United States
Environmental Protection
Agency
Office of Enforcement &
Compliance Assurance
Washington, DC 20460
December 1996
EPA 300-B-96-012A
3rd Edition
Em
GENERIC PROTOCOL FOR
CONDUCTING ENVIRONMENTAL
AUDITS OF FEDERAL FACILITIES
Volume I: Phase 1; Auditing for Compliance
^tDS%
Prepared
by the Members
of the Interagency
Environmental Audit
Protocol Workgroup
for the Federal
Community
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Generic Protocol
for Conducting
Environmental Audits
of Federal Facilities
Volume I: Phase 1; Auditing for Compliance
December 1996
c/EPA
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NOTICE
This document comprises the second revision to an earlier document, Generic Protocol for
Environmental Audits at Federal Facilities, prepared in 1989 by EPA's Office of Federal Activities,
and later in 1995, by EPA's Federal Facilities Enforcement Office. This 1996 revision includes a
discussion and reference to EPA's new 1995 audit policy and also reorganizes the protocol into a
two volume set. Both volumes contain the instructions for use of all three auditing sections or
"phases." Volume I includes Phase 1 of the protocol, which provides a focus on compliance with
federal environmental requirements. Volume II contains Phases 2 and 3 of the protocol, which
details procedures for conducting environmental management system audits of both facility specific
programs and the overall programs managed at the agency's headquarters.
This document has been developed to assist in conducting environmental audits and
environmental management assessments. The use of this document should be restricted to
environmental audits only. Areas such as safety, transportation, occupational health, and fire (to
name a few) are mentioned solely for clarification purposes. It is a comprehensive look at
environmental regulations only and is not intended to ensure compliance with all regulations.
This document is not designed to provide environmental auditors with detailed information
on the administrative and management processes of auditing during the planning, on-site
investigations, and post-audit periods. Rather, it is designed to primarily focus auditors on specific
technical issues to determine 1) compliance with environmental requirements (both regulatory and
otherwise), and 2) adherence to good management practices to assure sound environmental
operations. To the extent practicable, management systems should be evaluated to prevent
recurrence of individual environmental issues.
A companion document, "Environmental Audit Program Design Guidelines for Federal
Agencies," (EPA Document No. 300-B-96-011) has been revised and issued by EPA to focus on the
development of strong environmental auditing programs and should be consulted in addition to using
this document.
The U.S. Environmental Protection Agency does not make any guarantee or assume any
liability with respect to the use of any information or recommendations contained in this document.
Federal facilities requiring additional auditing information or advice should consult a qualified
professional.
In addition, the information and recommendations set forth herein are intended as guidance
to Government employees. It does not constitute rulemaking by the EPA, and may not be relied on
to create a substantive or procedural right or benefit enforceable, at law or in equity, by any person
The Government may take action at variance with this guidance and its internal procedures.
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ACKNOWLEDGMENT
This manual was prepared and coordinated by the Federal Facilities Enforcement Office
(FFEO), U.S. Environmental Protection Agency (EPA) for federal facilities to use as a guidance
document to assist in the conduct of environmental auditing activities. Mr. Richard J. Satterfield of
EPA served as director for this task. Arthur D. Little, Inc. assisted in the preparation of the manual.
EPA gratefully acknowledges the contributions of the U.S. Army Construction Engineering
Research Laboratory (USACERL) which graciously provided the DoD "Environmental Audit
("Purple") Manual" as the model for Part 1 of this Manual and the Department of Energy (DOE)
which provided the "Protocols for Conducting Environmental Management Assessments of DOE
Organizations" (DOE/EH-0326), as the model for Parts 2 and 3 of this document.
To further assist both EPA and DOE in this effort, the Interagency Environmental Audit
Protocol Workgroup was formed. The Workgroup, consisting of environmental auditing
professionals and environmental compliance officers from other federal agencies provided advice
and consultation to EPA and DOE for this effort in order to help ensure maximum quality and
generic character to this document. It is a pleasure to acknowledge the assistance of the following
Workgroup members and their respective agency/department who kindly provided consultation
during this effort as well as technical review: Frank Russo and Richard Green, DOE; Dr. Diane
Mann and Donna Schell, USACERL; Carolyn Macola, Will Garvey, Sally Dalzell, Melanie B.
Garvey, James Bridges, Bob Carr, EPA; Gail Weston, US Navy; Bob Shakeshaft, US Army; Nancy
Carper and Carol Ditmer, US Air Force; Ken Morin, Bureau of Land Management, Dol; Tami
McVey, Maryalice Locke, Katherine Johnson, DoT; George Sunstrom, USDA; Bernie Denno, US
Postal Service; Mike Green, NASA; Frank Covington and Jim Hatheway, National Enforcement
Investigation Center; Jeffrey D. Williams and Kathy Hutson, NSA. The Workgroup was chaired by
Richard Satterfield of FFEO, EPA.
The National Enforcement Investigation Center (NEIC) conducted an internal review of this
document and suggested changes and enhancements to improve its quality. These changes have
been incorporated into this final version.
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Overall Introduction
A. Background
On October 13,1978, President Carter signed Executive Order 12088 which ensures federal
government compliance with applicable pollution control standards. The order conveys the
responsibility for compliance to the head of each executive agency. The Executive Order requires
federal agencies to comply with all substantive and procedural requirements of federal, state, and
local environmental regulations. Agencies are encouraged to consult EPA, state, and local
regulatory agencies in the prevention, control and abatement of environmental pollution. EPA in
turn, is required by the Executive Order to provide technical advice and assistance to ensure
compliance by federal agencies. In response to this mandate, EPA has committed to provide
technical assistance to federal agencies to facilitate the development of environmental audit
programs. This protocol manual is one form of that assistance.
Environmental auditing and EPA's policy providing encouragement and assistance on this
matter are linked not only to Executive Order 12088, but also to public policies regarding its position
on environmental audits. On July 9,1986, EPA publicly addressed environmental auditing for the
first time when the agency published it's environmental audit policy in the Federal Register (51 EE
25004). At that time, EPA encouraged regulated entities to initiate environmental audit programs
that achieve and maintain compliance with environmental regulations. In the 1986 policy statement,
EPA also encouraged federal agencies to develop audit programs and stated that EPA would provide
assistance to help federal agencies establish such programs.
Over the years, EPA has initiated several efforts to encourage and assist federal agencies in
designing and initiating environmental audit programs. These efforts have included:
• Conducting a survey of Audit Activities at Federal Agencies (1987);
• Sponsoring two nationwide environmental auditing conferences for federal agencies (1988
and 1995);
• Issuing guidelines to assist federal agencies in establishing audit programs ("Environmental
Audit Design Guidelines for Federal Agencies") in 1989 and 1996 and;
• Issuing environmental audit protocols as guidance as guidance for federal agencies
("Generic Protocolfor Conducting Environmental Audits of Federal Facilities") in 1988 and
1995.
EPA, through the Federal Facilities Enforcement Office (FFEO), will continue to provide
sustained technical assistance to federal agencies to encourage the practice of environmental auditing.
Overall Introduction
1
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B. EPA's 1986 and 1995 Environmental
Audit Policies
The U.S. Environmental Protection
Agency (EPA) recognizes that environmental
auditing and sound environmental
management, generally can provide potentially
powerful tools toward protection of public
health and the environment. In encouraging the
use of these tools, EPA announced the
"Environmental Auditing Policy Statement" on
July 9,1986 (51 ER 25004) (1986 audit policy)
and the "Incentives for Self-Policing:
Discovery, Disclosure, Correction and
Prevention of Violations" on December 22,
1995 (60 EE 66706) (1995 or final audit or self
-policing policy).
The 1986 audit policy states that "it is
EPA policy to encourage the use of
environmental auditing by regulated industries
to help achieve and maintain compliance with
environmental laws and regulation, as well as
to help identify and correct unregulated
environmental hazards." The policy also
specifically endorses environmental auditing at
federal facilities.
The 1995 audit policy offers major
incentives for entities (including federal
facilities) to discover, disclose and correct
environmental violations. Under the 1995
policy, EPA will not seek gravity-based
penalties or recommend that criminal charges
be brought for violations that are discovered
through an "environmental audit" (as defined in
the 1986 audit policy) or a management system
reflecting "due diligence" and that are promptly
disclosed and corrected, provided that other
important safeguards are met. These
safeguards protect health and the environment
by precluding policy relief for violations that
cause serious environmental harm or may have
presented an imminent and substantial
endangerment, for example. The effective date
Audit Policy Provides Significant Incentives
to Discover, Disclose and Correct
Environmental Violations
Under the final Audit/Self Policing Policy,
EPA will not seek gravity-based penalties and
will not recommend criminal prosecution for
companies that meet the requirements of the
Policy. Gravity-based penalties represent the
"seriousness" or "punitive" portion of
penalties over and above the portion
representing the economic gain from non-
compliance The policy requires companies:
• to promptly disclose and correct
violations,
• to prevent recurrence of the violation,
and
• to remedy any environmental harm
The Policy excludes:
• repeated violations
• violations that result in serious actual
harm, and
• violations that may present an
imminent and substantial endangerment
Corporations remain criminally liable for
violations resulting from conscious disregard of
their legal duties, and individuals remain liable
for criminal wrongdoing. EPA retains
discretion to recover the economic benefit
gained as a result of noncompliance, so that
companies will not be able to obtain an
economic advantage over their competitors by
delaying investment in compliance.
Companies that do not discover violations
through an audit or CMS, yet meet all of the
other Policy conditions, will receive 75%
mitigation of gravity-based penalties.
The Final Audit/Self-Pol icing Policy was
published in the Federal Register on December
22, 1996, (60 FR 66706). It took effect on
January 22, 1996. For further information,
contact the Audit Policy Docket or call 202-
564-4187.
Overall Introduction
2
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of the policy is January 22, 1996. The 1986 and 1995 EPA audit policies are discussed in greater
detail in EPA's "Environmental Audit Program Design Guidelines for Federal Agencies," which is
a companion document to this protocol manual. Copies of both the 1986 and 1995 policy documents
are contained in the Design Guidelines document.
In the 1986 policy, EPA defines environmental auditing as "a systematic, documented,
periodic, and objective review of facility operations and practices related to meeting environmental
requirements." Figure 1 depicts EPA's definition of environmental auditing. The policy identifies
several objectives for environmental audits:
• Verifying compliance with environmental requirements,
• Evaluating the effectiveness of in-place environmental management systems; and
• Assessing risks from regulated and unregulated materials and practices.
Figure 1: EPA Definition of Environmental Auditing
A REVIEW
Periodic
Systematic
Documented
Objective
Regulated
Entities
Facility
Operations
and
Practices
To Assure
Meeting
Environmental
Requirements
The EPA policy encouraged all federal agencies subject to environmental laws and
regulations to develop environmental auditing programs to help ensure the adequacy of internal
systems to achieve, maintain, and monitor compliance with environmental requirements. The policy
also notes that federal agency auditing programs should be designed to identify environmental
problems and develop schedules for remedial actions for audit findings.
Overall Introduction
3
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C. Purpose
The purpose of this protocol manual is to provide the federal environmental auditing
community with a set of protocols that can be used as a basis to implement, upgrade, or benchmark
their environmental auditing activities. It can be regarded as a management tool for measuring
environmental performance and provide management the opportunity of identifying not only the
degree of its problems, but the nature of its problems and therefore may serve to facilitate the
rethinking process for optimization of organizational environmental performance. The protocols,
contained in this manual, can be used by auditors to assist them in the preparation for conducting
environmental compliance audits and assessments of the environmental management systems
developed to support compliance activities. In addition, this document can be used to assist federal
agencies and facilities in outlining their approach to environmental management.
Many organizations have benefitted from the utilization of protocols in environmental audits
and structural programs. For example, these programs have helped organizations:
• Pinpoint areas for immediate correction;
• Determine how successfully a facility is managing its environmental responsibilities;
• Compare between facilities;
• Make a "snapshot" of the operation and effectiveness of environmental management systems;
and
• Decide whether or not environmental performance is improving year to year.
Environmental auditing has enabled many federal agencies to assess their environmental
performance, correct deficiencies, and reduce their overall risk ~ especially the risk of
noncompliance with key government regulations.
Despite enormous progress developing and implementing audit programs, many federal
agency environmental management personnel are not yet comfortable with their answers to questions
such as these:
• Do reaudits find the same, or similar, problems?
• Do similar problems show up again at the same facility? Do different facilities share
common problems?
• Are a facility's corrective actions fixing only the symptoms, or are they also getting at the
root causes behind recurring problems?
• Is senior management satisfied with its overall environmental record?
Recently when organizations began assessing their own audit programs and evaluating
overall environmental performance, they began to sense some discomfort regarding these questions.
A disconnection between the environmental audit program and continuing improvements in
environmental management systems was apparent. Organizations that find their audit programs
most valuable understand the key relationship between environmental audits and a successful
corrective action process in improving environmental performance (Figure 2). In other words, an
Overall Introduction
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environmental audit program is only as good as the organizations^ success in identifying the root
cause of each audit finding and then taking the "right" corrective action.
Figure 2: The Value of the Corrective Action Process
Environmental
Management Systems
Audit Program
Corrective Action
Process
Measures Effectiveness of
Systems
Improves Effectiveness
:^»_Of Systems
D. How to Use This Document
To help identify root causes to audit findings and select the most appropriate corrective
actions, this set of protocols or manual is divided into three sections: (1) "Auditing for Compliance,"
(2) "Auditing for Effective Management of Specific Environmental Programs," and (3) "Conducting
Environmental Management Assessments of Federal Agencies." As a convenience to the auditors
using this manual, the protocols are organized into two volumes. Volume I (EPA Document No.
300-B-96-012A) contains Phase 1 which provides for a review of facility conditions in regard to
specific media areas (e.g., air, water, and solid and hazardous waste) with a focus on compliance
with federal environmental requirements. Volume II (EPA Document No. 300-B-96-012B) contains
Phases 2 and 3. Phase 2 of the protocol examines cross-cutting issues and approaches such as
pollution prevention and seven other organizational disciplines that help foster success in the
technical management areas outlined in Phase 1. Phase 3 examines the management of all
environmental programs at the facility and the parent agency to help establish compliance as the
"starting point" rather than the goal of environmental performance.
Overall Introduction
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E. Scope
This protocol manual is set up to support a wide range of environmental auditing programs
from recently developed to mature audit programs. The sets of protocols have been created to
support the stage of environmental auditing that best represents the status of the federal agency
and/or facility under review. The protocols are designed to meet all the environmental review needs
of the various facilities; therefore, some protocol areas may not be applicable in all facility
circumstances and should be disregarded in such instances.
Phase 1 of the manual may be used to conduct a baseline compliance audit and/or as a
starting point for agencies that have just begun new programs. Phases 2 and 3 of this manual are for
federal agencies that have already developed a basic compliance program and desire to assess the
management effectiveness of individual environmental programs or entire facilities or agencies.
Phase 1, Auditing for Compliance, addresses the evaluation of compliance with environmental laws
and regulations and their corresponding environmental practices. Phase 1 consists of 16 sections:
Section 1
Air Pollution Control
Section 2
Water Pollution Control
Section 3
Nonhazardous Waste Management
Section 4
Hazardous Waste Management
Section 5
CERCLA/SARA
Section 6
Spill Control and Response
Section 7
Management of Environmental Impacts (i.e., NEPA and NEPA components such as
FONSI, EAs, EISs, etc.)
Section 8
Hazardous Materials Management
Section 9
Emergency Planning and Community Right to Know
Section 10
Cultural and Historic Resources Management
Section 11
Storage Tank Management
Section 12
Drinking Water Management
Section 13
PCB Management
Section 14
Pesticides Management
Section 15
Groundwater Protection
Section 16
Environmental Radiation
As Phase 1 of the protocol covers Management Practices (MPs), it must be understood that
some management practices are non-environmental regulatory requirements/non-federal regulatory
requirements or deal with programmatic aspects of environmental operations. Programmatic
practices in Phase 2 address a comprehensive approach to the assessment of specific environmental
programs that include MPs. Phase 1 does not take a comprehensive approach to consideration of
MPs.
Phase 2, "Auditing for Effective Management of Specific Environmental Programs" (Section
17-32 in Volume II), targets the same 16 environmental areas but with the emphasis on evaluating
the strengths and weaknesses of the environmental management systems established for assuring
long-term compliance of these sixteen environmental program areas.
Overall Introduction
6
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Phase 2 is designed for environmental auditors in specific technical disciplines to concentrate
solely upon the management systems supporting a specific environmental program such as the
hazardous waste management or the air pollution control program. Each Phase 2 section
concentrates on a "programmatic evaluation" in which the auditor assesses the effectiveness of the
management systems supporting the individual environmental program. As such, a single auditor
could design an evaluation that takes either a representative or a comprehensive look at the
management systems.
Each Phase 2 section can also be used in conjunction with the appropriate Phase 1 section
to conduct a joint compliance and programmatic evaluation. Where appropriate, elements within
each Phase 2 section contain specific examples to help guide the auditor in an evaluation of the
specific environmental program.
Each of the sections in Phase 2 includes seven management systems plus an assessment of
the pollution prevention initiatives for the applicable environmental discipline. The eight elements
for Phase 2 include:
1. Organizational Structure
2. Environmental Commitment
3. Formality of Environmental Programs
4. Internal and External Communication Program
5. Staff, Resources, Training, and Development
6. Program Evaluation, Reporting, and Corrective Action
7. Environmental Planning and Risk Management
8. Pollution Prevention
For the purposes of this manual, these eight elements constitute one approach that can be used to
establish an effective management system. However, variations may also serve to satisfy the needs
of the individual federal organization.
Phase 3 is different from Phase 2 in that Phase 3 is designed for a team of auditors to take
a comprehensive look at individual components of environmental management systems that apply
to all environmental programs at a facility or throughout the entire federal agency. The elements or
disciplines within Phase 3 are essentially the same as that of Phase 2, except that Phase 3 contains
an element called Environmental Protection Program (EPP) and does not contain the Phase 2
element pollution prevention. In Phase 3 pollution prevention is rolled into the EPP discipline,
whereas in Phase 2 it is a stand alone element. Within the EPP element, an auditor or team of
auditors with an understanding of both the regulatory requirements and management systems
performs a detailed evaluation of a representative number of environmental programs as opposed
to the other auditors who take a detailed look at the management system component across the
facility. The EPP discipline is used to evaluate the specific implementation of a representative
number of environmental programs; their corresponding management system provides specific
evidence supporting the degree of effectiveness of the larger environmental management systems.
The EPP evaluation includes interviews and document reviews in addition to a limited amount of
inspection.
Overall Introduction
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Phase 3, "Conducting Environmental Management Assessments of Federal Agencies"
evaluates the strengths and weaknesses of the management systems that have been developed to
provide overall assurance that facility/agency-wide environmental management issues have been
properly addressed with the right mix of resources, organization, policies and procedures, etc. Phase
3 reviews are designed to assure high-quality sustained management of environmental operations
throughout entire facilities/agencies rather than focusing on any specific environmental programs
(e.g., air quality, waste management, etc.).
Many federal facilities have tenant organizations, usually other federal agencies, but also
state and local agencies and private parties. Although these tenant organizations may be responsible
for environmental compliance of their activity, the facility owner may be ultimately held accountable
by regulators should compliance problems persist or should future liabilities be discovered. The
protocols in this manual can be used to address environmental compliance and management issues
associated with tenant organizations. The agreements between the facility owner and the tenant
organizations need to clearly establish environmental responsibilities of both the facility owner and
tenant organization and the mechanisms that the facility owner will utilize to monitor compliance,
including application of these protocols to the tenant organizations.
F. Approach
This protocol manual can be regarded as a tool box for conducting environmental auditing
activities of federal organizations. The reviews may look at a single environmental program [e.g.,
RCRA compliance at a facility (Phase 1)]; or take a much broader look at the design and
implementation of environmental management programs across the agency (Phase 3). Additionally,
based on the specific audit objectives and scope, the audit team can pick and choose its tools from
Phases 1, 2, or 3 or use a combination of the tools to meet its objective.
Stages of Environmental Auditing
Environmental audit programs can be thought of as having three phases of evolution as
depicted in Figure 3, "Phases of Environmental Auditing," which illustrates how the three parts of
auditing have been addressed in this protocol manual.
As agency environmental audit programs and overall environmental management systems
mature, the focus of the audit program tends to shift. When an organization first establishes its
environmental auditing program, it begins by auditing for compliance and subsequently identifying
problems to be corrected (Figure 3). As the audit program evolves, the emphasis moves from
identifying problems to determining compliance status, and then on to assessing the effectiveness
of the environmental management control systems designed to prevent these problems. Thus, as an
agency's environmental performance improves, the emphasis should shift from identifying problems
to confirming the absence of problems ~ a much more difficult task. The most significant benefits
from a well-established audit program are successful environmental performance and a feeling of
increased comfort and security that environmental risks are being managed.
A similar evolution should occur in how federal agencies act on the results of their audits.
In the early stages of audit programs, immediate attention is given to fixing the problems identified.
Overall Introduction
8
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Figure 3: Phases of Environmental Auditing
Increasing
Sophistication
and Effectiveness
of the
Audit Program
Phase 3 Auditing for Management Effectiveness
off all Environmental Programs at a Facility/Site
Phase 2 Auditing Management Effectiveness
of Specific Environmental Programs
L^.
Phase 1 Auditing for Compliance
Time
In some cases, agencies develop sophisticated tracking tools to ensure that such corrective actions
do, in fact, occur. A more comprehensive approach, not yet taken by many agencies, is to analyze
the problems identified during the audit for cause and effect and develop and implement appropriate
corrective actions for those underlying causes. Those agencies that simply stick to fixing the
problem may not achieve the performance desired and may even begin to consider their audit
programs to be ineffective.
When performance improvements are not quickly forthcoming after implementation of an
audit program, some agency managers blame the program itself for being ineffective. It may be,
however, that blame should be directed at the corrective action process. Unfortunately, many
agencies have little experience in analyzing the corrective action process or the effectiveness of the
corrective actions implemented, despite their relative sophistication in gauging the audit program's
ability to find the problems.
To successfully correct problems, keep the problems corrected, and head off finding the same
problems in other facilities, the corrective action process needs to be expanded (Figure 4). In this
expanded model for corrective action, audit findings are evaluated for underlying causes, and
corrective actions involve developing management solutions to resolve root causes. Frequently,
when findings are grouped, it is possible to identify common root causes. When the focus of
corrective actions is on correcting common root causes, the effectiveness of the audit is increased
tremendously.
Overall Introduction
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Figure 4: The Expanded Corrective Action Process
Fix
Problems
Group Findings
for Common
Causes
Develop Actions
to Correct
Underlying
Causes
Examine each
Group for
Underlying
Causes
Analyze
Exceptions
for
Cause/Effect
Identify
Problems
Improve
Environmental
Management
System
Effectiveness
Audit
The expanded corrective action process can be applied at any level — facility, field division
or bureau, or overall agency. Rarely does the root cause for serious facility problems stop at the
facility gate; it usually extends upward into the division or parent agency.
There are many different ways to enhance the corrective action planning process. One
method used successfully is to group audit findings into categories built on the following phases in
a simple model for risk management:
• Identify hazards and evaluate risks;
• Develop control programs;
• Implement control programs; and
• Maintain and oversee programs.
By placing problems identified during an audit or audit program into such risk categories,
it may be possible to see patterns in the findings, which can then help direct corrective actions. The
results of such groupings can help to answer the following questions:
• Are facilities personnel aware of requirements?
• Are control programs missing important elements? If so, why?
Overall Introduction
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• What prevents full implementation of control programs, even when the program itself seems
sound?
• Do facilities have internal measurement processes to continually gauge the effectiveness of
their programs?
Grouping findings into the four categories described above can provide one of the simplest
methods for evaluating overall agency performance, making comparisons between facilities, and
measuring facility improvement. Auditing program managers are always looking for ways to use
audit results more broadly. It is not uncommon for senior management to fall into the trap of making
year-to-year and facility-to-facility comparisons by counting the number of findings in an audit.
Counting findings may not be appropriate, however, because no two findings typically carry the
same risk. On the other hand, if most findings at a facility are weighted toward Phase 1 (identify and
evaluate), it may say a lot about the facility's overall environmental risk management systems (no
programs).
Relationship Between the Audit Phases
Phase 1 of environmental auditing will determine the areas in which compliance with
environmental standards has not been achieved. These environmental standards can be either
external to an organization (40 CFR) or internal (e.g., DoD Directives, DOE Orders, etc.). The
protocols in Phase 1 can assist an organization in making a determination as to the compliance status
of the entity under review, whether it be a facility or organization within the agency. Phase 1
typically reconciles environmental regulations promulgated by the EPA and state and local
governments against facility conditions to establish the baseline of acceptable practice. Typically,
environmental auditing programs focusing on Phase 1 activities are more reactive to environmental
management and emphasize determining a facility's compliance with applicable regulations and
standards so that actions can be taken to address individual deficiencies identified (Figure 5).
Phase 2 audit programs are designed to identify problems related to the management of
environmental aspects of the organization, but do not stop there. In Phase 2, there is an added
emphasis on confirming where the environmental programs are compliant and documenting why
they are in compliance (i.e., how the management system works). By documenting why and how
the program functions well, and sharing this with other facilities, a major benefit can be realized:
this is the beginning of understanding and assessing the management systems that support the
environmental program. Compliant programs typically have management systems in-place and
functioning to ensure long-term compliance. By looking at the management systems in-place (e.g.,
organizational structure, environmental planning, policies and procedures), a judgment can be made
as to whether the program is sound and can stay compliant. To do this, the reviewer needs to
determine the who, what, when, where, how, and why of the program under review.
Take as an example the training of personnel to address the standards found in the hazardous
waste management regulations (RCRA). Training must be given annually and within the first six
months of taking on hazardous waste responsibilities. How would the auditor understand the
training system?
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Figure 5: Various Components of Audit Phases
PHASE 3 - AUDITING FOR MANAGEMENT EFFECTIVENESS OF ALL ENVIRONMENTAL PROGRAMS
AT A FACILITY/SITE
ENVIRONMENTAL
ORGANIZATIONAL
ENVIRONMENTAL
FORMALITY OF
COMMUNICATION
STAFF,
PROGRAM
ENVIRONMENTAL
COMMITMENT
STRUCTURE
PROTECTION
ENVIRONMENTAL
RESOURCES,
EVALUATION &
PLANNING & RISK
PROGRAMS
PROGRAMS
TRAINING
REPORTING
MANAGEMENT
SUSTAINED EXCELLENCE OF ENVIRONMENTAL PROGRAMS (ASSURANCE RATHER THAN COMPLIANCE)
TYPICALLY A MANAGEMENT PRACTICE RATHER THAN A REQUIREMENT (E G , STAFFING FOR ALL ENVIRONMENTAL PROGRAMS AT A FACILITY. OR FORMAL DOCUMENTATION TO
SUPPORT ENVIRONMENTAL PROGRAMS)
PROACTIVE RATHER THAN REACTIVE
AUDITING PROGRAM AND FACILITY ENVIRONMENTAL MANAGEMENT MORE SOPHISTICATED
LOOKS AT ROOT CAUSES
PHASE 2 - AUDITING FOR EFFECTIVENESS OF SPECIFIC ENVIRONMENTAL PROGRAMS
MANAGEMENT OF
AIR PROGRAM
MANAGEMENT OF
WATER PROGRAM
MANAGEMENT OF
NON-HAZARDOUS
WASTE PROGRAM
MANAGEMENT OF
HAZARDOUS
WASTE PROGRAM
MANAGEMENT OF
SPILL CONTROL
AND RESPONSE
PROGRAM
MANAGEMENT OF
ENVIRONMENTAL
IMPACT PROGRAM
MANAGEMENT OF
HAZARDOUS
MATERIALS
PROGRAM
MANAGEMENT OF
EMERGENCY
PLANNING &
COMMUNITY RIGHT
TO KNOW PROGRAM
(CERCLA/SARA)
MANAGEMENT PRACTICE & TYPICALLY NOT REQUIRED (E G, STAFFING FOR WASTE MANAGEMENT PROGRAM)
LOOKS AT CAUSAL FACTORS
LOOKS AT COMPLIANCE TRENDS
PHASE 1 - AUDITING FOR COMPLIANCE
AIR POLLUTION
WATER
NON-
HAZARDOUS
SPILL CONTROL
ENVIRONMENTAL
HAZARDOUS
STORAGE TANKS
EMERGENCY
CONTROL
POLLUTION
HAZARDOUS
WASTE (RCRA
AND RESPONSE
IMPACTS
MATERIALS
PLANNING &
CONTROL
WASTE
SUBTITLE D)
COMMUNITY RIGHT
[RCRA SUBTITLE
TOKNOW
D)
(CERCLA/SARA)
MORE REACTIVE PROGRAM RATHER THAN PROACTTVE
TYPICALLY REQUIRED (REGULATORY OR INTRA AGENCY), MAY BE A MANAGEMENT PRACTICE (E G, RCRA TRAINING)
PROGRAM SPECIFIC FOCUS RATHER SYSTEM WIDE FOCUS MORE LIKELY
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In the case of this example, appropriate questions may include:
• Who is the trainer, and is he/she qualified?
• What type of training is given, and what is the curriculum?
• When is training provided to personnel?
• Where is training given?
• How often is training offered?
• How is training administered, and how does management/the trainer know that the trainees
understand?
• Why are certain people selected to receive training?
If the training program is designed to ensure that compliance is achieved, compliance should
be attained if the program is properly implemented. If the design of the program is flawed, the
program will break down and compliance deficiencies may result. The Phase 2 protocols have been
developed to assist the auditor in asking the right questions to be able to understand the structure of
the management systems for specific environmental programs and to understand how they are
designed to achieve compliance.
Phase 3 auditing concentrates on evaluating the macro level management systems that have
been put into place to address all environmental programs at the facility or throughout the agency.
Phase 3 looks at programs that have been designed to achieve compliance and those that go beyond
compliance. The evaluation centers on the total environmental program design that has been put into
place to effectively manage sustainable high-quality environmental operations Further, auditors
evaluate overall management of the entire spectrum of environmental operations as well as
benchmarking ideas, initiatives, and actions reaching toward good stewardship of the environment.
The purpose of Phase 3 assessments is to review environmental management systems for all
programs; there should be some investigation into specific program areas (e.g., air quality, waste
management, etc.) to ensure that the program is being implemented as it was designed. This is
known as taking a "vertical slice." The goal is to determine how the management system is
implemented on a programmatic level. By conducting the "vertical slice", the auditor can verify that
the program is implemented as it was designed. In fact, there are two levels of review: (1) an
assessment of weaknesses of the management system, and (2) whether the program has been
implemented. It is critical that auditors be able to determine whether the management system design
can attain compliance if implemented and also to follow up with the verification of implementation
to ensure that systems are functioning. Additional detail is provided in the introductions to each part
of this manual.
G. Audit Procedures
Those agencies attempting to identify the areas in which compliance deficiencies are present
should focus on Phase 1 auditing and use the Phase 1 protocols.
To conduct effective compliance-oriented audits, the audit team needs to possess sound
working knowledge of the operations/processes to be reviewed, the regulations used as audit
standards, and of good auditing practices. The Phase 1 audit protocols should be reviewed by the
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auditor and used as a planning tool to assist the auditor in understanding the requirements for
conducting a comprehensive audit. The federal, state and local environmental standards should be
reviewed, and the Phase 1 protocols should be annotated, as required, to include other standards not
present in the protocol.
The auditor should determine which regulatory agency has authority for executing an
environmental program so that the proper set of regulations is consulted. For example, many states
have been granted authority for carrying out the Hazardous Waste Management Program under the
Resource Conservation and Recovery Act (RCRA). State programs that have authority for
implementing federally mandated programs may have more stringent standards. This is especially
true for air pollution control standards in major metropolitan areas. Use the protocol as an auditing
tool, but not as a substitute for the applicable regulations.
Phase 2 of the protocol manual is designed to facilitate the assessment of management
systems established for specific environmental programs. The emphasis here will be on
understanding the regulatory standard of care and how it can best be achieved. Many environmental
standards are performance-based standards that establish a minimum level of care that must be
achieved. The agency has the obligation to establish programs for addressing how the standards will
be attained. For example, understanding the hazardous waste standards will give great insights into
what is required to achieve and maintain compliance. Therefore, assembling a team to assess the
management systems of a specific environmental program will require regulatory knowledge,
knowledge of the facility operation under review, and an understanding of the principles of
management and organization. The team's purpose will be to gain an understanding of the design
of the regulatory program and to have the skills to assess the strengths and weaknesses of the
program to determine whether it can attain and maintain compliance.
Phase 3 focuses on the most sophisticated of environmental programs. These programs set
in place the fundamental building blocks of the management systems for each environmental
program as well as link these programs to an umbrella management system. These assessments
center on management systems and not on the regulatory standards. The team makeup is quite
different for these reviews, with the emphasis on management and organizational skills rather than
on intimate knowledge of the regulatory standards. The review encompasses understanding, (1)
what makes up the management system, (2) whether the umbrella management system can achieve
compliance with all environmental programs, and (3) how the agency knows that it works.
Verification of the system implementation is less than in Phase 2. The assessor completing the EPP
discipline will verify that the programs address standards and meet requirements. This auditor is key
to the overall success of the review because this is where theory of design meets actual
implementation in the field. There are far fewer standards dictating what is to be done and even less
on how to carry out Phase 3 programs, so the team must have management experience as well as
strong interpersonal skills.
It is critical that the auditors conducting each type of review (Phase 1, 2, or 3) act as a team.
There is far greater depth of knowledge as well as perspective in acting as a team. It is also
suggested that auditors take detailed notes while conducting a review. It is simply impossible to
remember who said what, what was observed, and which records were reviewed over the course of
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an audit. Finally, audit protocols and notes are extremely useful resources in planning future audits.
They can be used to highlight bottlenecks and breakdowns in the audit process that may be avoided
by future audit teams and may be a source of reference to previous environmental management
performance.
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Phase 1
Auditing for Compliance
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Phase 1
Auditing for Compliance
Table of Contents
Auditing for Compliance
Section 1 Air Pollution Control 1-1
Section 2 Water Pollution Control 2-1
Section 3 Nonhazardous Waste Management 3-1
Section 4 Hazardous Waste Management 4-1
Section 5 CERCLA/SARA 5-1
Section 6 Spill Control and Response 6-1
Section 7 Management of Environmental Impacts (i.e., NEPA and NEPA
components such as FONSI, EAs, EISs, etc.) 7-1
Section 8 Hazardous Materials Management 8-1
Section 9 Emergency Planning and Community Right to Know 9-1
Section 10 Cultural and Historic Resources Management 10-1
Section 11 Storage Tank Management 11-1
Section 12 Drinking Water Management 12-1
Section 13 PCB Management 13-1
Section 14 Pesticides Management 14-1
Section 15 Groundwater Protection 15-1
Section 16 Environmental Radiation 16-1
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Phase 1
Section 1
Air Pollution Control
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Phase I
Section I
Table of Contents
Air Pollution Control
A. Applicability 1-1
B. Federal Legislation 1-1
C. State/Local Regulations 1-5
D. Key Compliance Requirements 1-6
E. Key Compliance Definitions 1-12
F. Records to Review 1-27
G. Physical Features to Inspect 1-28
H. Guidance for Checklist Users 1-30
Appendices
1-1. Reid Vapor Pressure for Installation Geographic Area Al-1
1 -2. Emissions Limitations for Incinerators
and Steam Generators A1-3
1-3. Formulas for Calculating Emissions Limitations Al-4
1-4. Particulate Emission Standards A1-6
1-5. Emissions Standards For NOx Al-7
1 -6. Formula for Calculation S02 Emissions Limitations A1 -8
1-7. NOx Emissions from Stationary Gas Turbines A1-9
1-8. Municipal Waste Combustor Operating Standards for CO Al-10
1-9. Lead Concentration in Sewage Sludge Fed to an Incinerator A1 -11
1-10. Total Hydrocarbon Operational Standards Al-12
1-11. Frequency of Monitoring for Incineration A1 -13
1-12. Compliance and Exemptions to CFR 63.320 through
63.325 Concerning Perchloroethylene Dry Cleaners Al-14
1-13. Controlled Substances and Ozone Depletion Weights A1 -15
1-14. Acceptable Substitutes Al-18
1-15 Unacceptable CFC and Halon Substitutes A1-27
1-16 Required Levels of Evacuation for Appliances Al-33
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A. Applicability
This section includes regulations, responsibilities, and compliance requirements associated
with air pollution emissions from equipment and vehicles. The major types and sources of air
emissions include:
• Particulates, S02, NOx, and CO from fuel burning at steam and hot water generation plants
and boilers;
• Particulates and toxic air emissions from the operation of hazardous waste, general waste,
classified material, and medical, pathological, and/or infectious waste incinerators;
• Particulates, CO, metals, and toxic air pollutant emissions from open burning and open
detonation operations;
• The emission of Volatile Organic Compound (VOC) vapors from the operation of
degreasers and other processes (paint stripping and metal finishing) that use solvents;
• The emission of CO from vehicles and equipment operated on the facility;
• Fugitive particulate emissions from training activities and construction/demolition
operations; and
• Asbestos emissions from building/equipment demolition/renovation operations.
Most facilities have air emissions sources in one or more of these categories. Therefore this
section is applicable to some extent at all facilities.
Assessors are required to review the agency, Federal, state, and local regulations to perform
a comprehensive assessment.
B. Federal Legislation
1. The Clean Air Act (CAA) of 1977
The purpose of the CAA (42 USCA 7401 et seq.) is to protect and enhance the quality of the
nation's air. To achieve this objective, five regulatory programs and objectives were established
by EPA:
• National Ambient Air Quality Standards (NAAQS);
• New Source Performance Standards (NSPS);
• National Emission Standards for Hazardous Air Pollutants (NESHAP);
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• Federal permitting requirements (New Source Review (NSR) and Prevention of Significant
Deterioration (PSD)); and
• State Implementation Plan (SIP) program (state plants to attain and maintain NAAQS).
2. The Clean Air Act Amendments (CAAA) of 1990
This Act, Public Law (PL) 101-549 (42 U.S. Code (USC) 7401 -767 lq), revised and added to
the scope of the CAAA.
The purposes of the CAAA are to:
• Protect and enhance the quality of the nation's air resources so as to promote the public
health and welfare and the productivity of its population;
• Initiate and accelerate a national research and development program to achieve the
prevention and control of air pollution;
• Provide technical and financial assistance to state and local governments regarding the
development and execution of their air pollution prevention and control efforts;
• Encourage and assist the development and operation of regional air pollution prevention and
control programs (42 USC 7401(b));
• Achieve a substantial reduction in emission of hazardous air pollutants from area sources
and an equivalent reduction in the public health risks associated with such sources including
a reduction of not less than 75 percent in the incidence of cancer attributable to emissions
from such sources (42 USC 7412(k)(l));
• Reduce the adverse effects of acid deposition through reductions in annual emissions of S02
from 1980 emission levels, and of NOx emissions from 1980 emission levels, in the 48
contiguous states and the District of Columbia and to bring about such reductions by
requiring affected sources to comply with prescribed emission limitations by specified
deadlines. Limitations may be met through alternative methods of compliance provided by
an emission allocation and transfer system; and
• Encourage energy conservation, use of renewable and clean alternative technologies, and
pollution prevention as a long-range strategy, consistent with the provisions of this Act, for
reducing air pollution and other adverse impacts of energy production and use (42 USC
7651(b)).
Each department, agency, and instrument of the executive, legislative, and judicial branches
of the Federal government, and each officer, agent, or employee of such a unit, must comply
with, all Federal, state, interstate, and local requirements, administrative authority, and process
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and sanctions respecting the control and abatement of air pollution in the same manner, and to
the same extent as any nongovernment entity. This applies to (42 USC 7418(a)):
• Any requirement whether substantive or procedural (including record keeping, reporting,
and emission);
• Any requirement to pay a fee or charge imposed by any state or local agency to defray the
costs of its air pollution regulatory program;
• The exercise of any Federal, state, or local administrative authority; and
• Any process and sanction, whether enforced in Federal, state, or local courts, or in any other
manner.
Each department, agency, or instrument of the Federal government must not engage in
support in any way or provide financial assistance for, license or permit, or approve, any activity
which does not conform to an implementation plan after it has been approved or passed under
this Act. Any Federal agency may not approve, accept, or fund any transportation plan, program
or project unless such plan, program, or project has been found to conform to any applicable
implementation plan in effect (42 USC 7506(c)(l)(2)).
3. The Clean Water Act (CWA)
This Act governs the control of water pollution in the nation. The objective of the CWA is
to restore and maintain the chemical, physical, and biological integrity of the nation's waters.
