient chemical, physical and biological quality of
ground-water; generally defined by State and local standards to determine
suitability as a drinking-water source. Uncontaminated ground-water's
suitability as a drinking-water source is generally based on its total dissolved
solids (TDS) content.
GROUND-WATER RECHARGE - The addition of water to the ground-water system by
natural or artificial processes.
GUIDANCE - Documents issued mainly to elaborate and provide direction on the
implementation of regulations.
HAMMER PROVISION - Statutory requirements that go into effect automatically if EPA
fails to issue regulations by certain dates specified in the statute.
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GLOSSARY OF TERMS Inspection Manual
HAZARD RANKING SYSTEM - The model used to determine inclusion of a waste site on
the EPA's National Priorities List for CERCLA (Superfund) cleanup.
HAZARDOUS WASTE - As defined in RCRA the term "hazardous waste" means a solid
waste, or combination of solid wastes, which because of its quantity,
concentration, or physical, chemical, or infectious characteristics may:
- Cause, or significantly contribute to an increase in mortality or an
increase in serious irreversible, or incapacitating reversible, illness; or
- Pose a substantial present or potential hazard to human health or the
environment when improperly treated, stored, transported, or disposed
of, or otherwise managed.
As defined in the regulations, a solid waste is hazardous if it meets one of three conditions:
1. Exhibits a characteristic of a hazardous waste (40 CFR Sections 261.20
through 262.24);
2. Has been listed as hazardous (40 CFR Sections 261.31 through 261.33);
3. Is a mixture containing a listed hazardous waste and a non-hazardous
solid waste (unless the mixture is specifically excluded or no longer
exhibits any of the characteristics of hazardous waste).
HAZARDOUS WASTE DATA MANAGEMENT SYSTEM (HWDMS) - A database
maintained by the EPA in which brief summary conclusions from inspection
reports are tracked.
HEAVY METAL - Any metal with a specific gravity greater than 4 (that is, any metal
more than four times as dense as water).
HMTA - The Hazardous Materials Transportation Act. This act provides authority for
regulating the transportation of hazardous material by road, air and rail. The
Department of Transportation's (DOT) Materials Transportation Bureau (MTB)
identified particular quantities and forms of materials as hazardous and specifies.
packaging, labeling and shipping requirements for the materials that pose a risk
to health,, safety or property. See 49 CFR 106, 107, 171-179.
HSWA - The Hazardous Solid Waste Amendments of 1984 (Public Law 98-616) that
significantly expanded both the scope and the coverage of RCRA.
HYDRAULIC GRADIENT - The direction of ground water flow.
IMMINENT HAZARD ORDER - Used by the responsible agency under authority of RCRA
Section 7003 to force any person contributing to an imminent and substantial
endangerment to human health or the environment caused by the handling of
non-hazardous or hazardous solid waste to take steps to clean up the problem.
INCINERATOR - Any enclosed device in which controlled flame combustion is such that it
cannot be classified as a boiler or as an industrial furnace.
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Inspection Manual GLOSSARY OF TERMS
INCOMPATIBLE - Two or more substances that cause fire, explosion, generation of
flammable or toxic gases, or other violent reactions when mixed.
INJECTION WELL - see Deep-Well Injection.
INNER LINER - A continuous layer of material placed inside a tank or container to
protect the construction materials of the tank or container from the contained
waste or reagents used to treat the wastes.
INTERIM STATUS - Allows owners and operators of TSDs that were in existence, or for
which construction had commenced, prior to November 19. 1980 to continue to
operate without a permit after this date. Owners and operators of TSDs are
eligible for interim status on an ongoing basis if the TSD is in existence on the
effective date of regulatory changes under RCRA that cause the facility to be
subject to Subtitle C regulation. Owners and operators in interim status are
subject to and must comply with the applicable standards in 40 CFR Part 265.
Interim status is gained through the notification process and by submitting Part
A of the permit application.
LANDFILL - A disposal facility or part of a facility where hazardous waste is placed in or
on land and which is not a land treatment faciiitj', a surface impoundment, or an
injection well.
LAND TREATMENT - A facility or part of a facility at which hazardous waste is applied
onto or incorporated into the soil surface. Such facilities are disposal facilities if
the waste remains after closure.
LEACH ATE - Any liquid (often rainwater or other precipitation), including any suspended
components in the liquid, that has moved through or drained from hazardous
waste. Not to be confused with a leak.
LEAK - The migration of liquid wastes outside of containment structures.
LIABILITY - The state of being legally responsible for property damage or bodily injury
caused during operation, closure or post-closure phases of a hazardous waste
management facility.
LINER - A continuous layer of natural (e.g., earthen) or man-made materials, beneath or
on the sides of a surface impoundment, landfill, or landfill cell, which restricts
the downward or lateral escape of hazardous waste, hazardous waste
constituents, or leachate.
LISTED WASTES- Hazardous wastes that have been placed on one of three lists
developed by EPA: Non-specific source wastes; Specific source wastes;
Commercial chemical products. These lists were developed by examining
different types of waste and chemical products to see if they exhibit one of four
characteristics, meet the statutory definition of hazardous waste, are acutely
toxic or acutely hazardous, or are otherwise toxic.
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GLOSSARY OF TERMS Inspection Manual
MANIFEST - The shipping document (EPS Form 8700-22) used for identifying the
quantity, composition, origin, routing, and destination of hazardous waste during
its transportation from the point of generation to the point of treatment, storage,
or disposal.
METRIC TONNE - 2,200 pounds.
MIGRATION ROUTE - The environmental media, that is, air, water or land, through
which hazardous waste can be released.
MONITORING - Methods used to inspect and collect data on a facility's operational
parameters or on contiguous air, ground-water, surface-water or soil quality.
MONITORING AND ANALYSIS ORDER - Used to evaluate the nature and extent of a
substantial hazard to human health or the environment that exists at a TSD. It
can be issued to either the current owner or to a past owner or operator if the
facility is not currently in operation or the present owner could not be expected
to have knowledge of the release potential.
NATIONAL PRIORITES LIST - The list of hazardous waste sites targeted for cleanup
action under CERCLA ("Superfund").
NATIONAL RESPONSE CENTER - Under CERCLA, all spills or discharges into the
environment of certain amounts of materials designated as hazardous must be
reported immediately to the National Response Center. The center maintains a
24-hour-a-day telephone line for reporting spills (800-424-8802). When the
center is called, responsibility for dealing with the release is immediately
assigned to either the Coast Guard or EPA, depending on the location and type
of emergency.
NEW FACILITY - A TSD which began operation or for which construction was begun
after November 19, 1980.
OFF-SITE - The logical opposite of ON-SITE (see "on-site")
ONE-HUNDRED-YEAR FLOOD PLAIN - Areas adjacent to streams where the
probability of flooding in any given years is one in a hundred.
ON-SITE - Means on the same or geographically contiguous property which may be
. divided by public or private right(s)-of-ways, provided the entrance and exit
between the properties is at a cross-roads, intersection, and access is by crossing
as opposed to going along the right(s)-of-way. Non-contiguous properties owned
by the same person but connected by a right-of-way which the person controls
and to which the public does not have access, is also considered on-site property.
OPEN DUMP - Specifically, any facility or site where solid waste is disposed of which is
not a sanitary landfill which meets the Criteria listed in 40 CFR Part 257
("Subtitle D Criteria") and which is not a facility for the disposal of hazardous
waste.
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Inspection Manual GLOSSARY OF TERMS
OPERATOR - The person responsible for overall operation of a facility.
OSHA - The Occupational Safety and Health Act. This act provides the regulatory vehicle
for assuring the safety and health of workers in firms generally employing more
than 10 people. Its goal is to set standards of safety that will prevent injury
and/or illness among workers. Safety, chiefly encompassing the physical work
place, and health, which governs exposure to settings that could induce acute or
chronic health effects, are covered by the act. See 29 CFR 1910, 1915, 1918,
1926.
OWNER - The person who owns a facility or part of a facility.
PART A - The first part of the two part application that must be submitted by a TSD
facility to receive a permit. It contains general facility information such as
location, waste types, quantities, process types, and capacities. There is a
standard form for the PART A.
PART B - The second part of the permit application that includes detailed and highly
technical information concerning the TSD in question. There is no standard
form for the PART B, instead the facility must submit information, based on the
regulatory requirements, on exactly how the operator or owner will comply with
RCRA.
PARTIAL CLOSURE - The closure of a discrete part of a facility in accordance with the
applicable closure requirements of 40 CFR Parts 264 and 265. For example,
partial closure may include the closure of a trench, a unit operation, a landfill
cell, or a pit, while other parts of the same facility continue in operation. (A
proposed redefinition was published on March 19, 1985, see 40 CFR 11068).
PERMEABILITY - The degree to which a liquid (usually water) can pass through a
substance or mass. Note: Some solvents can move quickly through clays that
are impermeable to water.
PERMIT - An authorization, license, or equivalent control document issued by EPA or an
authorized State to implement the regulatory requirements of Subtitle C Parts
264 and 265 for TSDs.
PERMIT-BY-RULE - A provision of Subtitle C whereby a facility is deemed to have a
RCRA permit if it is permitted under the Safe Drinking Water Act, the Clean
Water Act, or the Marine Protection, Research, and Sanctuaries Act and also
meets a few additional Subtitle C requirements as specified at 40 CFR Section
270.60. The term "permit" does not include RCRA "interim status" nor refer to
any permit that has not yet been the subject of final agency action, such as a
draft permit or a proposed permit.
PERMIT-BY-RULE - A provision of RCRA Subtitle C whereby a facility is deemed to have
a RCRA permit if it is permitted under the Safe Drinking Water Act; the Clean
Water Act; or the Marine Protection, Research, and Sanctuaries Act and also
meets a few additional Subtitle C requirements specified in 40 CFR Section
270.60.
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GLOSSARY OF TERMS Inspection Manual
PERMIT REQUIREMENTS - Requirements in the RCRA permit, including ambient,
performance, design, and/or operating standards contained in the regulations
that the owner or operator must meet in perpetuity in constructing, operating,
closing, and caring for the facility.
PERSON - As used in RCRA this term means an individual, trust, firm, joint stock
company, corporation (including a governmental corporation), partnership,
association, State, municipality, commission, political subdivision of a State, or
any interstate body.
pH - A measure of the acidity or alkalinity of a solution on a scale of 0 to 14 (low is acidic,
high is alkaline or caustic, 7 is neutral).
PICKLING LIQUOR - A corrosive liquid (usually an acid) used to remove scale and oxides
from metals.
POINT SOURCE - Any discernible, confined, and discrete conveyance, including, but not
limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure,
container, rolling stock, concentrated animal feeding operation, or vessel or other
floating craft, from which pollutants are or may be discharged. This term does
not include return flows from irrigated agriculture.
POLICY - A document that specifies operating policies that must be followed. They are
used by program offices to outline the manner in which pieces of the RCRA
program are to be carried out.
POST-CLOSURE REQUIREMENTS - Monitoring and maintenance requirements for
closed hazardous waste management units throughout the post-closure care
period (i.e., 30 years); these are specified as part of facility-specific permit
conditions.
RCRA - Resource Conservation and recovery Act of 1976. What is commonly referred to
as RCRA is an amendment to the first piece of Federal policy on solid waste
management called the Solid Waste Disposal Act of 1965. RCRA was amended
in 1980 and again on November 8, 1984 by HSWA. Although RCRA was
passed to control all varieties of solid waste disposal and to encourage recycling
and alternative energy sources, its major emphasis is control of hazardous waste
disposal. See 40 CFR 240-271.
REACTIVE - A substance that is normally unstable and readily undergoes violent change;
or reacts violently with water; or generates toxic gases, vapors or fumes in a
quantity sufficient to present danger to human health or the environment when
mixed with water.
RECHARGE - The replenishment of groundwater by infiltration of atmospheric water
(precipitation) through the soil.
REGIONAL ADMINISTRATOR - The highest ranking official in each of the ten EPA
regions.
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Inspection Manual GLOSSARY OF TERMS
REGULATION - The legal mechanism that spells out how a statute's broad policy
directives are to be carried out. Regulations are published in the Federal
Register and then codified in the Code of Federal Regulations (CFR).
REGULATORY COMPLIANCE - Meeting the requirements of Federal or State
regulations regarding facility design, construction, operation, performance,
closure and post-closure care.
REMEDIAL ACTION - Those cleanup measures consistent with a permanent remedy
taken instead of or in addition to removal.
REMOVAL ACTION - The cleanup or removal of released hazardous substance from the
environment to prevent, minimize or totally mitigate damage.
REPRESENTATIVE SAMPLE - A sample of a whole (e.g., waste pile, lagoon, ground
water, or waste stream) which can be expected to have the average properties of
the whole.
RESIDENCE TIME - The length of time during which a hazardous waste is subjected to
elevated temperatures during incineration.
RESOURCE CONSERVATION - Reduction of the amounts of solid waste that are
generated, reduction of overall resource consumption, and utilization of recovered
resources.
RESOURCE RECOVERY - The recovery of materials or energy from waste.
RUNOFF - A liquid that migrates over an uncontained or improperly contained area.
SDWA - The Safe Drinking Water Act. This act requires the establishment of uniform
federal standards for drinking water quality and development of a system to
regulate underground injection of wastes and other substances that could
potentially contaminate underground water sources. Note that surface water is
protected under the CWA. Among other things, the act bans the underground
injection of certain materials in or near an underground water source and
requires issuing of permits, monitoring and recordkeeping for underground
injection that is permitted. See 40 CFR 140-149.
SEISMIC ACTIVITY - Earthquake activity (see also fault).
SITE - The land or water area where any facility or activity is physically located or
conducted, including adjacent land used in connection with the facility or activity.
SLUDGE - Any solid, semi-solid, or liquid waste generated from a municipal, commercial,
or industrial wastewater treatment plant, water supply treatment plant, storm
water control facility, or air pollution control facility exclusive of the treated
effluent from a wastewater treatment plant.
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GLOSSARY OF TERMS Inspection Manual
SLURRY WALL - An underground vertical wall made of relatively impermeable material
that significantly retards leachate and ground water migration.
SMALL QUANTITY GENERATOR - A generator who produces less than 100 kilograms
of hazardous waste per month (or accumulates less than 100 kilograms at any
one time) or one who produces less that 1 kilogram of acutely hazardous waste
per month (or accumulates less than 1 kilogram of acutely hazardous waste at
any one time).
SOIL STRUCTURE - Defines the overall appearance of soil aggregates as to their grade,
size and form or type (shape). Determines the soil's physical condition at
different moisture levels and its ability to retard or accelerate water and
contaminant movement.
SOLVENT - A liquid capable of dissolving another substance.
SOLID WASTE - As defined in RCRA the term "solid waste" means any garbage, refuse,
sludge from a waste treatment plant, water supply treatment plant, or air
pollution control facility and other discarded material, including solid, liquid,
semisolid, or contained gaseous material resulting from industrial, commercial,
mining, and agricultural operations, and from community activities, but does not
include solid or dissolved material in domestic sewage, or solid or dissolved
materials in irrigation return flows or industrial discharges which are point
sources subject to permits under the Clean Water Act, or special nuclear or
byproduct material as defined by the Atomic Energy Act of 1954.
SOLID WASTE DISPOSAL ACT OF 1965 - See "RCRA."
STATE - Any of the 50 States, the District of Columbia, the Commonwealth of Puerto
Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the
Northern Mariana Islands.
STATE HAZARDOUS WASTE PLAN - A scheme generated at the State level to deal with
the management of hazardous waste generated, treated, stored or disposed of
within the State or transported outside the State.
STATUTE - The law as passed by Congress and signed by the President.
STORAGE - The holding of hazardous waste for a temporary period, at the end of which
the hazardous waste is treated, disposed of, or stored elsewhere.
SUPERFUND - See "CERCLA."
SURFACE IMPOUNDMENT - A facility or part of a facility which is a natural
topographic depression, man-made excavation, or diked area formed primarily of
earthen materials (although it may be lined with man-made materials), which is
designed to hold an accumulation of liquid wastes or wastes containing free
liquids, and which is not an injection well. Examples of surface impoundments
are holding, storage, settling, and aeration pits, ponds and lagoons.
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Inspection Manual GLOSSARY OF TERMS
SURFACE WATER - Any body of water that is found above ground (e.g., canals, creeks,
lakes, ponds, rivers, streams).
TANK - A stationary device, designed to contain an accumulation of hazardous waste,
which is constructed primarily of non-earthen materials (e.g., wood, concrete,
steel, plastic) that provide structural support.
TEST BURN - A trial incineration of hazardous waste that tests an incinerator's
destruction efficiency.
THERMAL TREATMENT - The treatment of hazardous waste in a device which uses high
temperatures as the primary means to change the chemical, physical, or
biological character or composition of the hazardous waste. Incineration is an
example of thermal treatment.
TOPOGRAPHIC MAP - A map indicating surface elevations of an area through the use of
contour lines. It also shows population centers and other cultural and land-use
features, surface water drainage patterns and forests. These maps enable quick
identification of areas of slopes that are more suitable for sanitary landfills.
TOTAL DISSOLVED SOLIDS (TDS) - A measurement of all solids that are dissolved in
water, waste water, or leachate, usually stated in milligrams per liter or parts
per million.
TOTALLY ENCLOSED TREATMENT FACILITY - A facility for the treatment of
hazardous waste which is directly connected to an industrial production process
and which is constructed and operated in a manner which prevents the release of
any hazardous waste or any constituent of hazardous waste into the
environment during treatment. An example is a pipe in which waste acid is
neutralized.
TOXIC - Capable of producing injury, illness, or damage to living organisms through
ingestion, inhalation or absorption through any body surface.
TRANSFER FACILITY - Any transportation related facility including loading docks,
parking areas, storage areas and other similar areas where shipments of
hazardous waste are held during the normal course of transportation.
TRANSPORTER - Any person engaged in the off-site transportation of hazardous waste
within the United States, by air, rail, highway, or water, if such transportation
requires a manifest under 40 CFR Part 262.
TREATMENT - Any method, technique or process, including neutralization, designed to
change the physical, chemical, or biological character or composition of any
hazardous waste so as to neutralize it, or render it non-hazardous or less
hazardous, or to recover it, make it safer to transport, store or dispose of, or
amenable for recovery, storage, or volume reduction.