This Act led to the promulgation of regulations concerning the incineration of sewage sludge.
4. The Toxic Substances Control Act (TSCA)
This Act, as last amended in 1986 (15 USC 2601-2671), is the Federal legislation that deals
with the control of toxic substances. The Act consists of three subchapters; one regulates the
control of toxic substances, another governs asbestos hazard emergency response, and another
subchapter regulates indoor radon abatement. The policy developed in TSCA on chemical
substances is as follows (15 USC 2601(b)):
a Adequate data should be developed with respect to the effect of chemical substances
and mixtures on health and the environment and that the development of such data
should be the responsibility of those who manufacture and those who process such
chemical substances and mixtures;
b. Adequate authority should exist to regulate chemical substances and mixtures which
present an unreasonable risk of injury to health or the environment, and to take action
regarding chemical substances and mixtures; and
c Authority over chemical substances and mixtures should be exercised in such a manner
as not to impede unduly or create unnecessary economic barriers to technological
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innovation while fulfilling the primary purpose of this Act to assure that such
innovation and commerce in such chemical substances and mixtures do not present an
unreasonable risk of injury to health or the environment.
Upon request by the EPA, each Federal department and agency is authorized to (15 USC
2625(a)):
a. Make its services, personnel, and facilities available (with or without reimbursement) to the
EPA to assist the EPA in the administration of this Act; and
b. Furnish the EPA with information, data, estimates, and statistics, and allow the EPA access
to all information in its possession as the EPA may reasonably determine to be necessary for
the administration of this Act
Under TSCA, the national long-term goal of the United States with respect to radon levels in
building is that the air within buildings in the United States should be as free of radon as the
ambient air outside of buildings (15 USC 2661). The head of each Federal department or agency
that owns a Federal building must conduct a study for the purpose of determining the extent of
radon contamination in such buildings. Such study must include, in the case of a Federal
building using a non-public water source (such as a well or other ground water), radon
contamination of the water. Such a study must be based on design criteria specified by the EPA
(15 USC 2669(a)(c)(e)).
5. The Asbestos Hazard Emergency Response Act (AHERA) of 1986
This Act, last amended in November 1990 (15 USC 2641-2656, et al, and 20 USC 4014, et
al.), is the Federal legislation that governs the control and abatement of asbestos hazard present
in school buildings. The purpose of this Act is (15 USC 2641(b)):
a. To provide for the establishment of Federal regulations that require inspection for
asbestos- containing material and implementation of appropriate response actions with
respect to asbestos-containing material in the nation's schools in a safe and complete
manner;
b. To mandate safe and complete periodic reinspection of school buildings following
response actions, where appropriate; and
c. To require the EPA to conduct a study to find out the extent of the danger to human
health posed by asbestos in public and commercial buildings and the means to respond
to any such danger.
6. The Hazardous Materials Transportation Act
This Act was amended in 1978 to regulate the transport of asbestos materials. The
regulations are contained in 49 CFR 172-177. In particular 49 CFR 177 requires that asbestos
must be loaded, handled, and unloaded in a manner that will minimize occupational exposure to
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airborne asbestos. Asbestos wastes which are transported for disposal at a landfill or other
disposal facility must meet all applicable requirements.
7. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires Federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
it funds meet applicable Federal, state, and local environmental requirements or to correct
situations that are not in compliance with such requirements. In addition, the EO requires that
each agency ensure that sufficient funds for environmental compliance are included in the agency
budget.
8. Executive Order (EO) 12873, Federal Acquisition, Recycling, and Waste Prevention
This EO, dated 20 October 1993, mandates waste prevention and recycling as part of an
agency's daily operations. It requires each agency to set a goal for solid waste prevention and a
goal for recycling to be achieved by the year 1995. Agencies are also required to set goals for
increasing the procurement of recycled and other environmentally preferable products.
C. State/Local Regulations
The primary mechanisms regulating air pollutant emissions are the state or Air Quality
Control Region (AQCR) regulations. These regulations will normally follow the Federal
guidelines for state programs and will have many similar features. However, depending on the
type and degree of air pollutant problems within the state/region, the individual regulations will
vary. As an example, photochemical oxidant (ozone) problems are widespread in California and
therefore the individual AQCRs in that state have stringent VOC emission requirements. The
State of North Dakota has no such problem and therefore has fewer and less stringent VOC
regulations.
New Source Performance Standards (NSPS) are established for particular pollutants in
industrial categories based upo i adequately demonstrated control technology. A permit is
normally required for new, expanded, or modified sources of air pollutants.
Some state regulations apply directly to some facilities and operations without requiring a
permit. At a minimum, state regulations should be reviewed for the following activities:
• Fugitive dust emissions;
• Control of particulate emissions from the transportation of refuse or materials in open
vehicles;
• Certification requirements for boiler operators;
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• Emissions and emission control requirements for the operation of existing fossil fuel-fired
steam generators;
• Open burning;
• Vehicle exhaust emissions testing;
• Spray painting of vehicles, buildings, and/or furniture;
• Certification of vehicles transporting VOC liquids;
• Paving of roads and parking lots;
• Toxic air pollutants;
• Operation of cold cleaners, degreasers, and open top vapor degreasers;
• Vapor control requirements for fuel pumps; and
• Prescribed burning.
Many state and local governments have enacted standards more stringent than the Federal
requirements concerning certification of asbestos workers and disposal of asbestos waste. If the
facility is engaging in asbestos removal or disposal, contact the appropriate state and local
agencies.
State and local governments may enact radon control standards.
D. Key Compliance Requirements
1. Steam Generating Units (greater than 29 MW (100 MBtu/h))
Steam generating units with capacity greater than 29 MW (100 Mbtu/h) that started
construction or modification after 19 June 1984 are required to meet emissions limitations for
particulates, S02, and NOx The limit that applies is dependent on the type of fuel being burned.
Records are required to be kept of the amounts of fuel combusted each day (40 CFR 60.40b
through 60 49b)
2. Steam Generating Units (2.9 MW (10 Mbtu/h) - 29 MW (100 Mbtu/h))
Steam generating units that started construction, modification, or reconstruction after 3 June
1989 with a maximum design heat input capacity of greater than or equal to 2.9 MW (10 Mbtu/h)
but equal to or less than 29 MW (100 Mbtu/h) are required to limit emissions of S02 and
particulates. Discharge rates are to be monitored, and if there is no monitoring system, fuel is
required to be sampled prior to combustion. Facilities are required to submit excess emissions
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reports for any calendar quarter in which it exceeds opacity limits. If a facility does not exceed
the limits in a given year, it is required to file semiannual reports confirming this fact. Facilities
required to meet S02 emission limits are also required to submit quarterly reports (40 CFR
60.40c through 60 48c).
3. Fuel Burning Facilities (greater than 73 MW (250 Mbtu/h))
Fuel burning facilities constructed or modified after 17 August 1971 with greater than 73
MW (250 Mbtu/h) heat input are required to limit emissions of particulates, S02 and NOx.
Monitoring these substances and fuel analysis are also required to be done (40 CFR 60.44 and
60 45).
4. Stationary Gas Turbines
Stationary gas turbines with a heat input greater than or equal to 10.7 gJ/h (10.17 Mbtu/h)
that were constructed or modified after 3 October 1977 are required to limit the amounts of NOx
and S02 emitted. In addition to the emissions, the sulfur and nitrogen content of the fuel being
fired must also be monitored (40 CFR 60.330 through 60.335).
5. Municipal Waste Combustor
Municipal waste combustors with a capacity greater than 225 megagrams (Mg) (250 tons)
per day that started construction or modification after 20 December 1989 are required to limit the
amounts of dioxin/furan, S02, hydrogen chloride, CO, and NOx emitted. The chief municipal
waste combustor operator and shift supervisors are required to be certified to operate the
combustor, and there must be an operating manual that is updated yearly (40 CFR 60.50a
through 60.58a).
6. Incinerators
Incinerators with greater than 45 metric tons/day (50 tons/day) charging rate that started
construction or modification after 17 August 1971 are required to meet emissions limitations for
particulates and C02. Additionally, they are to maintain records of daily charging rates and
hours of operation (40 CFR 60.50 through 60.54).
7. Sewage Sludge Incinerators
Sewage sludge incinerators that combust greater than 1000 kg/day (2205 lb/day) that were
constructed or modified after 11 June 1973 are required to limit their emissions of particulates.
Monitoring devices are required depending on what type of incinerator the facility operates (40
CFR 60.150 through 60 156)
8. Beryllium Incinerators
Incinerators for beryllium containing waste, beryllium, beryllium oxide, or beryllium alloys
cannot emit more than 10 g (0.32 oz) of beryllium over a 24 hour period into the atmosphere.
Records of emissions tests are required to be kept for two years (40 CFR 61.30 through 61 34).
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9. Incineration of Sewage Sludge
Facilities with incinerators that fire sewage sludge must meet specific emissions standards
for beryllium emissions, mercury emissions, and hydrocarbons. The incinerators are required to
have continuous monitoring devices for hydrocarbons and oxygen in the exit gas and continuous
monitoring for combustion temperature as specified by the permitting authority. Assorted
reports are required to be submitted and records kept (40 CFR 503.40 through 503.48).
10. Gasoline Dispensing
Leaded gasoline shall not be introduced into any motor vehicle that is labeled UNLEADED
GASOLINE ONLY, or that is equipped with a gasoline tank filler inlet designed for introduction
of unleaded gasoline. Fuel pumps are required to display signs stating the type of fuel in each
pump and that only unleaded gas can be introduced into labeled vehicles. The nozzles of the
pumps are required to be properly sized. Depending on whether the oxygenated gas is still in the
control period, or the area has an oxygenated gasoline program with a credit program, pumps
dispensing oxygenated gasoline are required to be labeled. During 1992 and later, high-ozone
seasons, and regulatory control periods, gasoline shall not be sold, offered for sale, imported,
dispensed, supplied, or transported that exceeds Reid vapor pressure standards in Appendix 1-1.
No diesel fuel shall be distributed, transported, offered for sale, or dispensed for use in motor
vehicles unless it is free of the dye 1,4-dialkylamino-antraquinone and has an acetane index of at
least 40, or a maximum aromatic content of 35 volume percent and a sulfur percentage of less
than 0.05 percent (40 CFR 80.22(a), 80.22(d), 80.22(e), 80.24(a)(1), 80.27(a)(2), 80.35, 80.80(d),
and 80.29(a)).
11. Rotogravure Printing Presses
Publication rotogravure printing presses, except for proof presses, that started construction
or modification after 28 October, are required to ensure that gases are not being discharged
containing VOC equal to more than 16 percent of the total mass of VOC solvent and water used
at that press during any one performance averaging period (40 CFR 60.430 through 60.435).
12. Fugitive Emissions
The emission of Volatile Hazardous Air Pollutants (VHAP), vinyl chlorides, and benzene is
required to be managed, monitored, and controlled according to specific requirements. These
include taking certain actions when a leak is detected, ensuring that certain records are
maintained, and ensuring that pumps and compressors meet certain standards and that pressure
relief devices in gas/vapor service have no detectable emissions except during pressure releases.
Valves and lines in VHAP service are required to be monitored monthly and repairs done within
15 days of leak detection. Systems and devices used to control VHAP emissions must recover
vapors with 95 percent efficiency or greater. Enclosed combustion devices will be designed and
operated to reduce VHAP and benzene emissions, and closed-vent systems will have no
detectable emissions (40 CFR 61.240 through 61.242-10, 61.246, and 61.247).
13. Sulfuric and Nitric Acid Plants
These plants are required to limit their emissions and install continuous monitoring systems
(40 CFR 60.70 through 60.85).
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14. Chlorofluorocarbons (CFC) and Halons
To protect the ozone, no person repairing or servicing motor vehicles for payment can
service a motor vehicle air conditioner in any way that affects the refrigerant unless they have
been trained and certified and are using approved equipment. Additionally, persons who
maintain, service, or repair appliance, except MVACs, and persons who dispose of appliances,
except for small appliances, room air conditioners, Motor Vehicle Air Conditioners (MVAC),
and MVAC-like appliances are required to be certified through an approved technician
certification program. As of 15 November 1992, no Class I or Class II substances suitable for
use in motor vehicles as a refrigerant can be sold or distributed in any container that is less than
20 lb (9.07 kg) to any person unless that person is trained and certified. Facilities that sell Class I
or Class II substances suitable for use as a refrigerant in containers of less than 20 lb (9.07 kg)
are required to display a sign with certain wording. The servicing of appliances containing CFCs
and halons is required to be done in a manner to prevent emissions (40 CFR 82.34(a), 82.34(b),
82.42(a) through 82.42(c), and 80.150 through 80.166).
15. National Ambient Air Quality Standards (NAAQS)
The cornerstone of the Clean Air Act is the development and implementation of the National
Ambient Air Quality Standards (NAAQS), as required in Title I, Section 109. States are required
to develop and submit State Implementation Plans (SIPs) to the EPA for approval and delegation
of authority. These SIPs are required to demonstrate how a State will control its current and
future emissions sources such that the State's air quality levels will attain and maintain the
NAAQS.
16. Criteria Pollutants
The Clean Air Act Amendments of 1977 established the basis that required EPA to develop
a list of air pollutants originating from numerous or diverse mobile and stationary sources that
may reasonably be anticipated to endanger public health or welfare. Criteria documents were
developed by EPA for such pollutants, reflecting the latest scientific knowledge useful in
indicating the kind and extent of all identifiable effects on public health and welfare that can be
expected from the presence of the pollutants in the ambient air. Substances designated as criteria
pollutants are sulfur dioxide, particulate matter (total suspended particulates prior to 1 July 1988,
and PM-10 subsequently), carbon monoxide, ozone, nitrogen dioxide, and lead.
17. State Implementation Plan (SIP)
The Clean Air Act required each state to develop a SIP that would provide for
implementation, maintenance, and enforcement of the primary and secondary ambient air quality
standards. Title I of the 1990 Clean Air Act Amendments requires states to upgrade and submit
modified SIPs particularly for ozone and PM10 nonattainment areas. Many states also included
requirements directed at the Prevention of Significant Deterioration (PSD) of air quality in areas
already meeting the air quality standards. States that did not develop their own more stringent
PSD regulations are subject to the Federal program defined in 40 CFR 52.21. The individual
states were provided an opportunity to establish air quality standards for the criteria pollutants
that are more stringent than the Federal standards, and also to establish air quality standards for
substances not listed as Federal criteria pollutants.
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18. Standard of Performance for New Stationary Sources (NSPS)
In response to the Clean Air Act, the EPA has developed (and is continuing to develop) a
specific list of sources, emission standards, notification and testing procedures, and monitoring
and reporting requirements that apply to sources commencing construction or modification
subsequent to proposal of a standard applicable to that facility. In many instances, authority has
been delegated to individual states to carry out this regulatory process.
19. National Emission Standards for Hazardous Air Pollutants (NESHAP)
Prior to the 1990 amendments, the EPA established emission standards, monitoring and
testing requirements, and reporting requirements for a relatively small group of sources that
potentially emit the following carcinogenic or mutagenic substances: inorganic arsenic, asbestos,
benzene, mercury, radionuclides, radon-222, and vinyl chloride. These regulations are found in
40 CFR61.
Under Title III of the 1990 Amendments, the EPA modified the NESHAP's program to
address a much larger population of sources with potential emissions of hazardous air pollutants.
This modified program leaves the previous program intact and principally creates two new
programs for the control of Hazardous Air Pollutants (HAPs) that separately address both
chronic and accidental releases. The Federal programs under Title III were pre-empted in many
states on the east and west coasts. The Federal program for the control of chronic releases is
technology based for specific source categories; the program is defined in 40 CFR 63. It
addresses both major and area sources of 189 hazardous air pollutants listed in the Title. Major
sources are defined in Title III as having potential emissions of 10 Tons Per Year (TPY) or
greater of a single listed HAP or 25 TPY in aggregate of listed HAPs. The EPA has the authority
to redefine major source criteria and also regulate smaller sources as area sources. The chronic
release control program regulations are to be promulgated for each source category by the year
2000. The accidental release program is currently in the regulatory proposal stage (40 CFR
68-58 FR 54190, 10/20/93 (proposed rule)).
It is important to note that a large number of states developed their own "air toxin's" control
programs prior to the enactment of the new Federal HAP control program. These state programs
typically have a control technology component and an acceptable ambient air concentration
component. The ambient air concentration component is not part of the initial Federal control
program, although after implementation of the control program under 40 CFR 63, the EPA is
required to address residual risks of sources of HAPs.
20. Acid Rain Control
Some facilities may also be subject to some components of the acid rain control program
mandated by Title IV of the Clean Air Act. This program mostly addresses utility emissions of
sulfur dioxide and nitrogen dioxide through mandated emissions limits, tradeable emissions
(e.g., allowances), and monitoring requirements. In addition, there are provisions for repowering
of power plants with Clean Coal Technologies, sponsored by the Department of Energy (DOE)
and other sources. Control programs are required to be implemented as early as 1995, with
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deadlines for applications and allowance demonstrations that began in 1993. The Acid Rain
provision core rules are codified in 40 CFR 72, 73, 75, and 77.
21. Federal Operating Permit Program
Under Title V of the Clean Air Act, states were required to submit to EPA by 15 November
1993 plans for developing operating permit programs. The operating permit program is required
as specified in 40 CFR 70 for sources subject to NSPS, NESHAPS, the Acid Rain provisions,
and other major sources. The first requirements of this program for stationary sources will be to
develop and submit permit applications to either the EPA or the state as early as the fall of 1994
for some sources
The operating permit application will be used to develop a single comprehensive operating
permit that encompasses all applicable air pollution control requirements for the source. In
addition, the source will be required to submit periodic reports to the regulatory agencies
regarding the source's performance relative to its permit requirements. These reports and the
process in general will be open to the public.
22. Renovation and Demolition of Asbestos-Containing Structures
Facilities that demolish structures containing asbestos above certain limits must meet
notification requirements, emission control requirements, and wetting requirements. This applies
to facilities that demolish structures containing at least 80 linear m (260 linear ft) of RACM on
pipes, or at least 15 m2 (160 m2) of RACM on other components or at least 1 m3 (35 ft3) off
facility components, and facilities renovating structures and stripping or removing at least 80
linear m (260 linear ft) of RACM on pipes, or at least 15m 2 (160 m2) of Regulated Asbestos-
Containing Materials (RACM) of friable asbestos on other facility components and at least 1 m3
(35 ft3) off facility components. If the concentration of asbestos is less than this level, then the
facility must submit notification of demolition. Facilities being demolished under state or local
governmental agency orders shall have the portion of the facility containing friable asbestos
adequately wetted during the wrecking operation. When a site is demolished by intentional
burning, all regulated all RACM must be removed. No RACM shall be stripped, removed, or
otherwise handled or distributed unless at least one onsite representative trained in asbestos
removal is present. When air cleaning is used as a method of controlling emissions of asbestos
to the outside air, the fabric filter collection systems are required to meet specific standards,
unless alternative equipment is authorized for use by the EPA (40 CFR 61.145 and 61.152).
23. Asbestos Disposal
Asbestos-containing waste must be wetted or bagged to prevent emissions to the air.
Asbestos waste has to be disposed of in landfills that have been approved for the acceptance of
asbestos-containing waste (40 CFR 61.150, 61 151, and 61.154).
24. Asbestos in Schools
School buildings are required to be inspected for asbestos. An asbestos management plan is
required and response action must be done in a timely manner. If there is friable asbestos in the
school, there must be an O&M and repair program that limits the asbestos from becoming
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airborne and from being exposed to personnel. Warning labels will be attached immediately
adjacent to any friable and nonfriable Asbestos-Containing Building Material (ACBM) and
suspected ACBM assumed to be Asbestos-Containing Material (ACM). Staff at the school must
receive training on the hazards involved (40 CFR 763).
E. Key Compliance Definitions
(NOTE: In many cases, similar or identical terms have different meanings in different air
pollution control regulations).
1. Active Waste Disposal Site
Any disposal site other than an inactive site (40 CFR 61.14).
2. Adequately Wetted
Sufficiently mixed or penetrated with liquid to prevent the release of particulates (40 CFR
61.14).
3. Air Pollution Control Device
One or more processes used to treat the exit gas from a sewage sludge incinerator stack (40
CFR 503.41(a)).
4. Ancillary Equipment
The equipment used with a dry cleaning machine in a dry cleaning system including, but not
limited to, emission control devices, pumps, filters, muck cookers, stills, solvent tanks, solvent
containers, water separators, exhaust dampers, diverter valves, interconnecting piping, hoses, and
ducts (40 CFR 63.321).
§. Annual Capacity Factor
The ratio between the actual heat input to a steam generating unit from an individual fuel or
combustion of fuels during a period of 12 consecutive calendar months and the potential heat
input to the steam generating unit from all fuels, had the steam generating unit been operated for
8,700 hours during that 12 month period at the maximum design heat input capacity (40 CFR
60.41c).
6. Appliance
Any device that contains and uses a Class I or Class II substance as a refrigerant and that is
used for household or commercial purposes, including any air conditioner, refrigerator, chiller, or
freezer (40 CFR 82.152(a)).
7. Approved Equipment Testing Organization
Any organization that has applied for and received approval from the administrator pursuant
to 40 CFR 82.160 (40 CFR 82.152(b)).
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8. Area Source
Any perchloroethylene dry cleaning facility that is not a major source (40 CFR 63.321).
9. Articles
Clothing, garments, textiles, fabrics, leather goods, and the like, that are dry cleaned (40
CFR 63.321)
10. Asbestos
Substances composed of or derived from actinolite, amosite, anthophyllite, chrysotile,
crocidolite, or tremolite (40 CFR 61.14)
11. Asbestos-Containing Waste Materials
Mill tailings or any waste that contains commercial asbestos and is generated by a source
subject to the provisions of 40 CFR 141 This term also includes filters from control devices,
friable asbestos waste material, and bags or other similar packaging contaminated with
commercial asbestos. However, as applied to demolition and renovation operations, this term
includes regulated ACM waste and materials contaminated with asbestos, including disposable
equipment and clothing (40 CFR 61.141).
12. Asbestos Material
Asbestos or any material containing asbestos (40 CFR 61.141).
13. Asbestos Waste from Control Devices
Any waste material that contains asbestos and is collected by a pollution control device (40
CFR 61 141).
14. Auxiliary Fuel
Fuel used to augment the fuel value of sewage sludge. This includes, but is not limited to,
natural gas, fuel oil, coal, gas generated during anaerobic digestion of sewage sludge, and
municipal solid waste (not to exceed 30 percent of the dry weight of sewage sludge and auxiliary
fuel together) (40 CFR 503 41(b)).
15. Benzene Service
A piece of equipment that either contains or contacts a fluid (liquid or gas) that is at least 10
percent benzene by weight (40 CFR 61 111).
16. Bulk Gasoline Terminal
Any gasoline facility that receives gasoline by pipeline, ship, or barge, and has throughput
greater than 75,000 L/day (19997.82 gal/day) (40 CFR 60.501).
17. Carbon Absorber
A bed of activated carbon into which an air-perchloroethylene gas-vapor stream is routed
and that adsorbs the perchloroethylene on to the carbon (40 CFR 63.321).
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18. Cartridge Filter
A discrete filter unit containing both filter paper and activated carbon that traps and removes
contaminants from petroleum solvent, together with the piping and ductwork used in installing
this device (40 CFR 60.621).
19. Category I Nonfriable Asbestos-Containing Material (ACM)
Asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products
containing more than one percent asbestos (40 CFR 61.141).
20. Category II Nonfriable ACM
Any material including Category I nonfriable ACM containing more than one percent
asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure
(40 CFR 61.141).
21. Certified Refrigerant Recovery or Recycling Equipment
Equipment certified by an approved equipment testing organization to meet the standards in
40 CFR 82.158(b) or (d), equipment certified pursuant to 40 CFR 82.36(a), or equipment
manufactured before 15 November 1993, that meets the standards in 40 CFR 82.158(c), (e), or
(g) (40 CFR 82.152(c)).
22. Closed-Vent System
A system that is not open to the atmosphere and is composed of piping, connections, and, if
necessary, flow inducing devices that transport gas or vapor from a piece or pieces of equipment
to a control device (40 CFR 61.241).
23. Coal Refuse
Any waste products of coal mining, cleaning, and coal preparation operations (e.g., culm,
gob, etc.) containing coal, matrix material, clay, and other organic and inorganic material (40
CFR 60.41a).
24. Co-fired Combustor
A unit burning municipal-type solid waste or refuse derived fuel with a nonmunicipal solid
waste fuel that is subject to a Federally enforceable permit limiting the unit to combusting a fuel
feed stream, 30 percent or less of the weight of which is comprised, in aggregate, of municipal-
type solid waste or refuse-derived fuel as measured on a 24 hour basis (40 CFR 60.5la).
25. Cogeneration Steam Generating Unit
A steam generating unit that simultaneously produces both electrical (or mechanical) and
thermal energy from the same primary energy source (40 CFR 60.41c).
26. Coin-Operated Dry Cleaning Machine
A dry cleaning machine that is operated by the customer (that is, the customer places articles
into the machine, turns the machine on, and removes articles from the machine) (40 CFR
63.321).
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27. Colorimetric Detector Tube
A glass tube (sealed prior to use) containing material impregnated with a chemical that is
sensitive to perchloroethylene and is designed to measure the concentration of perchloroethylene
in the air (40 CFR 63.321).
28. Commercial Asbestos
Any material containing asbestos that is extracted from ore and has value because of its
asbestos content (40 CFR 61.141).
29. Commercial Refrigeration
For the purposes of 40 CFR 82.156(i), represents the refrigeration appliances utilized in the
retail food and cold storage warehouse sectors. Retail food includes the refrigeration equipment
found in supermarkets, convenience stores, restaurants and other food service establishments.
Cold storage includes the equipment used to store meat, produce, dairy products, and other
perishable goods. All of the equipment contains large refrigerant charges, typically over 75 lb
(34.02 kg) (40 CFR 82.152(d)).
30. Commercial/Retail Waste
Material discarded by stores, offices, restaurants, warehouses, nonmanufacturing activities at
industrial facilities, and other similar establishments or facilities (40 CFR 60.51a).
31. Continuous Emissions Monitoring Systems (CEMS)
A monitoring system for continuously measuring the emissions of a pollutant from an
affected facility (40 CFR 60.51a).
32. Control Efficiency
The mass of a pollutant in the sewage sludge fed to an incinerator minus the mass of that
pollutant in the exit gas from the incinerator stack divided by the mass of the pollutant in the
sewage sludge fed to the incinerator (40 CFR 503.41(c)).
33. Cutting
To penetrate with a sharp-edged instrument; includes sawing, but does not include shearing,
slicing, or punching (40 CFR 61.141).
34. Demolition
The wrecking or taking out of any load-supporting structural member of a facility together
with any related handling operations or the intentional burning of a facility (40 CFR 61.141).
35. Designated Volatility Nonattainment Area
Any area designated as being in nonattainment with the NAAQS for ozone pursuant to rule
making under Section 107(d)(4)(A)(ii) of the CAA (40 CFR 80.2).
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36. Designated Volatility Attainment Area
An area not designated as being in nonattainment with the NAAQS for ozone (40 CFR
80.2).
37. Diesel Fuel
Any fuel sold in any state and suitable for use in diesel motor vehicles and diesel motor
vehicle engines, and that is commonly or commercially known or sold as diesel fuel (40 CFR
80.2).
38. Dispersion Factor
The ratio of the increase in the ground level ambient air concentrations for a pollutant at or
beyond the property line of the site where the sewage sludge incinerator is located to the mass
emission rate for the pollutant from the incinerator stack (40 CFR 503.41(d)).
39. Disposal
The process leading to and including (40 CFR 82.152(e)):
a. The discharge, deposit, dumping, or placing of any discarded appliance into or on any
land or water;
b. The disassembly of any appliance for discharge, deposit, dumping or placing of its
discarded component parts into or on any land or water; and
c. The disassembly of an appliance for reuse of its component parts.
40. Diverter Valve
A flow control device that prevents room air from passing through a refrigerated condenser
when the door of the dry cleaning machine is open (40 CFR 63.321).
41. Duct Burner
A device that combusts fuel and that is placed in the exhaust duct from another source (such
as a stationary gas turbine, internal combustion engine, kiln, etc.) to allow the firing of additional
fuel to heat the exhaust gases before the exhaust gases enter a steam generating unit (40 CFR
60.41(c)).
42. Dry Cleaning Cycle
The washing and drying of articles in a dry-to-dry machine or transfer machine system (40
CFR 643.321).
43. Dry Cleaning Facility
An establishment with one or more dry cleaning systems (40 CFR 63.321).
44. Dry Cleaning Machine
A dry-to-dry machine or each machine of a transfer machine system (40 CFR 63.321).
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45. Dry Cleaning Machine Drum
The perforated container inside the dry cleaning machine that holds the articles during dry
cleaning (40 CFR 63.321).
46. Dry Cleaning Systems
A dry-to-dry machine and its ancillary equipment or a transfer machine system and its
ancillary equipment (40 CFR 63.321).
47. Dryer
A machine used to remove petroleum solvent from articles of clothing or other textile or
leather goods, after washing and removing excess petroleum solvent, together with the piping
and ductwork used in the installation of this device (40 CFR 60.621).
48. Dryer
A machine used to remove perchloroethylene from articles by tumbling them in a heated air
stream (40 CFR 63.321).
49. Dry-to-Dry Machine
A one-machine dry cleaning operation in which washing and drying are performed in the
same machine (40 CFR 63.321).
50. Emergency Renovation Operation
A renovation operation that was not planned but results from a sudden, unexpected event
that if not immediately attended to presents a safety or public health hazard, is necessary to
protect equipment from damage, or is necessary to avoid imposing an unreasonable financial
burden. This term includes operations necessitated by nonroutine failures of equipment (40 CFR
61.141).
51. Emerging Technology
Any S02 control system that is not defined as a conventional technology and for which the
owner or operator of the affected facility has received approval from the administrator to operate
as an emerging technology (40 CFR 60.41(c)).
52. Exhaust Damper
A flow control device that prevents the air-perchloroethylene gas-vapor stream from exiting
the dry cleaning machine into a carbon adsorber before room air is drawn into the dry cleaning
machine (40 CFR 63.321).
53. Facility Component
Any part of any facility, including equipment (40 CFR 61.141).
54. Federally Enforceable
All limitations and conditions enforceable by the administrator, including those
requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within any applicable
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state implementation plan, and any permit requirements established pursuant to 40 CFR 52.21 or
under 40 CFR 51.18 and 40 CFR 51.24 (40 CFR 60.41(b)).
55. Fluidized Bed Incinerator
An enclosed device in which organic matter and inorganic matter in sewage sludge are
combusted in a bed of particles in the combustion chamber gas (40 CFR 503.41(e)).
56. Fossil Fuel
Natural gas, petroleum, coal, and any form of solid, liquid, or gaseous fuel derived from
such materials for the purpose of creating useful heat (40 CFR 60.41(a)).
57. Friable Asbestos Material
Any material that contains more than one percent asbestos by weight and can be crumbled,
pulverized, or reduced to powder, when dry, by hand pressure (40 CFR 61.141).
58. Fuel Pretreatment
A process that removes a portion of the sulfur in a fuel before combustion of the fuel in a
steam generating unit (40 CFR 60.41(c)).
59. Fugitive Emissions
Air pollutants entering into the atmosphere from other than a stack chimney, vent, or other
functionally equivalent opening. Examples are vapors, dust, and fumes (40 CFR 51.301 (j)).
60. Fugitive Source
Any source of emissions not controlled by an air pollution control device (40 CFR 61.141).
61. Gasoline Carrier
Any distributor who transports or stores, or causes the transportation or storage of gasoline
or diesel fuel without taking title to or otherwise having any ownership of the gasoline, and
without altering either the quality or quantity of the gasoline or diesel fuel (40 CFR 80.2).
62. Gasoline Distributor
Any person who transports or stores, or causes the transportation or storage of gasoline or
diesel fuel at any point between any gasoline refinery or importer's facility and any retail outlet
or wholesale purchaser consumer facility (40 CFR 80 2).
63. Glove Bag
A sealed compartment with attached inner gloves used for the handling of ACM (40 CFR
61.141).
64. Heat Input
Heat derived from combustion of fuel in a steam generating unit; does not include the heat
derived from preheated combustion air, recirculated flue gases, or exhaust gases from other
sources (40 CFR 60.41(c)).
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65. High-Pressure Appliance
An appliance that uses a refrigerant with a boiling point between -50 and 10°C (-58 and
50°F) at atmospheric pressure (29.9 in (75.946 cm) of mercury). This definition includes but is
not limited to appliances using refrigerants -12, -22, -114, -500, or -502 (40 CFR 82.152(f)).
66. Hourly Average
The arithmetic mean of all measurements taken during one hour. At least two measurements
must be taken during the hour (40 CFR 503.41(f)).
67. Household Waste
Includes material discarded by single and multiple residential dwellings, hotels, motels, and
other similar permanent or temporary housing (40 CFR 60.51(a)).
68. In Poor Condition
The binding of the material is losing its integrity as indicated by peeling, cracking, or
crumbling of the material (40 CFR 61.141).
69. Inactive Waste Disposal Site
Any disposal site (or portion of it) where additional asbestos-containing waste material will
not be deposited and where the surface is not disturbed by vehicular traffic (40 CFR 61.141).
70. Incinerator
Any furnace used in the process of burning solid waste for the purpose of reducing the
volume of the waste by removing combustible matter (40 CFR 60.51).
71. Industrial Process Refrigeration
For the purposes of 40 CFR 82.156(i), this represents complex customized appliances used
in the chemical, pharmaceutical, petrochemical, and manufacturing industries. This sector also
includes industrial ice machines and ice rinks (40 CFR 82.152(g)).
72. Institutional Waste
Includes materials discarded by hospitals, schools, nonmanufacturing activities at prisons,
and government facilities (40 CFR 60.51(a)).
73. Large Municipal Waste Combustor (MWC)
An MWC plant with a capacity greater than 225 Mg/day (250 tons/day) of municipal solid
waste (40 CFR 60.51(a)).
74. Lignite
Coal that is classified as lignite A or B according to the American Society for Testing and
Materials (ASTM) Standards (40 CFR 60.41(a)).
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75. Low-Loss Fitting
Any device that is intended to establish a connection between hoses, appliances, or recovery
or recycling machines and that is designed to close automatically or to be closed manually when
disconnected, minimizing the release of refrigerant from hoses, appliances, and recovery or
recycling machines (40 CFR 82.152(h)).
76. Low-Pressure Appliance
An appliance that uses a refrigerant with a boiling point above 10°C (50 °F) at atmospheric
pressure (29.9 in (75.946 cm) of mercury). This definition includes but is not limited to
equipment utilizing refrigerants -11,-113, and -123 (40 CFR 82.152(i)).
77. Major Maintenance, Service, or Repair
Any maintenance, service, or repair involving the removal of any or all of the following
appliance components (40 CFR 82.152(j)):
a. Compressor;
b. Condenser;
c. Evaporator; and
d. Auxiliary heat exchanger coil.
78. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
79. Maximum Heat Input Capacity of a Steam Generating Unit
Is determined by operating the facility at maximum capacity for 24 hours and using the heat
loss method described in Sections 5 and 7.3 of the American Society of Mechanical Engineers
(ASME) Power Test Codes 4.1 (see 40 CFR 60.17(h)) no later than 180 days after initial startup
of the facility and within 60 days after reaching maximum production rate at which the facility
will be operated (40 CFR 60.51a).
80. Medical Waste
When defined as applicable to municipal waste combustors, it is any solid waste generated
in the diagnosis, treatment, or immunization of human beings or animals; in research pertaining
thereto; or in production or testing of biologicals. Medical waste does not include any hazardous
waste identified under the Resource Conservation and Recovery Act (RCRA), Subtitle C, or any
household waste as defined in RCRA Subtitle C (40 CFR 60.51(a)).
81. Modification
In relation to New Source Performance Standards (NSPS), any physical or operational change to
an existing facility that results in an increase in the emission rate to the atmosphere of any
pollutant to which a standard applies except (40 CFR 60.14):
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a. Maintenance, repair, and replacement that the administrator determines to be routine for
a source category;
b. An increase in production rate of an existing facility, if that increase can be
accomplished without a capital expenditure on that facility;
c. An increase in the hours of operation; and
d. Use of an alternate fuel or raw material if, prior to the date any standard under this part
becomes applicable to that source type, the existing facility was designed to
accommodate that alternate use. A facility will be designed to accommodate an
alternative fuel or raw material if that use could be accomplished under the facility's
construction specifications as assessed prior to the change.
82. Motor Vehicle Air Conditioner (MVAC)
Any appliance that is a motor vehicle air conditioner as defined in 40 CFR 82, subpart B (40
CFR 82.152(k)).
83. Muck Cooker
A device for heating perchloroethylene-laden waste material to volatilize and recover
perchloroethylene (40 CFR 63.321).
84. Municipal-Type Solid Waste
Household, commercial/retail, and/or institutional waste Household, commercial/retail, and
institutional wastes do not include sewage, wood pallets, construction and demolition wastes, or
industrial process or manufacturing wastes. Municipal-type solid waste does include motor
vehicle maintenance materials, limited to vehicle batteries, used motor oil, and tires. Municipal-
type solid waste does not include wastes that are solely segregated medical wastes. However,
any mixture of segregated medical wastes and other wastes that contains more than 30 percent
medical waste is considered municipal-type solid waste (40 CFR 60.51(a)).
85. Municipal Waste Combustor (MWC)
Any device that combusts solid, liquid, or gasified municipal solid waste including, but not
limited to, field-erected incinerators, modular incinerators, boilers, furnaces, and
gasification/combustion units. This does not include combustion units, engines, or other devices
that combust landfill gases collected by landfill gas collection systems (40 CFR 60.51(a)).
86. MVAC-Like Appliance
Mechanical vapor compression, open-drive compressor appliances used to cool the driver's
or passenger's compartment of a non-road motor vehicle. This includes the air conditioning
equipment found on agricultural or construction vehicles. This definition is not intended to cover
appliances using HCFC-22 refrigerant (40 CFR 82.152(1)).
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87. Nitric Acid Production Unit
Any facility producing nitric acid that is 30 to 70 percent in strength by either the pressure or
atmospheric pressure process (40 CFR 60.70).
88. Nonscheduled Renovation
A renovation operation necessitated by the routine failure of equipment, which is expected
to occur within a given period based on past operating experience but for which an exact date
cannot be predicted (40 CFR 61.141).
89. Normally Containing a Quantity of Refrigerant
Containing the quantity of refrigerant within the appliance or appliance component when the
appliance is operating with a full charge of refrigerant (40 CFR 82.152(m)).
90. Opacity
The degree to which emissions reduce the transmission of light and obscure view of an
object in the background (40 CFR 60.2).
91. Opening an Appliance
Any service, maintenance, or repair on an appliance that could be reasonably expected to
release refrigerant from the appliance to the atmosphere unless the refrigerant were previously
recovered from the appliance (40 CFR 82.152(n)).
92. Outside Air
The air outside buildings and structures, including but not limited to, air under a bridge or an
open ferry dock (40 CFR 61.141).
93. Particulate Asbestos Material
Finely divided particles of asbestos or material containing asbestos (40 CFR 61.141).
94. Particulate Matter Emissions
Any airborne, finely divided solid or liquid material except uncombined water that is emitted
to the ambient air (40 CFR 60.2).
95. Perceptible Leaks
Any perchloroethylene vapor or liquid leaks that are obvious from (40 CFR 63.321):
a. The odor of perchloroethylene;
b. Visual observation, such as pools or droplets of liquid; and/or
c. The detection of gas flow by passing the fingers over the surface of the equipment.
96. Perchloroethylene Consumption
The total volume of perchloroethylene purchased based upon purchase receipts or other
reliable measures (40 CFR 63.321).
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97. Petroleum Dry Cleaner
A dry cleaning facility that uses petroleum solvent in a combination of washers, dryers,
filters, stills, and settling tanks (40 CFR 60.621).
98. Planned Renovation Operations
A renovation operation, or a number of such operations, in which the amount of friable
asbestos material that will be removed or stripped within a given period of time can be predicted.
Individual nonscheduled operations are included if a number of such operations can be predicted
to occur during a given period of time based on operating experience (40 CFR 61.141).
99. PM,0
Particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers
(40 CFR 58.1).
100. Process Sub
A length of tubing that provides access to the refrigerant inside a small appliance or room air
conditioner and that can be resealed at the conclusion of repair or service (40 CFR 82.152(p)).