February 1988 Page 13
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GLOSSARY OF TERMS Inspection Manual
TSCA - The Toxic Substances Control Act. This act provides the regulatory vehicle for
controlling exposure and use of raw industrial chemicals that fall outside the
jurisdiction of other environmental laws. Where other environmental laws
control chemicals during use, transport and disposal, the TSCA was passed to
assure chemicals would be evaluated before use to make sure they pose no
unnecessary risk to human health or the environment. See 40 CFR 700-799.
TSD - Acronym for treatment, storage, or disposal facility.
UNCONFINED AQUIFER - An aquifer that contains water under atmospheric pressure.
Not overlain by impermeable stratum, the water level in the aquifer may rise or
fall according to the volume of water stored, a variable dependent upon seasonal
cycles of natural recharge.
UNSATURATED ZONE - The geological region below the earth's surface and above the
uppermost seasonal level of the water table.
UST - An "underground storage tank" is defined as any tank with at least 10 percent of
its volume buried below the ground, including any pipes attached to the tank.
Thus, above-ground tanks with extensive underground piping may be regulated
under Subtitle I of RCRA.
VECTOR - A carrier, usually an insect, which is capable of transmitting disease from one
organism to another.
VOLATILE - Evaporating readily at normal temperatures and pressures.
WASTE MANAGEMENT PRACTICES - Refers to aspects of a facility's design, operation
and closure that ensure protection of human health and the environment while
treating, storing or disposing of hazardous waste.
WATER TABLE - (1) The upper limit of the part of the soil or underlying rock material
that is wholly saturated with water; (2) the upper surface of the zone of
saturation in ground waters in which the hydrostatic pressure is equal to
atmospheric pressure.
WETLANDS - Fragile environments such as bogs, bayous, swamps, marshes, tidal flats or
other areas that are regularly inundated or saturated by ground or surface
water with a frequency sufficient to support a prevalence of vegetative or
aquatic life that requires saturated or seasonally saturated soil conditions for
growth and reproduction.
Page 14 February 1988
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TRAIN-THE-TRAINER
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Inspector Training
Manual
Developed by the
School of Natural Resources
The University of Michigan
Ann Arbor, Michigan
for the
Association of State and Territorial
Solid Waste Management Officials
with the support of the
U.S. Environmental Protection Agency
February, 1988
-------
INSPECTOR TRAINING PROGRAM
TRAINER'S MANUAL
FEBRUARY 1988
Developed for the
Association of State and Territorial
Solid Waste Management Officials
by
The School of Natural Resources
The University of Michigan
Ann Arbor, Michigan
with the support of the
U.S. Environmental Protection Agency
-------
TRAINER'S MANUAL
I. Introduction
A. How to use this manual
B. Using our materials
II. Getting Ready
A. Program development
B. Site planning
C. Publicity
D. Registration
E. On-site logistics
F. Contingencies/Problem-shooting
G. Budget
III. Managing the Workshop
A. The Participants
B. Written materials
C. Presentations
D. Speakers
E. Group discussions
F. Case studies, role plays and simulations
G. Visual Aids and audio-visuals
IV. Following Up
A. Evaluations
B. Follow-up
V. Appendices
A. Checklists
B. Sample Agendas and Evaluations
C. Questions and Answers to Training Manual
D. Exercises
E. Resources and References Used
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CHAPTER 1. INTRODUCTION
A. How to Use this Manual 1. 5
HOW TO USE THIS MANUAL
The ASTSWMO inspector training program is an introduction for the entry-level RCRA
inspector. This program has three major design elements:
1) the Inspector Training Manual (or Inspection Manual)
2) the Trainer's Manual
3) a series of Video tapes
This Trainer's Manual provides information on using the inspector training materials in
different formats ranging from an individual study program to a workshop program. It
sketches out three, four and five day workshops with sample agendas and evaluation
forms and testing materials. The flexible nature of the materials is one of the key aspects
of this program design.
The manual has two parts — specific discussions on using the ASTSWMO training
materials, and more general information on planning a training workshop. The suggested
programs offer guidelines, but at the same time, give the trainer freedom to change them
or to create new program elements to fit their training needs. Hopefully the general
discussion on workshops will sketch in some of the basics.
If you have questions about using this material or about designing a program, consider call
the ASTSWMO office in Washington. B.C. for help (202) 624-7886.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 6
USING OUR MATERIALS
The following is a brief discussion about using the ASTSWMO materials in your training
workshop. More generic and detailed information on the specifics of running workshops is
provided in the other chapters in this manual.
As the instructor, you guide the training process. This program is designed so that you
have flexibility depending on your time, interest and training experience. The essential
"givens" in this program are that the participants read the Inspector's Training Manual
and view the video tapes.
USING THE INSPECTOR TRAINING MANUAL
The Inspector Training Manual contains the basic information to which each entry-level
inspector must be exposed. While it can stand alone as an authoritative resource for entry-
level inspectors, the Manual is also central to the training program. It provides the
"storyline" and factual materials that should underpin the workshop activities. To ensure
adequate coverage of the material, participants are expected to have read the Manual
prior to the workshop. Ideally trainees receive the Manual at least two weeks before the
training program begins. If they do not have at least ten days to read the manuai before
training, we suggest a longer workshop (.4-5 days).
USING THE VIDEO TAPES
The video materials are designed to enrich the material and to emphasize important points
in the Inspection Manual. The video tapes are coordinated closely with Manual chapters.
USING THE MATERIALS IN A SELF-TEACHING MODE
There are a series of questions included in this Manual (Appendix C) to facilitate training
outside of the workshop setting. After reading a set of chapters of the manual and viewing
the appropriate videos, trainees complete the appropriate question set. The question
groupings relate to chapter sequences. You can pace the training by assigning chapters or
let the participants move at their own rate.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 7
Once a section is done, the instructor can set up a supervised "test" situation, have the
participants send the answers to be graded, or have people grade their own using the
answers provided as guides. In any case, if less than 75-80% of the questions are
answered adequately, the participant must redo the readings and videos, and answer the
second question set. An overall average of 80% is required to pass the program. The
general open-ended questions (Appendix C) can serve as a final evaluation of the self-
taught training.
It is important that participants working alone have someone with whom they can discuss
these questions. Three important sources are the more experienced inspectors in the office,
the trainee's supervisor and you as the training coordinator. The supervisor should
understand that the trainee may need this kind of help. The participant also needs to be
aware of these resources and how best to use them.
OTHER MATERIALS IN THE TRAINER'S MANUAL
Like the Inspector Training Manual, this manual contains appendices with supplemental
information and resources for future reference. Depending on State programs, there may
also be additional materials specific to that state.
Only this manual contains the questions and answers for the Training manual so that the
trainer has discretion over their distribution. The questions can be xeroxed directly, or you
may choose to select specific ones. The answers provided on separate sheets are schematic.
Depending on the training situation, you may want to require more extensive responses.
GROUP DISCUSSIONS USING OUR MATERIALS
The importance of group discussion and interaction in the workshop cannot be
overemphasized. Although the small groups may not cover as much substantive material
as is possible with lectures or question and answer sessions, they are very effective at
involving participants and reinforcing their learning. Chapter 3D covers group discussions
in depth, but there are several points worth stressing here.
Generating Questions. Questions are often used as topics of group discussion. Depending
on how you want to organize the workshop, you might consider:
1) using the discussion questions from Appendix C
2) developing some questions yourself
3) having the large group generate and select questions for small group discussion
4) breaking into small groups to develop them
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 8
Reporting Out. Make clear to the smaller groups how and when they are to report back to
the larger group. Having a "reporter" to take notes, providing newsprint for recording
ideas, etc. can help the small group organize itself (see Chapter 3D).
Time. Group discussions take time. If you have promised time for reporting out, it is
important that you follow through. Try not to eliminate that portion of the agenda if you
are behind schedule. Instead, consider reducing the amount of time each group can report
out; assign as "homework" some portion of another activity; or use the reporting out as the
kick-off to the next section.
Air Time. During larger group discussions, the trainer (or someone) needs to facilitate and
monitor the group so that everyone has a chance to speak. An effort should be made to
encourage involvement by quieter participants.
Question-and-Answer. Question-and-Answer sessions provide a good change of pace when
time is limited or the subject matter does not warrant, the amount of time it takes to do
group discussions.
DESIGNING THE WORKSHOP
Although a three day workshop is most desirable, these materials can used for a three.
four or five day workshop. As discussed above, the Inspection Manual and videos provide
the basic organization and can be supplemented with small group discussions, speakers.
question-and-answer sessions, and if appropriate, a field trip. The trainer has considerable
flexibility with how these supplements fit into the training program. Although the specific
design of the workshop may vary, the trainer should keep in mind that in addition to
helping participants learn factual information, a primarj- objective of the program is to
provide a forum for discussing values and ethics involved in hazardous waste inspection.
The following guidelines for meeting these goals will be discussed in later chapters:
1. Develop the information in a logical pattern. The Inspector Training Manual has been
developed in a logical fashion and we expect that unless there are unforeseen
circumstances that you will follow that pattern.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 9
2. Plan with the participant in mind. To develop the workshop so that it achieves its full
potential you must be concerned about the learner. This involves both developing a
meaningful sequence for presenting material, and being concerned with the use of time and
its affect on the participants' learning and enthusiasm for the program.
Many trainers pay very little attention to these "process" kinds of considerations, and
their workshops suffer. All too many program planners think only about the information
being presented not about how the participants are absorbing (or not absorbing) that
information. The timing of coffee breaks, sequencing of activities, and the length of the
formal workshop day all play a major role in the success of the program.
3. Plan to mix the elements of the program. A variety of different activities provide a
change of pace that will help maintain the participants' interest and attention.
4. Incorporate group discussion. Providing opportunities for participants to discuss issues
and ideas both increases interest and helps people "fix" those ideas in their minds. People
check out what they don't understand and compare what they understand with what
others are saying. Small group sessions very effectively promote this type of interaction.
You should not. however, overlook the learning that occurs through class discussion, coffee
breaks, meal times and after hours. Encourage joint meal times among trainers, speakers
and participants: schedule slightly longer coffee breaks, etc. to facilitate this type of
interaction.
5. Oversee the content of the program. If you have guest speakers, tell them what you
want and describe the audience. Speakers welcome your input to help them do a better job
in their presentation. Likewise, you can guide discussions and question-and-answer periods
so that they reinforce the material you want conveyed.
6. Keep in mind the flow of the program. If the ideas start to become stagnant or the
discussion is starting to fade, bring it to a conclusion and move on. This is not always
easy. The trainer must make judgments about staying with a topic or returning to it if the
group is interested in it. Try to be flexible and let the group redirect at least a part of its
time to alternate activities. It is important to plan some "flux" time for these unplanned
contingencies. This means you want to have an overall plan of those aspects of the
program that must be covered and some flexibility in how that will be achieved.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 10
The Three Day Workshop
ANNOTATED THREE DAY PROGRAM SCHEDULE
1st Day
8:00 AM Registration & Coffee
Time to verify participants, addresses, phone numbers, payment schedules, etc.
and to distribute materials for the workshop. (See Chapter 2D).
S:30 AM Introductions &. Ice breaker
You want to help people get to know one another and to break down
communciation barriers as early in the workshop as possible -- thus the
"icebreakers". These can be very simple as noted in Appendix D. The introductions
at this point should be quick and provide everyone with a chance to speak. Of
course, you will want to introduce yourself and your staff as well.
9:30 AM How the Program Works
This sessions lays out the "road map" of the workshop -- what you are going to do
and why. You explain the agenda, what materials will be used, and the
evaluations.
10:00 AM VIDEO on RCRA* - Chapter 2
There are two types of videos in this program -- chapter videos and "experienced
field person" tapes. The chapter videos are linked directly to the text in the
Inspector Training Manual and are designed to reinforce the values and information
provided there.
10:15 AM Coffee Break
As discussed in the text, coffee breaks and other "off times" are important
opportunitites for communication. Although it may be tempting to cut these short,
don't.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 11
10:30 AM Organize small group session on RCRA
Make sure participants understand the purpose of the small group sessions as their
responsibilities as professionals. The main purpose of these sessions is to give each
person a chance to discuss and raise questions about the materials on RCRA.
There are a number of ways to organize these small groups. We suggest that the
groups select a leader to facilitate the discussion and a recorder and speaker to
report on that discussion to the larger group. You could ask the groups to make a
prioritized list of several questions they think are important about ths topic. They
should then cover as many of those questions, in order of importance, as time
allows.
10:45 AM Small group sessions on RCRA
Once the groups understand their task and ground rules for the groups have been
set. the sessions can begin. If possible, have about 6-8 people per group, and put
each group in a separate room. It will probably be helpful in the first session to
have a staff person look in on each group to clarify any procedural questions. It is
important in later small group sessions that the groups work out their own
problems. Someone should also remind the groups about reconvening 5 minutes
before the scheduled time.
11:30 AM Feedback from the small group sessions
During this time, the small groups bring their ideas to the large group. This serves
a number of purposes. The participants share ideas. The staff can see what kinds
of problems participants are having. It also sets up an environment for staff and
experienced inspectors to interact and respond directly to participants1 questions.
This first session is a short time session to help participants understand the
process. Each group will have only about five minutes to report out. The more
important feedback session will in the afternoon with the first ASK THE
INSPECTOR session.
12:00 AM Lunch
Lunch, like coffeebreaks is important. Expect your staff to eat with the group if at
all possible. Valuable insight and evaluation of the workshop can be gained. Also
the staff may be able to answer some questions participants may have been
hesitant to ask in the larger group setting.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 12
1:15 PM VIDEO on SAFETY* - Chapter 3
1:30 PM BUI Bokey SAFETY VIDEO
This is the first of the experienced field person videos. It supplements the chapter
videos and adds the voice of "experience". Think of this as one of your "expert
speakers."
2:00 PM Coffee Break
2:15 PM Small group sessions on SAFETY
This is an extension of the morning small group session. The same groups are
used, but with a different leader and speaker. Their task is to finish any work from
the morning, and to follow the same procedure to address SAFETY. The time-span
of this activity is flexible. Each group will have three or more questions, but. if
time runs short, you may cycle through only one or two rounds.
3:30 PM Small group feedback -- ASK THE INSPECTOR
ASK THE INSPECTOR provides the small groups with an opportunity to share
their questions and answers with the group at large. It is the responsibility of the
experienced inspectors present to not only answer any questions directed to them.
but also help the group pull together and synthesize important points about
SAFETY.
4:45 PM Review of the day
At the end of each day, take time to pause and review the day's activities, to
remind participants of evening activities (or homework), and to establish beginning
times or logistics for the next day.
5:00 PM Finish program for the day
Although j'ou should try to end the program as close to the scheduled time as
possible, the program has some slack time built into the last hour. It would be
possible to go until 5:15 if necessary. In closing, encourage participants and staff to
spend some of the evening together (e.g., at dinner, cocktails, etc.)
* A speaker could be used in connection with RCRA or Safety for a change of pace.
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CHAPTER 1. INTRODUCTION
B. Using Our Materials 1. 13
2nd Day
8:00 AM VIDEO on RCRA by Herb Johnson
The second of the experienced person videos. We suggest you review RCRA
because it is such a complicated topic.
8:30 AM Group discussion on RCRA again
This large group discussion is a quick way to clear up any last questions about
RCRA.
9:15 AM VIDEO on permits--Chapter 4
9:30 AM Small group discussions on RCRA and PERMITS
Try to change participants in the small group sessions each day so that people
have a chance to meet and work with most of the individuals attending the
program. At this point, it is the small group's responsibility to select leaders,
reporters, etc.
10:30 AM Coffee Break
10:45 AM Small group feedback -- ASK THE INSPECTOR
12:00 N Lunch
1:15 PM VIDEOS on INSPECTION - Chapters 5,6 & 1
2:00 PM Coffee Break
2:15 PM Presentation on INSPECTION by an experienced inspector
We feel it is important to have an experienced inspector make a presentation on
inspections. It gives participants a more real feeling for inspections. We suggest
you try to find someone who can speak well in front of groups. Help this person
understand the group, his/her role, and your expectations and constraints (see
Chapter 3D).
3:15 PM Small groups on INSPECTION
4:15 PM Feedback from small groups -- ASK THE INSPECTOR
5:00 PM Finish program for the day
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CHAPTER 1. INTRODUCTION
B. Usine Our Materials 1. 14
3rd Day
8:00 AM VIDEO on SAMPLING - Chapter 8
8:30 AM Presentation on SAMPLING by an experienced inspector
10:00 AM Coffee Break
10:15 AM ASK THE INSPECTOR about SAMPLING
11:15 AM VIDEO on Chapters 9 & 10
11:45 AM Lunch
1:00 PM Question-and-Answer session on any subject
1:45 PM Review of the Program
2:15 PM Evaluations
Make sure you do evaluations at the end of the program. See Chapter 4.
2:45 PM EndofProeram
Four and Five Day Programs
For a four day program (see Appendix B):
1) add presentations about sampling, inspection, RCRA and safetj' to develop these
major themes more completely.
2) provide more time for group sessions.
3) if help is available, add live demonstrations.
Although possible, fitting reading time into the four-day program will make the workshop
schedule much tighter.
A five day program should be used only if the participants have not had time to read the
Inspector Training Manual before they come to the program. Otherwise, the program would
be the same as the 4-day program. You can expect some reading at night, but daytime
scheduling would be preferred. Participants shold have Finished reading sections of the
Manual before seeing the videos and having discussions.
A FINAL REMINDER
The most important material for the participants to cover in this program is in the
Inspector Training Manual. The activities and effectiveness of the program depend on a
basic comprehension of that information. Therefore, each person must be given time and
expected to read the manual.
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
CHAPTER 2
GETTING READY FOR THE WORKSHOP
A. Program Development
B. Site Planning
C. Publicity
D. Registration
E. On-Site Logistics
F. Contingencies / Problem-shooting
G. Budget
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
A. Program Development 2. 3
GETTING READY FOR THE WORKSHOP
The key to a successful workshop is preparation. This involves running two models at
once: the design and flow of the workshop itself — program development — and attending to
the detailed logistics — site planning, publicity, etc. -- that make it happen.
The importance of adequate, thoughtful preparation to a smooth running workshop cannot
be overemphasized. If you are working with other people, they should understand what is
expected of them and when. The timeline on the next page offers a general sequencing
(this will vary as you refine your workshop, specific requirements of the agency, etc.).