101. Publication Rotogravure Printing
Any number of rotogravure printing units capable of printing simultaneously on the same
continuous web or substrate. Includes any associated device for continuous cutting and folding
the printed web, where the following sellable paper products are printed: catalogues; direct mail
advertisements; display advertisements; magazines; miscellaneous advertisements including
brochures, pamphlets, catalogue sheets, circular folders, and announcements; newspapers;
periodicals; and telephone and other directories (40 CFR 60.431).
102. Radon-222
A naturally occurring, inert radioactive gas that is formed from the radioactive decay of
uranium.
103. Reclaim Refrigerant
To process refrigerant to at least the purity specified in the ARI Standard 700-1988,
Specifications for Fluorocarbon Refrigerants (Appendix A to 40 CFR 82, Subpart F) and to
verify this purity using the analytical methodology prescribed in the ARI Standard 700-1988. In
general, reclamation involves the use of processes or procedures available only at a reprocessing
or manufacturing facility (40 CFR 182.52(q)).
104. Reclaimer
A machine used to remove perchloroethylene from articles by tumbling them in a heated air
stream (40 CFR 63.321).
105. Reconstruction
In relation to perchloroethylene dry cleaners, it means replacement of a washer, dryer, or
reclaimer or replacement of any components of a dry cleaning system to such an extent that the
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fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would
be required to construct a comparable new source (40 CFR 63.321).
106. Recover Refrigerant
To remove refrigerant in any condition from an appliance without necessarily testing or
processing it in any way (40 CFR 182.52(r)).
107. Recovery Efficiency
The percentage of an appliance that is recovered by a piece of recycling or recovery
equipment (40 CFR 82.152(s)).
108. Recycle Refrigerant
To extract refrigerant from an appliance and clean refrigerant for reuse without meeting all
of the requirements for reclamation. In general, recycled refrigerant is refrigerant that is cleaned
using oil separation and single or multiple passes through devices, such as replaceable core filter-
driers, which reduce moisture, acidity, and particulate matter. These procedures are usually
implemented at the field job site (40 CFR 82.152(t)).
109. Refrigerated Condenser
A vapor recovery system into which an air-perchloroethylene gas-vapor stream is routed and
the perchloroethylene is condensed by cooling the gas-vapor stream (40 CFR 63.321).
110. Refuse Derived Fuel
Combustible or organic portion of municipal waste that has been separated out and
processed for use as fuel (40 CFR 60.51(a)).
111. Regulated Asbestos-Containing Material (RACM)
Includes friable asbestos material; Category I nonfriable asbestos-containing material that
has become friable; Category I nonfriable asbestos-containing material that has been subjected to
grinding, casting, cutting, or abrading; and Category II nonfriable asbestos-containing material
that has a high probability of becoming crumbled, crushed, or pulverized (40 CFR 61.141).
112. Remove
To take out RACM from any structure (40 CFR 61.141).
113. Renovation
Altering in any way one or more structure components. Operations in which load-supporting
structural members are wrecked or taken out are excluded (40 CFR 61.141).
114. Risk Specific Concentration
The allowable increase in the average daily ground level ambient air concentrations for a
pollutant from the incineration of sewage sludge at or beyond the property line of the site where
the sewage sludge.incinerator is located (40 CFR 503.4l(i)).
Phase 1 - Section 1
Air Pollution Control
1-24
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115. Room Enclosure
A stationary structure that encloses a transfer machine system and that is vented to a carbon
adsorber or an equivalent control device during operation of the transfer machine system (40
CFR 63.321).
116. Self-Contained Recovery Equipment
Refrigerant recovery or recycling equipment capable of removing the refrigerant from an
appliance without the assistance of components contained in the appliance (40 CFR 82.152(u)).
117. Sewage Sludge Feed Rate
Either the average daily amount of sewage sludge fired in all sewage sludge incinerators
within the property line of the site where the sewage sludge incinerators are located for the
numbers of days in a 365-day period that each sewage sludge incinerator operates, or the site
where the sewage sludge incinerators are located (40 CFR 503.41 (j)).
118. Sewage Sludge Incinerator
An enclosed device in which only sewage sludge and auxiliary fuel are fired (40 CFR
503.4 l(k)).
119. Small Appliance
Any of the following products that are fully manufactured, charged, and hermetically sealed
in a factory with 5 lb (11.02 kg) or less of refrigerant (40 CFR 82.152(v)):
a. Refrigerators designed for home use;
b. Freezers designed for home use;
c. Room air conditioners (including window air conditioners and packaged terminal air
conditioners);
d. Packaged terminal heat pumps;
e. Dehumidifiers;
f. Under-the-counter ice makers;
g. Vending machines; and
h. Drinking water coolers.
120. Stationary Gas Turbines
Any simple cycle gas turbine, regenerative cycle gas turbine, or any gas turbine portion of a
combined cycle steam/electric generating system that is not selfpropelled. It may be mounted on
a vehicle for portability (40 CFR 60.331).
121. Steam Generating Unit
Any furnace, boiler, or other device used for combusting fuel for the purpose of producing
steam (including fossil fuel-fired steam generators associated with combined cycle gas turbines).
Nuclear steam generators are not included (40 CFR 60.41(a)).
Phase 1 - Section 1
Air Pollution Control
1-25
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122. Strip
To take off RACM from any part of a facility (40 CFR 61.141).
123. Structural Member
Any load-supporting member of a structure, such as beams and load-supporting walls, or any
nonload-supporting member, such as ceilings and nonload-supporting walls (40 CFR 61.141).
124. Sulfuric Acid Production Unit
Any facility producing sulfuric acids by the contact process by burning elemental sulfur,
alkylation acid, hydrogen sulfide, organic sulfides and mercaptans, or acid sludge; does not
include facilities where conversion to sulfuric acid is used primarily as a means of preventing
emissions to the atmosphere of S02 or other sulfur compounds (40 CFR 60.81).
125. System-Dependent Recovery Equipment
Refrigerant recovery equipment that requires the assistance of components contained in an
appliance to remove the refrigerant from the appliance (40 CFR 82.152(w)).
126. Technician
Any person who performs maintenance, service, or repair that could reasonably be expected
to release Class I or Class II substances from appliances into the atmosphere, including but not
limited to, installers, contractor employees, in-house service personnel, and, in some cases,
owners. Technician also means any person disposing of an appliance except for small appliances
(40 CFR 82.152(x)).
127. Transfer Machine System
A multiple-machine dry cleaning operation in which washing and drying are performed in
different machines. Examples include but are not limited to (40 CFR 63.321):
a. A washer and dryer;
b. A washer and reclaimer; and
c. A dry-to-dry machine and reclaimer.
128. Very High-Pressure Appliance
An appliance that uses a refrigerant with a boiling point below -50°C (-58°F) at atmospheric
pressure (29.9 in (75.95 cm) of mercury). This definition includes but is not limited to
equipment utilizing refrigerants -13 and -503 (40 CFR 82.152(y)).
129. Very Low Sulfur Oil
An oil that contains no more than 0.5 weight percent sulfur or that, when combusted without
S02 emission control, has a S02 emission rate equal to or less than 215 ng/J (0.5 lb/ MBtu) heat
input (40 CFR 60.41(b)).
Phase 1 - Section 1
Air Pollution Control
1-26
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130. VHAP Service
A piece of equipment that either contains or contacts a fluid (liquid or gas) that is at least 10
percent by weight a Volatile Hazardous Air Pollutant (VHAP) (40 CFR 61.241).
131. Visible Emissions
Any emissions that are visually detectable without the aid of instruments, and that are
derived from RACM or asbestos-containing waste material, or from any asbestos milling,
manufacturing, or fabricating operation. This does not include condensed water vapor (40 CFR
61.141).
132. VOC Service
In relationship to fugitive emissions, this is when a piece of equipment contains or contacts a
process fluid that is at least 10 percent VOC by weight (40 CFR 61.241).
133. Volatile Hazardous Air Pollutants (VHAPs)
A substance regulated under 40 CFR 61, Subpart V, for which a standard for equipment
leaks of the substance has been proposed and promulgated. Benzene and vinyl chloride are
VHAPs (40 CFR 61.241).
134. Volatile Organic Compounds (VOCs)
Any compound of carbon (excluding CO, C02, carbonic acid, metallic carbides, carbonates,
and ammonium carbonate) that participates in atmospheric photochemical reactions (40 CFR
51.100).
135. Washer
A machine used to clean articles by immersing them in perchloroethylene. This includes a
dry-to-dry machine when used with a reclaimer (40 CFR 63.321).
136. Water Separator
Any device used to recover perchloroethylene from a water-perchloroethylene mixture (40
CFR 63.321).
137. Wholesale Purchaser-Consumer
Any organization that is an ultimate consumer of gasoline or diesel fuel, and that purchases
or obtains gasoline or diesel fuel from a supplier for use in motor vehicles, and that receives
delivery of that product into a storage tank of at least 550 gal (2081.98 L) capacity substantially
under the control of that organization (40 CFR 80.2).
F. Records to Review
• State and local air pollution control regulations
• Emissions inventory
• All air pollution source permits
Phase 1 - Section 1
Air Pollution Control
1-27
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• Plans and procedures applicable to air pollution control
• Emission monitoring records
• Opacity records
• Notices of Violations (NOVs) from regulatory authorities
• Instrument calibration and maintenance records
• Reports/complaints concerning air quality
• Air Emergency Episode Plan
• State and/or Federal regulatory inspections
• Regulatory inspection reports
• Documentation of preventive measures or actions
• Results of air sampling at the conclusion of response action
• Asbestos management plan and operating plan
• Notification to regulators concerning asbestos disposal
• Records of onsite disposal and transportation and offsite disposal of asbestos
• Regulatory inspection reports
• Documentation of asbestos sampling and analytical results
• Documentation of preventive measures or actions
• Results of air sampling at the conclusion of response action
• Records of asbestos training program
• List of buildings insulated with asbestos or housing ACM
• Record of demolition or renovation projects in the past five years that involved friable
asbestos
• Decision documents/records of decision
• Administrative record
• Facility Master Plan Document
• Training and certification records for Federal employees who reclaim or recycle refrigerants
• Site plans and drawings.
G. Physical Features to Inspect
• All air pollution sources (fLxel burners, incinerators, VOC sources, etc.) (see Table 1)
• Air pollution monitoring, control devices, and locations
• Air emission stacks
• Air intake vents
• Pipe, spray-on, duct, and troweled cementitious insulation and boiler lagging
• Ceiling and floor tiles.
Phase 1 - Section 1
Air Pollution Control
1-28
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Table 1
Potential Air Pollution Sources Found at Federal Facilities
Heat/Steam/Energy Production
Coal-fired power plants
Package boilers
Diesel generators
Emergency generators
Peak shaving generators
Turbines
Petroleum Product Storage and Transport
Tank farms
Gasoline service stations
Loading racks
Tanker transfer
Underground storage tanks
Aboveground storage tanks
Graphic Arts
Letterpress
Rotogravure
Offset lithography
Silkscreening
Degreasing Operations
Vapor degreasers
Cold solvent cleaning
Solvent dip tanks
Surface Coating Operations
Paint booths
Metal parts coating lines
Furniture refinishing
Architectural coatings
Traffic striping
Firing Ranges
Artillery
Small caliber weapons
Additional Sources
Air-conditioning/refrigeration shops
Pesticide/herbicide applications
Asphalt production
Wastewater treatment plants
Controlled forest and agricultural burning
Firefighter training burns
Smoke generators
Engine test cells/dynamometers
Ethylene oxide sterilizers
Laboratory hood vents
Sandblasting operations
Woodworking operations
Quarries
Plastics production
Explosive and munitions production
Acid production
Forging and annealing operation
Metal treatment and plating
Waferboard manufacturing
Foam packing operations
Unpaved roads
Storage piles
Storage silos
Prescribed burns and trash burning
Additional Sources
Paint stripping operations
Drycleaning operations
Photoprocessing operations
Training Aid Support Centers (TASC)
Chemical recycling and recovery
Waste Disposal
Incineration of medical/pathological or
hazardous waste
Open buming/open detonation
Landfills
Surface impoundment
Landfarms/bioremediation
Phase 1 - Section 1
Air Pollution Control
1-29
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H. Guidance for Checklist Users
Refer TO
Checklist Hems
PageJVym&ers
All Facilities
A.l through A.2
1-32
A3
1-33
New Source Performance Standards (NSPS)
General
A.4 through A 5
1-34
A.6 through A.7
1-35
Steam Generators
A.8
1-35
A 9 through A 10
1-36
All
1-37
A 12
1-39
A 13
1-40
Gas Turbines
A. 14 through A 15
1-41
Municipal Waste Combustors
A 16
1-42
AM
1-43
Incinerators
A 18
1-44
A 19
1-45
A.20
1-46
Printing Presses
A 21
1-47
Acid Production Units
A 22
1-47
A.23 through A.24
1-47
Sewage Sludge Incinerators
A. 25
1-47
A 26 through A 29
1-48
A.30
1-49
A 31
1-50
A 32
1-51
Thermal Processing Facilities
A 33
1-56
Gasoline
A 34 through A 35
1-51
A.36 through A 38
1-52
A.39
1-53
National Emission Standards for Hazardous
Air Pollutants (NESHAP)
General
A 40
1-53
Fugitive Emissions
A 41
1-53
A 42 through A 43
1-54
A 44 throught A 45
1-55
A 46
1-56
A.47
1-57
Phase 1 - Section 1
Air Pollution Control
1-30
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R«&r¥d
Ctwckltst Item*
Page Numbers
Dry Cleaning Operations
Petroleum Solvent Dry Cleaning
A 48
1-57
Perchloroethylene Dry Cleaning
A 49
1-58
A 50 through A 52
1-59
A 53 through A 55
1-60
A 56 through A 58
1-61
A 59 through A 60
1-62
CFCs and Halons
Purchasing/Procurement
A 1
1-62
Repair/Recy cling
A 62 through A 64
1-63
A 65
1-63
A 66 through A 70
1-64
A 71 through A 74
1-65
A 75 through A 77
1-66
A 78 through A 81
1-67
A 82 through A 85
1-68
A 86 through A 87
1-69
A 88 through A 90
1-70
A 91
1-71
Recordkeeping
A 92 through A 96
1-72
A.97 through A. 100
1-73
A 101 through A. 104
1-74
A 105 through A. 106
1-75
Air Pollution Alert and Emergency Plan
A 107
1-75
Phase 1 - Section 1
Air Pollution Control
1-31
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CtedkMstltent!*
Page Nurobers
Asbestos Management
All Facilities
A-108
1-75
Renovation and Demolition of
A.109 through A.110
1-76
Asbestos-Containing Structures
A 111
1-76
A.l 12 through A. 113
1-77
A.l 14 through A.l 16
1-78
A. 117 through A.l 19
1-79
Asbestos Personnel Training
A. 120
1-79
Asbestos Disposal
A.121 through A.122
1-80
A. 123 through A. 124
1-81
Asbestos in Schools
A. 125 through A. 126
1-82
A.127
1-83
A.128 through A.129
1-84
A. 130 through A. 133
1-85
A.134
1-86
Radon Management
A.135 through A.137
1-86
Phase 1 - Section 1
Air Pollution Control
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Compliance Category: Air Pollution CoatroJ
ReguUtory Requirements
j Rev&wfcrChetfcs:
All Facilities
A 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined. (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation.)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements, or equivalent state enforcement actions.
For these open items, indicate what corrective action is planned and milestones
established to correct problems
A 2. Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding.)
Determine if any new regulations concerning air quality have been issued since the
finalization of the manual. If so, annote checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations.
Phase 1 - Section 1
Air Pollution Control
1-33
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 3 Facilities are required to
Verify that the facility is complying with state and local air quality requirements.
comply with state and local air
quality regulations (42 USC
Verify that the facility is operating according to permits issued by the state or local
7418(a)).
agencies.
(NOTE' Issues typically regulated by state and local agencies include
Air pollution episode standby plans
Permits for construction and operation of sources of emissions
Placement of control devices on fuel burning sources
Incinerators with less than 45 metric tons/day (50 tons/day) heat input
Incineration of medical, pathological, and infectious waste
Open burning and detonation
Firefighting training
Motor vehicle emissions and inspections
Use of vapor control systems at gas dispensing facilities
Transfer of fuel in tank trucks
Solvent metal cleaners such as degreasers and cold cleaners
Fugitive dust emissions from sources such as roads, quarries, sand and gravel
pits, and construction activities
Control of particulate emissions from woodworking shops
Transportation of refuse or materials in open vehicles
Emissions and emission control requirements for the operation of existing
fossil fuel-fired steam generators
The spray painting of vehicles, buildings, and/or furniture
Certification of vehicles transporting VOC liquids
Certification for operators of boilers
Paving of roads and parking lots
Toxic air pollutants
Indoor air pollution)
(NOTE Under 42 USC 7418(c) and 7418(d) each department, agency, and
instrumentality of executive, legislative, and judicial branches of the Federal
government are required to comply with valid vehicle inspection and maintenance
programs except for vehicles that are considered military tactical vehicles. Also, all
employees operating vehicles on a property or an facility over which the Federal
government has jurisdiction are required to furnish proof of compliance with
applicable requirements of any valid vehicle inspection and maintenance programs.)
New Source
Performance Standards (NSPS)
(NOTE- EPA requires new stationary sources constructed, reconstructed, or modified within a specified time frame to
meet source-specific standards for emissions, testing, monitoring and sampling, reporting, etc The auditor must
determine the applicability of NSPS categories (see 40 CFR 60) Steps A 4 through A 7 are general NSPS provisions
Some specific NSPS categories are included in A.8 through A.25)
Phase 1 - Section 1
Air Pollution Control
1-34
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Compliance Category: Air Pollution Control
Regulatory Requirements
| Reviewer Cheeks:
General
A 4 Notifications to EPA must
be provided prior to
commencing construction,
performance testing, and startup
(40 CFR 60 7)
Confirm that the appropriate notifications regarding new source performance have
been made (e.g, construction date, performance testing, etc.) by interviewing facility
personnel and reviewing facility records to confirm that the facility submitted the
appropriate written notifications to EPA in a timely manner) In particular, look for
the following:
Notification of the date of commencement of construction or reconstruction of
an affected facility was filed within 30 days after such date.
Notification of the anticipated date of initial startup of an affected facility was
filed between 30 and 60 days before such date
Notification of the actual date of initial startup was filed within 15 days after
such date
Notification of any physical or operational changes to an existing facility which
may increase the emission rate of any air pollutant was filed 60 days (or as
soon as practicable) before the change was commenced
Notification of the date upon which demonstration of the performance of the
continuous monitoring system commenced was filed at least 30 days prior to
such date.
Notification of the anticipated date for conducting opacity observations was
filed at least 30 days prior to such date
Notification that continuous opacity monitoring system data results will be
used to determine compliance with the applicable opacity standard during a
performance test was filed at least 30 days prior to the date of the performance
test
Verify that the facility has a program to review its operations for NSPS
applicability, specifically air sources that may undergo modification or
reconstruction
A 5 Certain NSPS standards
require continuous emissions
monitoring (40 CFR 60 8,
60 13)
Review documentation to verify conformance with monitoring equipment and
performance testing requirements by performing the following
Confirm that continuous monitoring equipment is available and functioning if
required by the particular NSPS. The review should include at least the
following-
(NOTE- Monitoring systems and devices should have been installed and operational
prior to conducting performance tests)
evaluate the adequacy of any alternative monitoring requirements used in the
absence of a continuous monitoring system;
confirm that performance specifications for Continuous Emission Monitoring
systems (CEMs) noted in 40 CFR 60 Appendix B, if conducted, are met,
confirm that the facility conducted performance tests according to approved
methods by interviewing facility personnel and reviewing facility records; and
determine that the manufacturer's written requirements or recommendations
for checking the operation or calibration of the devices were carried out
Interview facility personnel and review facility records to verify that
performance tests were conducted within 180 days after the startup of the
facility
Phase 1 - Section 1
Air Pollution Control
1-35
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 6 Each NSPS standard
specifies emission limitations
and monitoring and reporting
requirements for regulated
sources (see individual NSPS
standards)
Review the applicable NSPS provisions and develop a list of monitoring and
reporting requirements (e g , frequency, limitations, etc ) Review a representative
sample of monitoring data to determine whether all applicable standards and
limitations are being met for regulated emissions for all sources
If the facility is required to install a continuous monitoring system, review the
facility's semiannual or periodic reports submitted to the EPA Administrator
regarding continuous emissions monitoring Verify that these reports are accurate by
comparing them to the monitoring data reviewed
For any permit or regulatory deviations, equipment malfunctions, and emission
complaints noted, review internal records for proposed and completed corrective
actions Note and investigate any instances where corrective actions were not taken
A 7 NSPS documentation must
be maintained for at least two
years (40 CFR 60 7(d))
Determine whether the facility has maintained a file of all measurements, evaluations,
calibration checks, adjustments, and maintenance on continuous monitoring systems
or devices (if such are required), for at least two years following the dates of such
measurements, maintenance, reports, and records
Steam Generators
A 8 Each fossil fuel fired
steam generating unit of more
than 73 MW (250 MBtu/h) heat
input rate and each fossil fuel
and wood-residue fired steam
generating unit capable of firing
fossil fuel at a heat input rate of
more than 73 MW (250
MBtu/h) heat input rate that
started construction or
modification after 17 August
1971 is required to meet
specific emission standards (40
CFR 60 40 and 60 42 through
60 44)
Verify that
Particulate emissions are not in excess of 0 10 Ib/MBtu
S02 emissions do not exceed levels outlined in Appendix 1-2
NOx emissions do not exceed levels outlines in Appendix 1-2
Verify that the individual conducting opacity monitoring is certified by the state
(NOTE Any change to an existing fossil fuel fired steam generating unit to
accommodate the use of combustible materials does not bring that unit under the
applicability of these requirements )
Opacity emissions are less than 20 percent except one 6 minute period/h of no greater
than 27 percent opacity
Phase 1 - Section 1
Air Pollution Control
1-36
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 9 Each fossil fuel fired
steam generating unit of more
than 73 MW/h (250 million
Btu/h) heat input rate and each
fossil fuel and wood-residue
fired steam generating unit
capable of firing fossil fuel at a
heat input rate of more than 73
MW (250 MBtu/h) heat input
rate that started construction or
modification after 17 August
1971 is required to have specific
types of monitoring instruments
installed (40 CFR 60 40 and
60 45)
Verify that the following monitors are in place
N02 continuous monitor
Opacity monitor (except in gaseous fuel burners)
S02 monitor (except for fossil fuel-fired steam generators not using a fuel gas
desulfunzation device and gaseous fuel burners)
Fuel sampling monitor when S02 monitor is not required
C02 or 02 monitors (except when continuous monitoring systems are not
required to be installed for SOx or NOx)
A 10 Lignite fired steam
generating units that started
construction or modification
after 22 December 1976 are
required to meet specific
emissions limitation for NOx (40
CFR 60 40(d), 60 44(a)(4),
60 44(a)(5))
Verify that NOx are not emitted in excess of 260 ng/J (0 60 lb/MBtu) heat input
except for lignite mined in North Dakota, South Dakota or Montana which is burned
in a cyclone fired unit which is allowed an emission rate of 340 ng/J (0 80 lb /MBtu)
heat input
Phase 1 - Section 1
Air Pollution Control
1-37
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 11 Steam generating units
that started construction,
modification, or reconstruction
after 19 June 1984 with a heat
input capacity of greater than 29
MW (100 MBtu/h) shall meet
specific emissions limitations
for particulates and S02 (40
CFR 60.40b through 60 43b,
60 45b through 60 49b)
Determine if the steam generating unit burns coal, oil, wood, or a combination of
fuels
Determine what percentage of the fuel mix each fuel type represents.
Verify that units combusting coal or oil are not discharging gases into the atmosphere
if the gases contain S02 in excess of 10 percent of the potential S02 emission rate (90
percent reduction) and that contain S02 in excess of the emission limit determined
according to the formula in Appendix 1-3 unless
The unit combusts coal refuse alone in a fluidized bed combustion steam
generating unit whereby an 80 percent reduction is required
The unit combusts coal and oil, either alone or in combination with any other
fuel and uses emerging technology for S02 emissions control whereby gases
shall not be discharged that contain in excess of 50 percent of the potential S02
emission rate and that contain S02 in excess of the emission limit determined
according to the formula in Appendix 1-3
They are in the following list whereby they cannot emit gases that contain S02
in excess of 520 ng/J (1 2 MBtu) heat input if the unit combusts coal or 215
ng/J (0 5 Ib/MBtu) heat input if the affected unit combusts oil
units that have an annual capacity factor for coal or oil of 30 percent or less and
are subject to a Federally enforceable permit limiting the operation of the unit
to an annual capacity factor of 30 percent or less
units located in noncontinental areas
affected units combusting coal or oil, alone or in combination with any other
fuel, m a duct burner as a part of a combined cycle system where 30 percent or
less of the heat input to the steam generating unit is from combustion of coal
and oil in the duct burner and 70 percent or more of the heat input to the steam
generating unit if from the exhaust gases entering the duct burner
(NOTE Typically, state regulations or state-issued permits set an emission limit for
S02.)
Verify that the particulate matter standards outlined in Appendix 1-4 are being met
(NOTE These particulate standards also apply to
Coal-fired units with a heat input capacity 29 MW (100 MBtu/h) and 73 MW
(250 MBtu/h) that were constructed, modified, or reconstructed after 19 June
1984 but before 19 June 1986
Coal-fired units with a heat input capacity greater than 73 MW (250 MBtu/h)
that started construction, modification, or reconstruction between 19 June 1984
and 19 June 1986
Incinerators over 45 metric tons/day (50 tons/day) charging rate )
Phase 1 - Section 1
Air Pollution Control
1-38
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Com pliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 11 (continued)
Verify that units that combust only coal, oil, or natural gas meet the NOx standards
outlined in Appendix 1-5 unless the unit simultaneously combusts coal or oil in a
mixture with natural gas, and wood, municipal solid waste, or any other fuel and has
an annual capacity factor for coal or oil or a mixture of these fuels with natural gas of
10 percent or less, or the unit has a heat input capacity of 73 MW (250 MBtu/h) heat
input or less that.
Only fires natural gas, distillate oil, or residual oil with a maximum nitrogen
content of 0 30 weight percent
Has a combined annual capacity factor of 10 percent or less for natural gas,
distillate oil, and residual oil with a nitrogen content of 0 30 weight percent or
less,
Are subject to a Federally enforceable requirement limiting operation of the
unit to the firing of natural gas, distillate oil, and/or residual oil with a nitrogen
content of 0.30 weight percent and limiting the operation to a combined annual
capacity of 10 percent or less for natural gas, distillate oil, and residual oil and
a nitrogen content of 0.30 weight percent
Verify that units that simultaneously combust mixtures of coal, oil, or natural gas do
not discharge NOx in excess of the limit determined by using the formula found in
Appendix 1-3 unless the unit combusts simultaneously coal or oil, or a mixture of
theses fuels with natural gas, and wood, municipal solid waste, or any other fuel and
has an annual capacity factor for coal or oil, or mixture of these fuels with natural gas
of 10 percent or less
Verify that NOx are not discharged in excess of 130 ng/J (0 30 lb/MBtu) heat input if
the unit simultaneously combusts natural gas with wood, municipal solid waste, or
other solid fuel, except coal Exempted are units that have an annual capacity factor
for natural gas of 10 percent or less and are subject to a Federally enforceable
requirements that limits operation of the affected unit to an annual capacity factor of
10 percent or less for natural gas
Verify that units that simultaneously combust coal, oil, or natural gas with by-
product/waste do not discharge NO, in excess of the limit determined by using the
formula in Appendix 1-3 unless the unit has an annual capacity factor for coal, oil,
and natural gas of 10 percent or less and is subject to a Federally enforceable
requirement that limits the operation of the unit to an annual capacity factor of 10
percent or less
Phase 1 - Section 1
Air Pollution Control
1-39
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Compliance Category; Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 12 Steam generating units
which started construction,
modification, or reconstruction
after 9 June 1989 with a
maximum design heat input
capacity of greater than or equal
to 2 9 MW (10 MBtu/h) but less
than 29 MW (100 MBtu/h) are
required to meet specific
standards for emissions of S02
(40 CFR 60 40c and 60 42c)
Determine if the facility operates steam generating units which started construction,
modification, or reconstruction after 9 June 1989 with a maximum heat input capacity
of greater than or equal to 2 9 MW (10 MBtu/h) but less than 29 MW (100 MBtu/h)
Verify that units which combust only coal do not discharge
Into the atmosphere gases containing S02 in excess of 10 percent of the
potential S02 emission rate (a 90 percent reduction)
Gases containing S02 in excess of 520 ng/J (1 2 Ib/MBtu) heat input
Verify that units which combust coal and use an emerging technology do not
discharge-
Into the atmosphere gases containing S02 in excess of 50 percent of the
potential S02 emission rate (a 50 percent reduction)
Gases that contain S02 in excess of 260 ng/J (0 60 Ib/MBtu) heat input
Verify that units which combust coal in combination with other fuels do not
discharge
Into the atmosphere gases containing S02 in excess of 10 percent of the
potential S02 emission rate (a 90 percent reduction)
Gases containing S02 in excess of the emissions limit determined by the
formula outlined in Appendix 1-6
Verify that units which combust coal in combination with other fuels and use
emerging technology do not discharge gases containing S02 in excess of:
50 percent of the potential S02 emission rate (a 50 percent reduction)
The emission limit determined by the formula outlined in Appendix 1-6
Verify that units which combust coal refuse alone or in a fluidized bed combustion
steam generating unit do not discharge gases containing S02 in excess of.
20 percent of the potential S02 rate (an 80 percent reduction)
520 n/J (1 2 lb/MBtu) heat input
(NOTE- If the unit combusts coal with coal refuse, the standards for units
combusting coal are required to be met)
Verify that units which fire oil, or any fuel other than coal, with coal refuse do not
discharge.
Into the atmosphere gases containing S02 in excess of 10 percent of the
potential S02 emission rate (a 90 percent reduction)
Gases containing S02 in excess of the emissions limit determined by the
formula in Appendix 1-6
Phase 1 - Section 1
Air Pollution Control
1-40
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Compliance Category: Air Pollution Control
Regulatory Requirements
Revtewer Checks:
A 12 (continued)
Verify that a unit which meets one of the following criteria, and combusts coal alone
or in combination with any other fuel, does not discharge SOj m excess of the
emissions limit determined by the formula in Appendix 1-6
Units with a heat input capacity of 22 MW (75 MBtu/h) or less
Units that have an annual capacity for coal of 55 percent or less
Units located in noncontinental areas
Units that combust coal in a duct burner as a part of a combined cycle system
where 30 percent or less of the heat entering the steam generating unit is from
combustion of coal in the duct burner and 70 percent or more is from exhaust
gases
Verify that units which combust oil meet one of the following
Gases are not discharged that contain S02 in excess of 215 ng/J (0 50 lb/MBtu)
heat input
No oil is combusted which contains greater than 0 5 weight percent sulfur
A 13 Steam generating units
which started construction,
modification, or reconstruction
after 9 June 1989 with a
maximum design heat input
capacity of greater than or equal
to 2.9 MW (10 MBtu/h), but
less than 29 MW (100 MBtu/h),
are required to meet specific
standards for emissions of
particulates (40 CFR 60 40c and
60 43c)
Verify that units which combust coal or mixtures of coal with other fuels and have a
heat input capacity of 8 7 MW (30 MBtu/h) or greater do not discharge particulate
matter in excess of the following
22 ng/J (0 05 lb/MBtu) heat input if the unit combusts only coal or coal with
other fuels and has an annual capacity factor for the other fuels of 10 percent
43 ng/J (0 10 lb/MBtu) heat input if the unit combusts coal with other fuels, has
an annual capacity factor greater than 10 percent for the other fuels.
Verify that units which combust wood or mixtures of wood with other fuels, except
coal, and have a heat input capacity of 30 MBtu/h or greater do not discharge
particulate matter in excess of the following
43 ng/J (0 10 lb/MBtu heat input if the units has an annual capacity factor for
wood greater than 30 percent
130 ng/J (0.30 lb/MBtu heat input if the unit has an annual capacity factor for
wood of 30 percent or less
Verify that units that combust coal, wood, or oil with a heat input capacity of greater
than 8 7 MW (30 MBtu/h) do not discharge gases with greater than 20 percent
opacity (6 min average), except for one 6 min period per hour of not more than 27
percent opacity
(NOTE Particulate matter and opacity standards apply at all times except during
periods of startup, shutdown, or malfunction)
Phase 1 - Section 1
Air Pollution Control
1-41
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checkst
A 14 Steam generating units
which started construction,
modification, or reconstruction
after 9 June 1989 with a
maximum design heat input
capacity of greater than or equal
to 2 9 MW (10 MBtu/h), but
less than 29 MW (100 MBtu/h),
are required to meet specific
monitoring standards for SOa
and particulate matter (40 CFR
60 46c and 60 47c)
Verify that continuous emissions monitoring systems are installed, calibrated,
maintained, and operated for measuring S02 concentrations and either oxygen or C02
concentrations at the outlet of the S02 control device or the outlet of the steam
generating unit if no control device is used
Verify that if continuous emissions monitoring systems for S02 are not used, the fuel
is sampled prior to combustion
Verify that a continuous monitoring system is installed, calibrated, maintained, and
operated for measuring opacity
A 15. Steam generating units
which started construction,
modification, or reconstruction
after 9 June 1989 with a
maximum design heat input
capacity of greater than or equal
to 2 9 MW (10 MBtu/h), but
less than 29 MW (100 MBtu/h),
are required to meet specific
reporting requirements (40 CFR
60 48c)
Verify that the facility submits excess emissions reports for any calendar quarter in
which opacity limits are exceeded
Verify that if there has been no excess opacity emissions, a semiannual report has
been submitted stating there were no excess emissions
Verify that units subject to the S02 emissions limits submit quarterly reports
including
Calendar dates covered in the report
Each 30-day average S02 emission rate or 30-day average sulfur content
Reasons for noncompliance
Descriptions of any correction actions taken
Phase 1 - Section 1
Air Pollution Control
1-42
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Compliance Category; Air Foliation Control
Regulatory Requirements
Reviewer Checks:
Gas Turbines
A 16 Stationary gas turbines
with a heat input at peak load
equal to or greater than 10 7
gJ/h (10 MBtu/h) based on the
lower heat value of the fuel
fired, which started
construction, modification, or
reconstruction after 3 October
1977 are required to meet
specific operations standards
(40 CFR 60 330 through
60 335)
Verify that gases that contain NOx are not emitted in excess of the amount calculated
using Formula A in Appendix 1-7 from electric utility stationary gas turbines with a
heat input at peak load greater than 107 2 gJ/h (100 MBtu/h) heat input based on the
lower heating value of the fuel fired
Verify that gases that contain NO, are not emitted in excess of the amount calculated
using Formula B in Appendix 1-7 from
Stationary gas turbines with a heat input at peak load equal to or greater than
10 7 gJ/h (10 MBtu/h) heat input but less than or equal to 107 2 gJ/h (100
MBtu/h) based on the lower heating value of the fuel fired except those with
greater than 10.7 gJ/h (10 MBtu/h) heat input that are fired with natural gas and
are being fired in an emergency
Stationary gas turbines with a manufacturer's rated base load at ISO conditions
of 30 MW (102 36 Mbtu/h) or less
Verify that gases are not discharged containing S02 in excess of 0.15 percent by
volume at 15 percent oxygen and on a dry basis
(NOTE. The following sources are exempt from meeting the N0„ emissions
limitations
Stationary gas turbines with a heat input at peak load greater than 2 9 MW (10
MBtu/h) heat input but less than or equal to 29 MW (100 MBtu/h) based on the
lower heating value of the fuel fired and that started construction before 3
October 1982
Stationary gas turbines using water or steam injection for control of NO, when
ice fog is deemed a traffic hazard
Emergency gas turbines, military gas turbines for use in other than a garrison
facility, military gas turbines installed for use as military training facilities, and
firefighting gas turbines
Regenerative cycle gas turbines with a heat input less than or equal to 29 MW
(100 MBtu/h)
Stationary gas turbines, except electric utility stationary gas turbines, with a
heat input at peak load of greater than 107 2 gJ/h (100 MBtu/h) that started
construction, modification, or reconstruction between 3 October 1977 and 27
January 1982 )
Verify that fuel stationary gas turbines using water injection to control NO, emissions
have installed and are operating a continuous monitoring system to monitor and
record fuel consumption and the ratio of water to fuel being fired in the turbine
Verify that the sulfur content and nitrogen content of the fuel being fired is being
monitored
Phase 1 - Section 1
Air Pollution Control
1-43
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i Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
Municipal Waste Combustors
A 17 Municipal waste
combustors with a capacity
greater than 225 Mg/day (250
tons/day) of municipal solid
waste or refuse-derived fuel
which started construction or
modification after 20 December
1989 are required to meet
specific operational standards
(40 CFR 60 50a through
60 58a)
Verify that gases are not discharged that contain the following constituents in excess
of the least stringent amount listed
Dioxin/fiiran in excess of 30 ng/dscm (12 grains/billion dscf), corrected to
seven percent oxygen (dry basis)
S02 in excess of20 percent of the potential S02 emission rate or 30 ppm by
volume, corrected to seven percent oxygen
Hydrogen chloride in excess of five percent of the potential hydrogen chloride
emission rate (95 percent reduction by weight or volume), or 25 ppm by
volume, corrected to seven percent oxygen (dry basis)
NO, emissions in excess of 180 ppm by volume corrected to seven percent
oxygen (dry basis)
34 mg/dscm (0 015 gr/dscf), corrected to seven percent oxygen (dry basis)
Verify that municipal waste combustors meet the operating standards for CO
emissions outlined in Appendix 1-8
Verify that the following operating practices are implemented
- Combustors do not operate at a load level greater than 110 percent of the maximum
demonstrated municipal waste combustor unit load
Combustors do not operate at a temperature exceeding 17 C (30°F) above the
maximum demonstrated particulate matter control device temperature
Verify that actions are being taken to ensure that by 11 February 1993 or within 24
months after the start-up of operation (whichever is later) each chief municipal waste
combustor operator and shift supervisor is certified
(NOTE. Exempted from these requirements are
Affected combustors that combust tires or fuel derived solely from tires and do
not combust any other municipal solid waste or refuse derived fuel
Cofired combustors
Coflred combustors that are subject to a federally enforceable permit limiting
the operation of the combustor to no more than 225 Mg/day (250 tons) of
municipal solid waste or refuse derived fuel
Municipal waste combustors only combusting medical waste )
Phase 1 - Section 1
Air Pollution Control
1-44
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Cora pliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 18 Municipal waste
combustors with a capacity
greater than 225 Mg/day (250
tons/day) of municipal solid
waste or refuse-derived fuel
which started construction or
modification after 20 December
1989 are required to meet
specific notification and record
keeping requirements (40 CFR
60 50a through 60 59a)
Verify that an operating manual is at the municipal waste combustor which is updated
yearly and indicates
Applicable standards
Procedures for receiving, handling, and feeding municipal solid waste
Start-up, shutdown, and malfunction procedures
Operational provisions for meeting emission standards
Response procedures for emergency situations
Monitoring procedures
Procedures for handling ash
Reporting and record keeping requirements
Verify that if a new municipal waste combustor is starting to operate a notice to
construct, planned start-up date, and fuels to be used at the combustor was provided
to the EPA This notification requirement also applies to cofired combustors and
municipal waste combustors which burn tires only
Verify that the following reports are submitted to the EPA Administrator
- Quarterly compliance reports
Quarterly excess emissions reports
Annual performance tests results
Quarterly reports of the daily weights of municipal solid waste and each other
fuel fired when records of this information is required to be kept
(NOTE Exempted from these requirements are
Affected combustors that combust tires or fuel derived solely from (ires and do
not combust any other municipal solid waste or refuse derived fuel
Cofired combustors
Cofired combustors that are subject to a federally enforceable permit limiting
the operation of the combustor to no more than 225 Mg/day (250 tons) of
municipal solid waste or refuse derived fuel
Municipal waste combustors only combusting medical waste )
Verify that the following records are maintained for two years
Emissions rates
Dates when excess emissions were identified and reason for excess emissions
Operating days when the minimum numbers of hours of S02 or NO, emissions
or operational data have not been obtained and the reasons
Identification of the times when S02 or NOx emissions or operational data have
been excluded from the calculation of average emission rates or parameters and
the reason for exclusion
Results of daily S02, NOx, and CO continuous emission monitoring systems
drift tests and accuracy assessments
Results of all annual performance tests
Continuous emissions monitoring data for opacity, S02, NO„, and CO, load
level data, and particulate matter control device temperature data
Names of the persons who have completed the review of the operating manual
Phase I - Section 1
Air Pollution Control
1-45
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Compliance Category: Air Poliotien Control
Regulatory Requirements
Reviewer Cheeks:
A. 18 Continued
Weights of municipal solid waste and other fuel combusted when being used in
a cofired combustor with a municipal waste capacity greater than 225 Mg/day
(250 tons)
The amount of nonmedical and medical waste combusted on a daily basis for
combustors firing both medical waste and other municipal solid waste unless it
is assumed that the total heat input to the combustor is from municipal solid
waste with a design heating value of 10,500 IcJ/ kg (4500 Btu/lb)
Incinerators
A 19 Incinerators over 45
metric tons/day (50 tons/day)
charging rate that started
construction or modification
after 17 August 1971 are
required to meet specific
emission limitations (40 CFR
60 50 through 60.54)
Verify that the limitations outlined in Appendix 1-2 are met
Phase I - Section 1
Air Pollution Control
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 20 Incinerators that started
construction or modification
after 11 June 1973 that combust
waste containing more than 10
percent sewage sludge (dry
basis) produced by municipal
sewage treatment plants, or
those that started construction or
modification after 11 June 1973
which charge more than 1000
kg (2205 lb) per day municipal
sewage sludge (dry basis) are
required to meet specific
emission standards (40 CFR
60 150 through 60 156)
Verify that particulate matter is not discharged in excess of 0 65 g/kg dry sludge input
(1 30 lb/ton dry sludge input)
Verify that the opacity of emissions does not exceed 20 percent
Verify that, except on multiple hearth, fluidized bed, or electric sludge incinerators
with a particulate emission rate less than or equal to 0 38 g/kg of dry sludge input
(0 75 lb/ton), a continuously operating flow measuring device to determine either the
mass or volume of sludge charged to the incinerator is in place, maintained, and
properly calibrated
Verify that a weighing device is available to determine the mass of any municipal
solid waste charged to the incinerator when sewage sludge and municipal solid waste
are incinerated together
Verify that multiple hearth fluidized bed or electric sludge incinerators equipped with
a wet scrubbing device have a continuously operating monitoring device that is
calibrated annually to measure and record the pressure drop of the gas flow through
the wet scrubbing device
Verify that a monitoring device, which is calibrated at least once every 24 hours, is in
place and continuously measures and records the oxygen content of the multiple
hearth fluidized bed or electric sludge incinerator exhaust gas
Verify that at least one continuously operating temperature measuring device is
installed on every hearth in the cooling and drying zones of multiple hearth furnaces
and two thermocouples are installed in each hearth in the combustion zone
Verify that at least one continuously operating temperature measuring device is
installed in the drying zone and one on the cooling zone, and a minimum of two in
the combustion zones of electric furnaces
Verify that a continuously operating fuel flow measuring device is operating on
multiple hearth fluidized bed or electric sludge incinerators
Verify that for multiple hearth, fluidized bed, or electric sludge incinerators except
those that emit particulates less than 0 38 g/kg of dry sludge input (0 75 lb/ton), a
grab sample of the sludge is collected and analyzed every day for the dry sludge
content and the volatile solids content
Verify that for multiple hearth, fluidized bed, or electric sludge incinerators, except
for those that emit particulates less than 0 38 g/kg of dry sludge input (0 75 lb/ton),
records are kept for two years of the following
The measured oxygen content of the exhaust gas
The rate of sludge charged, the temperatures, fuel flow, and total solids and
volatile solids
The measured pressure drop of the gas flow through the wet scrubbing device
Verify that the operator of any multiple hearth, fluidized bed, or electric sludge
incinerator submits a report semiannually detailing the operations of the incinerator
Phase 1 - Section 1
Air Pollution Control
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Coiapflance Category: Air Pollution Controf
Regulatory Requirements
Reviewer Checks:
A 21 Incinerators that process
beryllium-containing waste,
beryllium, beryllium oxide, or
beryllium alloys are required to
meet specific standards (40 CFR
61.30 through 61 34).