Often you may have both the responsibility of setting up and running the workshop. It is
all the more important that you spend time carefully planning, organizing and anticipating
what you would like to have land what, might,) happen in the workshop.
Many coordinators develop a Planning manual, with master and supplementary checklists.
assignments for staff, contacts, phone numbers, etc. This provides a central "information
source" for you and your staff, and serves as a resource for future workshop planning.
PROGRAM DEVELOPMENT
THE AGENDA
The first step in program development is to know what you want to accomplish and how
much time you have to accomplish that. (How this is decided may vary from state to
state). You then want to develop an agenda that logically works toward that goal. The
agenda is a "road map" for the participants, and should be outlined for them near the
beginning of the workshop.
Every agenda (see Appendix B) should include (not necessarily in this order):
I. Introductions
A. Welcome/Housekeeping
B. Expectation/objectives of workshop
C. Icebreaker Activity
II. Specific activities/presentations (and scheduled breaks)
III. Conclusion
A. Summary
B. Evaluation/debriefing
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
A. Program Development 2. 4
WORKSHOP SETUP TIMELINE
Count Down Activities
16-12 weeks Establish responsibilities for
aspects of workshop
Outline program design
Locate possible site
Preliminary announcements
11-9 Identify resource people
Contact them by phone
S Confirm by letter/clarify AV needs
Finalize specific program design
Finalize site choice
7 Send out publicity/brochures/posters
4 Line up child care
Finalize food/housing arrangements, etc.
Follow up phone call to speakers
PSA's/final publicity
3-2 Registration deadline
1 Order food
Compile/xerox materials
HOLD THE WORKSHOP
-1-2 Compile final participant list
Write up workshop notes to yourself
Write thank-you letters to speakers
-2-3 Evaluation/feedback
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
A. Program Development 2. 5
Introductions
There should be a clear beginning and end to the workshop. In addition to preliminary
introductions and presentation of the agenda, the beginning activities include outlining both
your objectives and expectations as workshop leader and those of the participants. This
helps establish trust and your credibility and will give you insight into the kind of group
you are working with. An icebreaking activity is an exercise that helps people relax and to
give them a shared experience (see Appendix D for examples).
Specific Activities
There are many kinds of activities you can and should try to incorporate into a workshop --
lectures, slides and video, field trips, exercises, group discussions. Firstly, because people
have different learning styles - some learning better through discussion, others visually.
and others through lectures -- having a diversity of activities will actually enhance
learning, (see Chapter 3C for more specific discussion). Secondly, conveying the same
information in slightly different ways -- e.g.. with a lecture, hands-on example, or video —
. reinforces the information so people are more likely to remember it. Finally, change of
pace and focus will keep people listening and interested. To maintain a sense of coherence
within the workshop, you will want to refer back to the agenda, and explain how the new
activity fits into the "road map" of the workshop.
Conclusion
It is important that participants feel a sense of closure. The agenda should also include a
closing session with a summary by the trainer, wrap-up questions, and time for evaluation
(see Chapter 4A).
THE DESIGN AND PACING
Design
Equally important to the what is how that information is presented. It is important that
the workshop be organized in way useful to the participants'" needs. In a 3-day entry-level
training workshop, for example,there may not be enough time to convey all of the
necessarj' information. Consider giving basics and skills for using other materials and
resources participants can refer to on the job. A permit-writing workshop, on the other
hand, might focus more on the details and nuts-and-bolts of permit writing. Chapter 5F
offers some specific design considerations given time for a 3, 4 or 5-day workshop.
Pacing
Two closely related agenda-design considerations are pacing and the group's energy levels.
You want to have the workshop move along so that participants don't become bored, but
not so quickly that they become confused. The pace is influenced by:
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
A. Program Development 2. 6
a) when activities are scheduled
b) the balance between different kinds of activities
c) your enthusiasm and energy.
The energy level of the group will vary during the course of the workshop -- even within a
session. This may be due to any number of factors:
1) the overall fatigue of the group
2) how intellectual!}' or emotionally tiring an activity is
3) the time of day or week
4) degree of involvement with topic
5) facilitator's ability to design activities that are energizing and involving.
By being aware and sensitive to the group's energy level -- physical, mental and/or
emotional -- you can design the agenda or alter the workshop to adjust. People's energy-
tends to sag after lunch, for example, so you might plan an activity rather than a lecture.
If energy levels are low (which they often are in late afternoon or evening) incorporate
activities that get people talking, moving around, and actively involved, e.g., group
exercises, simulations, roleplays (see Chapter 3E). If energy levels are high, it's a good
time to introduce heavier intellectual material, lectures, slide/video presentations.
SUMMARY
Some rules of thumb to consider as you plan and develop your workshop program:
1) Make sure the material is relevant to the participants. Ask yourself, "Why
should they care?"
2) Present ideas in a logical order. Help the participants see a beginning, end and
progression in the workshop.
3) Keep the agenda flexible. Have sections you can cut or lengthen depending on
the time frame. You may want to have additional materials available either for
those with special interests or to fill in.
4) Pace the workshop with a variety of activities and breaks. Follow a more quiet
section with an active one. NEVER go more than 1 1/2 hours without a break.
5) Be sensitive to how much information you are trying to convey. Try to
reinforce the main point throughout the exercises.
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
B. Site Planning 2. 7
SITE PLANNING
Most often your workshop will take place either in a state office, or at a university or
hotel. Some important considerations are:
Location and Convenience
If the site is not a hotel, are there overnight accomodations nearby? Are there other things
to do within walking distance (e.g. shopping, book stores, entertainment)? Is it easy to get
to? Is parking available? If you are planning outdoor simulations, are they within a
reasonable distance?
Cost/Room Charges
Are the costs within your budget or covered by the workshop fee? If food and refreshments
will be served, must these be ordered from the location or can they be catered from
another source?
Space
Does the facility have appropriate space for the kinds of activities you are planning? Are
rooms conveniently located? Are there extra rooms? Can you provide smoking and non-
smoking areas? Can rooms be easily divided into sections? If, for example, you have a
group of 25-30 and intend to break them into small groups, you might want a medium
sized lecture/conference room with dividers or with several smaller rooms nearby. If your
workshop involves hands-on use and testing of equipment, you would also want outdoor or
warehouse-type space.
Comfort/aesthetics
Is the facility pleasant? How do you like the lighting, colors, furniture, layout? Are
heating, cooling, and ventilation adequate? Does it lend itself to the tone you want for the
workshop?
Seatine: flexibilitv, visibilitv
Does the seating arrangement of the workshop room lend itself to your needs? Are there
poles that will limit viewing for some? Can you rearrange the chairs to meet your needs?
Try to fit the size of the meeting room to the size of your audience. If the room is too large,
the audience tends to scatter. If you cannot reserve a smaller room, try to make the
seating cluster around the speaker area.
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B. Site Planning 2. 8
Amenities
Where are the restrooms? telephone, vending and cigarette machines? restaurants? What
kinds of services will the facility itself offer? Do they have audio/visual equipment? Can
they provide off-site transportation?
SETTLING ON A SITE
Unless it has been preselected, start looking for a site 11-12 (12-16 for a commercial site)
weeks before the workshop. Once you have narrowed down the choices, visit the facility to
see it firsthand. Try to establish a good rapport with the facility liaison.
Confirmation
As soon as possible, confirm your choice in writing (preferably at least 2 1/2 months before
the workshop). At that point, you should establish with the facility:
a) the date of the workshop
b) # rooms needed
c) # of people anticipated
d) meals to be served (if any) and the times
e) sleeping accomodations if necessary
f) costs and billing arrangements/PO number
g) equipment availability
Make sure you keep a copy of this correspondence.
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CHAPTER 2. GETTING READY FOR THE WORKSHOP
C. Publicitv 2. 9
PUBLICITY
While the agency orientation and "captive" audience of these workshops may simplify
doing publicitj'. it nevertheless is a critical step in workshop planning. It gives potential
participants an opportunity to screen themselves and sets the tone for the workshop.
The timing of publicity needs to be carefully coordinated with site selection, workshop date
and program design (see timeline above). There also needs to be enough lead time to allow
for participants to adjust their schedules, make reservations, etc. As suggested in the
timeline (Section A of this chapter), you might have three waves of publicity.
12 weeks prior: an early, general announcement and request for more information
to give you a sense of the interest
7 weeks prior: brochure, flyer or letter outlining specific dates, places, times and
program design with a registration form
4 weeks: public announcement to agencies, appropriate newletters
Whom to Contact
For most of the hazardous waste workshop? you will run. there are probably already a
number of networks in place for publicizing your workshop. These may include newletters
and publications distributed by different agencies and states: mailing lists of agencies or
people who might be interested.
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D. Registration 2. 10
REGISTRATION
There are two registration phases: pre-registration, the iiitial contact and commi-.nent
from participants, and registration, when they actually sign in for the workshop.
Depending on the nature of the workshop (e.g., if you do not need to know the number or
kind of people planning to attend), pre-registration may not be necessary. At some point in
the registration process, you will want to have at least the participants' names, addresses.
phone numbers, agency, and contact in case of an emergency.
PRE-REGISTRATION
There are a number of ways of pre-registering participants. If the workshop is mandatory,
you may receive a list of participants; if registration is more voluntary, this may involve
having potential participants call or mail in registrations.
Before coming to the workshop, participants should receive some kind of confirmation. This
might include a letter reiterating
a) the name and location of the site
b) the dates and times of the workshop
c) directions to workshop and parking (include map)
d) a brief sketch of the workshop flow
e) arrangements for sleeping or if accomodations are the participants'
responsibility, a list of hotels and rates in the nearby area
f) phone ^/address where participants can be contacted while at workshop
g) supplies, etc. participants should bring with them
h) some information about the area, expected weather conditions, etc.
i) a reminder of whether meals are provided or participants will need to buy or
bring food.
ON-SITE REGISTRATION
There should be a registration table or area clearly marked when participants arrive. Here
they sign in. receive name tags and some written materials -- specifics about the workshop
(e.g., an agenda, starting times and locations) and information about the surrounding area,
restaurants, etc. If you can afford the staff, it is good to have someone signing in
registrants; if not have a clearly labelled sign-in sheet and pre-labelled nametags if
possible.
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E. On-Site logistics 2. 11
ON-SITE LOGISTICS
DELEGATION
Unless you are putting on the workshop singlehanded. it is important that you delegate
responsibility, and focus your attention on supervising, troubleshooting, and keeping the
workshop moving according to plan. Those working with you need to understand the flow
of the workshop and what is expected of them. While you will want to verbally walk them
through their responsibilities, also provide them with detailed checklists (Appendix A). You
may want to draw up a room set-up diagram for both those helping you and the facility.
This is another time when a Planning manual (see page 2> can prove invaluable.
EQUIPMENT
Some of the most common problems with equipment -- it's not available; there aren't any
plugs in the room; something burns out or breaks; you can't figure out how it works - can
be avoided with a little preparation time. Before the workshop, locate the equipment you
will be using and do a trial run. Verify that there are back-up parts and machines.
extension cords, etc. available, and, if necessary, someone who knows how to run them.
Identify lighting, heating/cooling, and ventilation controls. Clarify with the facility when
and where the equipment will be needed. You might want to include the equipment request
and placement on the room set-up map. For specifics on equipment use, see Chapter 3.
FOOD
What you serve in terms of refreshment will obviously depend on your budget. There
should be, however, some kind of refreshment available at the breaks and beginning of the
workshop. This may be as simple as coffee and tea or you may want to offer snacks or
meals as well. For the later afternoon break, you may want to consider a change from the
usual caffeine options.
Work out with the facility when the workshop breaks will be, who will be responsible for
setting up and breaking down the refreshment area. Put every detail in writing, and check,
recheck and double check food and beverage requirements.
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F & G. Contingencies / Budget 2. 12
On the day of the workshop, introduce yourself to facility staff responsible for serving the
food. Verify serving times and any special arrangements. Identify a person to contact if
refreshments do not arrive or additional help. etc. is needed.
EMERGENCIES
Before the workshop starts, you should be aware of who to call within the facility in case
of emergencies and have an emergency contact for each participant.
Know the emergency fire plans for the facility and what the fire escape routes are.
CONTINGENCIES/PROBLEM SHOOTING
Even the best planned workshop can go awry. Take nothing for granted and expect the
unexpected. This means double-checking the facility set-up, your equipment, verifying with
your speakers. Have backups, be it spare bulbs for the slide projector; plans should a
speaker back out, or additional materials to plug into the program should something go
wrong (see checklists in Appendix A).
BUDGET
Budgeting procedures for workshops vary from state to state. Typical costs include:
a) site
b) speakers/consultants/resource people
c) travel/parking/airfare
d) publicity and mailings
e) equipment and hiring personnel to run them
g) meals and accomodations
h) staff time
i) administrative - phone calls, etc.
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CHAPTER 3. MANAGING THE WORKSHOP
CHAPTER 3
MANAGING THE WORKSHOP
A. The Participants
B. Written Materials
C. Presentations
D. Speakers
E. Group Discussions
F. Case Studies, Role Plays £ Simulations
G. Visual Aids & Audio-Visuals
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A & B. The Participants / Written Materials 3. 3
MANAGING THE WORKSHOP
THE PARTICIPANTS
The success of a workshop depends in part on how well its design and objectives fit the needs of
the participants. A general sense of the backgrounds, level of experience, and reasons people have
for coming to the workshop should help guide your program design (see Chapter 2A). If you have
a particular audience in mind, you will want to target your publicity towards them. In terms of
logistics, you also will want to have an idea of how many are coming, their travel and lodging
arrangements and needs.
You may request this information on a registration form, or it may be supplied by the agencies or
departments sending the participants for training. Many trainers also build this information
gathering into the introductory portion of the workshop (see Chapter 2A and Appendix B).
WRITTEN MATERIALS
THE INFORMATION PACKET
Each participant should receive an information at registration or early in the workshop. The
packet includes preliminary materials relating to the workshop — the agenda and other related
materials, a notepad, pencil, and often evaluation form. You may also want to include information
and a map of the workshop facility as well as to the surrounding area - a map marked with
restaurants, shops, etc. (see Appendix A for checklist examples).
There will also probably be materials to be handed out during the workshop. These may be
intended for immediate use or as reference materials. If they are xeroxed copies, references should
be cited. Always make sure jrou have more than enough copies.
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C. Presentations 3. 4
PRESENTATIONS
Presentations — lectures, talks -- are usually the cornerstone of a workshop. As such, you want
them to not only convey substantive information, but to do that in a way that is both interesting
and useful for the participants. This requires:
1) Planning the presentation
2) Making the information relevant to your audience
3) Encouraging audience involvement group interaction
PLANNING
Being organized does not mean you must write out a speech (although you may find this works
best't. It does entail having an outline of your presentation goals — where you want to go. points
you want to discuss, and supporting information. Try a variety of tools to find out which style of
organizing you prefer, be it note cards with key points and backup information, or slides, flip
charts, etc. (see section G).
The information itself should be new. useful -- not just a repeat of written materials - and not too
much. The old adage: "Tell them what you're going to say; say it; tell them what you said"
provides an important insight into how people iearn. People are not information sponges; they are
easily overwhelmed if presented with too much. This is especially true if that information is not
organized into "packages" they can hold on to. Studies suggest that at their best, people will
remember 3-5 major points. This means that as a presenter, you want to cover a few items, but
cover them well. Organizing, highlighting and summarizing your main points will help both you
and audience be clear on major themes.
This does not mean that you reiterate j'our speech three times. Reinforcing information by
presenting it in a variety of ways is a key to facilitating learning. Just as you vary activities
within the workshop, you will want to use several ways of presenting information within your
presentation. This might include using visual or audio aids, incorporating a question and answer
period, inserting an illustrative story or joke.
However, don't overdo this. The bottom line is presenting a logical, understandable presentation.
Use short sentences and try not to use jargon; if you do define your
terms. Try to reinforce your major points and check with your audience to make sure they are
following you.
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C. Presentations 3. 5
MAKING THE MATERIAL RELEVANT TO YOUR AUDIENCE
Most people are not very interested in learning new material if it is not important to them. As
discussed in program development, here, you also want to be sensitive to participants' background
and how they plan to use the information. By knowing "where your audience is coming from, you
can give examples that relate to their experience. You can anticipate some of their needs and
questions, and be prepared to address them.
ENCOURAGING GROUP INTERACTION
Actively involving people in your presentation will keep them interested, thinking, and will help
you make the information relevant to them. Encourage interaction with the material
— provide opportunties for people to accept, question, or rephrase material you present. A number
of approaches discussed below -- role playing, hand:s-on sessions, group discussions, even
homework are effective tools to encourage involvement (see below).
THE SPEAKER'S PRESENCE
The final ingredient, to an effective presentation is the speaker's presence. A talk delivered with
enthusiasm and concern, even a few theatrics will be more interesting. Practice your presentation
not only to evaluate the talk -- its length, clarity, interest -- but to observe your posture, voice
tone, and rate of delivery.
The adequacy of your preparation will influence your credibility as a speaker. Participants will be
more likely to accept what you have to say if they see you as well-informed, intelligent and
trustworthy — all offshoots of a thoughtful presentation. Speakers who are organized and know
their material demonstrate their professionalism. They can field questions with skill and
knowledge. Rather than trying to figure out what to say next, they can spend time and attention
on delivery (e.g.. more eye contact) and audience response.
Finally, make the room work for you -- check the lighting, room set-up and temperature, and
effectiveness of the aids you plan to use. A video screen, for example, while very effective in a
small conference room would be inappropriate in a large lecture hall.
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D. Speakers 3. 6
SPEAKERS
There may be times when you want to bring in additional resource people to speak -- to provide
insight into their speciality, to add variety to your workshop. You need to know why you want the
speaker, how he/she fits into your objectives for the workshop. AND make those expectations clear
to the speaker.
If you are in the position of finding arid choosing a speaker, the names and resources in Appendix
D may be a start. Also utilize the networks with which you are familiar: ask other trainers for
recommendations, talk to co-workers about effective speakers they have heard, etc. After you
have narrowed down your choices or have a person in mind, contact him/her directly. Ask each
prospective speaker enough questions to help you decide. You will probably want to ask about:
a'i their schedule and availability (and fee if relevant'
b) experience, credentials, recommendations
c) what could they offer given your workshop format and needs
d) handouts; audio-visual needs, etc. to be considered
e) possibility of you attending a presentation or seeing a demonstration tape.
e) contract agreements: what travel/payment arrangements they want
0 if selected as a speaker, how soon he/she needs to know.