Verify that emissions to the atmosphere do not exceed 10 g (0 32 troy ounces) of
beryllium over a 24-hour period unless approval has been received for a larger
quantity of emissions.
Verify that emissions testing is done within 90 days of the startup of a new source.
Verify that monitoring sites are operated continuously
Verify that records of the emissions testing results are kept and made available for
two years
Printing Presses
A 22. Publication rotogravure
printing presses, except for
proof presses, that started
construction, modification, or
reconstruction after 28 October
1980 are required to meet
specific standards concerning
VOC emissions (40 CFR 60.430
through 60.435)
Determine if the facility operates any publication rotogravure printing presses
Verify that gases are not being discharged containing VOC equal to more than 16
percent of the total mass of VOC solvent and water used at that press during any one
performance averaging period.
(NOTE Each performance averaging period is 30 consecutive calendar days.)
Verify that presses using waterborne ink systems or solvent-bome ink systems with
solvent recovery systems record the amount of solvent and water used, solvent
recovered, and estimated emission percentage for each calendar month
Verify that these records have been maintained for two years
Acid Production Units
A 23 Nitric acid production
units that started construction or
modification after 17 August
1971 are required to meet
specific standards (40 CFR
60.70 through 60 74)
Verify that gases are not discharged that contain NO, in excess of 1.5 kg per metric
ton of acid produced (3 lb/ton) when the production is expressed as 100 percent nitric
acid.
Determine if a continuous monitoring system for the measurement of NO„ is in place.
A 24. Sulfuric acid production
units which started construction
or modification after 17 August
1971 are required to meet
specific standards (40 CFR
60.80 through 60 85)
Verify that these units do not emit gases that contain S02 in excess of 2 kg per metric
ton of acid produced (4 lb/ton) when the production is expressed as percent H2S04
Verify that the gases emitted do not exhibit 10 percent opacity or greater and they do
not contain sulfuric acid mist, expressed as H2S04, in excess of 0.075 kg per metric
ton of acid produced (0 15 lb/ton) when the production is expressed as 100 percent
h2so4.
Determine if a continuous monitoring system is in place for the measurement of S02
Sewage Sludge Incinerators
Phase 1 - Section 1
Air Pollution Control
1-48
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 25 Facility with incinerators
that fire sewage sludge must
meet specific emissions
standards (40 CFR 503 43(a)
and 503 43(b))
Verify that incinerators that fire sewage sludge meet the requirements on beryllium
and mercury emissions outlined in 40 CFR 61 30 through 61 34 and 61.50 through
61 56 (see checklist item A.22)
A 26 Sewage sludge being fed
to an incinerator is required to
meet specific concentration
limitations for lead, arsenic,
cadmium, and nickel (40 CFR
503 43(c) and 503 43(d))
Verify that the daily concentration of lead in sewage sludge fed to a sewage sludge
incinerator does not exceed the concentration calculated using Formula 1 in Appendix
1-9
Verify that the daily concentration of arsenic, cadmium, chromium, and nickel do not
exceed the concentrations calculated using Formula 2 in Appendix 1-9
A 27 The concentration of
total hydro-carbons in the exit
gas from a sewage sludge
incinerator must meet specific
limits (40 CFR 503 44)
Verify that the monthly average concentration for total hydrocarbons in the exit gas,
corrected to zero percent moisture using the correction factor from Formula 1 of
Appendix 1-10 and to seven percent oxygen using the correction factor from Formula
2 of Appendix 1-10 does not exceed 100 ppm on a volumetric basis
A 28 Sewage sludge
incinerators are required to have
continuous monitoring devices
for hydrocarbons and oxygen in
the exit gas, and a continuous
monitoring for combustion
temperature, as specified by the
permitting authority (40 CFR
503 45(a) through 503 45(0).
Determine what the permitting authority has specified in terms of continuous
monitors for combustion temperature, and hydrocarbons and oxygen in the exit gas
Verify that the required monitors are in place and operational
(NOTE.
The requirement for continuous monitors for hydrocarbons is effective 19
February 1994 unless construction of new pollution control facilities is
required, in which case the compliance date is 19 February 1995.)
The requirements for monitoring for total hydrocarbons does not apply if the
following conditions are met*
the exit gas from a sewage sludge incinerator stack is monitored continuously
for CO
the monthly average concentration of CO in the exit gas from a sewage sludge
incinerator stack, corrected for zero percent moisture and to seven percent
oxygen, does not exceed 100 ppm on a volumetric basis
the person who fires the sewage sludge incinerator retains the following
information for five years
the CO concentrations in the exit gas
a calibration and maintenance log for the instrument used to measure the CO
concentration
Class I sludge management facilities, POTWs with a design flow rate equal to
or greater than 1,000,000 gal per day, and POTWs that serve a population of
10,000 people or greater submit the monthly average CO concentrations in the
exit gas to the permitting authority on February 19 of each year
A 29 As of 19 February 1994,
sewage sludge must not be fired
in a sewage sludge incinerator if
it is likely to affect a threatened
or endangered species (40 CFR
503 45(g)).
Determine if the facility has any endangered or threatened species which might be
affected by the firing of the incinerator
Phase 1 - Section 1
Air Pollution Control
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Compliance Category; Air Pollution Omtroi
Regulatory Requirements
Reviewer Checks:
A 30 Monitoring for arsenic,
chromium, lead, and nickel shall
be done at the frequency
outlined in Appendix 1-11 (40
CFR 503 46)
Verify that monitoring is done at the frequency outlined in Appendix 1-11
(NOTE.
After two years of monitoring the permitting authority might reduce the
required frequency.
Beryllium, mercury, and air pollution control device operating parameters will
be monitored at the frequency designated by the permitting authority)
The requirements for monitoring for total hydrocarbons does not apply if the
following conditions are met
the exit gas from a sewage sludge incinerator stack is monitored continuously
for CO
the monthly average concentration of CO in the exit gas from a sewage sludge
incinerator stack, corrected for zero percent moisture and to seven percent
oxygen, does not exceed 100 ppm on a volumetric basis
the person who fires the sewage sludge incinerator retains the following
information for five years
the CO concentrations in the exit gas
a calibration and maintenance log for the instrument used to measure the CO
concentration
Class I sludge management facilities, POTWs with a design flow rate equal to
or greater than one million gal per day, and POTWs that serve a population of
10,000 people or greater submit the monthly average CO concentrations in the
exit gas to the permitting authority on February 19 of each year)
Phase 1 - Section 1
Air Pollution Control
l-SO
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Compliance Category: Air Pollution Control
Regulatory Requirement#
Reviewer Cheeks:
A 31. Individuals who fire
sewage sludge in an incinerator
are required to keep specific
information on file for five
years (40 CFR 503 47).
Verify that the following information is kept on file for five years'
The concentration of lead, arsenic, cadmium, chromium, and nickel in the
sewage sludge fed to the incinerator
The total hydrocarbons concentration in the exit gas from the sewage sludge
incinerator stack
Information that indicates the National Emissions Standards for beryllium and
mercury are met
The combustion temperatures, including the maximum combustion temperature
for the incinerator
Values for the air pollution control device operating parameters
The oxygen concentrations and information used to measure moisture content
in the exit gas from the sewage sludge incinerator stack
The sewage sludge feed rate
The stack height for the incinerator
The dispersion factor for the site where the incinerator is located
The control efficiency for lead, arsenic, cadmium, chromium, and nickel for
each incinerator
The risk specific concentrations for chromium
A calibration and maintenance log for the instruments used to measure the total
hydrocarbons and oxygen content in the exit gas and the combustion
temperature
(NOTE The requirements for recordkeeping for total hydrocarbons does not apply if
the following conditions are met
The exit gas from a sewage sludge incinerator stack is monitored continuously
for CO
The monthly average concentration of CO in the exit gas from a sewage sludge
incinerator stack, corrected for zero percent moisture and to seven percent
oxygen, does not exceed 100 ppm on a volumetric basis
The person who fires the sewage sludge incinerator retains the following
information for five years
The CO concentrations in the exit gas
A calibration and maintenance log for the instrument used to measure the CO
concentration
Class I sludge management facilities, POTWs with a design flow rate equal to
or greater than one million gal per day, and POTWs that serve a population of
10,000 people or greater submit the monthly average CO concentrations in the
exit gas to the permitting authority on February 19 of each year)
Phase 1 - Section 1
Air Pollution Control
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 32 Class I sludge
management facilities, POTWs
with a design flow rate equal to
or greater than 1,000,000
gal/day (3,785,412 L/day), and
POTWs that serve 10,000
people or more are required to
submit specific information to
the permitting authority (40
CFR 503 46)
Verify that the following information pertaining to incinerators is submitted to the
permitting authority by 19 February of each year
The concentration of lead, arsenic, cadmium, chromium, and nickel in the
sewage sludge fed to the incinerator
The total hydrocarbons concentration in the exit gas from the sewage sludge
incinerator stack
Information that indicates the National Emissions Standards for beryllium and
mercury are met
The combustion temperatures, including the maximum combustion temperature
for the incinerator
Values for the air pollution control device operating parameters
The oxygen concentrations and information used to measure moisture content
in the exit gas from the sewage sludge incinerator stack
The sewage sludge feed rate
The stack height for the incinerator
The dispersion factor for the site where the incinerator is located
The control efficiency for lead, arsenic, cadmium, chromium, and nickel for
each incinerator
The risk specific concentrations for chromium
A calibration and maintenance log for the instruments used to measure the total
hydrocarbons and oxygen content in the exit gas and the combustion
temperature
Thermal Processing Facilities
A 33 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (50 80 metric tons) or
more per day of municipal solid
wastes are required to operate in
a manner which protect air
quality (40 CFR 240 100(a) and
240 205)
(NOTE This does not apply to hazardous, agricultural, or mining wastes )
Verify that emissions do not exceed applicable existing emission standards
Verify that all emissions, including dust from vents, are controlled
Verify that when monitoring instrumentation indicates excessive emissions,
appropriate adjustments are made to lower the emission to acceptable levels
Gasoline
A 34 Leaded gasoline shall not
be introduced into any motor
vehicle that is labeled unleaded
gasoline only, or that is
equipped with a gasoline tank
filler inlet designed for
introduction of unleaded
gasoline (40 CFR 80.22(a))
Determine what grades of gasoline are used, where they are dispensed, and what
controls are in place to ensure proper fueling of vehicles by interviewing personnel
A 35 Fuel pumps are required
to display specific signs (40
CFR 80 22(d) and 80 22(e))
Inspect the facility gas stations to ensure that
Signs stating the only unleaded gas should be introduced into labeled vehicles
are displayed at each pump stand
Nozzles are properly sized
Each fuel pump is labeled indicating the type of fuel, e.g, UNLEADED
GASOLINE or CONTAINS LEAD ANTI-KNOCK COMPOUNDS.
Phase 1 - Section 1
Air Pollution Control
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 36 Gasoline pumps
dispensing oxygenated gasoline
are required to meet specific
labeling requirements (40 CFR
80 35)
Determine if the facility is located in an area with an oxygenated gasoline program
with a minimum oxygen content per 1 gal (3 79 L) or minimum oxygen content
requirements in conjunction with a credit program
Verify that if the facility is located in such an area, each gasoline pump dispensing
oxygenated gasoline at a retail outlet has a label attached during the control period
that states "The gasoline dispensed from this pump is oxygenated and will reduce CO
pollution from motor vehicles"
Verify that if the facility is located in an area with an oxygenated gasoline program
with a credit program and no minimum oxygen content requirement, the fuel pump at
a retail outlet in the control area has the following label The fuel dispensed from this
pump meets the requirements of the Clean Air Act as part of a program to reduce CO
pollution from motor vehicles
(NOTE Consult with state and local authorities concerning control areas and control
periods)
A 37 During 1992 and later
high ozone seasons and
regulatory control periods
gasoline shall not be sold,
offered for sale, imported,
dispensed, supplied, or
transported that exceeds specific
Re id vapor pressure standards
(40 CFR 80 27(a)(2) and
80 80(d))
Verily that facilities are monitored as indicated
Retailers and wholesale purchaser-consumers during the high ozone season (1
June to 15 September of any year)
Importers, distributors, resellers, or carriers during the regulatory control
period (1 May to 15 September of any year)
Verify that a standard of 9 0 psi (62 05 kPa) is not exceeded for all designated
volatility attainment areas
Verify that the standards outlined in Appendix l-l are met for any designated
volatility nonattainment areas (see 40 CFR 81)
(NOTE Gasoline which contains denatured, anhydrous ethanol of at least nine
percent and no more than 10 percent may exceed the Reid vapor pressure standards
outlined in Appendix 1-1 by 1 0 psi (6 89 kPa))
A 38 As of 1 October 1993 no
dtesel fuel shall be distributed,
transported, offered for sale, or
dispensed for use in motor
vehicles unless it is free of the
dye 1,4- dialkylammoanthr-
aquinone and has an octane
index of at least 40 or a
maximum aromatic content of
35 volume percent and a sulfur
percentage less than 0 05
percent (40 CFR 80 24(a)(1)
and 80 29(a))
Verify that the dye, which is blue green, is not used in the fuel
Phase 1 - Section I
Air Pollution Control
1-53
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AirPoHotiwi Control / -J" V, A
Reviewer Checks: : ¦ V
A 39. After 1 January 1996
retailers and wholesale
purchaser-consumers (see
definitions) handling over
10,000 gal/mo {37,854.12
L/mo) of fuel are required to
provide specific equipment on
dispensing pumps (40 CFR
80 220)).
Determine if the facility handles over 10,000 gal/mo (37,854.12 L/mo) of fuel.
Verify that each pump from which gasoline or methanol is introduced into motor
vehicles is equipped with a nozzle that dispenses fuel at a flow rate not exceeding 10
gal/min (37.85 L).
(NOTE:
After 1 January 1998 this requirements applies to every retailer and wholesale
purchaser-consumer regardless of size
This requirement does not apply to pumps that are shown to be dedicated to
heavy-duty vehicles.)
National Emission Standards for
Hazardous Air Pollutants (NESHAP)
(NOTE Where facility operations are such that they emit or have the potential to emit a regulated hazardous air
pollutant, the facility must meet the applicable emission standard (NESHAP) for that hazardous air pollutant. The auditor
must determine the applicability of NESHAP categories (see 40 CFR 61). Step A.41 provides general NESHAP
provisions. Steps A.42 through A 48 cover some specific NESHAP categories.)
General
A.40 Documentation relating
to the construction modification,
and operation of NESHAP
sources must be maintained (40
CFR 61 11,61 12-61 14)
Review documents applicable to the construction, modification, or operation of any
stationary sources which emit hazardous air pollutants. Check the following
Completeness and accuracy of the information forwarded to regulatory
agencies (e.g., emission test results, monitoring data, etc),
Approvals and/or subsequent correspondence from regulators (e g, waiver of
compliance).
Fugitive Emissions
A 41. The emission of VHAPs,
which includes vinyl chlorides
and benzene, from pumps,
compressors, pressure relief
devices, sampling connection
systems, flanges and other
connectors, and product
accumulator vessels operating
in VHAP service, are required
to be managed according to
specific requirements (40 CFR
61 240 through 61 242-1,
61 242-10,61 246, and 61 247)
Determine where the facility operates sources in VHAP service.
Verify that when a leak is detected
A weatherproof and readily visible identification marked with the equipment
identification number is attached to the leaking equipment
The identification is removed only after no leak has been detected for two
months or the leak is repaired
Leaks detected for pumps, compressors, pressure-relief devices in liquid
service, and flanges are recorded in a log and maintained for two years at a
readily accessible location.
Verify that the following records are maintained.
A list of identification numbers of all equipment to which a standard applies
A list of equipment designated for no detectable emissions
Dates of compliance tests
A list of identification numbers for equipment in vacuum service
Information and data used to demonstrate that a piece of equipment is not in
VHAP service.
Verify that a semiannual report listing the number of leaks identified, items which
were not repaired, explanation of repair delays or infeasibility of a shutdown, dates of
shutdowns, and revisions to previous reports is submitted to the EPA Administrator.
Phase 1 - Section 1
Air Pollution Control
1-54
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks?
A 42 The emission of VHAPs,
which includes vinyl chlorides
and benzene, from pumps in
VHAP service are required to
be monitored and controlled (40
CFR61 240 through 61 242-2)
Determine where the facility operates pumps in VHAP service
Verify that pumps meet the following standards
- They are visually inspected weekly for leaks
They are monitored monthly using standard test methods for leaks
Leaks are repaired within 15 days with a first attempt within 5 days
(NOTE: Exemptions include
Pumps equipped with properly operating dual mechanical seal systems are
exempt from the monitoring requirements
Pumps designated for no detectable emissions, as indicated by a reading of less
than 500 ppm above background, only have to comply with the repair
requirements if there is no externally actuated shaft penetrating the pump house
and it is tested as having no detectable emissions
Pumps equipped with a closed-vent system capable of capturing and
transporting any leakage from the seal or seals to a control device are exempt
from all standards
Pumps in unmanned plant sites are exempt from weekly inspection
requirements if each pump is visually inspected as often as possible and at least
monthly)
A 43 The emission of VHAPs,
which includes vinyl chlorides
and benzene, from compressors
in VHAP service are required to
be monitored and controlled (40
CFR61 240 through 61 242-1,
and 61 242-3)
Determine if the facility operates compressors in VHAP service
Verify that compressors meet the following
They are equipped with a seal system that includes a barrier fluid system and
that prevents leakage of process fluids and one of the following
Operate with the barrier fluid at a pressure greater than the compressor stuffing
box pressure
They are equipped with a barrier fluid system that is connected by a closed-
vent system to a control device
They are equipped with a system that purges the barrier fluid into a process
stream with zero VHAP emissions
The barrier fluid is not in VHAP service
Barrier fluid systems are equipped with a sensor to detect the failure of the seal
system, barrier fluid system, or both, and sensors are checked daily or have an
audible alarm unless the compressor is located within the boundary of an
unmanned plant site
Leaks are repaired within 15 days with a first attempt within five days
(NOTE Exemptions include
Compressors equipped with closed vent systems for capturing and transporting
leakage into a control device are exempt from seal system requirements
Compressors designated for no detectable emissions are exempt form all
requirements if it is demonstrated to be operating with an instrument reading of
less than 500 ppm above background and is tested for compliance annually )
Phase 1 - Section 1
Air Pollution Control
1-55
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 44 The emission of VHAPs,
which includes vinyl chlorides
and benzene, from pressure
relief devices, sampling
connection systems, flanges and
other connectors, and product
accumulator vessels operating
in VHAP service are required to
be monitored and controlled (40
CFR61 240 through 242-1,
61 242-4,61 242-5,61 242-8,
and
61 242-9)
Determine where the facility operates sources in VHAP service.
Verify the pressure relief devices in gas/vapor service meet the following, except
during pressure releases
They are operated with no detectable emissions as indicated by an instrument
reading of less than 500 ppm above background
After a pressure release the device is returned to a state of no detectable
emissions within five days
(NOTE Pressure relief devices equipped with a closed-vent system capable of
capturing and transporting leakage to a control device are exempted from the listed
requirements)
Verify that sampling connectors are equipped with a closed-purge system or closed
vent system that does one of the following
Returns the purged process fluid directly to the process line
Collects and recycles the purged process fluid
Is designed and operated to capture and transport all purged process fluid to a
control device
(NOTE- In situ sampling systems are exempt from the requirements for sampling
connectors.)
Verify that pressure relief devices in liquid service and flanges and other connectors
are monitored within five days if evidence of a potential leak is found by visual,
audible, olfactory, or any other detection method, and repair is done within 15 days.
Verify that product accumulator vessels are equipped with a closed-vent system
capable of capturing and transporting any leakage from the vessel to a control device.
A 45 The emission of VHAPs,
which includes vinyl chlorides
and benzene, from pumps,
compressors, pressure relief
devices, sampling connection
systems, flanges and other
connectors, and product
accumulator vessels operating
in VHAP service, are required
to be managed according to
specific requirements (40 CFR
61.240 through 61.242-1,
61.242-10,61.246, and 61.247)
Determine where the facility operates sources in VHAP service.
Verify that when a leak is detected:
A weatherproof and readily visible identification tag marked with the
equipment identification number is attached to the leaking equipment
The identification tag is removed only after no leak has been detected for two
months or the leak is repaired
Leaks detected for pumps, compressors, pressure-relief devices in liquid
service, and flanges are recorded in a log and maintained for two years at a
readily accessible location.
Verify that the following records are maintained
A list of identification numbers of all equipment to which a standard applies
A list of equipment designated for no detectable emissions
Dates of compliance tests
A list of identification numbers for equipment in vacuum service
Information and data used to demonstrate that a piece of equipment is not in
VHAP service
Verify that a semiannual report listing the number of leaks identified, items which
were not repaired, explanation of repair delays or infeasibility of a shutdown, dates of
shutdowns, and revisions to previous reports submitted to the EPA Administrator.
Phase 1 - Section 1
Air Pollution Control
1-56
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Cheeks:
A 46. Valves and lines in
VHAP service, this includes
vinyl chlorides and benzene, are
required to be properly
operating and monitored
(40 CFR61 242-6,61 242-7,
61.243-1,61 246, and 61 247)
Determine what valves and lines at the facility are in VHAP service
Verify that open-ended valves or lines are equipped with a cap, blind flange, or
second valve that seals the open end at all times except during operations requiring
process fluid flow through the valve or line
Verify that open-ended valves or lines with a second valve are operated so that the
valve on the process fluid end is closed before the second valve is closed
Verify that valves are properly operated and monitored-
Valves are monitored monthly except that valves for which a leak has not been
detected for two successive months may be monitored quarterly until a leak is
detected
After notifying the EPA Administrator the following practices may be used
after two consecutive quarterly leak detection periods where the percentage of
valves leaking is equal to or less than 2 0, the operator may begin to skip one of
the quarterly leak detection periods
after five consecutive quarterly leak detection periods where the percentage of
the valves leaking is equal to or less than 2 0, the operator may begin to skip
three quarterly leak detection periods
repair is done within 15 days of leak detection
(NOTE The following valves are exempted from the identified requirements
Valves designated for no detectable emissions are exempt from the monthly
monitoring requirements if there is no external actuating mechanism in contact
with the process fluid and the valve is tested for compliance annually
Valves designated as unsafe-to-monitor are exempt from the monthly
monitoring requirements if it is demonstrated that the valve is unsafe to
monitor and there is a written plan requiring monitoring of the valve during
safe-to-monitor times
Valves designated as difficult to monitor are exempt from the monthly
monitoring requirements if it is demonstrated that the valve cannot be
monitored without elevating the monitoring personnel more than 2 m (6 56 ft)
above a support surface and a written plan is followed that requires monitoring
of the valve at least once a year.)
(NOTE- Repair may be delayed if the repair is technically mfeasible or if the
equipment is isolated)
Verify that when a leak is detected-
A weatherproof and readily visible identification tag marked with the
equipment identification number is attached to the leaking equipment
Tne identification tag is removed only after no leak has been detected for two
months or the leak is repaired
Verify that the following records are maintained:
A list of identification numbers of all equipments to which a standard applies
A list of equipment designated for no detectable emissions
Dates of compliance tests
A list of identification numbers for equipment in vacuum service
Information and data used to demonstrate that a piece of equipment is not in
VHAP service
Verify that a semiannual report listing the number of leaks identified, items which
were not repaired, explanation of repair delays or infeasibility of a shutdown, dates of
shutdowns, and revisions to previous reports is submitted to the EPA Administrator.
Phase 1 - Section 1
Air Pollution Control
1-57
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Cheeky ..
A 47 Systems and devices
used to control VHAP
emissions, including benzene
and vinyl chloride emissions,
shall be properly operated (40
CFR61 242-11,61.246, and
61 247)
Verify that closed-vent systems and control devices used to control VHAP emissions
meet the following:
Vapor recovery systems are designed and operated to recover the organic
vapors vented to them with 95 percent efficiency or greater
Enclosed combustion devices are designed and operated to reduce the VHAP
and benzene emissions vented to them with an efficiency of 95 percent or
greater or provide a minimum residence time of 0 50 sec at a minimum
temperature of 7606 C (1400° F)
Closed-vent systems have no detectable emissions and are monitored annually
and leaks repaired within 15 days with a first attempt within five days
These systems are operated at all time when emissions may be vented to them.
Verify that for closed vent system and control devices the following records are kept
in a readily accessible location:
Detailed schematics
Dates and descriptions of any changes to the system
Periods when they are not operating
Dates of startups and shutdowns.
Dry Cleaning Operations
Petroleum Solvent Dry Cleaning
A 48. Petroleum solvent dry
cleaning dryers, washers, filters,
stills, and settling tanks at
petroleum dry cleaning plants
are required to meet specific
standards of operation (40 CFR
60 620 through 60 625)
(NOTE. These requirements apply to petroleum dry cleaning plants with a total
manufacturers' rated dryer capacity equal to or greater than 38 kg (84 lb) that started
construction or modification after 14 December 1982, except for dryers installed
between 14 December 1982 and 21 September 1984 in a plant with an annual solvent
consumption level less than 4,700 gal (17,7391 44 L))
Verify that dryers are solvent recovery dryers
Verify that the petroleum solvent filters are cartridge filters that are drained in their
sealed housing for at least eight hours before their removal.
Determine if the facility has been granted approval from the EPA to use alternate
equipment or procedures to reduce VOC emissions
Perchloroethylene Dry Cleaning
Phase 1 - Section 1
Air Pollution Control
1-58
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Compliance Category; Air Pollution CotltroJ
Regulatory Requirements
A 49 Existing dry cleaning
systems that use
perch loroethylene are required
to use specific emissions control
devices (40 CFR 63 322(a),
63 322(e), 63 322(f), 63 322(h),
63 323(a), and 63 323(b))
(NOTE: See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that the dry cleaning facilities provide one of the following
The air-perch loroethylene gas-vapor stream contained in each dry cleaning
machine is routed through a refrigerated condenser or an equivalent control
device
The air-perchloroethylene gas-vapor stream contained within each dry cleaning
machine is routed through a carbon adsorber installed on the dry-cleaning
machine installed prior to 22 September 1993
Verify that if a refrigerated condenser is used to achieve compliance, temperature
measurements are made weekly and
For a refrigerated condenser on a dry-to-dry machine or a reclaimer the
temperature of the air-perchloroethylene gas-vapor stream on the oullet side is
equal to or less than 7 2 CC (45° F)
For a refrigerated condenser on a washer the difference in the temperatures of
the air-perchloroethylene gas-vapor stream entering the refrigerated condenser
and the air-perchloroethylene gas-vapor stream exiting the condenser is greater
than or equal to 11.1 °C(51 98 °F).
Verify that if a refrigerated condenser is installed on a dry-to-dry machine, dryer, or
reclaimer lo achieve compliance, it is operated.
So that the air-perchloroethylene gas-vapor stream contained within the dry
cleaning machine is not released or vented to the atmosphere while the dry
cleaning machine drum is rotating
With a diverter valve to prevent air drawn into the dry cleaning machine when
the door of the machine is open from passing through the refrigerated
condenser
Verify that if the dry cleaning machine is a transfer machine system located at a major
source it is contained inside a room enclosure that is
Constructed of materials impermeable to perch loroethylene
Designed and operated to maintain a negative pressure at each opening at all
times that the machine is operating
Operated to vent all air from the room enclosure through a carbon adsorber or
an equivalent control device
Equipped with a separate carbon adsorber
Verify that if a carbon adsorber is used for a transfer machine located at a major
source contained inside a room enclosure, the concentration of the perchloroethylene
in the exhaust is measured weekly and is less than or equal to 100 ppm by volume
Phase 1 - Section 1
Air Pollution Control
1-59
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CoraplianceCategory: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 50 New dry cleaning
systems that use
perchloroethylene are required
to use specific emission control
devices (40 CFR 63 322(b),
63 322(e), and 63 323(a)(1))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards )
Verify that the air-perch loroethylene gas-vapor stream contained within each dry
cleaning machine is routed through a refrigerated condenser or an equivalent control
device
Verify that emissions of perchloroethylene during the transfer of articles between the
washer and dryer is eliminated
Verify that the air-perchloroethylene gas-vapor stream from inside the dry cleaning
machine drum is passed through a carbon adsorber, or equivalent control device,
immediately before or as the door of the dry cleaning machine is opened if the dry
cleaning machine is located at a major source.
Verify that if a refrigerated condenser is used to achieve compliance on a dry-to-dry
machine or a reclaimer, temperature measurements are made weekly and the
temperature of the air-perchloroethylene gas-vapor stream on the outlet side is equal
to or less than 7.2 °C (45 °F)
Verify that if a refrigerated condenser is installed on a dry-to-dry machine, dryer, or
reclaimer to achieve compliance, it is operated
So that the air-perchloroethylene gas-vapor stream contained within the dry
cleaning machine is not released or vented to the atmosphere while the dry
cleaning machine drum is rotating
With a diverter valve to prevent air drawn into the dry cleaning machine from
passing through the refrigerated condenser when the door of the machine is
open
A 51 Perchloroethylene dry
cleaning systems are required to
be operated according to
specific standards (40 CFR
63 322(c) and 63 322(d))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that the door of each dry cleaning machine is closed immediately after
transferring articles to or from the machine and the door is kept closed at all times
Verify that the dry cleaning systems are operated and maintained according to
manufacturers specifications and recommendations
A 52 Carbon absorbers that are
used as a method of emissions
control at perchloroethylene dry
cleaners are required to meet
specific parameters (40 CFR
63 322(g), 63 323(b), and
663 323(c))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards.)
Verify that carbon absorbers are not bypassed to vent or release any air-
perchloroethylene gas-vapor stream to the atmosphere at any time
Verify that the carbon adsorber is monitored weekly to determine that the
perchloroethylene concentration in the exhaust is equal to or less than 100 ppm by
volume
Phase 1 - Section 1
Air Pollution Control
1-60
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 53 Perchloroethylene dry
cleaners are required to drain all
cartridge filters and handle the
waste according to specific
procedures (40 CFR 63 322(i)
and 63 3220))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards )
Verify that all cartridge filters are drained in their housing, or other sealed container,
for a minimum of 24 hours or treated in an equivalent manner before removal from
the dry cleaning facility
Verify that all perchloroethylene and wastes that contain perchloroethylene in solvent
tanks or solvent containers with no perceptible leaks
A 54 Perchloroethylene dry
cleaning systems are required to
be inspected for perceptible
leaks (40 CFR 63 322(k) and
63 322(1))
(NOTE See Appendix 1 -12 for a table outlining which dry cleaning facilities are
required to comply with these standards )
Verify that the following components are inspected weekly for perceptible leaks
while the dry cleaning system is operating
Hose and pipe connections, fittings, couplings, and valves
Door gaskets and seatings
Filter gaskets and seatings
Pumps
Solvent tanks and containers
Water separators
Muck cookers
Stills
Exhaust dampers
Diverter valves
Cartridge filter housings
(NOTE When total dry cleaning facility consumption is less than the following,
inspections can be done biweekly
A total perchloroethylene consumption of the dry cleaning facility is less than
530 L/yr (140 gal/yr) for existing dry-to-dry machines and ancillary equipment
located in a dry cleaning facility that includes only dry-to-dry machines and
each existing transfer machine system and its ancillary equipment, as well as
each existing dry-to-dry machine and its ancillary equipment, located in a dry
cleaning facility that includes both transfer machine systems and dry-to-dry
machines
A perchloroethylene consumption of the dry cleaning facility of less than 760
L/yr (200 gal/yr)r for each existing transfer machine system and its ancillary
equipment located in a dry cleaning facility that includes only transfer machine
systems.)
A 55 All perceptible leaks and
temperature violations are
required to be repaired within
24 h unless parts must be
ordered (40 CFR 63 322(m) and
63 322(n))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that unless parts need to be ordered, repairs are made within 24 hours of
discovery of a leak
Verify that parts are ordered within two working days of leak detection
Verify that parts are installed within five working days after receipt
Phase 1 - Section 1
Air Pollution Control
1-61
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Compliance Category: Air Pollution Control
Regulatory Retirements
Reviewer Checks:
A 56 Receipts of
perchloroethylene purchases
and a log of detailing volume
calculations and monitoring
results is required to be kept at
perchloroethylene dry cleaning
facilities for five years (40 CFR
63.324(d)).
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that receipts for the purchase of perchloroethylene are kept at the facility
Verify that the log contains the following information:
The volume of perchloroethylene purchased per month
The calculation and result of yearly perchloroethylene consumption that is
determined on the first of each month
The dates when system components are inspected for leaks and the name or
location where leaks are identified
The dates of repair and records of written or verbal orders for repair parts
The date and temperature sensor monitoring results
The date and colorimetric detector tube monitoring results if a refrigerated
condenser is used to achieve compliance.
A 57. A copy of the design
specifications and the operating
manual is required to be on site
for each perchloroethylene dry
cleaning system and each
emission control device (40
CFR 63 324(e))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards )
Verify that there is a copy of the operating manual and design specifications for each
dry cleaning system and each emission control device at the facility
A.58. A notification on the
types of machines and the
yearly of consumption of
perchloroethylene and the types
of control devices used must
have been submitted to the EPA
Administrator or delegated State
authority by 18 June 1994 (40
CFR 63 324(a))
(NOTE: See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that the dry cleaning facility submitted an initial report signed by a responsible
official and certified by a public notary that includes the following information
Name and address of the owner/operator of the dry cleaning facility
The address of the dry cleaning facility
A brief description of each type of machine at the dry cleaning facility
Documentation of the yearly perchloroethylene consumption at the dry
cleaning facility for the previous year or an estimate of the perchloroethylene
consumption
A description of the types of emission control devices and whether the control
device is currently in use or will be purchased
Documentation that room enclosures are in compliance
Phase 1 - Section 1
Air Pollution Control
1-62
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 59 Specific types of
perchloroethylene facilities are
required to submit a statement
of perchloroethylene
consumption and compliance to
the EPA Administrator or
delegated State authority (40
CFR 63 324(b))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards)
Verify that dry cleaning systems that started construction or reconstruction on or after
9 December 1991, except for systems complying with Section 112(i)(2) of the CAA
submit this statement by 22 October 1993 to the EPA Administrator or delegated
State authority
Verify that dry cleaning systems that started construction or reconstruction before 9
December 1991 submit this statement by 20 January 1994 to the EPA Administrator
or delegated State authority
(NOTE Dry cleaning facilities that do not fall into either of these two categories are
required to submit notification by 18 June 1994 )
Verify that the statement is signed by a responsible individual and certified by a
notary public and contains the following'
The yearly perchloroethylene solvent consumption limit based on the yearly
solvent consumption
Whether or not they are in compliance with 40 CFR 63 322.
(NOTE When these certified solvent consumption limits are exceeded a new
statement must be submitted)
A 60 Perchloroethylene dry
cleaning facilities that exceed
their reported solvent
consumption are required to
submit a statement compliance
status to the EPA Administrator
or delegated State authority (40
CFR 63 324(c))
(NOTE See Appendix 1-12 for a table outlining which dry cleaning facilities are
required to comply with these standards )
Verify that the statement is submitted by 23 September 1996 for the following
Each existing dry-to-dry machine and its ancillary equipment located in a dry
cleaning facility that includes only dry-to-dry machines
Each existing transfer machine and its ancillary equipment, as well as each
existing dry-to-dry machine and its ancillary equipment, located in a dry
cleaning facility that includes both transfer machine systems and dry-to-dry
machines
Each existing transfer machine and its ancillary equipment located in a dry
cleaning facility that includes only transfer machine systems
CFCs and Halons
Purchasing/Procurement
A 61 Facilities which sell
Class 1 or Class 11 substances
suitable for use as a refrigerant
in containers of less than 20 lb
(9 07 kg) are required to display
a specific sign (40 CFR
82 42(c))
Verify that a sign is displayed stating the following
It is a violation of Federal laws to sell containers of Class I and Class II
refrigerant of less than 20 lb of such refrigerant to anyone who is not properly
trained and certified to operate approved refrigerant recycling equipment
(NOTE See Appendix 1 -13 for a list of Class 1 and Class 11 substances)
Phase 1 - Section 1
Air Pollution Control
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A.62. Facilities are required to
comply with restrictions
concerning the use of CFC and
halon substitutes (40 CFR
82 174(b) through 82.174(d))
Verify that no personnel at the facility uses a substitute which they know, or have
reason to know was manufactured, processed, or imported in violation of Federal
regulations
Verify that when a substitute is used, it is an acceptable substitute and is used
according to the use restriction outlined in Appendix 1-14
Verify that unacceptable substitutes are not used (see Appendix 1-15)
A 63 As of 1 January 2015 the
use of Class II substances (see
Appendix 1-13) is forbidden
except in certain situations
(42 USC 7671d(a)).
Verify that a program is underway to eliminate the use of Class II substances unless.
The substance has been reused or recycled
It is used and entirely consumed (except for trace quantities) in the production
of other chemicals
It is used as a refrigerant in appliances manufactured prior to 1 January 2020.
A 64. No Class I or Class 11
substances suitable for use in
motor vehicles as a refrigerant
(see Appendix 1-13) can be sold
or distributed in any container
that is less than 20 lb (9.07 kg)
to any person unless that person
is trained and certified (40 CFR
82.34(b) and
82 42(b)(3))
Determine if the facility carries any of the Class I or Class II substances listed in
Appendix 1-13
Verify these substances are only sold or distributed to certified individual by
reviewing records of sales and distribution.
Verify that distribution and sales records for these substances are kept for three years.
(NOTE' Sales of these substances can be made to an uncertified individual if the
purchaser is purchasing small containers for resale only)
Repair/Recycling
A 65 In order to protect the
ozone, no person repairing or
servicing motor vehicles for
payment can service a MVAC
in any way that affects the
refrigerant unless they have
been trained and certified and
are using approved equipment
(40 CFR 82.34(a), 82.42(a),
82.42(b)(1), 82.42(b)(2), and
82.42(b)(4)).
Determine if the facility services MVAC for payment.
Verify that the individual who does the repair is certified and that the equipment
being used is approved by the EPA
Verify that the EPA Administration has been notified that there is an individual on
site who has been trained and certified that is performing MVAC repair.
Verify that the facility keeps records of where the refrigerant is sent and personnel
certification for three years.
(NOTE:
These restrictions do not become effective until 1 January 1993 when less than
100 MVAC were serviced or repaired in calendar year 1990 and the EPA
Administrator was notified of the number of vehicles serviced by 13 August
1992.
Certifications are not transferable)
Phase 1 - Section 1
Air Pollution Control
1-64
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Compliance Category: Air Pollution Control
Regulatory Requirements
Rwfewer Checks:
A 66 Persons who maintain,
service, or repair appliance,
except MVACs, and persons
who dispose of appliances,
except for small appliances,
room air conditioners, MVACs
and MVAC-like appliances are
required to be certified through
an approved technician
certification program (40 CFR
82 161)
Verify that personnel have received technician certification
(NOTE- Apprentices are exempt from this requirement if the apprentice is closely
and continually supervised by a certified technician while performing any
maintenances, service, repair, or disposal that could reasonably be expected to release
refrigerant from appliances into the environment)
A 67 No person maintaining,
servicing, repairing, or
disposing of appliances can
knowingly vent or release to the
environment any Class I or
Class II substance used as a
refrigerant (40 CFR 82.150 and
82 154(a))
Determine if the facility is maintaining, servicing, repairing, or disposing of
appliances containing refrigerants
Verify that Class I or II substances are not being vented to the atmosphere
(NOTE.
De minimis releases that are associated with good faith attempts to recycle or
recover refrigerants are not considered a violation )
These requirements apply to the following
any person servicing, maintaining, or repairing appliances except for MVACs
persons disposing of appliances, including MVAC
refrigerant reclaimers, appliance owners, recycling and recovery equipment)
A 68 No person can open
appliances, except MVACs, for
maintenance, service, or repair,
and no person can dispose of
appliances, except for small
appliances, MVAC, and
MVAC-like appliances unless
specific requirements are met
(40 CFR 82 154(b), 82 156
(a)(5)) )
Verify that the required practices outline in 40 CFR 82.156 (see checklist items A 71
through A.80) are met.
Verify that equipment is used that is certified for the appliance in question
A 69 Facilities maintaining,
servicing, or repairing
appliances, except for MVACs,
and facilities disposing of
appliances, except for small
appliances and MVACs, are
required to submit certification
to the EPA (40 CFR 82.162(a)).
Verify that the facility has submitted certification to the EPA that it has acquired
certified recovery or recycling equipment and is in compliance with applicable
requirements
Phase 1 - Section 1
Air Pollution Control
1-65
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Compliance Category; Air Pollution Control
Regulatory Requirements
Reviewer Checks;
A.70. Facilities which sell
Class I or Class II substances
suitable
for use as a refrigerant in
containers of less than 20 lb
(9 07 kg) are required to display
a specific sign (40 CFR
82 42(c))
Verify that a sign is displayed stating the following
It is a violation of Federal laws to sell containers of Class I
and Class II refrigerant of less than 20 lb of such refrigerant
to anyone who is not properly trained and certified to operate
approved refrigerant recycling equipment.
(NOTE1 See Appendix 1-13 for a list of Class I and Class II
substances)
A 71. Facilities are required to
comply with restrictions
concerning the use of CFC and
halon substitutes (40 CFR
82 174(b) through 82.174
(d))
Verify that no personnel at the facility uses a substitute which they
know, or have reason to know was manufactured, processed, or imported
in violation of Federal regulations.
Verify that when a substitute is used, it is an acceptable substitute
and is used according to the use restriction outlined in Appendix
1-14.
Verify that unacceptable substitutes are not used (see Appendix 1-15)
A 72. As of 1 January 2015 the
use of Class II substances (see
Appendix 1-13) is forbidden
except in certain situations (42
USC 767 ld(a».
Verify that a program is underway to eliminate the use of Class II
substances unless.
The substance has been reused or recycled
It is used and entirely consumed (except for trace quantities) in the production
of the chemicals
It is used as a refrigerant in appliances manufactured prior to 1 January 2020.
A 73 No Class I or Class II
substances suitable for use in
motor vehicles as a refrigerant
(see Appendix 1-13) can be sold
or distributed in any container
that is less than 20 lb (9 07 kg)
to any person unless that person
is trained and certified (40 CFR
82 34(b) and
82 42 (b)(3))
Determine if the facility carries any of the Class I or Class II
substances listed in Appendix 1-13
Verify these substances are only sold or distributed to certified
individual by reviewing records of sales and distribution.
Verify that distribution and sales records for these substances are
kept for three years
(NOTE Sales of these substances can be made to an uncertified
individual if the purchaser is purchasing small containers for resale
only)
A 74 Facilities which sell or
offer for sale used refrigerants
are required to meet specific
parameters (40 CFR 82 154(g)
and 82 154(h))
(NOTE' These requirements apply from 18 October 1994 to 15 May 1995 )
Verify that no Class I or Class II substances is sold or offered for
sale as a refrigerant that consists wholly or in part of used
refrigerant unless
The substance has been correctly reclaimed
The substance was used only in a MVAC or MVAC like appliance or it is
contained in an appliance that is sold or offered for sale together with the
substance
Phase 1 - Section 1
Air Pollution Control
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Compliance Category: Air Pollution Control
Regulatory Requirement?
Reviewer Check?;
A 75 In order to protect the
ozone, no person repairing or
servicing motor vehicles for
payment can service a MVAC
in any way that affects
the refrigerant unless they have
been trained and certified and
are using approved equipment
(40 CFR 82 34(a), 82 42(a),
82 42(b)(1), 82 42(b)(2), and
82 42(b)(4))
Determine if the facility services MVAC for payment
Verify that the individual who does the repair is certified and that
the equipment being used is approved by the EPA
Verify that the EPA Administration has been notified that there is an
individual onsite who has been trained and certified that is performing
MVAC repair.
Verify that the facility keeps records of where the refrigerant is sent
and personnel certification for three years
(NOTE Certifications are not transferable)
(NOTE The term "for payment" is not clearly defined For agency
facilities the interpretation will be that if the personnel repairing
or servicing MVACs is a paid employee of the facility, they must be
trained and certified)
A 76 Recycling and recovery
equipment for use in the
maintenance, service, or repair
of appliances, except MVACs
and MVAC-like appliances, or
during the disposal of
appliances except small
appliances, MVACs, and
MVAC-like appliances is
required to be certified
by an approved equipment
testing organization (40 CFR
82 158(a))
Verify that the equipment which is used is certified.
A 77 Persons who maintain,
service, or repair appliance,
except MVACs, and persons
who dispose of appliances,
except for small appliances,
room air conditioners, MVACs
and MVAC like appliances are
required to be certified through
an approved technician
certification
program (40 CFR 82 161)
Verify that personnel have received technician certification.
(NOTE Apprentices are exempt from this requirement if the apprentice
is closely and continually supervised by a certified technician while
performing any maintenances, service, repair, or disposal that could
reasonably be expected to release refrigerant from appliances into the
environment)
Phase 1 - Section 1
Air Pollution Control
1-47
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Cheeks:
A 78 No person maintaining,
servicing, repairing, or
disposing of appliances can
knowingly vent or release to the
environment any Class I or
Class II substance used as a
refrigerant (40 CFR 82 150 and
82 154(a))
Determine if the facility is maintaining, servicing, repairing, or
disposing of appliances containing refrigerants
Verify that Class I or II substances are not being vented to the
atmosphere
(NOTE De minimis releases that are associated with good faith
attempts to recycle or recover refrigerants are not considered a
violation.)
(NOTE These requirements apply to the following
Any person servicing, maintaining, or repairing appliances except for MVACs
Persons disposing of appliances, including MVAC
Refrigerant reclaimers, appliance owners, recycling and recovery equipment)
A 79 No person can open
appliances, except MVACs, for
maintenance, service, or repair,
and no person can dispose of
appliances, except for small
appliances, MVAC, and
MVAC-like appliances unless
specific requirements are met
(40 CFR 82 154(b), 82 156
(a)(5))
Verify that the required practices outline in 40 CFR 82 156 (see
checklist items A 78 through A 87) are met
Verify that equipment is used that is certified for the appliance in
question
A 80 Facilities maintaining,
servicing, or repairing
appliances, except for MVACs,
and facilities disposing of
appliances, except for
small appliances and MVACs,
are required to submit
certification to the
EPA (40 CFR 82 162(a)
Verify that the facility has submitted certification to the EPA that
it has acquired certified recovery or recycling equipment and is in
compliance with applicable requirements
(NOTE Submission of certification is required no later than 12 August
1993 or 20 days after starting business)
A 81 Facilities recovering
refrigerant from small
appliances, MVACs, and
MVAC-like appliances for the
purpose of disposal of these
appliances are required to
certify to the EPA that
appropriate recovery equipment
has been acquired (40 CFR
82 162(c))
Verify that the facility has submitted certification to the EPA that
it has acquired appropriate recovery equipment
Phase 1 - Section 1
Air Pollution Control
1-68
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Compliance Category: Air Pollution Controt
Regulatory Requirements
Reviewer Checks:
A 82 Facilities opening
appliances, except for small
appliances and MVACs for
maintenance, service, or repair
and all persons disposing of
appliances other than small
appliances, MVACs, and
MVAC-like appliances must
have at least one piece of
certified, self-contained
recovery equipment available
(40CFR 82 156(b) and
82 156(e))
Verify that the facility has at least one available piece of equipment
(NOTE' Refrigerant may be returned to the appliance from which it is recovered or
to another appliance without being recycled or reclaimed, unless the appliance is a
MVAC or MVAC-like appliance )
(NOTE Facilities that maintain, service, repair, or dispose of only appliances that
they own and contain pump out units are exempt from this requirement, but not from
other requirements of 40 CFR 82 156 )
A 83 System dependent
equipment must not be used
with appliances normally
containing more than 15 lb
(6 80 kg) of refrigerant (40 CFR
82 156(c))
Verify that system dependent equipment is not used with appliances
normally containing more than 15 lb (6 80 kg) of refrigerant unless
the system dependent equipment is permanently attached to the
appliance as a pump out unit
A 84 When appliances are
opened for service, maintenance
or repair, except for MVACs,
the refrigerant must be
evacuated in either the entire
unit or the part to be serviced, if
the part can be isolated, to a
system receiver or a certified
recovery or recycling machine
(40
CFR 82 150 and 82 156(a))
Verify that refrigerant is evacuated to either a system receiver or
certified recovery or recycling machine
Verify that a certified technician ensures that the applicable level of
evacuation has been reached in the appliance or the part before it is
opened
A 85 When appliances, except
for small appliances, MVAC
and
MVAC-like appliance are
disposed of, the refrigerant must
be evacuated from the entire
unit to a certified recovery or
recycling
machine (40 CFR 82 150 and
82 156(a))
Verify that if disposal is occurring, the refrigerant is being
evacuated to a certified recovery or recycling machine
Phase 1 - Section 1
Air Pollution Control
l-€9
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Cheeky
A 86 When appliances, except
for small appliance, MVAC,
and
MVAC-like appliances, are
opened for maintenance, service
or repair, they must be
evacuated to specific levels
before the appliance is
opened (40 CFR 82 150 and
82 156(a)(1) and 82 156(a)(2))
Verify that evacuation is done to the levels in Appendix 1-16 prior to
opening the appliance unless one of the following is met*
Evacuation of the appliance is not to be done after completion of the
maintenance service or repair, and the maintenance service or repair is not
major
The evacuation limits in Appendix 1 -16 are not possible because of leaks in the
equipment, or the refrigerant being recovered would be substantially
contaminated
The recycling or recovery equipment is certified
Verify that if evacuation is not to be done after completion of the
maintenance, service, or repair and the maintenance, service, or
repair is not major, the appliance is
Evacuated to a pressure no higher than zero psig before it is opened if it is a
high or very high-pressure appliance
Pressurized to zero psig before it is opened if it is a low pressure appliance
(NOTE Persons pressurizing low pressure appliances that use
refrigerants with boiling points at or below 85° F at 29.9 in. Hg (e g ,
CFC-11 or HCFC-123) must not use methods, such as nitrogen, that
require subsequent purging Persons pressurizing low-pressure
appliances that use refrigerants with boiling points above 85° F at
29 9 in Hg (e g. CFC 113) must use heat to raise the internal
pressure, but may use nitrogen to raise the internal pressure of the
appliance from the level attainable through use of heat to atmospheric
pressure)
Verify that if the evacuation limits in Appendix 1-16 are not possible
because of leaks in the equipment or the refrigerant being recovered
would be substantially contaminated, the person opening the
appliance
Isolates leaking from non-leaking components whenever possible
Evacuates leaking components to be opened to the lowest level that can be
attained without substantially contaminating the refrigerant, in no case
exceeding zero psig
Verify that if the recycling or recovery equipment is certified, the
technicians follow the manufacturer's directions for achieving required
recovery efficiency
A.87 Appliances, except for
small appliances, MVACs, and
MVAC-like appliances, that are
being disposed of must be
evacuated to the levels
in Appendix 1-16 (40 CFR
82.150 and 82 156(a)(3))
Verify that appliances are evacuated to the levels listed in Appendix
1-16 prior to disposal unless leaks in the appliance do not allow for
the attainment of Appendix 1-16 or would substantially contaminate the
refrigerant being recovered
Verify that if Appendix 1-16 levels are not attainable, persons
disposing of appliances
Isolate leaking from non-leaking components whenever possible
Evacuate leaking components to the lowest level that can be attained without
substantially contaminating the refrigerant (not to exceed zero psig)
Phase 1 - Section 1
Air Pollution Control
1-70
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks;
A 88 Specific evacuation
limits must be met when
opening small appliances for
maintenance, service, or repair
(40CFR 82 150 and
82 156(a)(4))
Verify that when recycling and recovery equipment manufactured prior to
15 November 1993 is used, 80 percent of the refrigerant is recovered or
the small appliance is evacuated to four in. of Hg vacuum (13 55 kPa)
Verify that when recycling and recovery equipment manufactured on or
after 15 November 1993 is used, 90 percent of the refrigerant in the
appliance is recovered when the compressor in the appliance is
operating, or 80 percent of the refrigerant when the compressor is not
operating or the small appliance is evacuated to 4 in (10 16 cm) of
mercury vacuum
A 89 Facilities which take the
final step in the disposal process
of a small appliance, room air
conditioning, MVACs, or
MVAC-like appliances must
meet specific standards (40 CFR
82 156(0, 82 166(i) and
82 166(m))
(NOTE Tins includes but is not limited to scrap recyclers and
landfill operators)
Verify that facilities
Recovers any remaining refrigerant from the appliance
Checks that the refrigerant has been evacuated from the appliance or shipment
of appliances by reviewing a signed statement from the person from whom the
appliance or shipment of appliances is obtained that all refrigerant has been
recovered
Verify that copies of signed statements are retained for three years
A 90 Facilities recovering
refrigerant for the purpose of
disposal must meet specific
standards (40 CFR 82 156(g)
and 82 156(h))
Verify that if the facility recovers refrigerant from MVACs and
MVAC-like appliances for the purpose of disposal of the appliance,
the system pressure is reduced to or below 102 mm of Hg (13.60 kPa)
vacuum
Verify that the facility recovering refrigerant from small appliances
for the purpose of disposal of the appliance does one of the
following.
Recover 90 percent of the refrigerant when the compressor in the appliance is
operating
Recover 80 percent of the refrigerant in the appliance when the compressor in
the appliance is not operating
Evacuate the small appliance to four in of Hg (13 55 kPa) vacuum
Phase 1 - Section 1
Air Pollution Control
1-71
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Cheeks:
A 91. Leaking appliances must
be repaired when specific limits
are exceeded (40 CFR 82 156
(«))
Verify that if the facility owns commercial and industrial process
refrigeration equipment normally containing more than 50 lbs or
refrigerant, all leaks are repaired if the equipment is leaking at a
rate such that the loss of refrigerant will exceed 35 percent of the
total charge during a 12-month period.
Verify that other appliances normally containing more than 50 lb (22 68
kg) of refrigerant are repaired if the appliance is leaking at a rate
such that the loss of refrigerant will exceed 15 percent of the total
charge during a 12-month period.
(NOTE- Leaks are not required to be repaired if, within 30 days, the
facility has developed a one-year retrofit or retirement plan for the
leaking equipment The plan, or a legible copy, must be kept at the
site of the equipment)
Verify that leaks have been repaired within 30 days of discovery or
within 30 days of when the leak should have been discovered, if the
facility intentionally shielded themselves from information which would
have revealed a leak.
Phase 1 - Section 1
Air Pollution Control
1-72
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CoraplianceCategory: Air Pollution Control
Regulatory Requirements
! Reviewer Checks:
Recordkeeping
A 92 Facilities that sell or
distribute any Class I or Class II
substance for use as a
refrigerant are required to retain
invoices (40 CFR 82 166(a) and
82 166(m))
Verify that facilities that sell or distribute any Class I or Class 11
substance for use as a refrigerant retain invoices indicating the name
of the purchaser, the date of sale, and the quantity or refrigerant
purchased
Verify that records are retained for three years
A 93 Facilities servicing
appliances normally containing
50 lb (22 68 kg) or more of
refrigerant are required to
supply the owner of the
appliance with documentation
as to how much refrigerant was
added and the owner of the
appliance must retain the
servicing records (40
CFR 82 1660), 82 166 (k), and
82 166(m))
Verify that documentation of servicing and amounts of refrigerant added
is provided to the appliance owner and retained for three years
A 94 Facilities recovering
refrigerant from small
appliances, MVACs, and
MVAC-like appliances for the
purpose of disposal of these
appliances are required to
certify to the EPA that
appropriate recovery equipment
has been acquired (40 CFR
82 162(c)).
Verify that the facility has submitted certification to the EPA that it has acquired
appropriate recovery equipment
A 95 Facilities opening
appliances, except for small
appliances and MVACs for
maintenance, service, or repair
and all persons disposing of
appliances other than small
appliances, must have at least
one piece of certified, self-
contained recovery equipment
available (40 CFR 82 156(b)
and 82 156(e))
Verify that the facility has at least one available piece of equipment
(NOTE Refrigerant may be returned to the appliance from which it is recovered or
to another appliance without being recycled or reclaimed, unless the appliance is a
MVAC-like appliance)
Phase 1 - Section 1
Air Pollution Control
1-73
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer CbwteR
A 96 System dependent
equipment must not be used
with appliances normally
containing more than 15 lb
(6 80 kg) of refrigerant (40 CFR
82 156(c)).
Verify that system dependent equipment is not used with appliances normally
containing more than 15 lb (6 80 kg) of refrigerant
A 97. When appliances are
opened for service, maintenance
or repair, except for MVACs,
the refrigerant must be
evacuated in either the entire
unit or the part to be serviced, if
the part can be isolated, to a
system receiver or a certified
recovery or recycling machine
(40 CFR 82 150 and 82 156(a))
Verify that refrigerant is evacuated to either a system receiver or certified recovery or
recycling machine
A.98 When appliances, except
for small appliances, MVAC
and MVAC-like appliance are
disposed of, the refrigerant must
be evacuated from the entire
unit to a certified recovery or
recycling machine (40 CFR
82 150 and 82 156(a))
Verify that if disposal is occurring, the refrigerant is being evacuated to a certified
recovery or recycling machine.
A 99. When appliances, except
for small appliance, MVAC,
and MVAC-like appliances, are
opened for maintenance, service
or repair, they must be
evacuated to specific levels
before the appliance is opened
(40 CFR 82.150 and
82 156(a)(1) and 82 156(a)(2)).
Verify that evacuation is done to the levels in Appendix 1-16 prior to opening the
appliance unless one of the following is met.
Evacuation of the appliance is not to be done after completion of the
maintenance service or repair, and the maintenance service or repair is not
major
The evacuation limits in Appendix 1-16 are not possible because of leaks in the
equipment, or the refrigerant being recovered would be substantially
contaminated
Verify that if evacuation is not to be done after completion of the maintenance,
service, or repair and the maintenance, service, or repair is not major, the appliance is
Evacuated to a pressure no higher than zero psig before it is opened if it is a
high or very high-pressure appliance
Pressurized to zero psig before it is opened if it is a low pressure appliance
without using methods, such as nitrogen, that require subsequent purging
Verify that if the evacuation limits in Appendix 1-16 are not possible because of leaks
in the equipment or the refrigerant being recovered would be substantially
contaminated, the person opening the appliance.
Isolates leaking from non-leaking components whenever possible
Evacuates leaking components to be opened to the lowest level that can be
attained without substantially contaminating the refrigerant, in no case
exceeding zero psig
Phase 1 - Section I
Air Pollution Control
1-74
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Compliance Category: AirPolIution Control
Regulatory Requirements
Reviewer Check?:
A 100 Appliances, except for
small appliances, MVACs, and
MVAC-like appliances, that are
being disposed of must be
evacuated to the levels in
Appendix 1-16(40CFR82 150
and 82 156(a)(3))
Verify that appliances are evacuated to the levels listed in Appendix 1-16 prior to
disposal.
A 101 Specific evacuation
limits must be met when
opening small appliances for
maintenance, service, or repair
(40 CFR 82 150 and
82 156(a)(4)).
Verify that when recycling and recovery equipment manufactured prior to 15
November 1993 is used, 80 percent of the refrigerant is recovered or the small
appliance is evacuated to four in of Hg vacuum (13 55 kPa)
Verify that when recycling and recovery equipment manufactured on or after 15
November 1993 is used, 90 percent of the refrigerant in the appliance is recovered
when the compressor in the appliance is operating, or 80 percent of the refrigerant
when the compressor is not operating or the small appliance is evacuated to four in
(10 16 cm) of mercury vacuum
A 102 Facilities which take the
final step in the disposal process
of a small appliance, room air
conditioning, MVACs, or
MVAC- like appliances must
meet specific standards
(40 CFR 82 156(0, 82 166(i)
and 82 166(m))
(NOTE This includes but is not limited to scrap recyclers and landfill operators )
Verify that facilities
Recover any remaining refrigerant from the appliance
Check that the refrigerant has been evacuated from the appliance or shipment
of appliances by reviewing a signed statement from the person from whom the
appliance or shipment of appliances is obtained that all refrigerant has been
recovered
Verify that copies of signed statements are retained for three years
A 103 Facilities recovering
refrigerant for the purpose of
disposal must meet specific
standards (40 CFR 82 156(g)
and 82 156(h))
Verify that if the facility recovers refrigerant from MVACs and MVAC-like
appliances for the purpose of disposal of the appliance, the system pressure is reduced
to or below 102 mm of Hg (13 60 kPa) vacuum
Verify that the facility recovering refrigerant from small appliances for the purpose of
disposal of the appliance does one of the following
Recovers 90 percent of the refrigerant when the compressor in the appliance is
operating
Recovers 80 percent of the refrigerant in the appliance when the compressor in
the appliance is not operating
Evacuates the small appliance to four in of Hg (13 55 kPa) vacuum
Phase 1 - Section 1
Air Pollution Control
1-75
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Compliance Category: Air Pollution Control
Regulatory Requirement?
Reviewer Checks:
A. 104 Leaking appliances
must be repaired when specific
limits are exceeded
(40 CFR 82 156(1)).
Verify that if the facility owns commercial and industrial process refrigeration
equipment, all leaks are repaired if the equipment is leaking at a rate such that the loss
of refrigerant will exceed 35 percent of the total charge during a 12-month period
Verify that other appliances normally containing more than 50 lb (22 68 kg) of
refrigerant are repaired if the appliance is leaking at a rate such that the loss of
refrigerant will exceed 15 percent of the total charge during a 12-month period
(NOTE Leaks are not required to be repaired if, within 30 days, the facility has
developed a one-year retrofit or retirement plan for the leaking equipment The plan,
or a legible copy, must be kept at the site of the equipment)
Verify that leaks have been repaired within 30 days of discovery or within 30 days of
when the leak should have been discovered, if the facility intentionally shielded
themselves from information which would have revealed a leak
A 105 Facilities that sell or
distribute any Class I or Class II
substance for use as a
refrigerant are required to retain
invoices (40 CFR 82 166(a) and
82 166(m))
Verify that facilities that sell or distribute any Class I or Class II substance for use as a
refrigerant retains invoices indicating the name of the purchaser, the date of sale, and
the quantity or refrigerant purchased
. Verify that records are retained for three years
A. 106. Facilities servicing
appliances normally containing
50 lb (22 68 kg) or more of
refrigerant are required to
supply the owner of the
appliance with documentation
as to how much refrigerant was
added and the owner of the
appliance must retain the
servicing records (40 CFR
82 1660) and 82 I66(k))
Verify that documentation of servicing and amounts of refrigerant added is provided
to the appliance owner and retained for three years
Air Pollution Alert and Emergency Plans
A 107 States may require
certain facilities to prepare and
implement air episode plans for
the reduction of emissions in the
event of an air pollution alert or
emergency (see state
regulations)
If an air or emergency plan is required by the state regulations, review the facility's
plan to verify that it conforms with regulatory requirements.
If a review of good management practices with respect to air toxics is included in the
scope of the review, complete the following
Review the facility's procedures for evaluating potential releases of toxics to
the atmosphere
For areas where it has been determined that potential toxic emissions may be a
problem, review plans to reduce or eliminate those emissions
Review the facility's plan for responding to toxic air releases and verify that the
plan is being implemented
Asbestos Management
All Facilities
Phase 1 - Section 1
Air Pollution Control
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Compliance Category; Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 108 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent State enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
A 109 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding)
Determine if any new regulations have been issued since the fmalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are Federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
AIIO Facilities are required to
comply with state and local
regulations concerning asbestos
management
(EO 12088, Sect 1-1)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
Certification of individuals sampling and/or working with asbestos
Renovation and demolition procedures
Asbestos handling and disposal procedures )
Renovation and Demolition of Asbestos-Containing Structures
Phase 1 - Section 1
Air Pollution Control
1-77
-------
Compliance Category: Air Poilutiwi Control
Regulator}' Requirements
Reviewer Checks:
A. 111 Facilities that demolish
structures must meet certain
notification requirements
(40CFR61 145(a)(1),
61 145(a)(3), 61.145(b))
(NOTE. This applies to facilities that demolish structures containing at least 80 linear
m (260 linear ft) of RACM on pipes, or at least 15 m1 (160 ft2) of RACM on other
components or at least 1 m3 (35 ft3) off facility components, and facilities renovating
structures and stripping or removing at least 80 linear m (260 linear ft) of RACM on
pipes, or at least 15 m: (160 ft2) of friable asbestos on other facility components and
at least 1 m3 (35 ft3) off facility components)
Determine if the EPA has been provided with written notice of intent to demolish or
renovate at least 10 working days before demolition begins and as early as possible
before renovation begins.
Verify that the written notice contains the following information
Name and address of facility
Description of facility being renovated or demolished (size, age, prior use)
Estimates of approximate amount (linear ft or surface area) of asbestos present
in the structure
Location of the structure
Scheduled start and completion dates of renovation or demolition
Nature of planned demolition or renovation methods to be used
Procedures for asbestos emissions control
Name and location of waste disposal site where asbestos will be disposed
Whether or not it is a revised notification
Certification that at least one trained person will supervise
Name of the facility owner/operator and telephone number
(NOTE- Facilities are also required to submit notifications following these guidelines
for facilities being demolished under an order of a state or local governmental agency
because the facility is structurally unsound and in danger of imminent collapse )
A. 112 Facilities demolishing a
facility with RACM of less than
80 linear m (260 linear ft) on
pipes and less than 15 m2 (160
ft2) on other facility components
and less than I m3 (35 ft3) off
facility components are required
to submit notification of
demolition (40 CFR
61 145(a)(2), 61.145(b))
Verify that a written notice of intent to demolish has been submitted to the
Administrator at least 10 working days before demolition and includes'
The name and address of owner and operator
Description of the facility being demolished including the size, age, and prior
use
Estimate of the approximate amount of friable asbestos present
Location of the facility
Schedule
Procedures to be used
Phase 1 - Section 1
Air Pollution Control
1-78
-------
Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 113 Facilities that demolish
or remove structures must meet
certain emission control
requirements (40 CFR
61 145(a)(1) through
61 145(a)(3), 61 145(c)(1)
through 61 145(cX3))
(NOTE This requirements applies to Facilities that demolish structures which
contain at least 80 linear m (260 linear ft) of RACM on pipes, or at least 15 m2(160
ft2) of RACM on other facility components and facilities renovating structures and
stripping or removing at least 80 linear m (260 linear ft) of friable asbestos on pipes,
or at least 15 m2 (160 ft2) of friable asbestos on other facility components or 1 m3 (35
ft3) or more off facility components)
Verify that all RACM are removed from facilities being demolished or renovated
before any wrecking or dismantling unless
It is a Category I nonfriable ACM that is not in poor condition and is not
friable
The RACM is on a facility component that is encased in concrete or other
similar material and is adequately wetted whenever exposed during demolition
It was not accessible for testing and is not discovered until after demolition
began and, as a result of demolition, the materials cannot be safely removed
It is Category II nonfriable ACM and the probability is low that the materials
will become crumbled, pulverized, or reduced to powder, during demolition
Verify that when a facility component that contains or is covered or coated with
RACM is being taken out of the facility in units or sections
They are adequately wetted when RACM is exposed during cutting and
disjointing operations
The units or sections are carefully lowered to ground level
Verify that RACM is adequately wetted when it is being stripped from facility
components while it remains in place in the facility except in renovation operation
where wetting would unavoidably damage equipment and the facility
Requests a determination from the Administrator as to whether unavoidable
damage would occur and supply Administrator with the information needed to
make the decision
Uses one of the following emission control methods
a local exhaust ventilation and collection system
a glove bag system
leaktight wrapping to contain all RACM.
A 114 Emissions from facility
components that have been
taken out in units or in sections
from facilities being demolished
under state or local orders or
facilities being demolished or
renovated with at least 80 linear
m (260 linear ft) of RACM on
pipes, or at least 15 m2 (160 ft2)
of RACM on other facility
components or at least 1 m3
(35 ft3) off facility components
must be controlled (40 CFR
61 145(c)(4) and 61 145(c)(5))
Verify that facility components are either stripped or contained in leaktight
wrappings.
Verify that facility components removed from facility as units or in sections for
stripping meet the following
RACM is adequately wet during stripping operations
A local exhaust ventilation and collection system designed and operated to
capture emissions is in use
The exhaust system exhibits no visible emissions to outside air
Verify that when wetting operations are stopped because of the temperature, a record
of the temperature is made and kept on file for two years
(NOTE For large facility components such as reactor vessels, large tanks, and steam
generators, but not beams, stripping is not required if the following are met
The component is removed, transported, stored, disposed of, or reused without
disturbing the RACM
The component is encased in leaktight wrapping and labelled)
Phase I - Section I
Air Pollution Control
1-79
-------
Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks;
A 115. Emissions from RACM
that has been removed or
stripped from facilities being
demolished under state or local
orders or facilities being
demolished or renovated with at
least 80 linear m (260 linear ft)
of RACM on pipes, or at least
15 mJ (160 ft2) of RACM on
other facility components or 1
m3 (35 ft3) or greater off facility
components must be controlled
(40CFR61 145(c)(6))
Verify that asbestos materials that have been removed or stripped meet the following
Materials are adequately wet, and remain wet until collected for disposal
Materials are carefully lowered to the ground or lower floor (not dropped or
thrown)
Materials not removed as units or in sections are transported to the ground via
dust-tight chutes or containers if they are removed more than 50 feet above
ground level.
A 116 When the temperature at
the point of wetting is below
0°C (32°F) and facilities are
being demolished under state or
local orders or facilities with at
least 80 linear m (260 linear ft)
of RACM on pipes, or at least
15 m2 (160 ft2) of RACM other
facility components or at least 1
m3 (35 ft3) off facility
components are being
demolished or renovated,
specific exemptions and
requirements apply (40 CFR
61 145(c)(7))
Verify that facility components coated or covered with RACM materials are removed
as units or in sections to the maximum extent possible.
(NOTE Wetting is not required at this temperature)
Verify that when wetting operations are stopped because of freezing temperatures, the
temperature is recorded in the areas containing the facility components at the
beginning, middle, and end of each work day.
Verify that the temperature records are kept for two years.
A 117. Facilities being
demolished under state or local
governmental agency orders
shall have the portion of the
facility containing friable
asbestos adequately wetted
dunng the wrecking operation
(40 CFR 61 145(c)(9))
Verify that in facilities being demolished under state or local governmental agency
orders the portion of the facility that contains friable asbestos materials is adequately
wetted during the wrecking operation.
A 118 When a structure is
demolished by intentional
burning, all RACM, including
Category I and II nonfhable
ACM, must be removed (40
CFR 61 145(c)( 10))
Verify that complex removal is done before burning.
Phase 1 - Section 1
Air Pollution Control
1-80
-------
Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 119 When air cleaning is
used as a method for controlling
emissions of asbestos to the
outside air, the fabric filter
collection systems are required
to meet specific standards
unless alternative equipment is
authorized for use by the EPA
(40CFR6I 152)
Verify that fabric filter collection systems meet the following requirements
Airflow permeability does not exceed 9 m3/min/m2 (30 ftJ/min/ft2) for woven
fabrics or 11 m3/min/m2 (35 ftVmin/ft2) for felted fabrics
The felted fabric weighs at least 475 g/m2 (14 oz/yd2) and is at least 1 6 mm
(1/16 in.) thick throughout
The use of synthetic fabrics containing fill yarn other than that which is spun is
avoided
Asbestos Personnel Training
A 120 No RACM shall be
stripped, removed, or otherwise
handled or distributed unless at
least one onsite representative
trained in asbestos removal is
present (40 CFR 61 145(c)(8))
Verify that trained person is present
Verify that the individual receives refresher training every two years
Asbestos Disposal
A 121 Asbestos-containing
waste materials are required to
be disposed of properly (40
CFR 61 150(a) through
61 150(b)).
(NOTE. These requirements do not apply to Categories I or II nonfriable ACM that
did not become crumbled, pulverized, or reduced to powder.)
Verify that no visible emissions are discharged to the outside air during the collection,
processing, packaging, transporting, or depositing of asbestos-containing waste
material, or that the facility uses one of the following methods
The asbestos-containing waste is adequately wetted
The asbestos-containing waste is processed into nonfriable forms
An alternative method approved by the EPA
Verify that if the waste is wetted
Asbestos waste from control devices is mixed with water to form a slurry and
the other materials are adequately wetted
No visible emissions are discharged or air cleaning is used to control the
emissions
The wetted materials are sealed in leaktight containers while wet and labeled
with the phrase CAUTION, Contains Asbestos Avoid Opening or Breaking
Container, Breathing Asbestos is Hazardous to Your Health or a label approved
by OSHA
Materials that don't fit in containers are put into leaktight wrapping
Verify that the waste generator deposits all ACM as soon as practical at one of the
following
A properly operated waste disposal site
An EPA approved site that converts RACM and asbestos-containing waste
material into asbestos-free material
Phase 1 - Section 1
Air Pollution Control
1-81
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 122 Asbestos-containing
waste must be transported
according to specific parameters
(40CFR61 150(c) through
61.150(e)).
Verify that vehicles used to transport asbestos-containing waste material are marked
indicating an asbestos dust hazard
Verify that for all ACM transported off the facility, waste shipment records are
maintained for at least two years and a copy is provided to the waste disposal site
Verify that a procedure is in place to notify the local, state, or EPA regional office if a
copy of the waste shipment record is not returned to the waste generator within 45
days after the waste was accepted by the initial transporter
A 123 Active waste disposal
sites where ACM is being
disposed are required to meet
specific standards (40 CFR
61 154(a) through 61 154(e)
and 61 154(i) through
61 1540))
Determine if the facility is operating a landfill where asbestos is being disposed
Verify that there are no visible emissions from active asbestos-containing waste
disposal sites, or that one of the following is done
At the end of each operating day, or once m a 24 hour period, the waste
material is covered with either at least 15 cm (6 in.) of compacted nonasbestos-
containing material
A resinous or petroleum based dust suppression agent is applied, waste
crankcase oil is not suitable for this purpose
An alternative method of control approved by the EPA is used
Verify that unless a natural barrier exists deterring access by the general public, either
the waste is properly covered by non-ACM daily or proper warning signs and fences
are installed and maintained as follows
Warning signs are displayed at all entrances at intervals of 100 m (330 ft) or
less along the property line of the site or the perimeter of the section of the site
where ACM is disposed and state that the site contains asbestos and warns
against creating dust
The area is adequately fenced
Verify that a copy of waste shipment records are maintained for two years
Verify that until closure, a record is kept of the location, depth, and area of asbestos-
containing waste on a map or diagram of the disposal area
Verify that upon closure, the administration receives a copy of all records
Verify that a procedure is in place to notify the administration in at least 45 days prior
to excavating or disturbing deposited asbestos-containing waste material
Phase 1 - Section 1
Air Pollution Control
1-82
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i CorapJianceCategory; Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A. 124 Inactive waste disposal
sites are required to meet
specific standards (40 CFR
61 154(0 through 61 154(h) and
61 151).
Verify that inactive waste disposal sites meet one of the following
No visible emissions are discharged
Asbestos-containing waste material is covered with at least 15 cm (6 in.) of
compacted non-ACM, and a vegetation cover is grown and maintained (In
desert areas where vegetation is difficult to maintain at least 8 cm (3 in )
additional of well-graded nonasbestos-contaimng crushed rock may be used
instead)
Cover the asbestos-containing waste material with at least 60 cm (2 ft) of
nonACM and maintain the cover to prevent exposure
Verify that unless a natural barrier exists, warning signs and a fence are installed to
deter public access
Verify that warning signs are displayed at all entrances and at intervals of 100 m (328
ft) or less and are easily read indicating the area is an asbestos waste disposal site
Verify that a procedure is in place to notify the administrator in writing at least 45
days prior to excavating or disturbing any asbestos-contaminated waste material at an
inactive waste disposal site
Asbestos in Schools
A 125 Each building that is
leased, owned, or otherwise
used as a school building is
required to be inspected for
asbestos and a report of the
inspection generated (40 CFR
763 85)
Determine which buildings at the installation are used as school buildings.
Verify that the buildings have been inspected for asbestos, including sampling, by an
accredited inspector
Verify that reinspection of all friable and nonfhable unknown or assumed ACBM
occurs every three years after a management plan is in place
Verify that each inspection and reinspection is documented in a report that is included
in the management plan
(NOTE Any building that is leased or acquired on or after 12 October 1988 that is to
be used as a school building must be inspected prior to use as a school building If
emergency use of a building is required, inspection will occur within 30 days.)
A 126 Each inspection or
reinspection is required to result
in a written assessment of all
friable known or assumed
ACBM in the school building
(40 CFR 763 88(a) through
763 88(c))
Verify that the assessment classifies the ACBM and suspected ACBM assumed to be
ACM into one of the following categories-
Damaged or significantly damaged thermal system insulation ACM
Damaged friable surfacing ACM
Significantly damaged friable surfacing ACM
Damaged or significantly damaged friable miscellaneous ACM
ACBM with potential for damage
ACBM with potential for significant damage
Any remaining friable ACBM or friable suspected ACBM
Verify that the designated person reviews the results of the inspections, reinspections,
and assessments and recommend a course of action to the local education agency
Phase 1 - Section 1
Air Pollution Control
1-83
-------
Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 127. An asbestos
management plan is required for
each school building and
submitted to the agency
designated by the governor of
the state (40 CFR 763 93)
Determine if there is a plan
Verify that plans have been submitted.