An additional consideration should also be your general feeling of rapport with the prospective
speaker -- is this someone you would like to work with?
Having selected your speaker, some general guidelines for preparing him/her are:
1) Inform him/her in advance of the structure of the workshop, what topics he/she
should cover, and the amount of time allotted for the presentation.
2) Make sure he/she understands the nature of the audience and roles of various
participants.
3) Establish and hold to a time schedule with the speaker. You can have a watch
on the lectern or arrange a signalling procedure (e.g. you will raise your hand
when he/she has 5 minutes remaining).
4) Once a speaker has agreed to come, hold him/her to that commitment. If he/she
calls to cancel, ask who he/she is sending as a replacement.
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E. Group Discussions 3. 7
GROUP DISCUSSIONS
A group discussion can be one of the most effective ways to actively involve your audience.
Participants have an opportunity to ask questions and express their reservations or concerns. The
discussion gives them time to process the infcrmation presented and relate it to their own lives.
The process of verbalizing their thoughts also reinforces their learning.
In addition to giving you, the workshop leader, a breather, a discussion can help you gauge where
your audience is coming from. The kinds of questions asked provide a way for you to monitor how
well you are being understood. And. more often than not. the group will come up with new ideas
and useful information.
Finally, a well managed discussion is both fun and informative. It provides for the lively exchange
of ideas and elicits the energy and humor of your audience.
WHEN TO HAVE A GROUP DISCUSSION
Obvious^, the group needs something to talk about. Discussions are especially effective when you
want to:
I'l do introductions
2) debrief a lecture or exercise
3) share the input and expertise of the group
Breaking into pairs or small groups gives each person the opportunity to meet at least one other
participant (see Appendix C). Having people in the group talk to the person sitting next to them
for three minutes, for example, is a non-threatening, easy way to break the ice at the beginning of
a workshop.
Discussing a lecture or exercise the group has done is appropriate any time during a workshop.
Sharing responses to an opening game or non-verbal exercise can be an effective way both to help
people "settle in" and to build a sense of comardarie, or shared experience within the group.
Exercises that are more content related, e.g., simulations, role plays or field trips as well as
lectures provide ample material for discussion. How well this discussion goes depends in part on
facilitator preparation. It is important that you:
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E. Group Discussions 3. 8
1) have a reason or purpose for doing the exercise and how it fits into the focus of
the workshop.
2) fit the type of exercise to the size, and sensibility of your group. A group of
strangers, for example may not repond favorably to an exercise that
involves extensive eye or physical contact.
3) be familiar with how the exercise should go
4) explain the instructions very clearly and make sure everyone understands them
before beginning.
5) allow time for people to discuss or "debrief and evaluate the exercise.
While the expertise and experience of the group will come through in virtually any discussion,
there are times when you may want to explicitly tap this:
I) to analyze and critique a shared issue or experience;
2) to generate or "brainstorm" ideas
3) when the participants range in amount of experience, to have the more
experienced share and "tutor" the novices.
RUNNING GOOD DISCUSSIONS
A good discussion is one:
1) where the atmosphere is relaxed and inviting.
People should feel comfortable about offering opinions and asking questions.
Discussions that become argumentative or confrontational are rarely productive.
Two seemingly trivial considerations, discussion group size and seating
arrangements (discussed below) are critical.
2) that holds people's attention.
The subject under discussion is relevant and interesting to everyone involved. If a
number of people seem bored or distracted, it may be time to switch topics.
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E. Group Discussions 3. 9
3) that stays on target and addresses the issues at hand.
A long-winded, unfocused discussion is fatiguing and a waste of time. One way to
focus the discussion is to track it on newsprint or a blackboard. Writing down key new
words or ideas; listing the pros and cons of an issue; problems and proposed solutions
provides a visual "anchor" and serves as a group memory.
4) where everyone has a chance, but is not forced to speak.
o'i that has an outcome.
The discussion should reach some kind of closure and synthesis the participants
can take with them.
GROUP SIZE AND SEATING
Two important, but often overlooked considerations in group discussions are group size and seating
arrangement. The smaller the group, the more likely people are to speak up. Discussions of more
than 25 can be unwieldy. It is often difficult to really interact with the group and is more
appropriate for fielding or asking questions, opinions and responses.
Breaking a larger group into sub-groups of 4-5 to work together on an issue will give each person
more "air time". In groups of 5-7. people will speak to one another. In slightly larger groups of 8-
12, quiet people will tend not to speak up. If a group is "larger than that. 5-7 people will tend to
dominate. Typically, each group takes notes so that it can report its conclusions to the larger
group.
How people are seated also can impact the flow of discussion. Formal discussions tend to promote
one or two way communication: informal ones encourage interaction not only between speaker and
audience, but among the audience. In more formal settings, such as a theater, auditorium or the
typical classroom with rows of desks, the audience faces speaker. Because all the attention is
focused on him/her, the person up front maintains control over both the content and direction of
meeting. In a more informal setting where you want to encourage small group discussions, a
circular arrangement faciliates discussion because no one is "at the head of the table". (If circular
tables are not available, square tables are your next best option.)
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E. Group Discussions 3. 10
THE TRAINER'S ROLE
Your job as facilitator is to help make a good discussion happen. Your degree of involvement will
vary with the type of discussion. If you are fielding questions after a lecture or presentations, you
will want to:
1) make sure everyone has heard and understands the question; especially in large
group, repeat the question -- also gives you time to think.
2) keep answers brief and to the point.
3) look at the person as he/she asks the question, but. direct the answer to
everyone.
41) if you don't know, say so. If appropriate, offer to find out the answer.
6) NOT get pulled into a personal discussion or argument. Instead, offer to speak
with that person in private afterwards.
At other times, you will not want to be the center of the discussion. Even if you are responsible for
teaching in other aspects of the workshop, your role here is to facilitate, not run the discussion.
This does not mean you let the discussion go where it will, but that you guide and focus the
discussion from the "sidelines." This includes
1) Starting the discussion and arousing curiosity and interest.
2) Clarifying and rephrasing inputs (e.g. using the visual aids -- newsprint or a
blackboard as discussed below.)
3) Relating discussion to other materials and weaving it into your teaching agenda.
4) Identifying relevent or important points as they arise.
5) Pacing and keeping the discussion on track.
6) Being sensitive to and, if necessary monitoring, group dynamics (e.g., who
dominates the discussion)
7) Above all. listening.
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E. Group Discussions 3. 11
There will be times when it's very difficult to get over the first hurdle -- getting the discussion
started and keeping it going. Some effective approaches are:
1) ELABORATE on a statement by adding your own or other's views.
2) PARAPHRASE the statement in your own words.
3) GENERALIZE from the statement (e.g., "Jim's concern about conflict of interest
touches on the larger issue of work ethics.")
4) INTEGRATE it with other materials being covered.
5) PRAISE the insight or relevance of the statement.
6) DISAGREE with (but don't evaluate) the statement.
7) SUMMARIZE, especially if statement was long.
8; BRIDGE to another topic using the statement as a transition.
9) INSTILL HUMOR.
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F. Case Studies. Role Plavs & Simulations 3. 12
CASE STUDIES, ROLE PLAYS & SIMULATIONS
A very effective way to provide hands-on experience in a short time is through case studies, role
plays, or simulations. Al! three are different approaches to having participants work step by step
through a situation. To different degrees they provide an opportunity for participants to:
1) look at real problems and examine both theoretically, and in terms of
interpersonal dynamics and their own responses
2) try out or "test run" a situation
3) examine roles and dynamics of these problems
4i anticipate new situations
5) develop skills and competency
It is important that as a trainer, you know why you want to use one of these. Be clear about your
objectives and the lessons you want participants to learn.
CASE STUDIES
The least participatory of the three is the case study. It provides an indepth example that the
group can jointly focus on for discussion and analysis. The Inspector Training Manual, for example
has several descriptions of waste streams. Even if workshop participants will not be inspecting
these kinds of facilities, the case study will help them understand the complexity and range of
industrial processes.
ROLE PLAYS
Role plays are case studies where people actually act out roles. A carefully run role play can help
people prepare for a future real situation or provide a setting for the group to evaluate a past one.
To run a role play:
1) Select the situation. Discuss group your reasons for doing the role play with the group, outlining
what you want them to look for. Keep the explanation and the role play situation simple.
Emphasize to the group that a role play is not a psychodrama.
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F. Case Studies, Role Plavs & Simulations 3. 13
2) Explain the situation: Given participants the situational setting and background they will need.
This is often distributed as a written handout.
3) Assign roles. This may be done randomly: although it is useful sometimes to have people take
on roles of people they do NOT identify with. Give the characters fictitious names.
4) Prepare the role players. Give participants a few minutes to "get into character," ie to think
about their roles. You may want to give each role a brief character sketch and/or special "inside"
information verbally or on a handout.
51 Set the scene and run the role play. You can "cut" the action to make instructive comments or
encourage participants to remember the goals of the role play. "Cutting" is an effective way to
control the energy and momentum of the activity.
6) Evaluation. Talking about the experience is essential. Try to let what is learned come from the
group. The tone set here is important: have participants refer to characters not the people playing
them; and discourage negative evaluations or "should have dones". Elements of the summation
time should include:
a) discussing feelings and tensions
b'i strategies and tactics
cj theory and application of the experience.
SIMULATIONS
A simulation does not usually involve acting out roles, but rather focuses on creating a setting in
which one can practice skills. For example, constructing a mock-hazardous waste site gives
trainees a chance to learn what to look for, how to conduct themselves, etc.
PRECAUTIONS: Role plays and simulations are difficult to do effectively. Role plays have a
tendency to engage people ~ they can become very involved in their roles and lose sight of the
"play-acting" element. You as a trainer need to be able to monitor the real emotions of the
participants and control the tone of the role play.
Simulations are difficult in another way -- making the situation seem real, especially in recreating
sites (rather than situations) may not be worth the time and effort required. Again, be clear on
what are your objectives and how you can achieve them.
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G. Visual Aids & Audio-visuals 3. 14
VISUAL AIDS & AUDIO-VISUALS
Visual aids and audio-visuals (AV) provide another tool to your presentation repertoire. Studies
have shown that combining different media helps increase information retention. They improve
understanding by helping people visualize and conceptualize the points you are making.
The aids available range in sophistication from newsprint and chalkboards to advanced audio-
visuals -- films, video and computerized sequences. Used at their best, the media can focus your
audience on main points and convey them in shorter time. If poorly done, they may actually
confuse and obscure your points and slow down the pace.
Aids are especially useful when you want to:
1i present technical or complicated ideas
2) reinforce specific message or point
PREPARING GOOD VISUAL AIDS
1) Make them large enough to be seen by entire audience. You might want to check out the size
and arrangement of facility you wili be using and adapt your visual aids accordingly.
A general rule of thumb: make each letter at least 1/32" high for each foot of distance from the
material (e.g. a 1" letter is legible from 32 feet, a 2" one from 64 feet).
2) Keep them simple and clear. Convey only one message per visual element (e.g., per sheet, slide,
or overhead). Don't crowd the visual with lots of data and keep the wording simple and familiar.
Use a simple typeface.
3) Color can be a very effective way to delineate parts, ideas, etc, but don't overdo it. The colors
used should have meaning and impact. Use "cool" colors for key messages and "halting" colors for
impact. Use contrasting colors.
4) Your use of aids should blend in with your presentation. Try to maintain eye contact and turn
your back to the audience as little as possible.
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G. Visual Aids & Audio-visuals 3. 15
5) Don't let your visual aids become distractions. Keep them covered or out of sight until you want
to use them. You also have a better chance of keeping your audience's attention if you hold off on
distributing handouts or sharing items until after your presentation, for example during discussion
periods.
6) You may lose your audience if you are clumsy with your aids. Be sure your charts and
overheads are in order and that the equipment is set up and works.
The best way to avoid these pitfalls:
1) practice
2 i allow adequate time for set up and preparation of visual aids
o.i be prepared for your worst scenario: bring emergency provisions -- pins. tape.
extension cords, extra bulbs, etc.
4'> before your presentation make sure
a i the equipment you requested is there
b) that il works
c) that the room is ready (see SITE CHECK beiow)
This section will give some general guidelines for using
1) newsprint, or flipcharts
2i overheads
3: slide programs
4.' videos, films, and tapes
Additional references are listed in Appendix E.
NEWSPRINT / FLIP CHARTS
Flip charts are one of the most simple but effective visual aids you can use in a teaching setting.
They give you the flexibility to visualize and highlight key points as well as respond to and record
input from the group. Unlike the chalkboard, they can be used to create a semi-permanent
"memory" that can be posted around the workshop area. Newsprint may effectively be used to
post the agenda and group expectations, which may be referred back to during the workshop.
Equipment
newsprint (at least 18" x 18")
felt tip markers (preferably 3-4 colors: make sure they all write)
masking tape (make sure it sticks)
easel (figure out how it works before your presentation)
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G. Visual Aids & Audio-visuals 3. 16
General Guidelines
1) Use large block letters (1-1 1/2"). If you have trouble writing in straight lines,
buy newsprint with a grid etched in.
2) Don't talk while writing: write quickly, briefly, then turn back to your audience.
3) Write in only KEY points. You don't have to write down everything.
4) Put only about 10 lines of information per page, and do not fill a page to the
bottom. (The back of room will not be able to see it.)
5) Wait 20-30 seconds before turning newsprint. PRACTICE flipping the paper so
that the easel does not tip over. Avoid standing in front of easel afterwards.
Posting Pages
If you want some sheets to remain visible, e.g. to be used for review, reference, or to tie in with
other activities, tape them up. Title each page before posting. (You may want to have someone
help with this so that you can continue talking.) Have masking tape cut and ready on side of easel.
Be careful to stick the sheets on a surface that will not peel off when you take them back down.
Don't write on the newsprint once it is posted. The ink may leak through to the wall.
Prepared Pages
Some reasons for pre-preparing your newsprint are that you wili have neat, legible visual aids:
you will not spend class time writing; and the sheets can double as your notes.
You can also pencil in notes or graphics to be "developed" during your talk. During your
presentation, mark over them with with a felt pen. You may also want to pencil in notes to
yourself -- points you want to be sure to make, ideas you do not want to forget as you talk.
Pre-preparing newsprint may not be desirable, however, if you want to record audience responses
or points in group discussion.
OVERHEADS/TRANSPARENCIES
Any camera ready image can be made into an overhead transparencies making this aid a very
easy, simple and relatively inexpensive way to produce visuals. You can also develop ideas,
images, etc. on blank transparencies (or add information to existing ones) as you talk.
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CHAPTER 3. MANAGING THE WORKSHOP
G. Visual Aids & Audio-visuals 3. 17
Equipment
overhead projector
prepared transparencies
clean transparencies
transparency pens (preferably several colors) such as "Sharpie"-p]yj
kleenex and spraj' (for corrections/cleaning)
Most of the caveats for using newprint apply also here, although they often go unheeded. It is
important that you know why you are using an overhead and how it fits into your presentation.
All too often the overhead is used to show xeroxed pages (and sometimes pages and pages) of text
or complicated charts too complex for the audience to understand and too small for many of them
to even read.
Some disadvantages:
a'i sometimes it is difficult to make the image project evenly on the screen.
b) the projector head blocks some participants' views.
c.i without practice, it is difficult to write directly on the transparency.
d'l some speakers feel bound to the projector because they have to change
the transparencies by hand.
Some effective uses of the overhead are to:
1.) develop a diagram, illustration or graphic as you talk
2.i highlight, a few (i.e.. up to 5-7) typewritten points
3) show a few charts or figures that contribute to i.not replace,1 your talk.
Again:
1) carefully consider what each transparency "buys" you in terms of the message
you want to convey to your audience.
2) make sure participants at the back can read the screen.
3) do not let transparencies take the place of informative narrative and discussion.
4) consider handing out copies of your overheads so that participants can write on
them and keep them for reference.
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CHAPTER 3. MANAGING THE WORKSHOP
G. Visual Aids & Audio-visuals 3. 18
SLIDES AND SLIDE SHOWS
Slide shows are a relatively inexpensive way to add "real-life" visuals and examples to your
presentation. You also have the flexibility to combine photographs with charts, graphs and other
images, or to reorganize your slides if necessary. A well-prepared slide show does require some
preparation, especially if you want to depict graphs or tables, etc.
Try to run through your slide tray before your talk to make sure the slides are in order, right side
up, etc. It is also a good idea to number your slides.
Some common mistakes to avoid:
In designing slides:
1) Blank spaces filled with the brilliant white of the projector
2^ Poor quality slides -- dirty, out of focus, poor composition, over or underexposed.
washed out colors
3) Slides with hard-to-fmd features so that you have to apologize. "Those of you in
the back probably can't see this."
In setting up slides:
1) Too many slides or too many of the same thing
2) Upside down or backwards slides
3) Slides off the screen or not aligned well
4) Dirty projector lens
In presenting:
1) Waiting for slides to appear ~ have the slide appeal- as you talk.
2) Spending too much time on one slide
3) Not talking about what is on the screen, or talking about something just off the
edge of the slide.
4) Interrupting the program to focus or readjust the projector.
5) Always introducing the slides with. "This scene shows...", "Here you see...", etc.
Equipment
Slide projector
Slides
Screen
Spare bulbs, etc.
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CHAPTER 3. MANAGING THE WORKSHOP
G. Visual Aids & Audio-visuals 3. 19
AUDIO-VISUALS: VIDEO AND FILMS
Audio visual aids — film, video and tapes have become increasingly more sophisticated and
available for teaching settings. They can be a very vivid and engaging way of conveying
information. Audio-visuals differ from the other aids discussed here in that visual aids are often
the mechanism for teaching. You may have a discussion afterwards, but while the video or film is
running, it has the undivided attention of your audience.
Because it is a significant expenditure of time and energy on the part of your audience, it is
important that you preview the video and think about how audio-visuals and your training scheme
fit. together. What aspects of your workshop are best conveyed through audio-visuals? How can
you tie in other aspects of your workshop to reinforce them?