Verify that the plan is kept current and up-to-date with on-going operational and
maintenance activities
Verify that the plan was developed by an accredited management planner and
includes'
A list of the names and addresses of each school building and whether the
building contains friable ACBM, nonfriable ACBM, and friable and nonfriable
suspected ACBM assumed to be ACM
Dates of inspections
A blueprint, diagram or written description of the school building identifying
where samples were taken
A description of sampling methodologies
Analysis results
Descriptions of any assessments made
Name, address, and telephone number of the designated asbestos manager
A detailed description of preventative measures and response actions taken
Statements of accreditation
A description in the form of a blueprint, diagram, or writing of any ACBM or
suspected ACBM assumed to be ACM which remains in the school after
response actions are taken
A plan for reinspection
A description of the steps taken to inform workers, building occupants, and/or
their legal occupants about asbestos related activities
An evaluation of the resources needed to complete response actions and carry
out reinspection, operations and maintenance activities, periodic surveillance
and training activities
Verify that a copy of the plan is on file in the school administrative office and
available to workers before work beginning in any area of the building
Verify that a copy of the plan is available for inspection by representatives of the
EPA, the state, and the public within five working days after receiving a request for
inspection
Phase 1 - Section I
Air Pollution Control
1-84
-------
Cora piiance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks:
A 128 Response actions are
required to be selected and
implemented in a timely manner
and according to specific
guidelines (40 CFR 763 90(a)
through 763 90(0)
Verify that if damaged or significantly damaged thermal system insulation ACM is
present in the building, the facility will
At least repair the damaged area
Remove the damaged material if it is not feasible, due to technological
difficulties, to repair the damage
Maintain all thermal system insulation ACM and its coverings in an intact state
and undamaged condition
Verify that if damaged friable surfacing ACM or damaged friable miscellaneous
ACM is present, the facility uses one of the following response actions
Encapsulation
Enclosure
Removal
Repair
Verify that if significantly damaged friable surfacing ACM or significantly damaged
friable miscellaneous ACM is present in a building, the facility
Immediately isolates the functional space and restricts access unless isolation is
not needed to protect human health
Removes the material in the functional space or, depending on whether
enclosure or encapsulation is sufficient to protect human health and the
environment, enclose or encapsulate
Verify that if any friable surfacing ACM, thermal system insulation ACM, or friable
miscellaneous ACM that has potential for damage is present in the building, an
appropriate operations and maintenance (O&M) program is implemented
Verify that if any friable surfacing ACM, thermal insulation ACM, or friable
miscellaneous ACM that has potential for significant damage is present, the facility
Implements an appropriate O&M program
Institutes preventative measures to eliminate the reasonable likelihood that the
ACM will become significantly damaged, deteriorated, or delaminated
Removes the material as soon as possible if appropriate preventative measures
cannot be implemented
A 129 An accredited person
must be designated by the local
education agency to perform
specific tasks and functions
(40 CFR 763 84(g), 763 88(d))
Verify that the person designated to ensure that requirements concerning asbestos in
school are implemented correctly is trained in the following
Health effects of asbestos
Detection, identification, and assessment of ACM
Options for controlling ACM
Asbestos management programs
Relevant state and Federal regulations
Phase 1 - Section 1
Air Pollution Control
1-85
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Compliance Category: Air Pollution Control
Regulatory Requirements
Reviewer Checks;
A. 130 An operations,
maintenance and repair program
is required to be developed
whenever any friable ACBM is
present or assumed to be present
in a building that is used as a
school building (40 CFR
763 91(a) through 763 9(e)).
(NOTE: Any material identified as nonfriable ACBM or nonfriable-assumed ACBM
must be treated as friable ACBM when the material is about to become friable as a
result of activities performed in the school building.)
Verify that the following actions are taken during small scale, short duration O&M
operations-
Entry is restricted into the area by persons other than those needed to perform
the maintenance project (this can be done by isolating the area or by
scheduling)
Signs are posted to prevent entry by unauthorized persons
Air-handling systems are shutoff or temporarily modified and other sources of
air movement are restricted
Whatever work practices are required to prohibit the spread of any released
fibers are used
All fixtures or other components are cleaned in the immediate work area
The asbestos debris and other cleaning materials are placed in a sealed,
leaktight container.
Verify that response actions for any maintenance activities disturbing friable ACBM,
other than small-scale, short-duration maintenance are designed by persons accredited
to design response actions and conducted by persons accredited to conduct response
actions.
A. 131 Warning labels are
required to be attached
immediately adjacent to any
friable and nonfriable ACBM
and suspected ACBM assumed
to be ACM located in routine
maintenance areas (such as
boiler rooms) at each school
building (40 CFR 763 95)
Verify that label are in place in the following areas
Where friable ACBM was responded to by any means other than removal
Where there is ACBM for which no response action was carried out
Verify that labels are displayed in highly visible places and remain posted until the
ACBM that is labeled is removed
Verify that the label reads CAUTION ASBESTOS HAZARDOUS. DO NOT
DISTURB WITHOUT PROPER TRAINING AND EQUIPMENT.
A 132 All members of the
school maintenance and
custodial staff who might work
in a building that contains
ACBM are required to receive
at least two hours of awareness
training whether or not they are
required to work with ACBM
(40 CFR 763 92(a)(1))
Verify that the school maintenance and custodial staff has been trained.
Verify that new personnel are trained within 60 days after start of employment
Verify that the training has included
Information regarding asbestos and the various uses and forms
Information on the health effects associated with asbestos exposure
Locations of all ACBM identified throughout each school building in which
they work
Recognition of damaged, deterioration, and location of the management plan
Name and telephone number of the person designated to carry out
responsibilities for asbestos management.
A 133 School maintenance and
custodial staff that conduct any
activities that will result in the
disturbance of ACBM are
required to received an
additional 14 hours of training
(40 CFR 763.92(a)(2))
Verify that staff has received additional training that includes
Descriptions of the proper methods of handling ACBM
Information on the use of respiratory protection and other personal protective
measures
The requirements found in 40 CFR 763
Hands-on training in the use of respiratory protection, other personal protection
measures, and good work practices
Phase 1 - Section 1
Air Pollution Control
1-86
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Compliance Category: Air Foliation Control
Regulatory Requirements
Reviewer Checks:
A 134 Records pertaining to
asbestos in schools are required
to be maintained in a central
location in the administrative
office of the school (40 CFR
763 94)
Verify that records concerning removal of ACBM are retained for three years after
the next reinspection
Verify that records for the following are retained
Preventive measures and response actions
Personnel training
O&M activities
F iber release ep isodes
Radon Management
A 135 The current status of
any ongoing or unresolved
Consent Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent State enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems.
A 136 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
Finding)
Determine if any new regulations have been issued since the finalization of the guide.
If so, annote checklist to include new standards.
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
A 137 Facilities are required to
comply with state and local
regulations concerning radon
management (EO 12088, Sect
1-1)
Verify that the facility is abiding by state and local requirements.
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
Testing requirements
Mitigation requirements.)
Phase 1 - Section 1
Air Pollution Control
1-87
-------
Section 1
Air Pollution Control
Appendices
-------
Appendix 1-1
Reid Vapor Pressure* for Installation Geographic Area
(40 CFR 80.27)
'¦ •• •• '¦
Alabama
90
7.8
7 8
7 8
7 8
Arizona
90
7.8
7 8
7 8
7 8
Arkansas
90
7.8
7 8
7.8
7 8
California
90
7 8
7 8
7 8
7 8
Colorado**
90
78
7 8
7 8
7 8
Connecticut
90
90
90
90
90
Delaware
9.0
9.0
9.0
90
90
District of Columbia
90
7.8
7 8
7 8
7 8
Florida
9.0
7.8
7.8
78
7 8
Georgia
90
7.8
7.8
7 8
7 8
Idaho
9.0
9.0
9.0
90
90
Illinois
90
90
90
90
90
Indiana
90
90
90
90
90
Iowa
90
90
90
90
90
Kansas
9.0
7 8
7 8
78
7 8
Kentucky
9.0
90
90
90
90
Louisiana
90
7.8
7 8
7 8
7 8
Maine
9.0
90
90
90
90
Maryland
90
7 8
7 8
7 8
7 8
Massachusetts
90
90
90
90
90
Michigan
9.0
9.0
9.0
9.0
90
Minnesota
90
90
90
90
90
Mississippi
90
7 8
7 8
78
7 8
Missouri
90
7 8
7 8
78
7 8
Montana
9.0
9.0
90
90
90
Nebraska
9.0
9.0
90
90
90
Nevada
90
7.8
7 8
7 8
7 8
New Hampshire
9.0
9.0
9.0
9.0
90
New Jersey
9.0
9.0
9.0
90
90
Al-l
-------
Appendix 1-1 (continued)
Reid Vapor Pressure for Installation Geographic Area
(40 CFR 80.27)
-
!¦.
¦> .
. * y
x""\
New Mexico
9.0
7 8
7 8
7 8
7 8
New York
90
90
90
90
90
North Carolina
9.0
78
7 8
7 8
7 8
North Dakota
9.0
90
90
90
90
Ohio
9.0
90
90
90
90
Oklahoma
90
78
7 8
7 8
7.8
Oregon
90
7 8
7 8
7 8
7 8
Pennsylvania
90
90
90
90
9.0
Rhode Island
90
9.0
9.0
9.0
90
South Carolina
90
7 8
7 8
7 8
7 8
South Dakota
9.0
90
90
90
90
Tennessee
Knox County
All other volatility
nonattainment areas
90
90
90
7 8
90
7 8
90
7 8
90
7 8
Texas
9.0
7 8
7.8
7 8
7 8
Utah
90
78
7 8
7 8
7 8
Vermont
9.0
90
90
90
90
Virginia
90
7.8
7.8
7 8
7 8
Washington
90
9.0
90
90
90
West Virginia
9.0
9.0
90
90
90
Wisconsin
90
90
90
90
9.0
Wyoming
90
90
90
90
90
* Standards are expressed in psi
**The standard for 1992 and 1995 in the Denver-Boulder nonattainment area will be 9.0 for 1 June through 15
September.
Al-2
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Appendix 1-2
Emissions Limitations for Incinerators and Steam Generators of 73 MW (250 Mbtu/h) or Greater
X
^-1
" ^ V"" -
40 CFR 60 40 through 60.44
Steam generators
> 73 MW (250 MBtu/h)
constructed or modified
after 17 August 1971
Solid Fossil Fuel
Particluate
43 ng/J (0 10
lb/MBtu)
None
Opacity
20%, 27% 6 min/h
Continuous
S02
ng/J (1 2
lb/MBtu)520
Continuous
NO, (except lignite
and coal refuse)
300 ng/J (0 70
lb/MBtu)
Continuous
Liquid Fossil Fuel
NO,
S02
340 ng/J (0 80
lb/MBtu)
Continuous
129 ng/J (0 30
lb/MBtu)
Continuous
Gaseous Fossil Fuel
NO,
86 ng/J (0 20
lb/MBtu)
Continuous
Lignite
NO,
260 ng/J (0 60
lb/MBtu)
Continuous
Lignite mined in
ND, SD, or MT
burned in a cyclone
fired unit
NO,
340 ng/J (0.80
lb/MBtu)
Continuous
40 CFR 60 50 through 60 54
Incinerators > 45 metric
tons (50 tons/day)
constructed or modified
after 17 August 1971
Incinerators
Particulate
0 18 g per dry
standard cubic meter
(dscm) (0 08 g per dry
standard cubic foot
(dscf)
corrected to 12 percent
C02
Record of daily
charging rates and
hours of operation
Al-3
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Appendix 1-3
Formulas for Calculating Emissions Limitations
(40 CFR 60.42b and 60.44b)
Steam generating units that started construction, modification, or reconstruction after 19 June 1984 with a
heat input capacity of greater than 29 MW (100 MBtu/h).
1. SO, From Facilities Combusting Coal or Oil
where:
E = the S02 emission limit
K, = 520 ng/J (1.2 Ib/MBtu)
K,, = 340 ng/J (0.80 lb/MBtu)
H, = the heat input from the combustion of coal
Hb = the heat input from the combustion of oil.
2. S02 From Facilities Combusting Coal or Oil Alone or With Other Fuel While Using Emerging
Technology
E, = the S02 emission limit (expressed in NOj), ng/J (lb/MBtu) heat input
K, = 260 ng/J (0.60 lb/MBtu)
K,, = 170 ng/J (0.40 lb/MBtu)
Hc = the heat input from the combustion of coal, J (MBtu)
H,, = the heat input from the combustion of oil, J (MBtu).
3. NOx Emissions From Facilities Simultaneously Combusting Coal, Oil, or Natural Gas With By-
products/Waste
E =
* W
(KHc KdHd)
(* e + H J
where-
_[(££„„//„„) + (ELroHro) + (ELcHc) 1
("go + "ro +HC)
where:
En
EL,
'go
the NOx emission limit (expressed as NOJ, ng/ (lb /MBtu)
the appropriate emission limit from paragraph (a)(1) for combustion of natural gas or
distillate oil, ng/J (lb/MBtu)
the heat input from combustion of natural gas or distillate oil and gaseous by-
product/waste, ng/J (lb/MBtu)
H,
'go
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-------
Appendix 1-3 (continued)
Formulas for Calculating Emissions Limitations
(40 CFR 60.42b and 60.44b)
ELro = the appropriate emission limit from paragraph (a)(2) for combustion of residual oil,
ng/J (Ib/MBtu)
Hro = the heat input from combustion of residual oil and/or liquid by-product/waste
ELc = the appropriate emission limit from paragraph (a)(3) for combustion of coal
Hc = the heat input from combustion of coal
4. NOx Emissions From Facilities Simultaneously Combusting Mixtures of Coal, Oil, or Natural Gas
E A{ELvoHvo) + (ELroHro) + (ELCHC)}
("go + ffro +Hc)
where
En = the NOx emission limit (expressed as N02), ng/J (lb/MBtu)
ELg0 = the appropriate emission limit from paragraph (a)(1) for combustion of natural gas or
distillate oil, ng/J (lb/MBtu)
Hg0 = the heat input from combustion of natural gas or distillate oil
ELro = the appropriate emission limit from paragraph (a)(2) for combustion of residual oil
Hro = the heat input from combustion of residual oil
ELC = the appropriate emission limit from paragraph (a)(3) for combustion of coal
Hc = the heat input from combustion of coal.
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Appendix 1-4
Particulate Emission Standards
(40 CFR 60.43b)
Steam generating units with a heat input capacity of greater than 29 MW (100 MBtu/h) that started
construction, modification, or reconstruction after 19 June 1984
Combusts only coal or coal and other fuels with an annual capacity factor for
the other fuels of 10 percent or less.
22 ng/J (0 05 Ib/MBtu) heat input
Combusts coal and other fuels and has an annual capacity factor greater than
10 percent and is subject to federally enforceable requirements limiting
operations to an annual capacity factor greater than 10 percent for fuels other
than coal
43 ng/J (0.10 lb/MBtu) heat input
Combusts coal or coal and other fuels, was constructed after 19 June 1984 but
before 25 November 1986 and has.
a. an annual capacity factor for coal, and coal and other fuels, of 30 percent
or less
b has a maximum heat input capacity of 73 MW (250 MBtu/h)
c has a federally enforceable requirement limiting operation of affected
facility to an annual capacity factor of 30 percent or less for coal or coal
and other solid fuels
86 ng/J (0.20 Ib/MBtu) heat input
Combusts oil or mixture of oil and uses a conventional or emerging
technology to reduce S02 emissions.
43 ng/J (0 10 Ib/MBtu) heat input
Combusts wood or wood with other fuels except coal and has an annual
capacity factor greater than 30 percent for wood
43 ng/J (0 10 lb/MBtu) heat inpul
Combusts wood or wood with other fuels, except coal, with a maximum heat
input capacity of 73 MW (250 MBtu/h) and has an annual capacity factor of
30 percent or less for wood and is subject to a federally enforceable
requirement limiting operation to an annual capacity factor of 30 percent or
less.
86 ng/J (0 20 Ib/MBtu) heat input
Combusts municipal-type solid waste or mixtures of municipal-type solid
waste with other fuels with an annual capacity factor of 10 percent or less for
other fuels.
43 ng/J (0.10 lb/MBtu) heat input
Combusts municipal-type solid waste or mixtures of municipal-type solid
waste with other fuels with an annual capacity factor of 30 percent or less for
other fuels and has a maximum heat input capacity of 73 MW (250 MBtu/h) or
less, constructed between 19 June 1984 and 25 November 1986, with federally
enforceable requirements limiting operating to an annual capacity factor of 30
percent
86 ng/J (0 20 Ib/MBtu) heat input
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Appendix 1-5
Emissions Standards For NOx
(40 CFR 60.44b)
Fuel burning sources greater than 29 MW (100 MBtu/h) heat input that started construction,
modification, or reconstruction after 19 June 1984
Nitrogen Oxide Emission Limit n«/J (Ib/MBtu) (Expressed As NO;)
Fuel/Steam Generating Unit Type
Heat Input
1 Natural gas and distillate oil except for
low heat release rate
high heat release rate
43 (0 10)
86 (0 20)
2 Residual oil
low heat release rate
high heat release rate
130 (0 30)
170 (0 40)
3 Coal
mass feed stoker
spreader-stoker and fluid bed combustion
pulverized coal
lignite
lignite mined in ND, SD, or MT, and combusted in a slag tap furnace
coal derived synthetic fuels
210(0 50)
260 (0 60)
300 (0 70)
260 (0.60)
340 (0.80)
210(0 50)
4 Duct burner used in combined cycle system
natural gas and distillate oil
residual oil
86 (0.20)
170 (0.40)
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Appendix 1-6
Formula for Calculating SO, Emissions Limitations
(40 CFR 60.42c(e)(2»
The following applies to steam generating units for which construction, modification, or reconstruction
started after 9 June 1989 with a maximum design heat input capacity of 29 MW (100 MBtu/h) or less, but
greater than or equal to 2 9 MW (10 Mbtu/h).
(K H K.H. + K H)
r* ^ a a bo c c'
E = *
(.H + H+ H)
v a b c'
where:
E = the S02 emission limit expressed in ng/J or lb/MBtu heat input
K,= 520 ng/J (1.2 lb/MBtu)
K* = 260 ng/J (0 60 lb/MBtu)
K, = 215 ng/J (0.50 lb/MBtu)
Ha = the heat input from the combustion of coal, except coal combusted in a facility that
combusts only coal and uses emerging technology, in Joules (J) (MBtu)
Hb = the heat input from the combustion of coal, except coal combusted in a facility that
combusts only coal and uses emerging technology, in J (MBtu)
Hc = the heat input from the combustion of oil, in J (MBtu).
Al-8
-------
Appendix 1-7
NOx Emissions from Stationary Gas Turbines
(40 CFR 60.332)
Formula A:
STD = 0.0075 x + F
Y
Formula B:
14 4
STD = 0 0150 x + F
Y
where
STD = allowable NOx emissions (percent by volume at 15 percent oxygen and on a dry basis)
Y = manufacturer's rated heat rate at manufacturer's rated load or, actual measured heat rate
based on lower heating value of fuel as measured at actual peak load for the facility. The
value of Y shall not exceed 14.4 kJ/watt hour
F = NOx emission allowance for fuel-bound nitrogen, defined as follows-
' ^ s slfr"" S V SSs S \ % N
i'" - s^ s % ¥ " s
^ SS--
: *¦ v - v :
:• 'iv. '• '• '•
N <0.015
0
0.015 0 25
0 0025
N is the nitrogen content of the fuel (percent by weight)
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-------
Appendix 1-8
Municipal Waste Combustor Operating Standards for CO
(40 CFR 60.54a, Table I)
Mass burn waterwall
100
Mass burn refractory
100
Mass burn rotary waterwall
100
Modular starved air
50
Modular excess air
50
RDF stoker
150
Bubbling fluidized bed combustor
100
Circulating fluidized bed combustor
100
Coal/RDF mixed fuel fired combustor
150
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-------
Appendix 1-9
Lead Concentration in Sewage Sludge Fed to an Incinerator
(40 CFR 503.43)
Formula 1:
_ 0 1 * NAAQS * 86,400
DF * (1 -CE) * SF
where:
C = Daily concentration of lead in sewage sludge in mg/kg of total solids (dry weight basis)
NAAQS = National Ambient Air Quality Standards for lead in micrometer/m3
DF = Dispersion factor in micrometer/mVg/s
CW = Sewage sludge incinerator control efficiency for lead in hundreths
SF = Sewage sludge feed rate in metric tons per day (dry weight basis)
Formula 2:
_ RSC * 86,400
DF * (1 -CE) * SF
where:
C = Daily concentrations of arsenic, cadmium, chromium, or nickel in sewage sludge in mg/kg
of total solids (dry weights basis)
CE = Sewage sludge incinerator control efficiency for arsenic, cadmium, chromium, or nickel in
hundreths
DF = Dispersion factor in micrometer/m3/g/s
RSC = Risk specific concentration in micrometer/m3 S
F = Sewage sludge feed rate in metric tons per day (dry weight basis)
AMI
-------
Appendix 1-10
Total Hydrocarbon Operational Standards
(40 CFR 503.44)
Formula 1:
Correction Factor (percent moisture) = —-—
(1-A)
where:
X = decimal fraction of the percent moisture in the sewage sludge incinerator exit gas in hundreths
Formula 2:
14
Correction Factor (oxygen) =
(21 ~Y)
where:
Y = Percent oxygen concentration in the sewage sludge incinerator stack exit gas
(dry volume/dry volume)
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-------
Appendix 1-11
Frequency of Monitoring for Incineration
(40CFR 503.16, Table 1,503.26, Table 1, 503.46, Table 1)
.AjtBOWW
., -- «"*«¥>#*<»> •"
Greater than zero but less than 290 (285 42)
Once per year
Equal to or greater than 290 (285 42) but less than 1500
(147631)
Once per quarter (four times per year)
Equal to or greater than 1500 (1476 31) but less than
15,000 (14,763.1)
Once per 60 days (six times less per year)
Equal to or greater than 15,000(14,763 1)
Once per month
* Either the amount of bulk sewage sludge applied to the land or the amount of sewage sludge received by a person who
prepares sewage sludge that is sold or given away in a bag or other container for application to the land (dry weight basis)
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-------
Appendix 1-12
Compliance and Exemptions to 40 CFR 63.320 through 63.325
Concerning Perchloroethylene Dry Cleaners
•v* v?\ ¦> ,, ..
S.S S s * s S
* s S s s* s
Coin-operated dry cleaners
None
None
None
Dry cleaning systems that started
construction or reconstruction on or
after 9 December 1991, except for
systems complying with Section
112(i)(2) of the Clean Air Act
63 320 through 63 325
A 50 through A.61
22 September 1993
Dry cleaning systems that started
construction or reconstruction before
9 December 1991
63.322(c), (d),(i),(j),(k),
(1), (m), 63 323(d) and
63 324(a), (b), (d)(1),
(d)(2), (d)(3), (d)(4), and
(e)
A.52, A 54, A.55, A.56,
A.57, A.58, A.59, A.60
20 December 1993
All other
Citations
A 50, A 51, A 53, A.61
23 September 1996
Existing dry-to-dry machines and
ancillary equipment located in a dry
cleaning facility that includes only a
dry-to-dry machines and each
existing transfer machine system and
its ancillary equipment, as well as
each existing dry-to-dry machine and
its ancillary equipment, located in a
dry cleaning facility that includes
both transfer machines systems and
dry-to-dry machines with a total
perchloroethylene consumption of
less than 530 L/yr (140 gal/yr)
63 322(c),(d), (i), 0), (k),
(1), (m), 63.323(d), and
63.324(a), (b), (d)(1),
(d)(2), (d)(3), (d)(4), (e)
A.52, A.54, A.55, A 56,
A 57, A 58, A 59, A 60
22 September 1993
Existing transfer machine systems
and ancillary equipment located in a
dry cleaning facility that includes
only transfer machine systems with
perchloroethylene consumption at
the facility of less than 760 L/yr (200
gal/yr)
63.322(c), (d),(.),G),(k),
(l)(m), 63.323(d) and
63 324(a), (b), (d)(1),
(d)(2), (d)(3), (d)(4), and
(e)
A.52, A 54, A.55, A.56,
A.57, A 58, A 59, A 60
22 September 1993
(NOTE If the total yearly consumption of perchloroethylene at a dry cleaning facility is initially less than the amounts
stipulated above, butd to comply within 180 days of the date that the facility determined it exceeded the baseline amounts
or by 23 September 1996, whichever is later)
AI -14
-------
Appendix 1-13
Controlled Substances and Ozone Depletion Weights
(40 CFR 82, Appendix A and Appendix B)
W vk^ \x i. ^ •-* • $¦., o <. 3-c.K -
\ NvXv. %*¦ V. % , %s \ s\s^
-------
Appendix 1-13 (continued)
Controlled Substances and Ozone Depletion Weights
(40 CFR 82, Appendix A and Appendix B)
< Controlled Substance .
igh^|
Group VII
CHFBr2
1 00
CHF2Br (HBFC-22B1)
0 74
CH2FBr
0.73
C2HFBr4
0 3-0.8
C2HF2Br3
05-1.8
C2HF3Br2
04-16
C2HF4Br
07-1.2
C2H2FBrj
0 1-11
CjH2FjBr2
02-15
C2H2F3Br
0 7-1.6
C2H3FBr2
0 1-17
CjHjFjBr
02-11
C2H4FBr
0 07 - 0 1
C3HFBr6
03-15
CjHF2Br5
02-19
C3HF3Br4
03-18
C3HF4Br3
0.5-2 2
C3HF,Br2
09-20
C2HF6Br
07-3 3
C3H2FBrs
0 1-19
CjH2F2Br4
0.2-2 1
CjH2FjBrj
02-56
C,H2F4Br2
03-75
C3H2F5Br
0.9 -1 4
C3HjFBr4
0 06 - 1 9
CjHjFjBrj
0 1-31
CjHjF3Br2
0 1-25
CjH3F4Br
03-44
C3H4FBr,
0 03 - 0 3
CjH4F2Br2
0.1 - 1 0
C3H4F3Br
0 07 - 0 8
C3H,FBr2
0.04 - 0.4
CjHjFjBr
0 07 - 0 8
CjHjFBr
0 02 - 0.7
Al-16
-------
Appendix 1-13 (continued)
Controlled Substances and Ozone Depletion Weights
(40 CFR 82, Appendix A and Appendix B)
MEpzonyDcplttionAVciRlitll*
... ..»r^"'.J^J'''.V V"..V " nu.^M
rciMfcir^ 5 s > " :¦»¦¦-¦ ' :v-"
J'" ' ..
s % \WS ¦¦ s s
CHFCI2 - Dichlorofluoromethane (HCFC-21)
*(res)
CHF2CI - Chlorodifluoromethane (HCFC-22)
0 05
CH2FCI - Chlorofluoromethane (HCFC-31)
(res)
C2HFCI4 - (HCFC-121)
(res)
C2HFCI2CI3 - (HCFC-122)
(res)
C2HF3CI2 - (HCFC-123)
0 02
C2HF4CI - (HCFC-124)
0 02
C2H2FC13-(HCFC-131)
(res)
C2H2F2CI2 - (HCFC-I32b)
(res)
C2H2F2CI - (HCFC-133a)
(res)
C2H3FCI2 - (HCFC-141b)
0 12
CjH3F2CI - (HCFC-142b)
0 06
C3HFC16-(HCFC-221)
(res)
CjHF2CI5 - (HCFC-222)
(res)
CjHFjCI, - (HCFC-223)
(res)
C3HF4CI3 - (HCFC-224)
(res)
C3HFSCI2 - (HCFC-225ca)
(res)
C3HF5CI2 (HCFC-225cb)
(res)
C3HF6CI - (HCFC-226)
(res.)
C3H2FCI5 - (HCFC-231)
(res)
C3H2F2CI4 - (HCFC-232)
(res)
CjHjFjCI, - (HCFC-233)
(res)
C3H2F4C12 - (HCFC-234)
(res)
C3H2F5CI - (HCFC-235)
(res)
C3H3FCI4 - (HCFC-241)
(res)
C3HjF2CI3 - (HCFC-242)
(res)
C3H3F3C12 - (HCFC-243)
(res)
C3H3F4CI - (HCFC-244)
(res)
C3H4FCI3 - (HCFC-251)
(res)
C3H4F2CI2 - (HCFC-252)
(res)
C3H4F3C1 - (HCFC-253)
(res)
C3H3FCI2 - (HCFC-261)
(res)
C3H5F2CI - (HCFC-262)
(res)
C3H6FCI - (HCFC-271)
(res)
All isomers of the above chemicals
(res)
*(res) means reserve It designates that the ozone depletion weight number has been reserved for a future rating
Al-17
-------
Appendix 1-14
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
. r.nd-usc
Substitute
, < .omtmons
: .. ..
Electronics
cleaning
w/CFC-l 13, MCF
Peril uoro-
carbons (C}F,i,
CftF |2, C.Fh,
C-F l6, C|Fn,
CsF,|NO,
c6f„no,
C7F,jNO, and
C,F,6)
Acceptable for high-
performance, precision-
engineered applications
only where reasonable
efforts have been made to
ascertain that other
alternatives are not
technically feasible due to
performance or safety
requirements
The principle environmental characteristic of
concern for Perfluorocarbons (PFCs) is that
they have long atmospheric lifetimes and high
global warming potentials Although actual
contributions to global warming depend upon
the quantities of PFCs emitted, the effects are
for practical purposes irreversible
Users must observe this limitation on PFC
acceptability by conducting a reasonable
evaluation of other substitutes to determine that
PFC use is necessary to meet performance or
safety requirements Documentation of this
evaluation must be kept on file
For additional guidance regarding applications
in which PFCs may be appropriate, users
should consult the Preamble for this
rulemaking
Precision cleaning
w/CFC-l 13, MCF
Peril uoro-
carbons (CSF12,
QF i2, C6F |4,
CtF |6> C|F )t,
CjF,|NO,
c6f„no,
C,F|5NO, and
C,F16)
Acceptable for high-
performance, precision-
engineered applications
only where reasonable
efforts have been made to
ascertain that other
alternatives are not
technically feasible due to
performance or safety
requirements
The principle environmental characteristic of
concern for PFCs is that they have long
atmospheric lifetimes and high global warming
potentials Although actual contributions to
global warming depend upon the quantities of
PFCs emitted, the effects are for practical
purposes irreversible
Users must observe this limitation on PFC
acceptability by conducting a reasonable
evaluation of other substitutes to determine that
PFC use is necessary to meet performance or
safety requirements Documentation of this
evaluation must be kept on file
For additional guidance regarding applications
in which PFCs may be appropriate, users
should consult the Preamble for this
rulemaking
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-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
.yiPjl)il{P>::-.,%; ^, Vl., V ^ -f
Halon 1211
Streaming Agents
(CFC Blend)
¦.' \JV "'j ' ' ' cw ^ " ¦
Acceptable in
nonresidential uses only
¦¦ .. -1:
s % X "s" "SJ s s' ^
s Vfl, s N s - ' - S V. * S
Use of CFCs are controlled under CAA section
610 which bans use of CFCs in pressurized
dispensers, and therefore are not permitted for
use in portable for extinguishers EPA will list
this agent as proposed unacceptable in the next
significant new alternatives policy (SNAP)
proposed rulemaking
Because CFCs are a Class 1 substance,
production will be phased out by 1 January
1996
See additional comments 1,2
HBFC-22B1
Acceptable in nonresidential uses
only
Proper procedures regarding the operation of
the extinguisher and ventilation following
dispensing the extmguisham is recommended
Worker exposure may be a concern in small
office areas
HBFC-22BI is considered an interim substitute
for Halon 1211 Because the HBFC-22B1 has
an ozone depleting potential (ODP) of 0 74,
production will be phased out (except for
essential uses on 1 January 1996)
This agent was submitted to the Agency as a
Premanufacturc Notice (PMN) and is presently
subject to requirements contained in a Toxic
Substance Control Act (TSCA) Consent Order
See additional comments 1,2
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-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
£Knd-«so Sfit>sliiufc " V5
KW.v/l'ivAC-SWv'k'WfA'/.i.v+wfvil11 lli*
csf,4
Acceptable for
nonresidential uses where
other alternatives are not
technically feasible due to
performance or safety
requirements
a Due to the physical or
chemical properties of
the agent, or
b Where human exposure
to the extinguishing
agent may approach
cardiosensitization
levels or result in other
unacceptable health
effects under normal
operating conditions
Users must observe the limitations on PFC
acceptability by making reasonable effort to
undertake the following measures
Conduct an evaluation of foreseeable
conditions of end use
Determine that the physical or chemical
properties or other technical constraints of
the other available agents preclude their
use, and
Determine that human exposure to the
other alternative extinguishing agents may
approach or result in cardiosensitization or
other unacceptable toxicity effects under
normal operating conditions
Documentation of such measures must be
available for review upon request
The principal environmental characteristic of
concern for PFCs is that they have high Global
Warming Potential (GWP) and long
atmospheric lifetimes Actual contributions to
global warming depend upon the quantities of
PFCs emitted
For additional guidance regarding applications
in which PFCs may be appropriate, users
should consult the description of potential uses
which is included in the preamble to this
rulemaking
See additional comments 1, 2
Additional Comments
1 Discharge testing and training should be strictly limited only to that which is essential to meet safety or performance requirements
2 The agent should be recovered from the fire protection system in conjunction with testing or servicing, and recycled for later use or destroyed
Al-20
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
;4>:.n
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
t'.nit-Uii1 Substitute Decision Conditions Ooimnciil.s
HCFC-124
Acceptable
Until OSHA establishes applicable workplace
requirements
Where egress from an area cannot be
accomplished within one minute, the employer
shall not use this agent in concentrations
exceeding its cardiotoxic NOAEL of 1 0
percent
Where egress takes longer than 30 seconds but
less than one minute, the employer shall not use
the agent in a concentration greater than its
cardiotoxic LOAEL OF 2 5 percent
HCFC-123 concentrations greater than 2 5
percent are only permitted in areas not normally
occupied by employees provided that any
employee in the area can escape within 30
seconds The employer shall assure that no
unprotected employees enter the area during
agent discharge
The comparative design concentration based on
cup burner values is approximately 8 4 percent
while its cardiotoxic LOAEL is 2 5 percent
Thus, it is unlikely that this agent will be used
in normally occupied areas
See additional comments 1,2,3,4
(HCFC
BLEND) A
Acceptable
Until OS HA establishes applicable
workplace requirements
Where egress from an area cannot
be accomplished within one
minute, the employer shall not use
(HCFC Blend) A in concentrations
exceeding its cardiotoxic NO A EL
of 10 0 percent
Where egress takes greater than 30
seconds but less than one minute,
the employer shall not use (HCFC
Blend) A in a concentration greater
than its cardiotoxic LOAEL of
100 percent
(HCFC Blend) A concentrations
greater than 10 percent are only
permitted in areas not normally
occupied by employees provided
that any employee in the area can
escape within 30 seconds The
employer shall assure that no
unprotected employees enter the
area during agent discharge
The comparative design concentration based on
full-scale testing is approximately 8 6 percent
The agent should be recovered from the fire
protection system in conjunction with testing or
servicing, and should be recycled for later use
or destroyed
See additional comments 1,2,3,4
A1-22
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
- s>s4",
HFC-23
Acceptable
Until OSHA establishes applicable
workplace requirements
Where egress from an area cannot
be accomplished within one
minute, the employer shall not use
HFC-23 in concentrations
exceeding 30 percent
Where egress takes greater than 30
seconds but less than one minute,
the employer shall not use HFC-23
in a concentration greater than
50 0 percent
HFC-23 concentrations greater
than 50 percent are only permitted
in areas not normally occupied by
employees provided that any
employee in the area can escape
within 30 seconds The employer
shall assure that no unprotected
employees enter the area during
agent discharge
The design concentration must
result in an oxygen level of at least
16 percent
The comparative design concentration based on
cup burner values is approximately 14 4 percent
while data indicates that its cardiotoxicity
NOAEL is 30 percent without added oxygen
and 50 percent with added oxygen Its LOAEL
is likely to exceed 50 percent
See additional comments 1,2, 3,4
HFC-125
Acceptable
Until OSHA establishes applicable
workplace requirements
Where egress from an area cannot
be accomplished within one
minute, the employer shall not use
this agent in concentrations
exceeding lis cardiotoxic NOAEL
of 7 5 percent
Where egress takes longer than 30
seconds but less than one minute,
the employer shall not use the
agent in a concentration greater
than its cadiotoxic LOAEL of 10 0
percent
HFC-125 concentrations greater
than 10 0 percent are only
permitted in areas not normally
occupied by employees provided
that any employee in the area can
escape within 30 seconds The
employer shall assure that no
unprotected employees enter the
area during agent discharge
The comparative design concentration based on
cup burner values is approximately 11 3 percent
while its cardiotoxic LOAEL is 10 0 percent
Thus, it is unlikely that this agent will be used
in normally occupied areas
See additional comments 1,2,3,4
Al-23
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
•AA S< ¦>> «\ "•
S&t&S
L J+
5T.K*oismn
v-v^r-
%s,ss% "S % •. %V.< w
•- v--
HFC-134a
Acceptable
Until OS HA establishes applicable
workplace requirements
Where egress from an area cannot
be accomplished within one
minute, the employer shall not use
this agent in concentrations
exceeding its cardiotoxic NOAEL
of 4 0 percent
Where egress takes longer than 30
seconds but less than one minute,
the employer shall not use the
agent in a concentration greater
than its cardiotoxic LOAEL of 8 0
percent
HFC-134a concentrations greater
than 8 0 percent are only permitted
in areas not normally occupied by
employees provided that any
employee in the area can escape
within 30 seconds The employer
shall assure thai no unprotected
employees enter the area during
agent discharge
The comparative design concentration based on
cup burner values is approximately 12 6 percent
while its cardiotoxic LOAEL is 8 0 percent
Thus, it is unlikely thai this agent will be used
in normally occupied areas
See additional comments 1,2,3,4
HFC-227ea
Acceptable
Until OSHA establishes applicable
workplace requirements
Where egress from an area cannot
be accomplished within one
minute, the employer shall not use
HFC-227ea in concentrations
exceeding its cardiotoxic NOAEL
of 90 percent
Where egress takes longer than 30
seconds but less than one minute,
the employer shall not use the
agent in a concentration greater
than its cardiotoxic LOAEL of
10 5 percent
HFC-227ea concentrations greater
than 10 5 percent are only
permitted in areas not normally
occupied by employees provided
that any employee in the area can
escape within 30 seconds The
employer shall assure that no
unprotected employees enter the
area during agent discharge
The comparative design concentration based on
cup burner values is approximately 7 0 percent
while data indicate (hat its cardiotoxicity
LOAEL is probably greater than 10 5 percent
EPA is accepting 10 5 percent as its LOAEL
This agent was submitted to the Agency as a
Premanufacture Notice (PMN) agent and is
presently subject to requirements contained in a
Toxic Substances Control Act (TSCA)
Significant New Use Rule (SNUR)
See additional comments 1,2,3,4
A1-24
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
SNiitwlllulc^^S
gpecMioiil
mmm
C*F 10
Acceptable
Where other alternatives are
not technically feasible due
to performance or safety
requirements
a Due to their physical or
chemical properties, or
b Where human exposure
to the extinguishing
agents may approach
cardiosensitization
levels or result in other
unacceptable health
efTects under normal
operating conditions
Until OS HA establishes applicable
workplace requirements
For occupied areas from which
personnel cannot be evacuated in
one minute, use is permitted only
up to concentrations not exceeding
the cardiotoxicity NOAEL of 40
percent
Although no LOAEL has been
established for this product,
standard OSHA requirements
apply, 1 e , for occupied areas from
which personnel can be evacuated
or egress can occur between 30
and 60 seconds, use is permitted
up to a concentration not
exceeding the LOAEL
All personnel must be evacuated
before concentration of C4FI0
exceeds 40 percent
Design concentration must result
in oxygen levels of at least 16
percent
Documentation of such measures
must be available for review upon
request
The comparative design concentration based on
cup burner values is approximately 6 6 percent
Users must observe the limitations on PFC
acceptability by making reasonable efforts to
undertake the following measures
• Conduct an evaluation of foreseeable
conditions of end use.