Before the Presentation
Test the equipment with the AA~ person. Even if you think you know how. have them show you
how equipment works. If you are showing a film, thread it and check the sound, focus, etc.
For a video, bring the video and a test tape if possible. A test tape is a tape with skin tones that
you know are correct. Use that tape to adjust the color setting on each of the monitors. Ideally.
you would play the video all the way through: but if you do not have time. fast, forward through
stopping at intervals to play it for a few seconds. Look and listen to the tape through all of your
monitors. Sit in the seat furthest from each monitor to adjust the sound and make sure picture can
be seen easily. Rewind and leave the equipment turned on if possible since it may be awkward to
turn it on during the session. Close the drapes if appropriate, and check that all cables are taped
down.
During the Presentation
Introduce the film or video tape.
Dim the lights. If you cannot do this, have someone near them do it.
Run the film or video tape.
When the film or tape is over, turn the lights back up.
Turn off the film projector. VCR (you can turn the monitors off later.)
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CHAPTER 3. MANAGING THE WORKSHOP
G. Visual Aids & Audio-visuals 3. 20
After the Presentation
Unless you have arranged otherwise with the A/V person, rewind the film or video and r.rn off
the machines. Check the room for any belongings participants may have left as well as your own
materials. As you leave, make sure the door is locked.
SITE CHECK
If possible, make a site check of the room before your presentation. You may want to make a
sketch of the room.
Placement: Evaluate whether or not the room is appropriate for the aids you want to use. Can all
of the audience see an easel for newsprint? Where would be its best location. If you are showing a
film, slides or using an overhead, check to see if there is a screen or where you wouid like to have
one placed. If you are showing a video, evaluate how many monitors you will need (figure about
10 people per monitor; and where to put them.
Electrical Outlets: Make sure there are electrical outlets near where you would like to place the
equipment. If there are only one or two, make sure extension cords and power strips will be
available.
Lighting: Are there windows? Are there drapes or shades for darkening the room? If not. you may
want to get another room. Slides, films and videotapes are best viewed in a semi-darkened room.
Locate the light switches and dimmers so that you can ask someone to turn them off.
When setting up the monitors (or screen) and chairs, try to have the door at the back of the room
so latecomers will not disturb the presentation. After checking out the rooms, contact the person
who will be providing the A/V equipment. Run through your checklists (see Audio-visual checklists
in Appendix A) of questions and things you will need.
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CHAPTER 4. FOLLOWING UP
CHAPTER 4
FOLLOWING UP
A. Evaluations
B. Follow-up
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CHAPTER 4. FOLLOWING UP
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CHAPTER 4. FOLLOWING UP
A. Evaluations 4. 3
FOLLOWING UP
EVALUATIONS
Evaluations provide you, the trainer with an opportunity to gain some honest feedback
about your workshop. Some reasons for doing an evaluation include:
1) evaluating the relevance and usefulness of various activities or tools
2) evaluating the overall effectiveness of the program
3,i measuring how well the perceived results of the workshop meet with your initial
goals
4) helping participants think about how the pieces of the workshop fit together
5) providing specific feedback to the trainer, speakers, etc.
6) facilitating future planning
Evaluations can range from simply asking for people's satisfaction with the workshop to
more complicated data gathering. They can be verbal or written; done individually or as a
group; during or after the workshop. An evaluation, for example, done after an activity- or
at the mid-point gives you the chance to make sure the workshop is meeting the
participants' needs and to make any necessary adjustments. A more formal, and usually
written evaluation occurs at the end of the day. Gear the type of evaluation to fit the tone
of the workshop.
Some topics typically included in evaluations:
a) Importance or relevance of the topic
b) Quality/appropriateness of the information presented
c) Quality of speakers' presentations
d) Usefulness of audio-visual materials
e) Agenda: was it realistic?
f) Format: did the workshop achieve its goals? Were group discussions useful?
g) Leadership/Facilitation
h) Physical Facilities
i) Suggestions/Criticisms
Ask for both successes and criticisms. Focusing participants on what they have learned
will not only give you important feedback, but also help them bring together the workshop
in their own minds. Try to keep evaluations of the process separate from those of the
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CHAPTER 4. FOLLOWING UP
A. Evaluations 4. 4
content. For example, give participants the opportunity to differentiate between their
feelings about the usefulness of a simulation from those about the effectiveness of the
facilitator running it.
You need to be clear about what it is you want to know, how you plan to use the
information, and what, if any, kind of feedback you want to offer the participants.
Remember to leave time on your agenda for evaluations and encourage everyone to
participate.
VERBAL EVALUATIONS
Verbal evaluations can serve as opportunities for the group as a whole to:
1) share learnings
2) vent emotions
3) clear up confusions
4) analyze what happened during an exercise or the workshop
5) integrate their learning and bridge various activities together
Since this kind of evaluation is done as a group, you may not get the depth of feedback
that you would with a written format. Verbal evaluations are best done in a small groups
(reporting back to the larger group if necessary). Have one person record responses on a
flip chart.
Some of the topics the group might discuss are:
1) how many of their expectations were met
2) "if I were to do this again, I would ...."
3) what am I leaving with?
4) what went well / what went poorly
5) the "highs" and "lows" of the workshop
An effective way to elicit positive and negative aspects (such as #4 and 5) is to have three
categories outlined on the flip chart: + / - / a triangle. Under each list the pluses/minuses/
and "change" aspects of the workshop.
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CHAPTER 4. FOLLOWING UP
A. Evaluations 4. 5
DESIGNING WRITTEN EVALUATIONS
Written evaluations encourage more individual feedback than verbal ones. They also
provide a permanent record. Designing a good evaluation form is not easy; it takes time
and careful wording to make sure the questions ask what you want to know. The issue of
anonymity is always a sticky one. You might want to encourage participants to sign the
evaluations, but not require it.
Written evaluations can include open or closed-ended questions. Open ended questions ask
for a written response (e.g. "What was the most valuable part of this workshop?"). Close
ended questions require a response to a limited number of options such as multiple choice,
yes or no. or a rating scale (e.g.. "I found the simulation: a') very useful: bi somewhat
useful: c) a waste of time"). It is much easier to tabulate and interpret close-ended
responses. You may want to include open ended questions so participants can include
responses not allowed by the more rigid format.
Since most training workshops are not one time events, at least some of the questions
should focus on specific improvements or changes that might be incorporated into the
program. A few sample evaluation forms are supplied in Appendix B.
USING EVALUATIONS
Feedback from the evaluation, once tabulated, can be incorporated into your workshop
design immediately. A rule of thumb for interpreting the rating scores: an average below
2.5 suggests that section needs improvement: 2.5-3.5 that it is adequate, 3.5+ that it is
worth keeping. When interpreting outliers -- those answers (usually negative) that
divergent from the general response -- it is useful to see where these responses are coming
from. Including questions in your evaluation such as previous experience, expectations,
and purpose for coming to the workshop may give you insight into the responses. This kind
of additional analysis is especially important if you need to explain the results to higher
ups.
You also might want to consider sending a follow-up questionnaire once participants have
started to use the workshop materials and information. Former workshop participants can
provide valuable information about what materials they have found most useful, other
areas that could have been covered, and other types of workshops they suggest.
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CHAPTER 4. FOLLOWING UP
B. Follow-up 4. 6
FOLLOW-UP
Follow-up in the context of a workshop can be of two kinds:
1) keeping track of the participants and speakers
2) notes to yourself about the workshop
KEEPING TRACK
Keeping track of participants can serve a number of different purposes. In addition to
tapping them for the follow-up evaluation mentioned above, you may want to share the
feedback from others about the workshop and keep them informed of other workshops. A
follow-up letter might also include the participant mailing list so that people can continue
to network and contact one another. Depending on the nature of the workshop and group.
2. more formalized communication such as a newsletter may be appropriate.
You should write any speakers and thank them for their assistance. This is also a good
time to share positive feedback on their presentation.
Spending some time on your personal "follow-up" will greatly facilitate future workshop
planning. In terms of the workshop itself, follow-up includes compiling the data from the
evaluation sheets and incorporating that feedback into the workshop itself. You may also
want to record and organize ideas and information that were generated during the
workshop. This might include handwritten notes recorded from small group discussions,
your jottings during the workshop, or transcribing information from the "group memory"
as recorded on newsprint. Keep notes to yourself of what activities worked well or did not;
other approaches you might want to trj' next time.
You may also want to keep a record of the specifics of how you arranged for the workshop:
how well the facility worked out: whom you contacted; prices quoted; some problems you
encountered; precautions to take next time.
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APPENDIX A. CHECKLISTS
WORKSHOP CHECKLISTS
Facility Checklist
Pre-Workshop Checklist
Personal Supplies Checklist
Post-workshop Checklist
Audio-visual Checklists
Pre-production
Video Checklist
A/V Person Checklist
Workshop Day Checklist
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APPENDIX A. CHECKLISTS
-------
APPENDIX A.
CHECKLISTS
FACILITY CHECKLIST
Name
Address
Phone
Size
Rates
Contact Person
# rooms available
housing accomodations
banquet, eating facilities
Availability
Conference Rooms
Comfortable seating with writing surfaces
Good lighting
Windows and ventilation
Electrical outlets
Availabilitv/Location of:
Public Telephones
Parking
cost
Restrooms
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APPENDIX A. CHECKLISTS
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APPENDIX A. CHECKLISTS
PRE-WORKSHOP CHECKLIST
Lobby sign announcing location of workshop
Coat rack
Table (for handouts, books)
Registration table
Public telephones
Signage
Ashtrays -- if smoking is allowed
Coffee and refreshments
Water pitchers and glasses
Equipment in place with backups
Lectern
Microphone (if warranted by group size.)
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APPENDIX A. CHECKLISTS
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APPENDIX A. CHECKLISTS
PERSONAL SUPPLIES CHECKLIST
Handout materials
Participant list and addresses
Printed Agenda
Name Tags
Signs
Extra pens, pencils, felt-tip markers, paper
Flipchart/newsprini
Easel
Audio-visual materials
Blackboard erasers, chalk
Props (if needed for group activities)
Masking tape
Clock
Pencil Sharpener (or locate one in the building)
Stapler
Scissors
Throat lozenges
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APPENDIX A. CHECKLISTS
-------
APPENDIX A. CHECKLISTS
Audio-visual checklists
PRE-PRODUCTION CHECKLIST
Workshop Name
Workshop Dates
Workshop Times
Number of People in Workshop
Video tape format 3/4" 1/2" VHS 1/2" Beta
Hotel/Meeting Place
Address
Phone
Directions
Contact Person (Room Reservationist)
Phone
A/'V Contact Person
Phone
Meeting Room Name/Number
Directions
Room Dimensions
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APPENDIX A. CHECKLISTS
Audio-visual checklists
-------
APPENDIX A. CHECKLISTS
Audio-visual checklists
VIDEO CHECKLIST
PRE-WORKSHOP: Room Check:
Number of electrical outlets
if not enough: extension cords/power strips
Number of windows w/without shades
if not available: arrange new room
locate light switches/dimmers
Sketcn of the room:
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APPENDIX A. CHECKLISTS
Audio-visual checklists
-------
APPENDIX A. CHECKLISTS
Audio-visual checklists
A/V PERSON CHECKLIST
Place he/she can be contacted at the time of the workshop
Phone
Alternate if A/V person cannot be located
Phone
EQUIPMENT LIST:
Number of monitors
Type of video tape recorder (VCR) needed (3/4". 1/2" VHS. 1/2" Beta)
Power strips and extension cords if outlets are limited
All cables and extension cords taped down/covered with carpeting, mats, or
commercial rugs to prevent people from tripping over cables.
-------
APPENDIX A. CHECKLISTS
Audio-visual checklists
-------
APPENDIX A. CHECKLISTS
Audio-visual checklists
WORKSHOP DAY CHECKLIST
1 1/2 hours before presentation
Video tape (and test tape)
Check monitor colors with test tape
Run video tape through
Check monitors, sound level, viewing ease
Rewind video, zero the counter
Close drapes if appropriate
Make sure cables are taped down
After Presentation
Turn off power
Contact AfV person
Check room for personal belongings
Gather workshop materials (handouts, etc) and your personal belongings
Turn off the lights
Lock the room as you leave. Video equipment should be secured at all times
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APPENDIX A. CHECKLISTS
Audio-visual checklists
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
THREE DAY PROGRAM SCHEDULE
1st Day
8:00 AM Registration & Coffee
8:30 AM Introductions &. Ice breaker
9:30 AM How the Program Works
10:00 AM VIDEO on RCRA - Chapter 2
10:15 AM Coffee Break
10:30 AM Organize small group session on RCRA
10:45 AM Small group sessions on RCRA
11:30 AM Feedback from the small group sessions
12:00 N Lunch
1:15 PM VIDEO on SAFETY - Chapter 3
1:30 PM VIDEO on SAFETY by Bill Bokey
2:00 PM Coffee Break
2:15 PM Small group sessions on SAFETY
3:30 PM Small group feedback -- ASK THE INSPECTOR
4:45 PM Review of the day
5:00 PM Finish program for the day
2nd Day
8:00 AM VIDEO on RCRA by Herb Johnson
8:30 AM Group discussion on RCRA again
9:15 AM VIDEO on permits -- Chapter 4
9:30 AM Small group discussions on RCRA and PERMITS
10:30 AM Coffee Break
10:45 AM Small group feedback - ASK THE INSPECTOR
12:00 N Lunch
1:15 PM VIDEOS on INSPECTION - Chapters 5,6 & 7
2:00 PM Coffee Break
2:15 PM Presentation on INSPECTION by an experienced inspector
3:15PM Small groups on INSPECTION
4:15 PM Feedback from small groups -- ASK THE INSPECTOR
5:00 PM Finish program for the day
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
3rd Day
8:00 AM VIDEO on SAMPLING - Chapter 8
8:30 AM Presentation on SAMPLING by an experienced inspector
10:00 AM Coffee Break
10:15 AM ASK THE INSPECTOR about SAMPLING
11:15 AM VIDEO on Chapters 9 & 10
11:45 AM Lunch
1:00 PM Question-and-Answer session on any subject
1:45 PM Review of the Program
2:15 PM Evaluation
2:45 PM End of Program
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
FOUR DAY PROGRAM SCHEDULE:
1st Day
8:00 AM Registration & Coffee
8:30 AM Introduction & Ice Breakers
9:30 AM How The Program Works
10:00 AM VIDEOS -- Chapters 1 £ 2
10:15 AM Coffee Break
10:30 AM Organize small group sessions on RCRA
10:45 AM Small group session on RCRA
12:00 N Lunch
1:15 PM Feedback from small groups -- ASK THE INSPECTOR
2:30 PM Coffee Break
2:45 PM VIDEO -- Chapter 3
3:00 PM VIDEO on SAFETY by Bill Bokey
3:30 PM Small group session on SAFETY
5:00 PM End of the program for the day
2nd Day
8:00 AM Feedback from small groups -- ASK THE INSPECTOR
9:30 AM VIDEO on RCRA by Herb Johnson
10:00 AM Coffee Break
10:15 AM Group discussion on RCRA
11:15 AM VIDEO - Chapter 4
11:30 AM Discussion on PERMITTING and MONITORING
12:00 N Lunch
1:15 PM Read a waste stream article from the Manual
1:45 PM Discussion by inspector on WASTE STREAM
2:00 PM Coffee Break
2:15 PM VIDEOS on Chapters 6,7 & 8
3:00 PM Presentation on INSPECTION by an experienced inspector
4:30 PM Group discussion with the inspector on INSPECTIONS
5:00 PM End of program for the day
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
3rd Day
8:30 AM Small group session on INSPECTION
10:00 AM Coffee Break
10:15 AM Feedback from small groups - ASK THE INSPECTOR
11:30 AM Group discussion on items covered
12:00 N Lunch
Option 1
(If a field trip can be arranged)
1:00 PM Field trip to regional office/facility or both
5:00 PM End of program for the day
4th Day
8:00 AM VIDEO on SAMPLING - Chapter 8
8:30 AM Presentation on SAMPLING by an experienced inspector
10:00 AM Coffee Break
10:15 AM ASK THE INSPECTOR about SAMPLING
11:15 AM VIDEO on Chapters 9 & 10
11:45 AM Lunch
1:00 PM Question-and-Answer session on any subject
1:45 PM Review of the Program
2:15 PM Evaluation
2:45 PM End of Program
Option 2
(If a field trip cannot be arranged)
1:15 PM VIDEO on SAMPLING - Chapter 8
1:30 PM VIDEO on SAMPLING by Bill Bokey
2:00 PM Coffee Break
2:15 PM Presentation on SAMPLING by an experienced inspector
4:00 PM Group discussion on SAMPLING SAMPLING
4:30 PM VIDEO on BASIC EVIDENCE COLLECTION -- CHAPTER 10
5:00 PM End of the program for the day
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
4th Day
8:00 AM Small group discussion on SAMPLING & EVIDENCE COLLECTION
10:00 AM Coffee Break
10:15 AM Feedback from small groups -- ASK THE INSPECTOR
11:30 AM Break for Lunch (Checkout day)
1:00 PM Presentation by workshop leader on Chapters 11 & 12 and using the
rest of the manual
2:00 PM Final Evaluation
2:30 PM End of the program
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
-------
APPENDIX B SAMPLE AGENDAS & EVALUATIONS
AGENDA
ASTSWMO INSPECTOR TRAINING PROGRAM
AUSTIN, TEXAS
January 13-15, 1988
Wednesday
8:00 AM Registration
8:30 AM Welcome & Introductions
9:00 AM You As An Inspector
10:00 AM Reading the Manual -- Chapter 2
10:30 AM Coffee Break
10:45 AM VIDEO -- Chapter 2
11:00 AM Small group session on RCRA
11:45 AM Feedback from the groups
12:00 N Lunch
1:15 PM Presentation on SAFETY by Tom Patterson
2:30 PM Coffee Break
2:45 PM ASK THE INSPECTOR -- SAFETY questions
3:15 PM Small group session on SAFETY
4:15 PM Feedback from small group sessions
4:45 PM ASK THE INSPECTOR -- SAFETY questions (againi
5:15 PM End of the program for the day
Thursday
8:00 AM A Look at RCRA as a Law by Herb Johnson
8:30 AM Class discussion on RCRA as a Law
9:00 AM VIDEO on WORK ETHICS -- Chapter 5
9:30 AM Review of manual on WORK ETHICS & PERMITS
10:00 AM Coffee Break
10:15 AM Develop questions on WORK ETHICS. PERMITS,
SAFETY & RCRA
10:45 AM Small group sessions to work on questions
11:30 AM ASK THE INSPECTOR -- questions from small groups
12:15 PM Lunch
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APPENDIX B SAMPLE AGENDAS & EVALUATIONS
1:30 PM VIDEO on PREPARING FOR THE INSPECTION -- Chapter 6
1:45 PM Conducting the Inspection by Tom Patterson
3:15 PM Coffee Break
3:30 PM Small group discussion of the INSPECTION
4:30 PM ASK THE INSPECTOR -- questions from small groups
5:15 PM End of the program for the day
Friday
8:00 AM Collecting Evidence and Sampling by Robert Phillips
9:45 AM Questions on EVIDENCE and SAMPLING
10:00 AM Coffee Break
10:15 AM VIDEO on POST-INSPECTION PROCEDURES -- Chapter 8
10:30 AM Review of manual on SPECIAL PROCEDURES & MEDICAL
MONITORING
11:00 AM Small group sessions on whole program
12:15 PM Lunch
1:15 PM Feedback and questions from small groups
1:45 PM Using the Manual and its appendices
2:00 PM Evaluations
3:00 PM End of Program
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APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
EVALUATIONS
Name
Agency
Overall, how would you rate the workshop?
excellent very good about average poor very poor
Why?
How would rate the following portions of the workshop?
List agenda activities excellent average poor
1.
2.
3. ~^^_ ~^^^ ^^2.
etc.
Were there other areas you would have liked to have discussed?
General comments
-------
APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
-------
APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
EVALUATION
ASTSWMO INSPECTOR TRAINING PROGRAM
AUSTIN, TEXAS
January 13-15, 1988
DIRECTIONS: Please respond to the following items so that we can have your ideas on
improving this program. Thank you for your help.
WEDNESDAY
REGISTRATION
Comments:
WELCOME & INTRODUCTIONS
Comments:
Please rate each program activity on a scale where:
5 = excellent l = very poor
YOU AS AN INSPECTOR
12345 Presentation
12345 Topic
Comments:
READING THE MANUAL -- Chapter 2
12345 Presentation
12345 Topic
Comments:
VIDEO -- Chapter 2
12345 Presentation
12345 Topic
Comments:
SMALL GROUPS ON RCRA
12345 Topic
Comments:
FEEDBACK FROM GROUPS
Comments:
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APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
SAFETY PRESENTATION by TOM PATTERSON
12345 Presentation
12345 Topic
Comments:
ASK THE INSPECTOR -- SAFETY questions
12345 Topic
Comments:
SMALL GROUP SESSION on SAFETY
12345 Topic
Comments:
FEEDBACK FROM THE GROUPS
12345 Topic
Comments:
ASK THE INSPECTOR -- SAFETY questions (again)
12345 Topic
Comments:
^ *****=:.•****
THURSDAY
A LOOK AT RCRA AS A LAW by Herb Johnson
12345 Presentation
12345 Topic
Comments:
GROUP DISCUSSION ABOUT RCRA
12345 Topic
Comments:
VIDEO on ETHICS - Chapter 5
12345 Presentation
12345 Topic
Comments:
REVIEW OF MANUAL on WORK ETHICS and PERMITS
12345 Topic
Comments:
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APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
DEVELOPING QUESTIONS about WORK ETHICS, PERMITS, & SAFETY
12345 Topic
Comments:
SMALL GROUP SESSION on questions
12345 Topic
Comments:
ASK THE INSPECTOR - questions from small groups
12345 Topic
Comments:
VIDEO on PREPARING FOR THE INSPECTION -- Chapter 6
12345 Topic
Comments:
CONDUCTING THE INSPECTION by TOM PATTERSON
12345 Presentation
12345 Topic
Comments:
SMALL GROUP SESSION on INSPECTIONS
12345 Topic
Comments:
ASK THE INSPECTOR -- questions from the small groups
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FRIDAY
COLLECTING EVIDENCE AND SAMPLING by ROBERT PHILLIPS
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QUESTIONS about EVIDENCE and SAMPLING
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APPENDIX B. SAMPLE AGENDAS & EVALUATIONS
Evaluations
VIDEO on POST-INSPECTION PROCEDURES -- Chapter 8
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REVIEW OF MANUAL on SPECIAL PROCEDURES and MEDICAL MONITORING
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SMALL GROUP SESSIONS -- Total Program
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FINDINGS & QUESTIONS from small groups
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USING THE MANUAL AND ITS APPENDICES
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OVERALL, hov; die' you like the:
12345 Training Manual
12345 videos
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12345 the entire workshop
What was the BEST part of the program for you ?
What part of the program do you think should be changed?
Do you have any suggestions for improving the:
Manual
videos
small group sessions
housing, food, travel arrangements
THANK YOU
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 1 / Test 1
PROBLEM SET 1
Chapters 2, 3; 4 & 5
TEST 1
Please briefly answer the following questions, or respond true or false to the following statements.
If false, please give the correct answer.
CHAPTER 2 - RESOURCE CONSERVATION AND RECOVERY ACT
1. True or false? Records of hazardous waste generated, shipped; and disposed must be
available to federal regulator}' authorities only.
2. True or false? Hazardous materials fully contained within a totally enclosed treatment
facility are always considered hazardous waste under Subtitle C of RCRA.
3. True or false? "Permitted" facility standards (40 CFR Part 264) outline practices that
owners and operators of hazardous waste storage facilities must follow to properly manage
hazardous waste.
4. True or false? Although the states and the EPA are jointly responsible for administering
RCRA, state authorities retain oversight responsibility for their jurisdiction.
5. True or false? Subtitle D of RCRA encourages states to develop a plan for the
management of solid waste, primarily non-hazardous waste such as household refuse.
6. True or false? The Underground Storage Tank Program regulates underground tanks
storing substances defined as hazardous waste (under CERCLA) as well as tanks storing
petroleum products.
7. What are the four characteristics of "hazardous waste" as defined by RCRA?
8. What is a "listed" waste?
9. Under what conditions can a generator accumulate hazardous waste onsite for up to 90
days?
10. What determines whether a TSD facility has "interim" or "permitted" status?
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 1 / Test 1
CHAPTER 3 - SAFETY PROCEDURES
11. True or false? Assuming the same type of chemical-resistent clothing is used, Level C
protection is distinguished from Level B protection only by the equipment used to protect
the respiratory system.
12. List five elements which you condsider the most critical, that should be included in a site-
specific safety plan.
CHAPTER 4 - PERMITS AND COMPLIANCE MONITORING
13. Briefly describe the role of an inspector during an inspection in support of the permitting
process.
14. The draft permit incorporates 'permit conditions' pertaining to a faility's operation. These
conditions are divided into two main categories. List the two categories and provide an
example of each condition.
15. Name the four major categories of inspections.
16. A(n) inspection is the
primary enforcement mechanism for detection of RCRA violations.
17. True or false? Transporters who store manifested hazardous wastes at a treatment
facility for less than 30 days are not required to obtain an operating permit.
18. True or false? Semi-annual inspections are required at all federal, state, or local
government-operated facilities and at least one inspection per year at every RCRA Subtitle
C facility.
19. True or false? Transporting hazardous waste without a legal manifest is subject to non-
judicial enforcement action.
CHAPTER 5 - PROFESSIONALISM
20. During an inspection, how should inspectors act to help them personally?
21. True or false? During an inspection, inspectors cannot accept any gratuities.
22. True or false? It is appropriate for inspectors to interrupt their inspection to give
information to the press, when they are requested to do so.
23. True or false? Information in an inspection report is always confidential.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 1 / Test 2
PROBLEM SET 1
Chapters 2; 3, 4 & 5
TEST 2
Please briefly answer the following questions, or respond true or false to the following statements.
If false, please give the correct answer.
CHAPTER 2 - RESOURCE CONSERVATION AND RECOVERY ACT
1. True or false? In addition to encouraging proper management of non-hazardous and
hazardous waste at active sites. RCRA also encompasses hazardous waste at inactive or
abandoned sites.
2. True or false? Once a transporter accepts hazardous waste from a generator, s/he can
store this waste at a transfer facility for a period of time not to exceed 10 days without
being subject to TSD regulations.
3. True or false? A storage tank for hazardous waste designed to industry specificatons is an
example of the criteria specified under the "permitted" facility standards.
4. True or false? Subtitle C of RCRA regulates certain underground tanks.
5. True or false? A detailed emergency response plan is required as part of the information
contained in the Uniform Hazardous Waste Manifest.
6. What are two main goals of RCRA? Describe briefly the programs designed to acheive
these goals.
7. Where would you find information on how to test for the four characteristics of hazardous
waste as defined by RCRA?
8. Name two wastes which are excluded from the definition of hazardous waste under
Subtitle C?
9. List and define the three functions of a TSD facilitv.
CHAPTER 3 - SAFETY PROCEDURES
10. True or false? A site-specific safety plan is required to be developed only before entering a
known hazardous facilitv.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 1 / Test 2
11. List the three primary channels that toxic materials can enter the body. How can you
prevent contamination through each?
CHAPTER 4 - PERMITS AND COMPLIANCE MONITORING
12. Describe a situation where EPA can forego the normal permitting process.
13. Name the two principle elements of the RCRA enforcement program.
14. In the permitting process, public notification occurs before or after the draft permit is
completed?
15. True or false? A farmer who disposes of hazardous insecticides on-site is not required to
obtain an operating permit under RCRA Subtitle C.
16. True or false? EPA-issued permits are required to construct a hazardous waste
management facility.
17. True or false? A comprehensive groundwater monitoring evaluation is an overall review of
a facility's compliance with all applicable RCRA requirements.
18. True or false? Omitting important information from, or making a false statement in a
manifest, label, report, or permit is subject to prosecution by federal and state
governments.
CHAPTER 5 - PROFESSIONALISM
19. True or false? During an inspection, it is good policy for an inspector to sit down and have
coffee and a snack with the facility personnel.
20. How should inspectors offer their opinions about the regulatory agency and its personnel to
facility personnel?
21. Inspectors should disclose alleged violations to (choose as many as apply):
a. agency personnel
b. legal councel
c. their supervisor
d. facility personnel
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 2 / Test
PROBLEM SET 2
Chapters 6, 7 & 8
TEST 1
CHAPTER 6 - PREPARING FOR THE INSPECTION
1. Before an inspector inspects a facility, with what other agencies should s/he coordinate?
2. Inspectors should take a(n) when they go to the field (choose as many as apply):
a. extra pair of boots
b. tape measure
c. watch
d. lunch
3. True or false? An inspector should notify a facility of intent to inspect (of a scheduled
inspection) when s/he has all the documents that s/he needs.
4. True or false? Standard equipment is used for all inspections.
5. When should safety goggles be worn during an inspection?
CHAPTER 7 - CONDUCTING THE INSPECTION
6. True or false? Any inspector may gather classified information, as long as s/he has
his/her supervisors permission to do so.
7. True or false? Inspectors need not notify facilitj' personnel of the preliminary results of
the inspection, unless the facility does not comply with the regulations.
8. What is the appropriate action for an inspector to take if facilty personnel withdraw
consent to inspect?
9. An opening conference during an inspection is useful to (choose as many as apply):
a. promote cooperation between state and the facility
b. give management information on RCRA
c. establish a follow-up inspection time
d. have a coffee break, before the work gets especially difficult
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 2 / Test
10. True or false? Inspectors should follow a standard format for checking documents at a
facility.
11. True or false? Inspectors should assume that the permit documents list the waste and
waste management information correctly; they don't need to verify with facility personnel
since these documents are required by law.
12. True or false? Facility personnel must provide a facility map to facilitate the inspection.
13. True or false? Inspectors should always follow the routes company officials take to avoid
getting into dangerous areas.
14. True or false? Inspectors should check for on-site treatment of stored waste.
15. True or false? Inspection checklists indicate all the aspects of an inspection to investigate.
16. True or false? Inspectors should always follow up all visits with additional information.
17. True or false? Facility personnel may not limit inspectors' access to any portion of the
facility if the inspector has a warrant.
18. True or false? An inspector must be certain s/he follows certain statutary requirements
when s/he uses a search warrant.
CHAPTER 8 - POST INSPECTION PROCEDURES
19. True or false? An inspection report is important documentation for funding received for
RCRA grants administered by the EPA.
20. True or false? Corrections in an inspection report should be initialed and dated.
21. True or false? When you are writing an inspection report for generators, you should
include information on the manifest, contingency plan and general standards in the report.
22. True or false? An inspection report should include documentation of suspected violations.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 2 / Test 2
PROBLEM SET 2
Chapters 6, 7 & 8
TEST 2
CHAPTER 6 - PREPARING FOR THE INSPECTION
1. Before inspectors visit a facility, they should (choose all that apply):
a. review all existing files for the facility
b. review waste stream information for that type of facility
c. write a thank you note to the facility for letting them inspect
d. write a letter to the facility about suspected violations.
2. True or false? A pre-inspection worksheet must be completed before an inspector may
inspect a facility.
3. True or false? When notifying facility personnel, an inspector should discuss discrepancies
found upon review of background documents.
4. True or false? Fireproof clothing should be worn for all inspections.
CHAPTER 7 - CONDUCTING THE INSPECTION
5. What does a Comprehensive Groundwater Monitoring Evaluation entail?
6. True or false? Inspectors must provide duplicate samples to facility personnel.
7. True or false? As long as an inspector is conducting an inspection during normal business
hours, s/he may continue the inspection regardless if facility personnel leave during the
inspection.
8. True or false? If consent to inspect is withdrawn, then the inspection to that point
becomes invalid.
9. What should permit applications contain (choose as many as apply)?
a. annual reports
b. manifests
c. only confidential information
d. EPA identification number
10. True or false? Landfill facilities must specify requirements for a closure plan.
11. An inspector should obtain a warrant from .
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 2 / Test 2
12. Inspectors should review the following documents at a facility (choose as many as apply):
a. contingency plan
b. list of personnel safety equipment available
c. manifest discrepancies
d. annual reports
13. True or false? An inspector should not re-inspect for previous violations since they would
have been corrected in a follow-up inspection for the particular violation.
14. True or false? Inspectors should not ask questions when thej' visit the waste storage
areas.
15. True or false? Inspectors must use an inspection checklist to complete a Comprehensive
Ground Water Monitoring Evaluation (CME).
16. Samples should be taken (choose as man}' as apply):
a. if the waste stream is suspected to be contaminated
b. when the samples can be easily collected by truck or car
c. of all stored waste
d. none of the above
17. True or false? Inspectors should avoid recommending a particular consulting firm to a
facility.
18. True or false? Your supervisor should accompany you on all inspections where a warrant
is needed.
CHAPTER 8 - POST INSPECTION PROCEDURES
19. Information in an inspection report must be (choose all that apply):
a. accurate
b. comprehensive
c. written specifically for technical audiences
d. cross-referenced with checklists, and appropriate citations
20. True or false? Compiled and organized inspection checklists are all that is needed for an
inspection report.
21. True or false? Usually an inter-office memorandum and inspection cover sheet are
sufficient to document an inspection.
22. How are confidential documents referenced in a final inspection report?
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 1
PROBLEM SET 3
Chapters 9, 10, 11 & 12
TEST 1
Please briefly answer the following questions, or respond true or false to the following statements.
If false, please give the correct answer.
CHAPTER 9 - SAMPLING PROCEDURES
1. Why are hazardous wastes sampled?
2. What is the first step in developing a site-specific sampling plan? What decisions must the
inspector make about the type of sampling to be performed?
3. True or false? Plastic containers should be used to collect and store aqueous samples not
containing oily residues, pesticides, or halogenated hydrocarbons.
4. True or false? When gathering evidence for possible legal action, multiple samples of a
waste are sometimes collected. Subdividing a waste sample is not generally recommended.
5. True or false? Inspectors should never open a sealed drum.
6. What is a good guideline to use when recording sampling information in the log book?
7. True or false? Chain of custody records need not accompany samples sent for laboratory
analvsis.
CHAPTER 10 - BASIC EVIDENCE COLLECTION
8. What documents are accountable? How should these documents be accounted for and
protected?
9. What information should log book entries include? (Name at least five pieces of
information.)
10. True or false? If the facility and agency files do not provide maps of plant and facility
locations, the inspector should prepare a sketch map of the site.
11. True or false? Comments about photograph content should be recorded in the field log
book.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 1
CHAPTER 11 - SPECIAL PROCEDURES
12. What is a discharge?
13. Personnel should have and
to investigate a spill where
personal safety protection is required.
14. True or false? Potentially hazardous areas should not be entered without adequate
personal protection.
15. If adequate response has not been initiated by response personnel, what should be your
first step when approaching the situation?
16. Name four safety procedures you should follow during any on-scene spill investigation.
17. True or false? It is inappropriate to discuss your testimony with the attorney who
subpoenaed you.
18. True or false? During testimony, all facts should be readily admitted, even if it is not to
the advantage of the party form whom you are testifying.
19. True or false? Answer only what is asked by the questioning attorney during testimony.
20. True or false? If you give an incorrect or unclear response, you may not correct your
statement.
21. True or false? It is appropriate to ask the Presiding Officer. Judge, or Board Member for
advice.
CHAPTER 12 - MEDICAL MONITORING PROGRAM
22. Which of the following job categories should have health monitoring made available?
(Choose as many as apply.)
A. Laboratory
B. Administrative
C. Solid and hazardous waste
D. Spill response
E. Technical personnel supporting A, C, and D
F. Secretarial personnel supporting A, C, and D
23. True or false? Occupational health monitoring provides a comprehensive health evaluation
which includes screening for many common non-occupational chronic disorders.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 1
24. True or false? Changes in the information on the employee's medical histor}' form should
be brought to the attention of the examining physician during the exployee's next annual
examination.
25. True or false? What is one of the best tools for diagnosing occupational illness? Describe
the test. How often is this test necessary?
26. What is audiometry? For what types of employees is it required?
27. Should an electrocardiogram be included in the baseline examination? When should
periodic electrocardiograms be obtained?
28. True or false? The examining physician and the occupational physician will evaluate any
medical condition which would place the employee at risk and recommend limitations upon
his/her assigned work.