Determine that human exposure to the
other alternative extinguishing agents may
approach or result in cardiosensitization or
other unacceptable toxicity efTects under
normal operating conditions, and
• Determine that the physical or chemical
properties or other technical constraints of
the other available agents preclude their
use
The principal environmental characteristic of
concern for PFCs is that they have high GWPs
and long atmospheric lifetimes Actual
contributions to global warming depend upon
the quantities of PFCs emitted
For additional guidance regarding applications
in which PFCs may be appropriate, users
should consult the description of potential uses
which is included in this rulemaking
See additional comments 1,2,3,4
(IG-541)
Acceptable
Until OSHA establishes applicable
workplace requirements
The design concentration must
result in at least 10 percent oxygen
and no more than 5 percent COj
If the oxygen concentration of the
atmosphere falls below 10 percent,
personnel must be evacuated and
egress must occur within 30
seconds
Studies have shown that healthy, young
individuals can remain in a 10 percent to 12
percent oxygen atmosphere for 30 to 40
minutes without impairment However, in a
fire emergency, the oxygen level may be
reduced below safe levels, and the combustion
products formed by the fire are likely to cause
harm Thus, the Agency does not contemplate
personnel remaining in the space after system
discharge during a fire without Self Contained
Breathing Apparatus (SCBA) as required by
OSHA
See additional comments 1, 2
Al-25
-------
Appendix 1-14 (continued)
Acceptable Substitutes
(40 CFR 82.170 through 82.194)
' "¦
IFW' S
( omifhons
Halon 1301 Total
Flooding Agents
C«F |-
Acctptable where other
alternatives are not
technically feasible due to
performance or safety
requirements
a Due to their physical or
chemical properties, or
b Where human exposure
to the extinguishing
agents may approach
cardiosensitization
levels or result in other
unacceptable health
effects under normal
operating conditions
Until OSHA establishes applicable
workplace requirement
For occupied areas from which
personnel cannot be evacuated in
one minuted, use is permitted only
up to concentrations not exceeding
the cardiotoxicity NOAEL of 40
percent
Although no LOAEL has been
established for this product,
standard OSHA requirements
apply, i e for occupied areas from
which personnel can be evacuated
or egress can occur between 30
and 60 seconds, use is permitted
up to a concentration not
exceeding the LOAEL
All personnel must be evacuated
before concentration of C4F,0
exceeds 40 percent
Design concentration must result
in oxygen levels of at least 16
percent
The comparative design concentration based on
cup burner values is approximately 6 6 percent
Users must observe the limitations on PFC
approval by undertaking the following
measures
Conduct an evaluation of foreseeable
conditions of end use.
Determine that human exposure to the
other alternative extinguishing agents may
approach or result in cardiosensitization or
other unacceptable toxicity effects under
normal operating conditions, and
Determine that the physical or chemical
properties or other technical constraints of
the other available agents preclude their
use
Documentation of such measures must be
available for review upon request
The principal environmental characteristic of
concern for PFCs is that they have high GWPs
and long atmospheric lifetimes Actual
contributions to global warming depend upon
the quantities of PFCs emitted
For additional guidance regarding applications
in which PFCs may be appropriate, users
should consult the description of potential uses
which is included in the preamble to this
rulemaking
See additional comments 1, 2,3, 4
Additional Comments
1 Must conform with OSHA 29 CFR 1910 Subpart L Section 1910 160 of the U S Code
2 Per OSHA requirements, protective gear (SCBA) must be available in the event personnel must reenter the area
3 Discharge testing should be strictly limited only to that which is essential to meet safety or performance requirements
4 The agent should be recovered from the fire protection system in conjunction with lesting or servicing, and recycled for later use or destroyed
A1-26
-------
Appendix 1-15
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
IllSlIi
V ".fni v> ^ "V-.
\miM ^,. ¦.. ,y.;x ¦> x. ¦> t. , v:v"
>+*|*r* f S.V "¦ w,-' «$"V S-- ¦, » ."vvN¦}
Metals cleaning
w/CFC-113
HCFC 141b and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment EPA
will grant, if necessary, narrowed use acceptability
listings for CFC-113 past the effective date of the
prohibition
Metals cleaning
w/MCF
HCFC 141b and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment
Electronics cleaning
w/CFC-113
HCFC 141b and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment EPA
will grant, if necessary, narrowed use acceptability
listings for CFC-113 past the effective date of the
prohibition
Electronics cleaning
w/MCF
HCFC 141b and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment
Precision Cleaning
w/CFC-113
HCFC 141b and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment. EPA
will grant, if necessary, narrowed use acceptability
listings for CFC-113 past the effective date of the
prohibition
Precision Cleaning
w/MCF
HCFC I4lb and
its blends
Unacceptable
High ODP, other alternatives exist Effective date As
of 30 days after final rule for uses in new equipment
(including retrofits made after the effective date), as of
1 January 1996 for uses in existing equipment
CFC-11 centrifugal
chillers (retrofit)
HCFC-I4lb
Unacceptable
Has a high ODP relative to other alternatives
Al-27
-------
Appendix 1-15 (continued)
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
^Substitute
["Derision
^Comments' Ct:"1
CFC-12 centrifugal
chillers (retrofit)
HCFC-22/HCF-
I42b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use.
CFC-11, CFC-12,
CFC-113, CFC-114,
R-500 centrifugal
chillers (new
equipment/NIKs)
HCFC-22/HCF-
I42b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use.
HCFC-141b
Unacceptable
Has a high ODP relative to other alternatives.
CFC-12 reciprocating
chillers (retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class 1 and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12 reciprocating
chillers (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use.
CFC-U,CFC-12, R-
502 industrial process
refrigeration (retrofit)
HCFC-22/HCF-
I42b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
CFC-11,CFC-12, R-
S02 industrial process
refrigeration (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
AI-28
-------
Appendix 1-15 (continued)
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
v.. S J . •. ..V A*
CFC-12, R-502 ice
skating rinks (retrofit)
HCFC-22/HCF-
I42b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-502 ice
skating rinks (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-502 cold
storage warehouses
(retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class 1 and Class II substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use.
CFC-12, R-502 cold
storage warehouses
(new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class 1 and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-500.R-
502 refrigerated
transport (retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-500,R-
502 refrigerated
transport (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-502 retail
food refrigeration
(retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
A1-29
-------
Appendix 1-15 (continued)
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
F.rul list' Substitute Decision Comments
CFC-12, R-502 retail
food refrigeration
(new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class 11 substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern. Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12, R-502
commercial ice
machines (retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances.
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use.
CFC-12, R-502
commercial ice
machines (new
equipment/NIKs)
HCFC-22/HCF-
I42b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class II substances.
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern. Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12 vending
machines (retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class 11 substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern. Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12 vending
machines (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class 11 substances.
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
A1-30
-------
Appendix 1-15 (continued)
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
nf
X" S S^s > .• s
-------
Appendix 1-15 (continued)
Unacceptable CFC and Halon Substitutes
(40 CFR 82.170 through 82.194, Appendix A)
' S<-> «v\". SM
CFC-12, R-500
residential
dehumidifiers (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class 1 and Class II substances, it
has a higher ODP than use of Class II substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12 motor
vehicle air
conditioners (retrofit)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class 11 substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
CFC-12 motor
vehicle air
conditioners (new
equipment/NIKs)
HCFC-22/HCF-
142b/CFC-12
Unacceptable
As a blend of both Class I and Class II substances, it
has a higher ODP than use of Class 11 substances
Hydrocarbon
blend A
Unacceptable
Flammability is a serious concern Data have not been
submitted to demonstrate it can be used safely in this
end-use
% •,/ ^
•»
s-
v %'a v. v 0* vfr * .. S
. . .
CFC-11 Polyolefin
HCFC-141b (or
blends thereof)
Unacceptable
HCFC- 141b has an ODP of 0.11, almost equivalent to
that of methyl chloroform, a Class I substance The
Agency believes that non-ODP alternatives are
sufficiently available to render the use of HCFC-14 lb
unnecessary in polyolefin foams
i -- - - ' " -V , " -
Halon 1211
Streaming Agents
(CFC-11)
Unacceptable
This agent has been suggested for use on large outdoor
fires for which non-ozone depleting alternatives are
currently used.
Al-32
-------
Appendix 1-16
Required Levels of Evacuation for Appliances
(Except for small appliances, MVACS, and MVAC-like appliances)
(40 CFR 82.156, Table 1)
Stiiaflii ret and Atmospheric Pressure "of 29/fin?
m^tppn
i - , - :v :t^WQ0i
' ' *' ^ w"> v. ""
y ,-V
;:^aipnsi?nt or-
08,or-15..¦¦¦¦,'"""""
«fnkl9^V
\- , v v-
HCFC-22 appliance, or isolated component of
such appliance, normally containing less than
200 lb of refrigerant
0
0
HCFC-22 appliance, or isolated component of
such appliance, normally containing less than
200 lb of refrigerant
0
0
HCFC-22 appliance, or isolated component of
such appliance, normally containing 200 lb or
more of refrigerant
4
10
Other high-pressure appliance, or isolated
component of such appliance, normally
containing less than 200 lb of refrigerant
4
10
Other high-pressure appliance, or isolated
component of such appliance, normally
containing 200 lb or more of refrigerant
4
15
Very high-pressure appliance
0
0
Low-pressure appliance
25
25 in Hg absolute
Al-33
-------
Phase 1
Section 2
Water Pollution Control
-------
Phase 1
Section 2
Table of Contents
Water Pollution Control
A. Applicability 2-1
B Federal Legislation 2-1
C State/Local Regulations 2-2
D. Key Compliance Requirements 2-2
E Key Compliance Definitions .... 2-4
F. Records to Review 2-21
G. Physical Features to Inspect 2-21
H Guidance For Checklist Users 2-23
Appendices
A2-1. Steam Electric Power Generating Point Sources A2-1
A2-2 Operations Excepted from Electroplating Point Source Effluent
Limitations A2-4
A2-3 Metal Finishing Point Sources A2-6
A2-4. Effluent Standards for Hospitals and Photographic Point Sources A2-8
A2-5 Relevant Dates for the Sewage Sludge Program A2-9
A2-6 Cumulative Pollutant Loading Rates for Sludge A2-10
A2-7. Ceiling Concentrations for Sludge A2-11
A2-8 Pollutant Concentrations for Sludge A2-12
A2-9 Annual Pollutant Loading Rates A2-13
A2-10 Frequency of Monitoring - Land Application and Surface Disposal A2-14
A2-11 Pollutant Concentrations for an Active Sewage Unit A2-15
A2-12 Effluent Guidelines and Pretreatment Standards Categories A2-16
-------
A. Applicability
This section includes regulations, responsibilities,and compliance requirements associated
with wastewater discharge at facilities. Wastewater discharge can include any of the following:
• Sanitary wastewater discharge directly to a receiving stream
• Sanitary or industrial wastewater discharge to a Publicly Owned Treatment Works
(POTW) or other treatment facilities
• Stormwater runoff from operational areas of the facility to a receiving stream or water
body
• Industrial or storm wastewater drained to an industrial waste reservoir.
Most facilities have wastewater discharge of one kind or another, and therefore this section
will be applicable to most facilities.
Assessors are required to review state and local regulations to perform a comprehensive
assessment.
B. Federal Legislation
1. The Federal Water Pollution Control Act
This Act, commonly known as the Clean Water Act (CWA), as amended 4 February 1987
(33 USC 1251-1387; PL 100-4), governs the control of water pollution in the nation. The
objective of the act is to restore and maintain the chemical, physical, and biological integrity of
the nation's waters. Federal agencies are required to comply with all Federal, state, interstate,
and local water pollution control requirements both substantively and procedurally (33 USC
1323(a)).
2. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing that the agencies, facilities, programs, and activities the
agency funds meet applicable Federal, state, and local environmental requirements or to correct
situations that are not in compliance with such requirements. In addition, the EO requires that
each agency ensure that sufficient funds for environmental compliance are included in the agency
budget.
Phase 1 - Section 2
Water Pollution Control
2-1
-------
C. State/Local Regulations
States normally have wastewater discharge legislation and regulations that require
permitting procedures similar to the National Pollution Discharge Elimination System (NPDES)
program. The state is often delegated authority to administer the NPDES permits for discharges
in their state. These permits are often joint permits issued pursuant to both Federal and state
legislation. In some cases, the state will not administer the NPDES program and will issue a
state permit even though a NPDES permit has been issued by the EPA. The states and the EPA
normally cooperate in the permit issuance process to ensure that the two permits are consistent,
but there may be differences in monitoring requirements and the number of pollutants limited.
These requirements normally do not conflict, but may require additional sampling and dual
reporting.
States also have more stringent requirements than EPA for wastewater treatment plant
operations. Many states have Wastewater Treatment Plant (WWTP) operator licensing and
certification programs that require operators to pass an exam and have a required amount of
experience.
Local entities (counties, cities) may also have enforceable wastewater discharge limitations
that regulate discharges to a POTW. Local limitations often include Ph, temperature, and
concentrations of various organic and inorganic compounds. Major industrial operations that
discharge to an off-site POTW will be subjected to pretreatment permits issued by the POTW,
state, or EPA as appropriate.
D. Key Compliance Requirements
1. NPDES Permits
Facilities with point source discharges and/or treatment works treating domestic wastewater
are required to have a Federal NPDES permit if located in states without an EPA-approved
NPDES permit program. Facilities that are dischargers of stormwater associated with an
industrial activity are required to apply for an individual permit, apply for a permit through a
group application, or seek coverage under a promulgated stormwater general permit. Facilities
must meet the sampling requirements stipulated by NPDES permits (40 CFR 122.1(b)(3) and
122.26(c)).
2. Treatment Works
Facilities must not discharge into a treatment works any pollutant that would cause pass
through or interference. Facilities shall not introduce into a treatment works pollutants that
create a fire or explosion hazard, cause corrosive structural damage, have a pH below 5.0, or are
solid or viscous enough to cause obstructions. Facilities are required to notify the treatment
works immediately of any discharge, including any slug loadings, that could cause problems to
the treatment works (40 CFR 403.5 and 403.12(f)).
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3. Operation and Maintenance of a Treatment Works
Treatment plant supervisors are required to maintain operating logs and records that are
posted daily and are neat and legible. Treatment plants are required to be operated in accordance
with all design parameters (40 CFR 403.12(f)).
4. Effluent Limitations for Steam Electric Power Generating Sources
Facilities that have steam electric power generating sources must meet point source effluent
limitations. Of special concern is the discharge of free available chlorine and total residual
chlorine. Additionally there must be no discharge of Polychlorinated Biphenyls (PCBs). There
are additional standards depending on if the source is a new or an existing source (40 CFR 423).
5. Effluent Limits for Electroplating Point Sources
Facilities that have existing electroplating operations that introduce pollutants into a POTW
resulting from the electroplating of common metals are subject to pretreatment standards, which
vary depending upon the level of discharge and the nature of the metals used (40 CFR 413).
6. Effluent Limitation for Metal Finishing Point Sources
Facilities that have shops performing electroplating, electroless plating, anodizing, coating,
chemical etching and milling, and printed circuit board manufacturing are subject to certain Best
Available Technology (BAT) point source effluent limitations, that include the self-monitoring
of cyanide. Facilities that introduce pollutants from existing metal finishing point sources into
POTWs are subject to certain pretreatment standards. Facilities that introduce pollutants from
new metal finishing point sources into POTWs are subject to certain performance and
pretreatment standards (40 CFR 433).
7. Discharge Limits for Hospitals
Hospitals are required to limit the quantity and quality of their discharges. The following are
restricted- BOD5, TSS, and pH (40 CFR 460).
8. Discharge Limits for Photo Labs
Photo labs that process more than 150 m2 per day of film must limit their discharges for
silver, CN, and pH (40 CFR 459).
9. Land Application of Sludge
40 CFR 503 details the pollutant concentrations, cumulative loading rates, and other
restrictions pertinent to the land application of sludge that is generated during the treatment of
domestic sludge in a treatment works.
10. Surface Disposal of Sewage Sludge
The operation, management, monitoring, and closure requirements for units used for the
surface disposal of sewage sludge are outlined in 40 CFR 503.20 through 503.28.
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£. Key Compliance Definitions
1. Active Sewage Sludge Unit
A sewage sludge unit that has not closed (40 CFR 503.21(a)).
2. Aerobic Digestion
The biochemical decomposition of organic matter in sewage sludge into C02 and water by
microorganisms in the presence of air (40 CFR 503.31(a)).
3. Agricultural Land
Land on which a food crop, a feed crop, or a fiber crop is grown. This includes range land
and land used as pasture (40 CFR 503.11(a)).
4. Agronomic Rate
The whole sludge application rate (dry weight basis) designed (40 CFR 503.11(b)):
• To provide the amount of nitrogen needed by the food crop, feed crop, fiber crop, cover
crop, or vegetation grown on the land; and
• To minimize the amount of nitrogen in the sewage sludge that passes below the root
zone of the crop or vegetation grown on the land to the groundwater.
5. Anaerobic Digestion
The biochemical decomposition of organic matter in sewage sludge into methane gas and
CO2 by microorganisms in the absence of air (40 CFR 503.31(b))
6. Annual Pollutant Loading Rate
The maximum amount of a pollutant that can be applied to a unit area of land during a 365-
day period (40 CFR 503.11(c)).
7. Annual Whole Sludge Application Rate
The maximum amount of sewage sludge (dry weight basis) that can be applied to a unit area
of land during a 365-day period (40 CFR 503.11(d)).
8. Apply Sewage Sludge or Sewage Sludge Applied To The Land
Means land application of sewage sludge (40 CFR 503.9(a)).
9. Aquifer
A geologic formation, group of geologic formations, or a portion of a geologic formation
capable of yielding groundwater to wells or springs (40 CFR 503.21(b)).
10. Base Flood
A flood that has a one percent chance of occurring in any given year (i.e., a flood with a
magnitude equalled once in 100 years) (40 CFR 503.9(b)).
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11. Blowdown
The minimum discharge of recirculating water for the purpose of discharging materials
contained in the water, the further buildup of which would cause concentrations in amounts
exceeding limits established by best engineering practice (40 CFR 401.1 l(p)).
12. Bulk Sewage Sludge
Sewage sludge that is not sold or given away in a bag or other container for application to
the land (40 CFR 503.11(e)).
13. Chemical Metal Cleaning Waste
Any wastewater resulting from the cleaning of any metal process equipment with chemical
compounds, including, but not limited to, boiler tube cleaning (40 CFR 423.11).
14. Class 1 Sludge Management Facility
Any POTW, as defined in 40 CFR 501.2, required to have an approved pretreatment
program under 40 CFR 403.8(a) (including any POTW located in a state that has elected to
assume local program responsibilities pursuant to 40 CFR 403.10(e)) and any treatment works
treating domestic sewage, as defined in 40 CFR 122.2, classified as a Class 1 sludge
management facility by the EPA Regional Administrator, or, in the case of approved state
programs, the Regional Administrator in conjunction with the State Director, because of the
potential for its sewage sludge use or disposal practice to affect public health and the
environment adversely. (Under 40 CFR 403.8(a), a POTW or combination of POTWs with a
total design flow greater than 5 million gal/day will be required to establish a POTW treatment
program if they are receiving from industrial users pollutants that pass through or interfere with
the operation of the POTW or are otherwise subject to pretreatment standards. A program may
also be desired at the discretion of the regulator.)
15. Class A Sludge
When one of the following methods is used, sludge is considered Class A with respect to
pathogens:
a. Alternative 1. Either the density of fecal coliform in the sewage sludge shall be less
than 1,000 Most Probable Number/gram (MPN/g) total solids (dry weight basis), or the density
of Salmonella sp bacteria in the sewage sludge shall be less than 3 MPN/4 g total solids (dry
weight basis) at the time the sewage sludge is used or disposed; at the time the sewage sludge is
prepared for sale or given away in a bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage sludge is prepared to meet the
requirements in 40 CFR 503.10(b), 503.10(c), 503.10(e), or 503.10(f).
The temperature of the sewage sludge that is used or disposed shall be maintained at a
specific value for a period of time. When the percent solids of the sewage sludge is 7 percent or
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higher, the temperature of the sewage sludge shall be 50 °C (122 °F) or higher; the time period
shall be 20 min or longer; and the temperature and time period shall be determined using the
following equation, except when small particles of sewage sludge are heated by either warmed
gases or an immiscible liquid.
Eq. (1)
D = 131.7 00,000
2q0 HOOt
Where D = time in days, t = temperature in °C.
When the percent solids of the sewage sludge is 7 percent or higher and small particles of
sewage sludge are heated by either warmed gases or an immiscible liquid, the temperature of the
sewage sludge shall be 50 °C (122 °F) or higher; the time period shall be 15 seconds or longer;
and the temperature and time period shall be determined using the above equation (Eq. (1)).
When the percent solids of the sewage sludge is less than 7 percent and the time period is at
least 15 seconds, but less than 30 minutes, the temperature and time period shall be determined
using the above equation (Eq. (1)).
When the percent solids of the sewage sludge is less than 7 percent; the temperature of the
sewage sludge is 50 °C (122 °F) or higher; and the time period is 30 minutes or longer, the
temperature and time period shall be determined using Equation (2).
Eq (2)
D=50.070.000
^qO 1400c
Where D = time in days, t = temperature in °C.
b. Alternative 2. Either the density of fecal coliform in the sewage sludge is less than
1,000 MPN/g total solids (dry weight basis), or the density of Salmonella sp bacteria in the
sewage sludge shall is less than 3 MPN/4 g total solids (dry weight basis) at the time the sewage
sludge is used or disposed; at the time the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the time the sewage sludge or material
derived from sewage sludge is prepared to meet the requirements in 40 CFR 503.10(b),
503.10(c), 503.10(e), or 503.10(f)- The pH of the sewage sludge that is used or disposed shall be
raised to above 12 and shall remain above 12 for 72 hours
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The temperature of the sewage sludge shall be above 52 °C (125.6 °F) for 12 hours or longer
during the period that the pH of the sewage sludge is above 12.
At the end of the 72 hour period during which the pH of the sewage sludge is above 12, the
sewage sludge shall be air dried to achieve a percent solids in the sewage sludge greater than 50
percent.
c. Alternative 3. Either the density of fecal coliform in the sewage sludge is less than
1,000 MPN/g total solids (dry weight basis), or the density of Salmonella sp bacteria in sewage
sludge shall be less than 3 MPN/4 g total solids (dry weight basis) at the time the sewage sludge
is used or disposed, at the time the sewage sludge is prepared for sale or given away in a bag or
other container for application to the land; or at the time the sewage sludge or material derived
from sewage sludge is prepared to meet the requirements in 40 CFR 503.10(b), 503.10(c),
503.10(e), or 503.10(f).
The sewage sludge shall be analyzed prior to pathogen treatment to determine whether the
sewage sludge contains enteric viruses.
When the density of enteric viruses in the sewage sludge prior to pathogen treatment is less
than one Plaque-forming Unit/4 g total solids (dry weight basis), the sewage sludge is Class A
with respect to enteric viruses until the next monitoring episode for the sewage sludge.
When the density of enteric viruses in the sewage sludge prior to pathogen treatment is equal
to or greater than one Plaque-forming Unit/4 g total solids (dry weight basis), the sewage sludge
is Class A with respect to enteric viruses when the density of enteric viruses in the sewage sludge
after pathogen treatment is less than one Plaque-forming Unit/4 g total solids (dry weight basis)
and when the values or ranges of values for the operating parameters for the pathogen treatment
process that produces the sewage sludge that meets the enteric virus density requirement are
documented.
After the enteric virus reduction is demonstrated for the pathogen treatment process, the
sewage sludge continues to be Class A with respect to enteric viruses when the values for the
pathogen treatment process operating parameters are consistent with the values or ranges of
values documented.
The sewage sludge shall be analyzed prior to pathogen treatment to determine whether the
sewage sludge contains viable helminth ova.
WTien the density of viable helminth ova in the sewage sludge prior to pathogen treatment is
less than 1/4 g total solids (dry weight basis), the sewage sludge is Class A with respect to viable
helminth ova until the next monitoring episode for the sewage sludge.
When the density of viable helminth ova in the sewage sludge prior to pathogen treatment is
equal to or greater than 1/4 g total solids (dry weight basis), the sewage sludge is Class A with
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respect to viable helminth ova when the density of viable helminth ova in the sewage sludge after
pathogen treatment is less than 1/4 g total solids (dry weight basis) and when the values or ranges
of values for the operating parameters for the pathogen treatment process that produces the
sewage sludge that meets the viable helminth ova density requirement are documented.
After the viable helminth ova reduction is demonstrated for the pathogen treatment process,
the sewage sludge continues to be Class A with respect to viable helminth ova when the values
for the pathogen treatment process operating parameters are consistent with the values or ranges
of values documented.
d. Alternative 4. Either the density of fecal coliform in the sewage sludge is less than
1,000 MPN/g total solids (dry weight basis), or the density of Salmonella sp. bacteria in the
sewage sludge is less than 3 MPN/4 g total solids (dry weight basis) at the time the sewage
sludge is used or disposed; at the time the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the time the sewage sludge or material
derived from sewage sludge is prepared to meet the requirements in 40 CFR 503.10(b),
503.10(c), 503.10(e), or 503.10(f).
The density of enteric viruses in the sewage sludge is less than 1 Plaque-forming Unit/ 4 g
total solids (dry weight basis) at the time the sewage sludge is used or disposed; at the time the
sewage sludge is prepared for sale or given away in a bag or other container for application to the
land; or at the time the sewage sludge or material derived from sewage sludge is prepared to meet
the requirements in 40 CFR 503.10(b), 503.10(c), 503.10(e), or 503.10(f), unless otherwise
specified by the permitting authority.
The density of viable helminth ova in the sewage sludge is less than 1/4 g total solids (dry
weight basis) at the time the sewage sludge is used or disposed; at the time the sewage sludge is
prepared for sale or given away in a bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage sludge is prepared to meet the
requirements in 40 CFR 503.10(b), 503.10(c), 503.10(e), or 503.10(f), unless otherwise specified
by the permitting authority.
e. Alternative 5. Either the density of fecal coliform in the sewage sludge is less than
1,000 MPN/g total solids (dry weight basis), or the density of Salmonella sp bacteria in the
sewage sludge is less than 3 MPN/4 g total solids (dry weight basis) at the time the sewage
sludge is used or disposed; at the time the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the time the sewage sludge or material
derived from sewage sludge is prepared to meet the requirements in 40 CFR 503.10(b),
503.10(c), 503.10(e), or 503.10(f).
Sewage sludge that is used or disposed shall be treated in one of the Processes to Further
Reduce Pathogens described in Appendix B of 40 CFR 503.
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f. Alternative 6. Either the density of fecal coliform in the sewage sludge is less than
1,000 MPN/g total solids (dry weight basis), or the density of Salmonella sp bacteria in the
sewage sludge is less than 3 MPN/4 g total solids (dry weight basis) at the time the sewage
sludge is used or disposed; at the time the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the time the sewage sludge or material
derived from sewage sludge is prepared to meet the requirements in 40 CFR 503.10(b),
503.10(c), 503.10(e), or 503.10(f).
Sewage sludge that is used or disposed shall be treated in a process that is equivalent to a
Process to Further Reduce Pathogens, as determined by the permitting authority.
Class B Sludge is considered Class A with respect to pathogens when one of the following
methods is used:
g. Alternative 1. Seven samples of the sewage sludge is collected at the time the sewage
sludge is used or disposed. The geometric mean of the density of fecal coliform in the samples
must be less than either 2,000,000 MPN/g total solids (dry weight basis) or 2,000,000 Colony
Forming Units/g (CFU/g) total solids (dry weight basis).
h. Alternative 2. Sewage sludge that is used or disposed shall be treated in one of the
processes designed to significantly reduce pathogens as described in Appendix B of 40 CFR 503.
I. Alternative 3. Sewage sludge that is used or disposed is to be treated in a process that is
equivalent to a process to significantly reduce pathogens, as determined by the permitting
authority.
16. CN,A
Cyanide amenable to chlorination (40 CFR 413.02).
17. CN,T
Cyanide, total (40 CFR 413.02).
18. Contaminate an Aquifer
To introduce a substance that causes the Maximum Contaminant Level (MCL) for nitrate in
40 CFR 141.11 to be exceeded in groundwater; or to introduce a substance that causes the
existing concentration of nitrate in groundwater to increase when the existing concentration of
nitrate in the groundwater exceeds the maximum contaminant label for nitrate in 40 CFR 141.11
(40 CFR 503.21(c)).
19. Continuous Discharge
A discharge that occurs without interruption throughout the operating hours of the facility,
except for infrequent shutdowns for maintenance, process changes, or other similar activities (40
CFR 123.3).
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20. Cover
Soil or other material used to cover sewage sludge placed on an active sewage sludge unit
(40 CFR 503.21(d)).
21. Cover Crop
A small grain crop, such as oats, wheat, or barley, not grown for harvest (40 CFR 503.9(d)).
22. Cumulative Pollutant Loading Rate
The maximum amount of an inorganic pollutant that can be applied to an area of land (40
CFR 503.11(f)).
23. Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period which
reasonably represents the calendar day for purposes of sampling (40 CFR 122.2).
24. Density of Microorganisms
The number of microorganisms per unit mass of total solids (diy weight) in the sewage
sludge (40 CFR 503.31(c)).
25. Direct Discharge
The discharge of a pollutant (40 CFR 122.2).
26. Discharge of Pollutant
The addition of any pollutant to navigable waters from any point source and any addition of
any pollutant to the waters of the contiguous zone or the ocean zone or the ocean from any point
source, other than from a vessel or other floating craft (40 CFR 401.11(h)).
27. Displacement
The relative movement of any two sides of a fault measured in any direction (40 CFR
503.21(e)).
28. Domestic Septage
Either liquid or solid material removed from a septic tank, cesspool, portable toilet, Type III
marine sanitation device, or similar treatment works that receives only domestic sewage.
Domestic septage does not include liquid or solid material removed from a septic tank, cesspool,
or similar treatment works that receive either commercial wastewater or industrial wastewater; it
also does not include grease removed from a grease trap at a restaurant (40 CFR 257.2).
29. Domestic Sewage
Waste and wastewater from humans or household operations that is discharged to or
otherwise enters a treatment works (40 CFR 503.9(g)).
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30. Effluent Limitations
Any restriction established by the Administrator on quantities, rates, and concentrations of
chemical, physical, biological, and other constituents that are discharged from point sources,
other than new sources, into navigable waters, the waters of the contiguous zone, or the ocean
(40 CFR 401.1 l(i)).
31. Environmentally Sensitive Area
An area of environmental importance that is in or adjacent to navigable waters (49 CFR
194.5).
32. Excluded Sludge
The following are types of sludge and activities are exempted from meeting the requirements
outlined in 40 CFR 503:
• Processes used to treat domestic sewage or processes used to treat sewage sludge prior
to final use except for the standards on pathogen and vector reduction in 40 CFR 503.32
and 503.33;
• Sewage sludge cofired in an incinerator with other wastes or the incinerator in which
sewage sludge and other wastes are cofired;
• Sludge generated at an industrial facility during the treatment of industrial wastewater,
including sewage sludge generated during the treatment of industrial wastewater
combined with domestic sewage;
• Sewage sludge determined to be hazardous;
• Sewage sludge with a concentration of PCBs equal to or greater than 50 mg/kg total
solids (dry weight basis);
• Ash generated during the firing of sewage sludge in a sewage sludge incinerator;
• Grit (i.e., sand, gravel, cinders, or other material with high specific gravity) or
screenings (e.g , relatively large materials such as rags) generated during preliminary
treatment of domestic sewage in a treatment works;
• Sludge generated during the treatment of either surface water or groundwater used for
drinking water; and
• Commercial septage, industrial septage, a mixture of domestic septage and commercial
septage, or a mixture of domestic septage and industrial septage (40 CFR 503.6).
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33. Fault
A fracture or zone of fractures in any materials along which strata on one side are displaced
with respect to strata on the other side (40 CFR 503.21(f)).
34. Feed Crops
Crops produced primarily for consumption by animals (40 CFR 503.90)).
35. Feedlot
A concentrated, confined animal or poultry growing operation for meat, milk, or egg
production; or stabling in pens or houses wherein the animals or poultry are fed at the place of
confinement and crop or forage growth or production is not sustained in the area of confinement
(40 CFR 412.11(b)).
36. Fiber Crops
Crops such as flax and cotton (40 CFR 503.9(k)).
37. Final Cover
The last layer of soil or other material placed on a sewage sludge unit at closure (40 CFR
503.21(g)).
38. Forest
A tract of land thick with trees and underbrush (40 CFR 503.11(g)).
39. Holocene Time
The most recent epoch of the Quaternary period, extending from the end of the Pleistocene
epoch to the present (40 CFR 503.21(h)).
40. Indirect Discharge
The introduction of pollutants into a POTW from any nondomestic source regulated under
section 307(b), (c), or (d) of the Act (40 CFR 403.3(g)).
41. Industrial Activities
In relation to stormwater runoff, industrial activities include (40 CFR 122.26(b)(14)(i)
through 122.26(b)(14)(xi)):
• Facilities subject to storm water effluent limitations guidelines and new source
performance standards under 40 CFR Subchapter N;
• Facilities classified as Standard Industrial Classification (SIC) 24 (except 2434), 26
(except 265 and 267), 28 (except 283), 29, 311, 32 (except 323) 35, 344 and 373;
• Facilities classified as SICs 10 through 14 (mineral industry) including active or
inactive mining operations and oil and gas explorations; production, processing, or
treatment operations; or transmission facilities that discharge stormwater contaminated
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by contact with or that has come into contact with, any overburden, raw material,
intermediate product, finished products, byproducts, or waste products located on the
site of such operations;
• Hazardous waste Treatment, Storage, or Disposal Facilities (TSDF), including those
which are operating under interim status or a permit under the Resource Conservation
and Recovery Act (RCRA), Subpart C;
• Landfills, land application sites, and open dumps that receive or have received industrial
wastes, including those sites that are subject to Federal regulation;
• Facilities involved in the recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards, including but not limited to those
classified as SICs 5015 and 5093;
• Steam electric power generating facilities, including coal handling sites,
• Transportation facilities classified as SICs 40,41, 42 (except 4221-25), 43,44,45, and
5171 that have vehicle maintenance shops, equipment cleaning operations, or airport de-
icing operations;
• Treatment works treating domestic sewage or any other sewage sludge or wastewater
treatment device or system, used in the storage treatment, recycling, and reclamation of
municipal or domestic sewage, including land dedicated to the disposal of sewage
sludges that are located within the confines of the facility with a design flow of 1 0 mgd
or more, or required to have an approved pretreatment program. Not included are
farmlands, domestic gardens, or lands used for sludge management where sludge is
beneficially reused; areas that are not physically located within the confines of the
facility; or areas that are in compliance with section 405 of the CWA;
• Construction activity including clearing, grading, and excavation activities except
operations that result in the disturbance of land comprising less than five acres of the
total land area that is not part of a larger common plan of development or sale;
• Facilities under SICs 20,21,22,23,2434,25,265, 267,27, 283,285, 30, 31 (except
311), 323, 34 (except 3441), 35, 36, 37 (except 373), 38, 39 and 4221-25 (and that are
not otherwise included in categories 1-10).
42. Industrial User
A source of indirect discharge (40 CFR 403.3(h))
43. Industrial Wastewater
Wastewater generated in a commercial or industrial process (40 CFR 503.9(n)).
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44. Integrated Facility
A facility that performs electroplating as only one of several operations necessary for the
manufacture of a product at a single physical location and that also has significant quantities of
process wastewater from nonelectroplating sources (40 CFR 413.02).
45. Interference
A discharge which, alone or in conjunction with one or more discharges from other sources,
inhibits or disrupts the POTW and causes a violation of any requirement of the POTW's NPDES
permit (40 CFR 403.3(i)).
46. Job Shop
A facility that owns not more than 50 percent (annual area basis) of the materials undergoing
metal finishing (40 CFR 433.11).
47. Land Application
The spraying or spreading of sewage sludge onto the land surface; the injection of sewage
sludge below the land surface; or the incorporation of sewage sludge into the soil so that the
sewage sludge can either condition the soil or fertilize crops or vegetation grown in the soil (40
CFR 503.11(h)).
48. Land With a High Potential for Public Exposure
Land that the public uses frequently. This includes, but is not limited to, a public contact site
and a reclamation site located in a populated area (e.g., a construction site located in a city) (40
CFR 503.31(d)).
49. Land With a Low Potential for Public Exposure
Land the public uses infrequently. This includes, but is not limited to, agricultural land,
forest, and a reclamation site located in an unpopulated area (e.g., a strip mine located in a rural
area) (40 CFR 503.31(e))
50. Leachate Collection System
A system or device installed immediately above a liner that is designed, constructed,
maintained, and operated to collect and remove leachate from a sewage sludge unit (40 CFR
503.21(i)).
51. Liner
Soil or synthetic material which has a hydraulic conductivity of 3 x 10"8 in/s (3 x 10-8 in./s)
or less (40 CFR 503.210)).
52. Lower Explosive Limit for Methane Gas
The lowest percentage of methane gas in air, by volume, that propagates a flame at 25 °C
(77°F) and atmospheric pressure (40 CFR 503.2 l(k)).
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53. Management Practices(MPs)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
54. Metal Cleaning Wastes
Any wastewater resulting from cleaning (with or without chemical cleaning compounds) any
metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside
cleaning, and air preheater cleaning (40 CFR 423.11).
55. Municipality
A city, town, borough, county, parish, district, association, or other public body (including
an intermunicipal agency of two or more of the foregoing entities created by or under state law;
an Indian tribe or an authorized Indian tribal organization having jurisdiction over sewage sludge
management; or a designated and approved management agency under section 208 of the CWA,
as amended). The definition includes a special district created under state law, such as a water
district, sewer district, sanitary district, utility district, drainage district, or similar entity, or an
integrated waste management facility as defined in section 201(e) of the CWA, as amended, that
has as one of its principal responsibilities the treatment, transport, use, or disposal of sewage
sludge (40 CFR 503.9(o)).
56. National Pretreatment Standard
Any regulation containing pollutant discharge limits promulgated by the EPA (40 CFR
403.3(j)) (see Appendix 2-12 of this manual for a listing of pretreatment categories).
57. Navigable Waters
All navigable waters of the United States; tributaries of navigable waters of the United
States; interstate waters, intrastate lakes, rivers, and streams that are utilized by interstate
travelers for rivers; and streams that are utilized by interstate travelers for recreational or other
purposes; intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in
interstate commerce; and intrastate lakes, rivers, and streams that are utilized for industrial
purposes by industries in interstate commerce. Navigable waterways do not include prior
converted cropland (40 CFR 401.11(1)).
58. New Source
In relation to NPDES permits, any building, structure, facility, or installation from which
there is or may be a discharge of pollutants the construction of which commenced:
• After promulgation of standards of performance under section 306 of CWA that are
applicable to such sources, or
• After proposal of standards of performance in accordance with section 306 of CWA that
are applicable to such source, but only if the standards are promulgated in accordance
with section 306 within 120 days of their proposal.
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The following are the criteria for new source determination:
• It is constructed at a site at which no other source is located, or
• It totally replaces the process or production equipment that causes the discharge of
pollutants at an existing sources, or
• Its processes are substantially independent of an existing source at the same site (40
CFR 122.2 and 122.29(b)).
59. New Source
Any building, structure, facility, or installation from where there is or may be the discharge
of pollutants, the construction of which is commenced after the publication of proposed
regulations prescribing a standards of performance under section 306 of the CWA, that will be
applicable to such source as such standards is thereafter promulgated in accordance with section
306 of the CWA (40 CFR 401.11 (e)).
60. Noncontact Cooling Water
Water used for cooling that does not come into direct contact with any raw materials,
intermediate product, waste product, or finished product (40 CFR 401.1 l(o)).
61. NPDES Permit
A permit granted by EPA to a direct discharger that permits wastewater discharge to a
watercourse in accordance with the conditions of the permit (40 CFR 403.3(1)).
62. Open Lot
Pens or similar confinement areas with dirt, concrete, paved, or hard surface wherein
animals or poultry are substantially or entirely exposed to the outside environment except for
possible small portions affording some protection by windbreaks or small shed-type shade areas
(40 CFR 412.11(f)).
63. Other Container
Either an open or closed receptacle. This includes, but is not limited to, a bucket, a box, a
carton, and a vehicle or trailer with a load capacity of 1 metric ton (1.1 short tons) or less (40
CFR 503.110)).
64. pH
The logarithm of the reciprocal of the hydrogen ion concentration (40 CFR 503.31(g)).
65. Pass Through
A discharge that exits the POTW into waters in quantities or concentrations which, alone or
in conjunction with one or more discharges from other sources, is a cause of a violation of any
requirement of the POTW's NPDES permit (40 CFR 403.3(n)).
Phase 1 - Section 2
Water Pollution Control
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66. Pasture
Land on which animals feed directly on feed crops such as legumes, grasses, grain stubble,
or stover (40 CFR 503.1 l(k)).