29. True or false? Copies of the Letter of Transmittal with physician comments will be filed
by an agency coordinator responsible for safety and health.
30. True or false? Health record information may be used to determine unusal susceptibility
to illness or injury from exposures in the work environment and suitability for
ssignments.
31. True or false? Health record information may be used to adjudicate claims, determine
benefits, and report medical conditions required by law to Federal, state, and local
agencies.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 1
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APPENDIX C QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 2
PROBLEM SET 3
Chapters 9. 10, 11 & 12
TEST 2
Please briefly answer the following questions, or respond true or false to the following statements.
If false, please give the correct answer.
CHAPTER 9 - SAMPLING PROCEDURES
1. What is the purpose of the sampling procedures in the Inspection Manual?
2. What are the three most important factors to consider when choosing containers for
hazardous waste samples?
3. True or false? Glass containers may be used to collect and store samples containing
hydrofluoric acid or strong alkalis.
4. What three safety guidelines should be followed whenvever sampling?
5. Each sample must be labeled and sealed properly after collection. The seal should be
attached so that .
6. True or false? The person collecting a sample will start the chain of custody procedure;
the sample should be kept in view or within limited access, locked storage until custody is
relinquished and formal documentation of the transfer is complete.
CHAPTER 10 - BASIC EVIDENCE COLLECTION
7. Since proper documentation and document control are crucial to enforcement actions, what
documentation steps should inspectors take before leaving inspection sites?
8. True or false? Field notes are the inspector's private, personal record.
9. Name two sources for maps of inspection sites.
10. What information must be documented if a photograph is to be a valid representation of an
existing site?
11. What safety precautions should be taken when photographing?
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APPENDIX C QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 2
CHAPTER 11 - SPECIAL PROCEDURES
12. True or false? Discharge response is a common responsibility of RCRA inspectors.
13. True or false? When approaching an emergency spill site, determine the spill location and
park your vehicle upwind at a safe distance.
14. If competent response personnel are on the scene, what should be your first step as an
inspector when appoaching the situation?
15. If there are no response personnel at the scene, you will notify the proper authorities and
make an initial survey of the scene from a safe distance. What will your survey include?
(Name at least three.)
16. How should a witness prepare for testimony? Why is this necessary?
17. True or false? You should always turn over all records in response to a subpoena from the
opposing party when you arrive in the courtroom.
18. True or false? It is inappropriate for you to ask for an attorney to repeat a question when
you are testifying.
19. True or false? When you are being cross-examined, your answers should be as brief and
concise as possible.
20. True or false? It is appropriate to look at written material during your testimony to
refresh your memorv about a detail of which you are uncertain.
CHAPTER 12 - MEDICAL MONITORING PROGRAM
21. What is an occupational health monitoring program?
22. True or false? Occupational health monitoring assists in the prevention and early
detection of adverse effects of occupational exposure and stresses.
23. True or false? No special preparation is necessary before employees' health examinations.
24. True or false? Pulmonary function testing is warranted only in special cases upon the
recommendation of the examining physician.
25. True or false? Each employee should receive a basic panel of blood counts and chemistries
to evaluate bloodforming organs, kidney, liver, and endocrine/metabolic functioning.
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APPENDIX C QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 2
26. A comprehensive physical exam is usually performed giving special consideration to an
employee's particular job function.
27. The examining physician and occupational physician will review the medical information
obtained during the examination. From this data, the physicians will evaluate the
employee's physical capability to perform
and .
28. The results of the examination will be documented and reported by
29. Employee records will document the following:
1.
2.
3.
30. True or false? Health record information is confidential and may not be used for
occupational and preventative health programs, epidemiologic research, teaching, or
statistical data.
31. True or false? Health record information may not be used for litigation purposes.
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APPENDIX C QUESTIONS & ANSWERS TO TRAINING MANUAL
Problem Set 3 / Test 2
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Discussion Questions
DISCUSSION QUESTIONS
1. a. Why is safety considered one of the most important issues in hazardous waste
inspection?
b. What kinds of precautions do you need to take?
2. Where would you go to find more information on: handling specific chemicals, sampling.
health monitoring, RCRA regulations, ethical standards, etc.?
3. What would you consider the most important aspects of your training as a hazardous
waste inspector, and why?
4. Outline the primary steps you would follow to prepare for an on-site investigation.
5. What would you do if someone threatened you or harassed you during an inspection?
6. What are some of the most important factors to consider for writing a case report that will
stand up in court?
7. What do you see as your roles as a hazardous waste inspector? How do they "play out" in
your job?
8. What kind of tone do 3'ou try to set at an inspection? Why? How might you do this?
9. What is the philosophy and intent behind RCRA? Given this philosophy, what are some of
your job priorities?
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Discussion Questions
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 1
ANSWERS TO PROBLEM SET 1
Chapters 2, 3, 4 & 5
TEST 1
Please refer to the Inspection Manual for more complete information.
CHAPTER 2 - RESOURCE CONSERVATION AND RECOVERY ACT
1. False: records of hazardous waste generated, shipped, and disposed must be available to
state as well as federal regulators' authorities.
2. False; hazardous materials full}- contained within a totally enclosed treatment facility may
be excluded.
3. False: interim status standards (NOT permitted facility standards) outline practices that
owners and operators of hazardous waste storage facilities must follow to properly manage
hazardous waste.
4. False: although the states and the EPA are jointly responsible for administering RCRA.
EPA (NOT state authorities) retain oversight responsibility for their jurisdiction.
5. True: Subtitle D of RCRA encourages states to develop a plan for the management of solid
waste, primarily non-hazardous waste such as household refuse.
6. True: the Underground Storage Tank Program regulates underground tanks storing
substances defined as hazardous waste (under CERCLA) as well as tanks storing
petroleum products.
7. What are the four characteristics of hazardous waste as defined by RCRA?
1. Ignitability
2. Corrosivitj'
3. Reactivity
4. EP Toxicity
8. What is a listed waste?
A listed waste is named on one of the three hazardous waste lists kept by the EPA:
1. Non-specific Source Wastes
2. Specific Source Wastes
3. Commerical Chemical Products
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 1
9. Under what conditions can a generator accumulate hazardous waste onsite for up to 90 days?
A generator must meet requirements for proper storage, emergency planning, personnel
training, and emergenc3r preparedness and prevention.
10. What determines whether a TSD facility has interim or permitted status?
The status depends on the time when the facility went into operation. Facilities meeting
the less stringent interim status requirements must later meet permitted status
requirements. The two classifications were developed by the EPA since the permitting
process may take years.
CHAPTER 3 - SAFETY PROCEDURES
11. True: assuming the same type of chemical-resistent clothing is used. Level C protection is
distinguished from Level B protection only by the equipment used to protect the
respiratory system.
12. List five elements which you condsider the most critical, that should be included in a site-
specific safety plan.
See page 3-3 for a more extensive listing. You might consider the following:
-site safety officer and telephone number
-objective of the inspection
-hazardous materials present
-hazard assessment
-possible need for pre-entry monitoring
-level of personal protection required
CHAPTER 4 - PERMITS AND COMPLIANCE MONITORING
13. Briefly describe the role of an inspector during an inspection in support of the permitting
process.
Inspector roles include informing the facility of the requirements of the law, identifying
aspects of the facility operations not meeting regulatory requirements, and suggesting
alternative actions necessary for compliance.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 1
14. The draft permit incorporates 'permit conditions' pertaining to a facility's operation. These
conditions are divided into two main categories. List the two categories and provide an
example of each condition.
1. Applicable to all permits: the facility is required to comply with all conditions listed
in the permit.
2. Case-by-case basis: use of compliance schedule.
15. Name the four major categories of inspections.
The categories are the following:
1. CEI: Compliance Evaluation Inspection
2. Record Review
3. Comprehensive Groundwater Monitoring Evaluation
4. Sampling Inspection
16. A(n) compliance evaluation inspection is the primary enforcement mechanism for detection
of RCRA violations.
17. False: transporters who store manifested hazardous wastes at a treatment facility for less
than H) days are not required to obtain an operating permit.
18. False: annual inspections are required at all federal, state, or local government-operated
facilities and at least one inspection per year at every RCRA Subtitle C facility.
19. False: transporting hazardous waste without a legal manifest is subject to criminal action.
CHAPTER 5 - PROFESSIONALISM
20. During an inspection, how should inspectors act to help them personally?
Inspectors should not accept any items or act in any way that might be viewed as
furthering a person or private interest.
21. True; during an inspection, inspectors cannot accept any gratuities.
22. False: inspectors are not press spokespersons, so are not expected to interrupt their duties
to give out information. Questions about alleged violations and enforcement should be
referred to the appropriate State enforcement staff attorney.
23. False: information in an inspection report is confidential only until the report is made final.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 1
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 2
ANSWERS TO PROBLEM SET 1
Chapters 2, 3, 4 & 5
TEST 2
Please refer to the Inspection Manual for more complete information.
CHAPTER 2 - RESOURCE CONSERVATION AND RECOVERY ACT
1. False; CERCLA (NOT RCRA) regulates hazardous waste at inactive or abandoned sites.
2. True; Once a transporter accepts hazardous waste from a generator, s/he can store this
waste at a transfer facility for a period of time not to exceed 10 days without being subject
to TSD regulations.
3. True: a storage tank for hazardous waste designed to industry specificatons is an example
of the criteria specified under the "permitted" facility standards.
4. False; Subtitle I (NOT Subtitle C) of RCRA regulates certain underground tanks.
5. False; a detailed emergency response plan is NOT required as part of the information
contained in the Uniform Hazardous Waste Manifest.
6. What are two main goals of RCRA? Describe briefly the programs designed to acheive these
goals.
1. To protect human health and the environment
2. To reduce waste and conserve energy and natural resources
3. To reduce or eliminate the generation of hazardous waste as quickly as possible
Subtitle D: encourages states to develop a plan for the management of primarily non-
hazardous solid waste
Subtitle C: establishes a system for the management of hazardous waste from generation
to disposal.
Subtitle I: regulates certain uncerground storage tanks
7. Where would you find information on how to test for the four characteristics of hazardous
waste as defined by RCRA ?
40 CFRPart 261
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 2
S. Name two wastes which are excluded from the definition of hazardous waste under Subtitle C:
-household refuse
-municipal resource recoverj' wastes
-agricultural wastes
-mining overburden returned to the mine site
9. List and define the three functions of a TSD facility.
Treatment: changes wastes so as to neutralize, recover, make safer for subsequent
handling, treatment, storage, or disposal
Storage: holding for 90 days for subsequent treatment, storage, or disposal elsewhere
Disposal: entrv of anv solid or hazardous waste into the environment.
CHAPTER 3 - SAFETY PROCEDURES
10. False: a site-specific safety plan is required to be developed for all inspections (NOT only
before entering a known hazardous facility).
11. List the three primary channels that toxic materials can enter the body. How can you prevent
contamination through each?
1. Ingestion: through gastro-intestinal tract
2. Absorption: through skin or cuts
3. Inhalation: through respiratory system
A. Do not chew gum. eat, smoke, etc. at insection site
B. Use approved protective suits in good condition
C. Use approved respirator
CHAPTER 4 - PERMITS AND COMPLIANCE MONITORING
12. Describe a situation where the EPA can forego the normal permitting process.
In a situations where there is immenent endangerment to human health . a temporary
permit (90 day) can be issued.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 2
13. Name two principle elements of the RCRA enforcement program.
These elements are inspections and enforcement action.
14. Yes, in the permitting process, public notification occurs after the draft permit is completed.
15. True; a farmer who disposes of hazardous insecticides on-site is not required to obtain an
operating permit under RCRA Subtitle C.
16. True; EPA-issued permits are required to construct a hazardous waste management
facility.
17. True; a comprehensive groundwater monitoring evaluation is an overall review of a
facility's compliance with all applicable RCRA requirements.
18. True; omitting important information from, or making a false statement in a manifest,
label, report, or permit is subject to prosecution by federal and state governments.
CHAPTER 5 - PROFESSIONALISM
19. False; inspectors should provide their own meals. Even accepting coffee may be seen as
taking a bribe from the facilities' viewpoint.
20. How should inspectors offer their opinions about the regulator? agency and its personnel to
facility personnel?
They should not offer their opinions at all. All information obtained during an inspection
for only official use.
21. Inspectors should disclose alleged violations to (choose as many as apply):
b. legal counsel
c. their supervisor
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 1 / Test 2
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 1
ANSWERS TO PROBLEM SET 2
Chapters 6, 7 & 8
TEST 1
Please refer to the Inspection Manual for more complete information.
CHAPTER 6 - PREPARING FOR THE INSPECTION
1. Before an inspector inspects a facility, with what other agencies should slhe should coordinate?
The agencies with which one should coordinate depend on the nature of the inspection. In
many cases, at least the state and federal agencies should be aware of what the inspector
is doing.
2. Inspectors should take a(n) when they go to the field (choose as many as apply):
b. tape measure
c. watch
3. True: when notifying facility personnel, an inspector should discuss discrepancies found
when s/he reviewed the background documents.
4. False; equipment for an inspection varies according to the nature and purpose of an
inspection. Certain items, though are needed for nearty all types of inspections, such as
clipboard, waterproof pens, and camera with batteries. (See page 6-7 for additional
recommended items.!.
5. When should safety goggles be worn during an inspection?
Safety goggles and hard hats should be worn as required by facility staff. Safety goggles
should also be worn when full face protection (such as Levels A and B) is unnecessary.
CHAPTER 7 - CONDUCTING THE INSPECTION
6. False: any classified information must be gathered only by an EPA or State employee with
security clearance.
7. False; to promote cooperation between the state and the facility, it is often helpful to
review the preliminary findings of the inspection with facility personnel. Inspectors should
stress that the information is preliminary, and that no decisions about the status of the
facility will be made until the inspection report is finalized.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 1
8. What is the appropriate action for an inspector to take iffacilty personnel withdraw consent to
inspect?
Facility personnel have the right to withdraw consent to inspect at any time during an
inspection. Inspectors should gather their belongings and records and leave the site. The
inspection up to the point of withdraw is valid.
9. An opening conference during an inspection is useful to (choose as many as apply):
a. promote cooperation between state and the facility
b. give management information on RCRA
c. establish a follow-up inspection time
10. False: no standard format exists for checking documents. Guidelines for the t3>pes of
documents to check are found pp. 7-5 to 7-10.
11. False; inspectors should always verify information on permit documents. This information
may be outdated, subject to an amendment, etc.
12. False; it is helpful for an inspector to review a facility map to understand where to inspect.
Often, facility personnel may provide you with a map. but they are not required to do so.
13. False; inspectors should be alert to problems during the inspection. Hence, s/he should
walk in areas that interest you such as drainage pathways and creeks. However, s/he
should also use professional judgement to avoid going into areas which could be dangerous.
14. True; inspectors should check for on-site treatment of stored waste.
15. False; inspection checklists are guides to help determine if the inspector has collected
relevant information. Depending on the inspection, however, additional information may
be needed which is not explicitly requested on the checklist.
16. False; in cases where facility personnel request additional information, inspectors should
provide it. This action indicates a genuine interest on the Agency's part. However, if
personnel do not request any additional information, there is no need to give them
anything.
17. True; facility personnel may not limit inspectors' access to any portion of the facility if the
inspector has a warrant.
18. True; an inspector must follow certain statutary requirements when s/he uses a search
warrant.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 1
CHAPTER 8 - POST INSPECTION PROCEDURES
19. True; an inspection report is important documentation for funding received for RCRA
grants administered by the EPA.
20. True; corrections in an inspection report should be initialed and dated.
21. True; when you are writing an inspection report for generators, you should include
information on the manifest, contingency plan and general standards in the report.
22. True; an inspection report should include documentation of suspected violations.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 1
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 2
ANSWERS TO PROBLEM SET 2
Chapters 6, 7 & 8
TEST 2
Please refer to the Inspection Manual for more complete information.
CHAPTER 6 - PREPARING FOR THE INSPECTION
1. Before inspectors visit a facility, they should (choose as many as apply):
a. review all existing files for the facility
b. review waste stream information for that type of facility
2. False: inspection worksheets are designed to guide inspectors in preparing for an
inspection. As such, they are not required by law. but extremely helpful in determining
whether inspectors have identified, assembled and reviewed all relevant materials prior to
conducting the inspection.
3. True; when notifying facility personnel, an inspector should discuss discrepancies found
when s/he reviewed the background documents.
4. False; fireproof clothing is appropriate for some inspections, and not necessarily needed in
all cases. Inspectors should follow the guidelines developed for Levels A,B.C,D for safety.
(See SAFETY chapter).
CHAPTER 7 - CONDUCTING THE INSPECTION
5. What does a Comprehensive Groundwater Monitoring Evaluation entail?
It entails reviewing records and sampling, and taking preliminary surveys.
6. True; inspectors must provide duplicate samples to facility personnel.
7. True; as long as an inspector is conducting an inspection during normal business hours,
s/he may continue the inspection regardless if facility personnel leave during the
inspection.
8. False; the inspection, until the point at which it is terminated, is valid. In addition, any
observations, or items which the general public could see. that an inpector makes as s/he
leaves a facility after consent is withdrawn, are considered valid information.
9. What should permit applications contain (choose as many as apply)?
a. annual reports
d. EPA identification number
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 2
10. True; landfill facilities must specify requirements for a closure plan.
11. An inspector should obtain a warrant from the Deputy Attorney General.
12. Inspectors should review the following documents at a facility (choose as many as apply):
a. contingencj' plan
c. manifest discrepancies
d. annual reports
13. False: ideally, previous violations will be corrected through a follow up inspection.
However, this does not always happen, so an inspector should always re-inspect units to
determine if the violations were corrected.
14. False; inspectors should always be alert to problems. Obviously, one way to find out about
a potential problem is to ask.
15. True; inspectors must use an inpsection checklist to complete a Comprehensive Ground
Water Monitoring Evaluation (CME).
16. Samples should be taken
a. if the waste stream is suspected to be contaminated
17. True; inspectors should avoid recommending a particular consulting firm to a facilitj'.
18. False; although in some cases it may be appropriate for your supervisor to accompany you,
law officals should accompany you in all cases.
CHAPTER 8 - POST INSPECTION PROCEDURES
19. Information in an inspection report must be (choose all that apply):
a. accurate
b. comprehensive
d. cross-referenced with checklists, and appropriate citations
20. False; inspection reports must be thorough and accurate for several reasons, including that
they may be used as evidence in court. Hence, including only checklists is rarely
sufficient. In addition, EPA identifying information, details about the particular facilit}',
and information about the kind of facility (generator, transporter, TSD) must also be
included (See pp. 8-3 to 8-5).
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 2
21. False; see Question 4. This type of document would be appropriate when a facility has not
determined its hazardous wastes, and an inspector has no evidence to make that
determination.
22. How should confidential documents be referenced in a final inspection report?
Confidential information should be referred to in a nonconfidential manner. This might
include a serial number or other code such that readers who have access to this material
can find it, but that general readers are not provided with the confidential information.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 2 / Test 2
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APPENDIX C. QUESTIONS AND ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 1
PROBLEM SET 3
Chapters 9,10,11 & 12
TEST 1
Please refer to the Inspection Manual for more complete information.
CHAPTER 9 - SAMPLING PROCEDURES
1. Why are hazardous wastes sampled?
In most instances, sampling determines if a facility is in compliance with existing
regulations. In other cases, sampling obtains data for purposes of classifying, treating,
recovering, recycling, or determining compatibility characteristics of the wastes.
2. What is the first step in developing a site-specific sampling plan? What decisions must the
inspector make about the type of sampling to be performed?
The first step in developing a site-specific sampling plan is to decide what is to be
accomplished by the data collected.
3. False: plastic containers should not be used to collect and store aqueous samples not
containing oily residues, pesticides, or halogenated hydrocarbons.
4. True: when gathering evidence for possible legal action, multiple samples of a waste are
sometimes collected. Subdividing a waste sample is not generalhr recommended.
5. True: Inspectors should never open a sealed drum.
6. What is a good guideline to use when recording sampling information in the log book?
Record sufficient information so that another person can easily reconstruct the sampling
situation without relying on the collector's memory.
7. False; chain of custody procedures must be used to ensure sample integrity, and legally
and technically defensible data.
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APPENDIX C. QUESTIONS AND ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 1
CHAPTER 10 - BASIC EVIDENCE COLLECTION
8. What documents are accountable? How should these documents be accounted for and
protected?
Log books, field data records, correspondence, sample tags, graphs, chain of custody
records, analytical records, and photographs should bear a serial number and should be
listed, with a number, in a project document inventory assembled at the project's
completion. Waterproof ink must be used when recording all data on these documents.
9. What information should log book entries include? (Name at least five pieces of information.)
See list on pages 10-2 and 10-3.
10. If the facility and agency files do not provide maps of plant and facility locations, what
measures should the inspector take?
The inspector should prepare a sketch map of the site.
11. False: any remarks about photograph content could jeopardize its value as legal evidence.
CHAPTER 11 - SPECIAL PROCEDURES
12. What is a discharge?
A discharge occurs when hazardous substances (in harmful quantities) enter waters
directly or indirectly. Since bodies of water include both groundwater and surfacewater.
any substance which comes in contact with the ground should be considered a discharge.
Hazardous substances in this context include any substance causing pollution if it enters
water.
13. Personnel with emergency response training and who participate in a health monitoring
program are best qualified to investigate a spill where personal safety protection is
required.
14. True; potentially hazardous areas should not be entered without adequate personal
protection.
15. If adequate response has not been initiated by response personnel, what should be your first
step when approaching the situation?
Direct the responsible part}' as to what appropriate action should be taken.
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APPENDIX C. QUESTIONS AND ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 1
16. Name four safety procedures you should follow during any on-scene spill investigation.
1. Avoid direct contact with spilled materials
2. Remain upwind from the spill
3. Stay out of low-lying areas
4. Provide for the removal and/or isolation of all ignition sources
5. Dispose of or decontaminate protective gear
17. False', it is appropriate to discuss your testimony with the attorney who subpoenaed you.
18. True; during testimony, all facts should be readily admitted, even if it is not to the
advantage of the party form whom you are testifying.
19. True: answer only what is asked by the questioning attorney during testimony.
0. False: at any time you may ask to correct a mistake made earlier in your testimony.
o
21. False: it is NOT appropriate to ask the Presiding Officer, Judge, or Board Member for
advice. If you are asked an improper question, your attorney will object for you.
CHAPTER 12 - MEDICAL MONITORING PROGRAM
22. Which of the following job categories should have health monitoring made available? (Choose
as many as apply.)
A. Laboratory
C. Solid and hazardous waste
D. Spill response
23. True: occupational health monitoring assists in the prevention and early detection of
adverse effects of occupational exposure and stresses.
24. False; An occupational health monitoring program is only designed to screeen for evidence
of adverse effects of occupational exposure, particularly exposure to toxic substances.
Occupational health monitoring does NOT provide a comprehensive health evaluation
which includes screening for many common non-occupational chronic disorders.
25. True; changes in the information on the employee's medical history form should be brought
to the attention of the examining physician during the exployee:s next annual examination.
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APPENDIX C. QUESTIONS AND ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 1
26. What is one of the best tools for diagnosing occupational illness? Describe the test. How often
is this test necessary?
The baseline chest x-ray (standard 14 x 17 inch posterior-anterior exposure) is required for
a thorough occupational evaluation. Subsequent testing is required every 5 years or at the
recommendation of the examining physician.
27. What is audiometry? For what types of employees is it required?
Audiometry tests hearing ability. Audiometry is required for all employees regularly
exposed to high noise levels (i.e. over 85 dB) and is indicated for employees inspecting
industrial and municipal facilities with high noise level equipment.
28. Should an electrocardiogram be included in the baseline examination? When should periodic
electrocardiograms be obtained?
Yes. When recommended by the examining phj'sician and for those employees older than
35 years of age.
29. True: the examining physician and the occupational physician will evaluate any medical
condition which would place the employee at risk and recommend limitations upon his/her
assigned work.
30. False; copies of the Letter of Transmittal without physician comments will be filed. Copies
will be mailed to the employee under a confidential stamp.
31. True; health record information may be used to determine unusal susceptibility to illness or
injury from exposures in the work environment and suitability for assignments.
32. True; health record information may be used to adjudicate claims, determine benefits, and
report medical conditions required by law to federal, state, and local agencies.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 2
ANSWERS TO PROBLEM SET 3:
Chapters 9, 10, 11 & 12
TEST 2
Please refer to the Inspection Manual for more complete information.
CHAPTER 9 - SAMPLING PROCEDURES
1. What is the purpose of the sampling procedures in the Inspection Manual?
In most instances, sampling determines if a facility is in compliance with existing
regulations. In other cases, sampling obtains data for purposes of classifying, treating,
recovering, recycling, or determining compatibility characteristics of the wastes.
2. What are the three most important factors to consider when choosing containers for hazardous
waste samples?
The three most important factors to consider when choosing containers for hazardous
waste samples are compatibility, resistance to breakage, and volume.
3. False; glass containers may not be used to collect and store samples containing
hydrofluoric acid or strong alkalis.
4. What three safety guidelines should be followed whenveuer sampling?
1. Treat each sample as if it were extremely toxic
2. Warn the laboratory receiving the sample if special handling is necessary.
3. Approved and appropriate safety equipment must be worn in areas where
hazardous conditions are suspected. Eye protection should be worn when
handling acidic, caustic, or other hazardous liquids (including preservative
chemicals).
5. Each sample must be labeled and sealed properly after collection. The seal should
be attached so that it is necessary to break the seal in order to open the sample
container.
6. True: the person collecting a sample will start the chain of custody procedure; the
sample should be kept in view or within limited access, locked storage until custody
is relinquished and formal documentation of the transfer is complete.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 2
CHAPTER 10 - BASIC EVIDENCE COLLECTION
7. Since proper documentation and document control are crucial to enforcement actions,
what documentation steps should inspectors take before leaving inspection sites?
Each inspector should keep detailed records of inspections, investigations, and
photographs taken. Notes should be thoroughly reviewed before leaving the site.
8. False: field notes are part of state agency files.
9. Name two sources for maps of inspection sites.
United States Geological Service maps, Soil Conservation Service maps, and
Federal Housing Administration fioodplain maps.
10. What information must be documented if a photograph is to be a valid representation
of an existing site?
1. Day. date, and time.
2. Signature of photographer.
3. Name and identification of site.
4. General direction faced.
5. Location on site.
6. Sequential number of the photograph and the roll number.
11. What safety precautions should be taken when photographing?
Near explosive hazards: do not get any closer than necessary and do not use a
flash or strobe.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 2
CHAPTER 11 - SPECIAL PROCEDURES
12. False; discharge response is a field in itself and is quite separate from a RCRA
inspector's normal duties. Inspectors are advised to consult with their supervisors
concerning their state's discharge response procedures.
13. True; when approaching an emergency spill site, determine the spill location and
park your vehicle upwind at a safe distance.
14. If competent response personnel are on the scene, what should be your first step as an
inspector when appoaching the situation ?
Locate the on-scene coordinator.
15. If there are no response personnel at the scene, you will notify the proper authorities
and make an initial survey of the scene from a safe distance. What will your survey
include? (Name at least three.)
a. Location of threatened or potentially threatened people
b. Presence of hazardous materials
c. Potential environmental threats
d. Whether proper safety procedures are being followed
e. Methods of containing the spill and/or arresting its source
16. How should a witness prepare for testimony? Why is this necessary?
A witness should prepare by thorough and detailed review of all relevant
documents and original notes taken by the witness at the time of the incident.
Witnesses may return to the spill site and talk to other persons present at the
scene. Persons who have not testified previously ma37 wish to visit a court trial or
hearing.
17. False; unless you were told in advance by your own lawyer to give the documents
to someone, do not turn over subpoenaed records until the judge orders you to do
so.
18. False; never answer a question you do not fully understand.
19. True; when you are being cross-examined, your anwsers should be as brief and
concise as possible.
20. True; it is appropriate to look at written material during your testimony to refresh
your memory about a detail of which you are uncertain.
CHAPTER 12 - MEDICAL MONITORING PROGRAM
21. What is an occupational health monitoring program?
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers tOlP^bjflpy,SBbi?p41>f^hg health status nf selppted emloees hv means of eriodip
medical examinations.
22. True; occupational health monitoring assists in the prevention and early detection
of adverse effects of occupational exposure and stresses.
23. False; employees are advised to refrain from drinking alcoholic beverages and
taking non-prescribed medication the day before the exam. Ideally, the employee
should not smoke on the morning of the exam since this could affect the results of
the EKG.
24. False; pulmonary function testing is desirable as part of the baseline examination,
especially for employees at respiratory system risk (such as those with significant
exposure to toxic dusts and irritants and for those employees over 35 years of age).
25. True; each employee should receive a basic panel of blood counts and chemistries to
evaluate bloodforming organs, kidney, liver, and endocrine/metabolic functioning.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 2
26. True: a comprehensive physical exam is usually performed giving special
consideration to an employee's particular job function.
27. The examining physician and occupational physician will review the medical
information obtained during the examination. From this data, the physicians will
evaluate the employee's physical capability to perform work while wearing a
respiratory protective device and his/her designated job function.
28. The results of the examination will be documented and reported by Letter of
Transmittal.
29. Employee records will document the following:
A. Health status
B. Changes in physical status
C. Care rendered, advice given, and consultations recommended.
30. False: health record information may be used for occupational and preventative
health programs, epidemiologic research, teaching, or statistical data.
31. False: health record information may be used for litigation purposes.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Answers to Problem Set 3 / Test 2
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Discussion Question: Issues to Consider
DISCUSSION QUESTIONS
Issues to Consider
1. a. Why is safety considered one of the most important issues in hazardous waste
inspection ?
b. What kinds of precautions do you need to take?
a. Safetj' is important for many reasons. Think about issues such as the
following:
-Inspectors are at high personal risk on a continuing basis.
-It would be impossible for an inspector to anticipate every hazard. Therefore
he/she must take extraordinary precautions.
-Not only is the inspector at risk, facility workers, management, and general public
are as well.
-Inspectors serve as models for proper handling and personal protection practices.
b. The types of precautions include:
-assessing the situation and types of hazards
-thoroughly understanding the levels of personal protection
-always decontaminating
-having a trial run using the personal protection and sampling equipment.
2. Where would yon go to find more information on: handling specific chemicals.
sampling, health monitoring. RCRA regulations, ethical standards, etc.?
A multitude of information sources are available. Many are listed in your
Inspector Training Manual. Resources include:
-fact sheets
-hotlines
-co-workers and supervisors
-EPA regional office staff
-Manuals (many listed on pp. C-l to C-3)
-Background documents (EPA; some listed in Chapter 3)
-Videos from the Bureau of National Affairs and National Audiovisual Center
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Discussion Question: Issues to Consider
3. What would you consider the most important aspects of your training as a hazardous
waste inspector, and why?
There are many aspects you might consider including:
-Safety (personal, worker, public)
-Problem-solving tips
-Sense of overall job mission
-Proper sampling procedures
-Proper documentation
-Sense of your role(s) as inspector
-An understanding of RCRA and its aims
4. Outline the primary steps you would follow to prepare for an on-site investigation.
You will need to develop your own system to research and organize information
before each inspection. The steps you take should ensure that you are able to
efficiently find and organize background information so that you have a sense of
what to ask facility representatives and what to look for at the facility.
The inspection should follow up issues from the last inspection and leave as few
"gaps" in information for future inspections. Appropriate sampling equipment
should be prepared as well. See Chapter 6 of the Inspection Manual for ideas on
how to prepare.
5. What would you do if someone threatened you. or harassed you during an inspection?
When someone threatens you. you should leave the premises immediately. If you
must return to complete an inspection, the appropriate law enforcement official.
such as a sheriff, should accompany you. The incident is treated as if it were a
denial of entry.
6. What are some of the most important factors to consider for write a case report that
will stand up in court?
Important documentation includes the following:
-a detailed, objective log report
-accurate maps and drawings
-comprehensive field notes
-photographs with proper documentation
In addition, your report should be thorough, accurate, and written for lay people.
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APPENDIX C. QUESTIONS & ANSWERS TO TRAINING MANUAL
Discussion Question: Issues to Consider
7. What do you seen as your roles as a hazardous waste inspector? How do they "play
out" in your job?
There are many roles you play as an inspector. A few you might consider include:
-Educator: Informing facility representatives about RCRA regulations and safe
hazardous waste management, as well as alternative handling, storage, and usage
(such as substitute materials). What influence might you have?
-Regulator: Observing facility practices, assessing whether regulations are
being met, and issuing recommendations, warnings, and fines. Consider the
importance of following through with necessary actions.
-Court witness: Gathering evidence for litigation and giving testimony.
What is the importance of careful documentation? Systematic objectivity? How
can your testimony affect trial outcomes?
8. What kind of tone do you frv to set at an inspection? Why? How might you do this?
In many cases, a cooperative, interactive tone will work best. You may try to
foster mutual understanding and respect. Each case is, however, different and
inspectors should use their best judgment.
The way you choose to set the tone of each inspection will, in turn, vary according
to each situation. What is important is realizing that your actions, as well as those
of facility representatives, will set the tone of the inspection. Adopting a helpful
tone, offering information about new technology, handling methods and resources
may be useful. Listen for difficulties facilities encounter and be sure to offer
suggestions and discuss problems tactfully.
9. What is the philosophy and intent behind RCRA ? Given this philosophy, what are
some of your job priorities?
RCRA's main intent is to control hazardous waste disposal ("cradle to grave"
monitoring). RCRA also has provisions to promote recycling, alternative energy
sources, and proper solid waste disposal.
Considering this purpose, you may find that your ideal job priorities might
emphasize accounting for generated waste, ensuring proper storage, tracking waste
disposal, and promoting measures necessitating less hazardous waste disposal. In
addition, an important part of your role includes checking for compliance and
violations of RCRA.
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APPENDIX D. EXERCISES
EXERCISES -- ICEBREAKERS
PERSONAL INTRODUCTIONS*
Each person gives name, where he/she is from and ONE other fact about him/herself.
Facilitator should suggest what this third fact might be something positive, like a recent
accomplishment; or something relevant to the workshop. Avoid using a question that can
be answered by a long list of accomplishments.
PAIR INTRODUCTIONS*
II Have participants pair up with people they do not know or know less well than others in
the group.
2. Person A listens to or "interviews" person B, then they switch roies. for five minutes
each.
3. Using the information gained in that conversations, A introduces B to the larger group
and vice versa.
Again, the facilitator may want to make specific suggestions for topics to include in the
introductions.
'Adapted from Resource Manual for a Living Revolution, pp. 72-73.
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APPENDIX D. EXERCISES
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APPENDIX D. EXERCISES
SPEAKERS BUREAU
For assistance in locating a Speaker for your
workshop, we suggest you contact your
agency or call the ASTSWMO Washington
B.C. office (202) 624-7886.
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APPENDIX D. EXERCISES
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APPENDIX E. RESOURCES and REFERENCES USED
GENERAL
Janner, G. (1986) Janner on Meetings. Brookfield, VT: Gower Publishing.
Kaufman, M. (1981) EPA and the Public: a handbook on public participation concepts and
skills. Boston: Barry Lawson Associates.
Materka, P.R. (1986) Workshops and Seminars: Planning, Producing, and Profiting.
Englewood Cliffs, NJ: Prentice-Hall
Murray, S.L. (1983) How to Organize and Manage a Seminar: What to do and when to do it.
Englewood Cliffs, NJ: Prentice-Hall.
WORKING WITH GROUPS
The Center for Conflict Resolution (1977) A Manual for Group Facilitators. (CCR. 731 Scate
St., Madison, WI 53706, $5.00).
Coover. V.: Deacon. E.; Esser C.: and Moore. C. (1985) Resource Manual for a Living
Revolution. Philadelphia; New Society Publishers.
PRESENTATIONS/USING AUDIO .VISUALS
BloomwelL A.E. "47 Tips for Flip-chart Users," Training. June 1983. 20(6):36-3S.
Sprague, J. and Stuart, D. (1984) The Speaker's Handbook, NY:Harcourt. Brace &:
Jovanovich.
Kirkpatrick, J.D. "A Three-Step Model for More Effective Presentations." The Personnel
and Guidance Journal, Nov. 1983: 178-179.
McKeachie, W.J. (1969) Teaching Tips: A guidebook for the beginning college teacher.
Lexington, MA: DC Heath &. Co.
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