67. Pathogenic Organisms
Disease-causing organisms. These include, but are not limited to, certain bacteria, protozoa,
viruses, and viable helminth ova (40 CFR 503.31(f)).
68. Person
An individual, association, partnership, corporation, municipality, state or Federal agency, or
an agent or employee thereof (40 CFR 503.9(q)).
69. Person Who Prepares Sewage Sludge
Either the person who generates sewage sludge during the treatment of domestic sewage in a
treatment works or the person who derives a material from sewage sludge (40 CFR 503.9(r))
70. Place Sewage Sludge or Sewage Sludge Placed
Disposal of sewage sludge on a surface disposal site (40 CFR 503.9(s)).
71. Point Source
Any discernible confined and discrete conveyance including, but not limited to, a pipe, ditch,
channel, or conduit from which pollutants are or may be discharged (40 CFR 401.11 (d)).
72. Pretreatment
The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of
the nature of pollutant properties in wastewater prior to or in lieu of discharging or otherwise
introducing such pollutants into a POTW (40 CFR 403.3(q)).
73. Process Generated Wastewater
In relation to feedlots, water directly or indirectly used in the operation of a feedlot for any
or all of the following: spillage or overflow from animal or poultry watering systems; washing,
cleaning, or flushing pens, barns, manure pits, or other feedlot facilities; direct contact
swimming, washing, or spray cooling or animals; and dust control (40 CFR 412.11(d)).
74. Process Wastewater
Any water that, during manufacturing or processing, comes into direct contact with or results
from the production or use of any raw material, intermediate product, finished product, or waste
product (40 CFR 401.1 l(q)).
75. Process Wastewater for Feedlots
Any process-generated wastewater and any precipitation (rain or snow) that comes into
contact with any manure, litter, or bedding, or any other raw material or intermediate or final
material or product used in or resulting from the production of animals or poultry or direct
production (40 CFR 412.11(c)).
Phase 1 - Section 2
Water Pollution Control
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76. Public Contact Site
Land with a high potential for contact by the public This includes, but is not limited to,
public parks, ball fields, cemeteries, plant nurseries, turf farms, and golf courses (40 CFR
503.11(1)).
77. Publicly Owned Treatment Works (POTW)
A treatment works that is owned by the state or a municipality. This includes any devices
and systems used in the storage, treatment, recycling, and reclamation of municipal sewage or
industrial wastes of a liquid nature. It also includes sewers, pipes, and other conveyances only if
they convey waste to a POTW (40 CFR 403.3(o)).
78. Qualified Groundwater Scientist
An individual with a baccalaureate or postgraduate degree in the natural sciences or
engineering who has sufficient training and experience in groundwater hydrology and related
fields, as may be demonstrated by state registration, professional certification, or completion of
accredited university programs, to make sound professional judgments regarding groundwater
monitoring, pollutant fate and transport, and corrective action (40 CFR 503.21(1)).
79. Range Land
Open land with indigenous vegetation (40 CFR 503.1 l(m)).
80. Reclamation Site
Drastically disturbed land that is reclaimed using sewage sludge This includes, but is not
limited to, strip mines and construction sites (40 CFR 503.1 l(n)).
81. Runoff
Rainwater, leachate, or other liquid that drains over land on any part of a land surface and
runs off of the land surface (40 CFR 503.9(v)).
82. Seismic Impact Zone
An area that has a 10 percent or greater probability that the horizontal ground level
acceleration of the rock in the area exceeds 0.10 gravity once in 250 years (40 CFR 503.21(m)).
83. Sewage Sludge
Solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in a
treatment works. Sewage sludge includes, but is not limited to, domestic septage, scum, or solids
removed in primary, secondary, or advanced wastewater treatment processes; and material
derived from sewage sludge. Sewage sludge does not include ash generated during the firing of
sewage sludges in a sewage sludge incinerator or grit and screenings generated during
preliminary treatment of domestic sewerage in a treatment works (40 CFR 257.2).
Phase 1 - Section 2
Water Pollution Control
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84. Sewage Sludge Unit
Land on which only sewage sludge is placed for final disposal. This does not include land on
which sewage sludge is either stored or treated. Land does not include waters of the United
States, as defined in 40 CFR 122.2 (40 CFR 503.21(n)).
85. Sewage Sludge Unit Boundary
The outermost perimeter of an active sewage sludge unit (40 CFR 503.2 l(o)).
86. Specific Oxygen Uptake Rate (SOUR)
The mass of oxygen consumed per unit time per unit mass of total solids (dry weight basis)
in the sewage sludge (40 CFR 503.31(h)).
87. Store or Storage of Sewage Sludge
The placement of sewage sludge on land on which the sewage sludge remains for two years
or less. This does not include the placement of sewage sludge on land for treatment (40 CFR
503.9(y)).
88. Stormwater Discharge Associated with an Industrial Activity
The discharge from any conveyance that is used for collecting and conveying stormwater
and that is directly related to manufacturing, processing, or raw materials storage areas at any
industrial plant. This does not include discharges from facilities excluded from the NPDES
program. For the categories of industries identified in the definition for Industrial Activities, the
items lettered A through K, the term includes, but is not limited to, stormwater discharges from
industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw
materials, manufactured products, waste material or byproducts used or created by the facility;
material handling sites; refuse sites; sites used for the application or disposal of process waste
wastes; sites used for the storage and maintenance of material handling equipment; sites used for
residual treatment, storage or disposal; shipping and receiving areas, manufacturing buildings,
storage areas (including tank farms) for raw materials and intermediate and finished products;
and areas where industrial activity has taken place in the past and significant materials remain
and are exposed to stormwater. For item Number 1 in the definition for Industrial Activities, the
term only includes only storm water discharges from all the areas (except access roads and rail
lines) that are listed in the previous sentence where materials handling equipment or activities,
raw materials, intermediate products, final products, waste materials, byproducts, or industrial
machinery are exposed to stormwater (40 CFR 122.26(b)(14)).
89. Strong Chelating Agents
All compounds that, by virtue of their chemical structure and amount present, form soluble
metal complexes that are not removed by subsequent metals control techniques, such as pH
adjustment followed by clarification or filtration (40 CFR 413.02).
90. Surface Disposal Site
An area of land that contains one or more active sewage sludge units (40 CFR 503.2 l(p)).
Phase 1 - Section 2
Water Pollution Control
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91. TTO
Total toxic organics (40 CFR 413.02).
92. Total Hydrocarbons
The organic compounds in the exit gas from a sewage sludge incinerator stack measured
using a flame ionization detection instrument referenced to propane (40 CFR 503.41 (m)).
93. Total Metal
The sum of the concentrations of mass of copper, nickel, chromium, and zinc (40 CFR
413.02).
94. Total Solids
The materials in sewage sludge that remain as residue when the sewage sludge is dried at
103 to 105 °C (217.4 to 221 °F)(40CFR 503.3 l(i)).
95. Treat or Treatment of Sewage Sludge
The preparation of sewage sludge for final use or disposal. This includes, but is not limited
to, thickening, stabilization, and dewatering of sewage sludge. This does not include storage of
sewage sludge (40 CFR 503.9(z)).
96. Treatment Works
Either a federally owned, publicly owned, or privately owned device or system used to treat
(including recycle and reclaim) either domestic sewage or a combination of domestic sewage and
industrial waste of a liquid nature (40 CFR 503.9(aa)).
97. Unstabilized Solids
Organic materials in sewage sludge that have not been treated in either an aerobic or
anaerobic treatment process (40 CFR 503.3 l(j)).
98. Unstable Area
Land subject to natural or human-induced forces that may damage the structural components
of an active sewage sludge unit. This includes, but is not limited to, land on which the soils are
subject to mass movement (40 CFR 503.2 l(q)).
99. Vector Attraction
The characteristic of sewage sludge that attracts rodents, flies, mosquitoes, or other
organisms capable of transporting infectious agents (40 CFR 503.3 l(k)).
100. Volatile Solids
The amount of the total solids in sewage sludge lost when the sewage sludge is combusted at
550 °C (1,022 °F) in the presence of excess air (40 CFR 503.31(1)).
Phase 1 - Section 2
Water Pollution Control
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101. Wetlands
Those areas that are inundated or saturated by surface water or groundwater at a frequency
and duration to support, and that, under normal circumstances, do support a prevalence of
vegetation typically adapted for life in saturated soil conditions. Wetlands generally include
swamps, marshes, bogs, and similar areas (40 CFR 503 9(bb)).
F. Records to Review
• NPDES Permits
• NPDES Permit renewal applications (if expire within 180 days)
• Discharge monitoring reports for the past year
• Laboratory records and procedures and EPA QA results
• Monthly operating reports for wastewater treatment facilities
• Flow monitoring calibration certification and supporting records
• Ash pond volume certification and supporting records
• Red water inspection records
• Special reports, certifications, etc., required by NPDES permit
• Spill Prevention Control and Countermeasure (SPCC) Plan
• All records required by SPCC Plan
• All notices of non-compliance
• All notices of violations
• NPDES state or Federal inspection reports
• Wastewater treatment plant operator certification
• Administrative Orders
• Sewer and storm drain layout
• Local sewer ordinance
• Local service use permit
• Notification to local POTW
• Old Spill Reports
• Repair/Maintenance records for the wastewater treatment system
• As Built Drawings
• Federal Facility Compliance Agreements
• Stormwater pollution prevention plan
• Pretreatment Permits
• Fact Sheet
• Pretreatment monitoring records
• Sludge handling permits
G. Physical Features to Inspect
• Discharge outfall pipes
• Wastewater treatment facilities
Phase 1 - Section 2
Water Pollution Control
2-21
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• Industrial treatment facilities
• Streams, rivers, open waterways
• Floor and sink drains (especially in industrial areas)
• Stormwater collection points (especially in industrial areas)
• Oil storage tanks
• Oil/water separators
• Wastewater generation points
• Sludge storage areas and land application sites
Phase 1 - Section 2
Water Pollution Control
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H. Guidance For Checklist Users
Refer To
Checklist Items
Page Niimters
All Facilities
WP.l through WP 3
2-25
NPDES Permits
WP 4 through WP 6
2-26
WP 7
2-27
Stormwater
WP 8 through WP 9
2-28
WP 10 through WP 13
2-29
Discharges to POTWs/FOTWs
WP 14 through WP 15
2-30
WP 16 through WP 18
2-31
WP 19 through WP 21
2-32
Effluent Limitations for Steam
Electric Power Generating
Sources
General
WP 22
2-32
WP 23 through WP 25
2-33
WP 26 through WP 28
2-34
New Sources
WP 29 through WP 30
2-35
WP.31 through WP.33
2-36
Existing Sources
WP 34
2-36
Effluent Limitations for Electroplating
Point Sources
WP.35 through WP 37
2-37
WP 38 through WP 40
2-38
WP 41
2-39
Effluent Limitations for Metal
Finishing Point Sources
General
WP 42 through WP 43
2-39
WP 44
2-40
Existing Sources
WP 45
2-40
New Sources
WP 46
2-40
WP 47
2-41
Effluent Limitations for Hospitals
WP48
2-41
Effluent Limitations for Photo Labs
WP49
2-41
Effluent Limitations for Feedlots
WP 50
2-42
Phase 1 - Section 2
Water Pollution Control
2-23
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Refer To
Checklist Items
! Page Nw# tors
Land Application of Sludge
General
WP.51
2-43
WP.52
2-44
WP 53
2-45
WP 54
2-46
WP 55 through WP 56
2-47
WP 57
2-48
Vectors and Pathogens
WP 58
2-48
WP.59
2-49
WP 60
2-50
WP61
2-51
WP.62
2-52
Notifications
WP 63 through WP 64
2-53
WP 65 through WP 66
2-54
WP 67
2-55
Monitoring
WP 68
2-55
WP 69
2-56
Recordkeeping and Reporting
WP.70
2-56
WP.71
2-57
WP 72
2-58
WP 73 through WP 74
2-59
WP 75 through WP 77
2-60
Surface Disposal of Sludge
General
WP.78 through WP 81
2-61
WP 82
2-62
WP 83 through WP.84
2-63
Monitoring and Documentation
WP 85 through WP 87
2-64
WP 88 through WP.90
2-65
Phase 1 - Section 2
Water Pollution Control
2-24
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Compliancy Category:
WaterPoHution Control
Regulatory Requirements:
1 Reviewer Checks;
All Facilities
WP 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation.)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
accomplished to correct problems
WP 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will nave the citation of
the applied regulation as a basis
of finaing )
Determine if the facility has activities or facilities that are federally regulated, but not
addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
WP 3 Facilities are required to
abide by state and local
wastewater regulations (EO
12088, Sect 1-1)
Verify that the facility is abiding by state and local water quality requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
- Nonpoint sources
- NPDES permits
- Wastewater
- Monitoring and recordkeeping for NPDES permitted sources
- Certification requirements for laboratories analyzing samples
- Wastewater treatment plant operator certification
- Sludge disposal
- Pretreatment standards
- Discharges to sewage treatment facilities
- Industrial wastewater
- Septic tanks
- Stormwater pollution prevention plan
- Stormwater discharges)
NPDES Permits
Phase 1 - Section 2
Water Pollution Control
2-25
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks;
WP.4 Facilities with point
source discharges and/or
treatment works treating
domestic sewage are required to
have a Federal NPDES permit if
located in states without an
EPA-approved NPDES permit
program (40 CFR 122 1(b)(3)).
Determine if the facility is located in a state with an EPA-approved NPDES permit
program.
Verify the facility has obtained the proper permits for point source discharges and/or
treatment works treating domestic sewage
Verify that the facility is operating according to permit requirements such as
- Monitoring/sampling
- Concentrations of discharge constituents
- Recordkeeping
- Reports
(NOTE The Regional Administrator may require the facility to have a permit for the
use/disposal of sewage sludge as necessary to protect public health)
(NOTE Stormwater runoff may be addressed in the NPDES permit.)
(NOTE Look for oil/water separators and washracks that discharge directly to the
environment)
WP 5 Samples must be
collected in accordance with
proper collection, testing,
preservation, and shipping
procedures in Standard
Methods for Water Analysis (40
CFR 136 1 through 136 4)
Verify that
- Proper sample containers are used
- Samples are refrigerated to 4°C during compositing
- Proper preservation techniques are used
- Flow-proportioned samples are obtained where required by permit
- Sample holding times prior to analyses conform with requirements
- The chain of custody is maintained from sampling point through analytic testing to
results (essential if litigation occurs)
Verify that results are reported in the facility's self-monitoring report
WP 6 Analytical testing must
be done in accordance with
EPA-approved analytical
procedures (40 CFR 136 3).
Determine if
- An EPA-approved analytical testing lab was used
- Proper approval was obtained from state/EPA if alternate analytical procedures are
used
- Parameters other than those required by the permit are analyzed
- Satisfactory calibration and maintenance of instruments and equipment is done
- Quality control procedures are used
- Duplicate samples are analyzed
- Spiked samples are used
- A commercial laboratory is used
- The commercial laboratory is state certified (states with formal certification
program).
Phase 1 - Section 2
Water Pollution Control
2-26
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Compliant Category:
Water PoButkra Control
Regulatory Requirements:
Reviewer Cbeefcs;
WP 7 Facilities with NPDES
permits are required to meet
specific reporting requirements
(40 CFR 122 41(1))
Verify that the facility gives notice to the Director as soon as possible of any planned
physical alterations or additions to the permitted facility when'
- The alteration or addition might meet one of the criteria for determining if the
facility is a new source (see definitions)
- The alteration or addition could significantly change the nature or increase the
quantity of pollutants discharged (this applies to pollutants that are not subject to
requirements in the permit or other notifications)
- The alteration or addition results in a significant change in the installations sludge
use or disposal practices
Verify that the facility notifies the Director of any planned changes at the permitted
facility or activity that may result in noncompliance with permit requirements
Verify that monitoring is reported as required in the permit
Determine if the facility is monitoring more frequently than required
Verify that if the facility is monitoring more frequently than required by permit these
results are also being reported
Verify that reports of compliance or noncompliance with, or any progress reports on,
interim and final requirements contained in any compliance schedule on the permit
are submitted no later than 14 days following each specified date
Verify that noncompliance that might endanger health or the environment is reported
as follows:
- Orally within 24 hours from the time the facility becomes aware of noncompliance
- In writing within five days of the time the facility becomes aware of
noncompliance
Stormwater
(NOTE An industrial facility whose stormwater discharges are' (1) associated with industrial activity, and (2) are
channeled directly into surface waters, into a separate municipal storm sewer, or into a federally or privately owned
separate sewer system must apply for, obtain, and comply with an NPDES permit covering the facility's stormwater
discharges (40 CFR 122 26(a)) An industrial facility may apply for NPDES permit coverage for stormwater discharges
by one of three permitting mechanisms: submitting an individual application by 1 October 1992, participating in a group
application by submitting Part 1 of the group application by 30 September 1991, or submitting a "notice of intent" to be
covered by a baseline general permit promulgated by EPA or a delegated NPDES state, where applicable (40 CFR
122 26(e)) Facilities with existing NPDES permits for stormwater discharges associated with industrial activity shall
maintain existing permits. New applications are to be submitted in accordance with the requirements of 40 CFR 122 21
and 122 26(c) 180 days before the expiration of such permits Facilities with expired permits or permits due to expire
before 18 May 1992 shall submit applications in accordance with the deadlines set forth under 40 CFR 122 26(e)(1)
In addition to the NPDES permit requirements, an owner of a stormwater discharge associated with industrial activity that
discharges through a large or medium municipal separate storm sewer system must submit to the owner of the municipal
separate storm sewer system receiving the discharge, no later than 15 May 1991 (or 180 days prior to commencing such
discharge) the name of the facility, a contact person and phone number, the location of the discharge, a description,
including the SIC code that best reflects the principal products or services provided by the facility, and any existing
NPDES permit numbers (40 CFR 122 26 (55 FR 47990, 16 November 1990)))
(NOTE On 19 November 1993 (57 FR 41235), EPA proposed a Multi-Sector Stormwater General Permit that was
formerly referred to as a group permit. The proposed permit is intended to cover discharges from 29 industrial sectors
and may include additional requirements for certain industries )
Phase 1 - Section 2
Water Pollution Control
2-27
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 8 Facilities that are
dischargers of stormwater
associated with an industrial
activity (see definitions) are
required to apply for an
individual permit, apply for a
permit through a group
application, or seek coverage
under a promulgated
stormwater general permit (40
CFR 122.26(c))
Determine if the facility is discharging stormwater associated with an industrial
activity
Verify that an application has been submitted for a permit
WP.9. As part of the facility's
stormwater management
program, the facility must
prepare a Stormwater Pollution
Prevention Plan (SWPPP) (40
CFR 122.26)
Obtain a copy of the facility's Stormwater Pollution Prevention Plan (SWPPP) and
determine if the SWPPP adequately addresses each of the required components'
- Identification of the pollution prevention team and their responsibilities for
developing the pollution prevention plan and assisting in its implementation,
maintenance, and revision
- A description of potential pollutant sources that specifically includes the following
- A site map that completely illustrates site features (e g , outfalls, drainage
patterns and directions, structural control measures, surface water bodies)
-- A complete inventory of the types of materials handled at the facility that
potentially may be exposed to precipitation
-- A list of all significant spills and significant leaks of toxic or hazardous
pollutants which drained to a stormwater conveyance and that occurred at the
facility in the three years prior to the effective date of the permit
-- A summary of existing stormwater discharge sampling data
-- Non-stormwater (e g, direct process water, non-contact cooling water, sanitary
wastes) discharge assessment.
-- A site evaluation summary that provides a narrative description of activities
with a high potential to contaminate stormwater and any pollutants of concern
that may be associated with such activities
- A description of facility stormwater management controls that specifically includes
the following-
-- Good housekeeping practices that are designed to maintain a clean and orderly
work environment
- A preventative maintenance program
-- Spill prevention and response procedures
-- Visual inspection plan including follow-up procedures and records of
inspections
- Employee training program for personnel responsible for implementing
activities in the SWPPP or whose job could possibly impact stormwater
discharges.
-- Sediment and erosion control plan.
-- Runoff management procedures
-- Recordkeeping and internal reporting procedures
- A signed, comprehensive annual site compliance evaluation by a qualified person
that includes inspections of the stormwater discharges and evaluation of the
stormwater management systems
Verify that the SWPPP is signed by an "authorized representative" who is a person
near the top of the facility's management chain (the president, vice president, or a
production manager) who has been delegated the authority to sign and certify this
type of document
Phase 1 - Section 2
Water Pollution Control
2-28
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Compliance Category:
Water Pollution Coalrol
Regulatory Requirements'.
Reviewer Cheeks:
WP 10 The S WPPP must be
modified within 14 days on a
spill of a hazardous substance
(equal to or exceeding a
reportable quantity) to
storm water (40 CFR 122 26)
Verify that if any spill of a hazardous substance in an amount equal to or in excess of
a reportable quantity (established in 40 CFR 117 or 40 CFR 302) occurs to a
stormwater discharge, the SWPPP is modified within 14 calendar days to include a
description of the release, the circumstances of the release, and the date of release
WP. 11 Semiannual monitoring
is required if stormwater comes
into contact with any Section
313 water priority chemical or
any area used for lead acid
battery reclamation (40 CFR
122 26)
Determine if stormwater comes into contact with any equipment, tank, container or
other vessel or area used for storage of a Section 313 water priority chemical or any
area used for lead acid battery reclamation If so, verify that semiannual monitoring is
conducted
(NOTE See Addendum B, 57 FR41235, dated 9 September 1992, for a listing of the
Section 313 water priority chemicals )
WP 12 Salt storage piles used
for de-icing or other purposes
must be kept covered (40 CFR
122 26)
Determine if storage piles of salt used for deicing or other commercial or industrial
purposes generate a stormwater discharge associated with industrial activity If so,
verify that they are covered to prevent exposure to precipitation, except for exposure
resulting from adding or removing materials from the pile
WP 13 Even where not
covered by NPDES permits,
stormwater discharge on the
facility should be
uncontaminated and periodic
surveillance of these discharges
should be completed (MP)
Determine which drains at the facility are connected to die storm sewer and the
location of all outfalls and discharge points
Determine if there is evidence of contamination (oil sheen, discoloration, etc ) by
physical review of stormwater discharge sites
Verify that oil/water separators connected to the storm sewer on the facility are
operating properly and correctly maintained
Determine if there is evidence of contaminated waste streams discharging to floor
drains connected to the stormwater discharge system by checking major industrial
shops or industrial areas physically, including
- Battery shop
- Corrosion control
- Engine shop
- Motor pool
- Paint shop
- Plating shop
- Pesticide shop
- Petroleum, Oils, and Lubricants (POL) area
Discharges to POTWs/FOTWs
Phase 1 - Section 2
Water Pollution Control
2-29
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 14 Facilities must not
discharge into a POTW/FOTW
any pollutant that would cause
pass through or interference (40
CFR 403 5(a) and 403 5(c)(2))
Determine the following
- What point source discharges are at the facility7
- What drains in the facility lead to the treatment works9
- What do personnel pour down the drains leading to the treatment works9
- What types of materials are located in areas where spills may reach the drains to the
treatment works9
Determine which drains are connected to the sanitary sewer draining to a
POTW/FOTW and possible pollutants entering these drains
Verily that the facility is not discharging to a POTW/FOTW pollutants that would
cause a pass through or interference (see definitions)
Determine if the POTW/FOTW has imposed any pretreatment standards or reporting
requirements on the facility and verify that they are being met.
WP 15 Facilities that are
regulated by a specific national
pretreatment standard must
comply with applicable
quantities or pollutant
properties for new and existing
sources (40 CFR 403 6)
Determine if the facility is subject to any national pretreatment standard (see
Appendix 2-12 for a listing of the categories )
Phase 1 - Section 2
Water Pollution Control
2-30
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 16 Facilities shall not
introduce specific pollutants
into a POTW/FOTW (40 CFR
403 5(b))
Verify that pollutants that create a fire or explosion hazard in the POTW/FOTW,
including but not limited to waste streams with a closed cup flashpoint of less than
140 °F (60 °C), are not being discharged from the facility to a POTW/FOTW
Verify that pollutants that will cause corrosive structural damage to the POTW/FOTW
are not being discharged from the facility to a POTW/FOTW
Verify that in no case are discharges with a pH below 5 0 released
Verify that solid or viscous pollutants in amounts that will cause obstruction to the
flow are not being discharged to the POTW/FOTW Examples are
- Fish cleaning stations
- Pieces of metals, rubber, and wood from shops
- Sand and sediment
Verify that no pollutants, including oxygen demand pollutants, are released at a flow
rate or concentration that will cause interference with the POTW/FOTW
Verify that heat in amounts that would inhibit biological activity at the POTW/FOTW
resulting in interference is not discharged, including
- Scrubber water
- Boiler blow down
(NOTE In no case will the temperature of discharges result in a temperature at the
POTW/FOTW of greater than 40 °C (104 °F))
Verify that petroleum, oil, nonbiodegradable cutting oil, or products of mineral oil
origin are not discharged in amounts that would result in a pass through or
interference (specifically check maintenance areas and oil/water separators)
Verify that pollutants that would result in the presence of toxic gases, vapors, or
fumes within the POTW/FOTW in quantities that would cause acute worker health
and safety problems are not discharged
Verify that no trucked or hauled pollutants are discharged except at discharge points
designated by the POTW/FOTW
Determine if the facility has been granted any exemptions or variances concerning its
discharges
WP 17 Facilities are required
to notify the POTW/FOTW
immediately of any discharge,
including slug loading, that
could cause problems to the
POTW/FOTW (40 CFR
403 12(0)
Verify that personnel at the facility are aware of the need to notify the POTW/FOTW
of any discharge that would cause problems
WP 18 Industrial users that are
not required to meet a
categorical pretreatment
standard are required to submit
specific reports (40 CFR
403 12(h))
Verify that if the facility is a significant noncategorical industrial user, it submits a
description of the nature, concentration, and flow of pollutants to the Control
Authority
(NOTE. The Control Authority is (1) The POTW/FOTW if the POTW's/FOTW's
submission for its pretreatment program has been approved, or (2) The Approval
Authority if the submission has not been approved )
Phase 1 - Section 2
Water Pollution Control
2-31
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 19. Industrial users are
required to notify the
POTW/FOTW, the Regional
Waste Management Division
Director, and state hazardous
waste authorities in writing of
any discharges into the
POTW/FOTW of a substance
that would be a hazardous waste
(40 CFR 403.12(p)).
Determine if the facility is discharging any substance to a POTW/FOTW that would
be classified as a hazardous waste if disposed of in any other manner
Verify that if they are discharging a hazardous waste to the POTW/FOTW, the correct
people have been notified of the following
- The name of the waste
- The type of discharge (batch, continuous, or other)
Verify that if the discharge is more than 100 kg/month, the following information is
also included to the extent that it is known and readily available.
- Identification of the hazardous constituents
- An estimate of the mass and concentrations of the constituents in the waste
discharges during the calendar month.
WP 20 All industrial users are
required to notify the
POTW/FOTW m advance of
any substantial change in the
volume or character of
pollutants in their discharge (40
CFR 403 120)).
Verify that the sources of industrial discharge on the facility notify the POTW/FOTW
in advance of any substantial changes in the volume or character of pollutants in their
discharge, including the listed or characteristic hazardous wastes
WP 21. Industrial users and
POTWs/FOTWs are required to
keep specific reports (40 CFR
403 12(o))
Verify that the facility and the POTW/FOTW keep records of all information
resulting from monitoring activities.
Verify that the records include for all samples the following information
- The date, exact place, methods, and time of sampling ana the names of the person
or persons taking the samples
- The dates analyses were performed
- Who performed analyses
- The analytical techniques and methods used
- The results of the analyses
Verify that records are kept for 3 years
Effluent Limitations for Steam Electric
Power Generating Sources
General
WP22. Facilities that have
steam electric power generating
point sources are subject to
certain point source effluent
limitations (40 CFR
423 12(b)(1) through
423 12(b)(2), and
423 12(b)(12))
Determine if the facility engages in the generation of electricity using fossil fuel
sources and employing the steam water system as the thermodynamic medium.
Verify that the following limitations for steam generation point source effluent are
met:
- pH of all discharges, except once-through cooling water, is in the range of 6 0-9.0
- There is no discharge of PCB compounds
(NOTE: If waste streams from various sources are combined for treatment or
discharge, the quantity of each pollutant or pollutant property attributable to each
contributing waste source are subject to the limitations listed here.)
(NOTE This applies to electricity power generating facilities utilizing fossil-type
fuel or nuclear fuel in conjunction with a thermal cycle employing the steam water
system as the thermodynamic medium )
Phase 1 - Section 2
Water Pollution Control
2-32
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 23 Facilities that have
steam electric power generating
point sources are subject to
certain point source effluent
limitations (40 CFR
423 12(b)(3) through
423.12(b)(7) and
423 12(b)(12»
Verify that the quantity of pollutant discharged from low volume waste sources and in
fly ash and bottom ash transport water do not exceed the quantity determined by
multiplying the flow of either source times the concentration listed in Chart 1 of
Appendix 2-1
Verify that the quantity of pollutants discharged in metal cleaning wastes do not
exceed the quantity determined by multiplying the flow of metal cleaning wastes
times the concentration listed in Chart 2 of Appendix 2-1
Verify that the quantity of free available chlorine discharged in once-through cooling
water or in cooling tower blow down does not exceed the quantity determined by
multiplying the flow of either source times the concentration listed below
- Maximum Concentration (mg/L) = 05
- Average Concentration (mg/L) = 02
(NOTE If waste streams from various sources are combined for treatment or
discharge, the quantity of each pollutant or pollutant property attributable to each
contributing waste source are subject to the limitations listed here)
(NOTE This applies to electricity power generating facilities utilizing fossil-type
fuel or nuclear ruel in conjunction with a thermal cycle employing the steam water
system as the thermodynamic medium )
WP 24 Facilities discharging
free available chlorine and total
residual chlorine are subject to
certain point source effluent
limitations (40 CFR
423 12(b)(8) and
423 12(b)( 12))
Verify that neither free available chlorine nor total residual chlorine are discharged
from any unit for more than 2 hours per day and not more than one unit in any plant
discharges at a time unless permission to do so has been granted by the appropriate
authority
(NOTE If waste streams from various sources are combined for treatment or
discharge, the quantity of each pollutant or pollutant property attributable to each
contributing waste source are subject to the limitations listed here)
WP 25 Facilities discharging
coal pile runoff are subject to
certain point source effluent
limitations (40 CFR
423 12(b)(9) through
423 12(b)(l 1), and
423 12(b)( 12))
Determine if the facility is discharging coal pile runoff.
Verify that the maximum concentration for any time of TSS does not exceed 50 mg/L
(NOTE: If waste streams from various sources are combined for treatment or
discharge, the quantity of each pollutant or pollutant property attributable to each
contributing waste source are subject to the limitations listed here)
Phase 1 - Section 2
Water Pollution Control
2-33
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Compliance Category:
Water Pollution Control
Regulatory Requirements;
Reviewer Che
-------
Compliance Category:
WaterPolutioH Control
Regulatory Requirements:
Reviewer Checfesr
Effluent Limitations for Steam Electric Power Generating Sources
New Sources
WP29 Facilities that have new
steam electric power generator
point sources are subject to
New Source Performance
Standards (NSPS) (40 CFR
423 15(a) through 423 15(d),
423 15(f), 423 15(j), and
423 15(n))
Determine if the facility has any new steam electric power generator point sources
Verify that the quantity of pollutants discharged from low volume waste sources and
bottom ash transport water do not exceed the quantity determined by multiplying the
flow of these sources times the concentration listed in Chart 1 of Appendix 2-1
Verify that the quantity of pollutant discharged in chemical metal cleaning wastes
does not exceed the quantity determined by multiplying the flow of chemical metal
cleaning wastes times the concentration listed in Chart 5 in Appendix 2-1
Verify that the quantity of free available chlorine discharged in cooling tower blow
down does not exceed the quantity determined by multiplying the flow of cooling
tower blow down times the concentration listed below
- Maximum concentration (mg/L) = 05
- Average concentration (mg/L) = 02
Verify that there is no discharge of waste water pollutants from fly ash transport
water
Verify that the quantity of pollutants discharged in cooling tower blow down does not
exceed the quantity determined by multiplying the flow of cooling tower blow down
times the concentration listed in Chart 3 of Appendix 2-1
(NOTE. If waste streams from various sources are combined for treatment or
discharge, the quantity of each pollutant or pollutant property attributable to each
contributing waste source are subject to the limitations listed here )
Verify that the pH of all discharges, except once-through cooling water, is within the
range of 6 0 to 9 0
Verify that there is no discharge of PCBs
WP 30 Facilities that introduce
pollutants from new sources
into a POTW/FOTW are subject
to certain pretreatment
standards (40 CFR 423 17)
Determine if the facility introduces pollutants from new sources into a treatment
works
Verify that there is no discharge of PCB compounds from new sources into
POTWs/FOTWs
Verify that discharge of copper (total) in chemical metal cleaning wastes from new
sources into POTWs/FOTWs does not exceed the maximum concentration for one
day of 1.0 mg/L
Verify that pollutants discharge in cooling tower blow down from new sources does
not exceed the concentration listed in Chart 7 of Appendix 2-1
Verify that there is no discharge of wastewater pollutants from fly ash transport water
from new sources into POTWs/FOTWs
Phase 1 - Section 2
Water Pollution Control
2-35
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks;
WP.31 Facilities that have new
steam electric power generator
facilities having a total rated
electric generating capacity of
25 or more MW are subject to
certain point source effluent
limitations (40 CFR 423 15(h))
Determine if the facility has new steam electric power generator facilities having a
total rated electric generating capacity of 25 or more MW
Verify that the quantity of total residual chlorine discharged in once-through cooling
water from each discharge point does not exceed the quantity determined by
multiplying the flow of once-through cooling water from each discharge point times
0 20 mg/L
Verify that total residual chlorine is not discharged from any single generating unit for
more than 2 hours per day, unless permitted to do so by the appropriate authority
(NOTE Simultaneous multi-unit chlorination is permitted )
WP 32 Facilities that have new
steam electric power generator
facilities having a total rated
electric generating capacity of
25 or fewer MW are subject to
certain point source effluent
limitations (40 CFR 423 15(i))
Determine if the facility has steam electric power generator facilities having a total
rated electric generating capacity of 25 or fewer MW.
Verify that the quantity of free available chlorine discharge in once-through cooling
water does not exceed the quantity determined by multiplying the flow of once-
through cooling water sources times the concentration listed
- Maximum concentration (mg/L) = 05
- Average concentration (mg/L) = 02
Verify that neither free available chlorine nor total residual chlorine is discharged at
any one time, unless the utility has been permitted to do so by the appropriate
authority
WP 33 Facilities discharging
coal pile runoff are subject to
certain point source effluent
limitations (40 CFR 423 I5(lc)
and 423 15(n))
Determine if the facility has coal pile storage areas
Verify that the quantity of TSS discharge in coal pile runoff does not exceed 50 mg/L
(NOTE Any untreated overflow from areas designed, constructed, and operated to
treat the coal pile runoff resulting from a 10-year, 24-hour rainfall event is not subject
to this limitation )
foisting Sources
WP 34 Facilities that introduce
pollutants from existing sources
into a POTW/FOTW are subject
to certain pretreatment
standards (40 CFR 423 16)
Determine if the facility introduced pollutants from existing sources into a
POTW/FOTW
Verify that there is no discharge of PCB compounds from existing sources into a
POTW/FOTW
Verify that copper (total) discharged in chemical metal cleaning wastes from existing
sources into a POTW/FOTW does not exceed the maximum for any 1 day of 1 0
mg/L
Verify that the pollutants discharged in cooling tower blow down from existing
sources into a POTW/FOTW does not exceed the concentration listed in Chart 6 of
Appendix 2-1
Effluent Limitations for Electroplating Point Sources
Phase 1 - Section 2
Water Pollution Control
2-36
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Compliancy Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks;
WP.35 Facilities that have
electroplating operations are
subject to certain point source
effluent limitations (40 CFR
413 01 (a) through 413 01 (c),
and 413 04)
Determine if the facility has electroplating operations.
(NOTE See Appendix 2-2 for similar but excepted operations )
Verify that pretreated pollutant standards are measured by determining the relevant
subcategory from the corresponding daily and four-day average values listed in Chart
1 in Appendix 2-2
Verify that where electroplating process wastewaters are combined with regulated
wastewaters that have 30-day average standards, the corresponding 30-day average
standard for electroplating is used
WP 36 Facilities that have
existing sources that introduce
pollutants into a POTW/FOTW
that discharge less than 38,000
L (10,000 gal) per calendar day
of pollutants in process
wastewaters resulting from the
electroplating of common
metals, are subject to certain
pretreatment standards (40 CFR
413 10,413 14(a), 413 14(b),
and 413 14(0)
(NOTE Electroplating of common metals refers to electroplating with copper,
nickel, chromium, zinc, tin, lead, cadmium, iron, aluminum, or any combination of
these)
Determine if the facility has existing sources that introduce pollutants into a
POTW/FOTW that discharges less than 38,000 L (10,000 gal) per calendar day of
process wastewaters resulting from the electroplating of common metals
Verify that the source's wastewater meets the limitations listed in Chart 2 of Appendix
2-2
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that the source's wastewater TTO is limited to 4 57 mg/L maximum for any
one day
WP 37 Facilities that have
existing sources that introduce
pollutants into a POTW/FOTW
that discharge 38,000 L (10,000
gal) or more per calendar day of
pollutants in process
wastewaters resulting from the
electroplating of common
metals, are subject to certain
pretreatment standards (40 CFR
413 10,413 14(a), 413 14(c)
through 413 14(e), and
413 14(g))
(NOTE Electroplating of common metals refers to electroplating with copper,
nickel, chromium, zinc, tin, lead, cadmium, iron, aluminum, or any combination of
these)
Determine if the facility has existing sources that introduces pollutants into a
POTW/FOTW that discharges 38,000 L (10,000 gal) or more per calendar day of
process wastewaters resulting from the electroplating of common metals
Verify that the source's wastewater meets the limitations listed in Chart 3 of Appendix
2-2
(NOTE Mass-based standards are equivalent to and may be applied in place of those
listed in Chart 3 upon prior agreement between the facility ana the treatment works
receiving the wastes)
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that if there is an absence of chelating agents in the pretreatment process, after
reduction of hexavalent chromium wastes, and after neutralization using calcium
oxide (or hydroxide) the limitations listed in Chart 4 of Appendix 2-2 are met
Verify that the source's wastewater TTO is limited to 2 13 mg/L maximum for any
one day
Phase 1 - Section 2
Water Pollution Control
2-37
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP38 Facilities that have
existing sources that introduce
pollutants into a POTW/FOTW
that discharge less than 38,000
L (10,000 gal) per calendar day
of pollutants in process
wastewaters resulting from
chromating, phosphating, or
immersion plating on ferrous or
nonferrous materials, are
subject to certain pretreatment
standards (40 CFR4I3 50,
413 54(a), 413 54(b), and
413 54(0)
Determine if the facility has existing sources that introduce pollutants into a
POTW/FOTW that discharges less than 38,000 L (10,000 gal) per calendar day of
process wastewaters resulting from chromating, phosphating, or immersion plating on
ferrous or nonferrous materials
Verify that the source's wastewater meets the limitations listed in Chart 2 of Appendix
2-2
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that the source's wastewater TTO is limited to 4 57 mg/L maximum
WP 39. Facilities that have
existing sources that introduce
pollutants into a POTW/FOTW
that discharge 38,000 L (10,000
gal) or more per calendar day of
pollutants in process
wastewaters resulting from
chromating, phosphating or
immersion plating on ferrous or
nonferrous materials, are
subject to certain pretreatment
standards (40 CFR 413 50,
413 54(a), 413 54(c) through
413.54(e), and 413 54(g))
Determine if the facility has existing sources that introduce pollutants into a
POTW/FOTW that discharges 38,000 L (10,000 gal) or more per calendar day of
process wastewaters resulting from chromating, phosphating or immersion plating
Verify that the source's wastewater meets the limitations listed in Chart 3 of Appendix
2-2
(NOTE Mass-based standards are equivalent to and may be applied in place of those
listed in Chart 3 upon prior agreement between the facility ana the treatment works
receiving the wastes)
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that if there is an absence of chelating agents in the pretreatment process, after
reduction of hexavalent chromium wastes, and after neutralization using calcium
oxide (or hydroxide), the limitations listed in Chart 4 of Appendix 2-2 are met
Verify that the source's wastewater TTO is limited to 2 13 mg/L maximum for any
one day
WP.40 Facilities that have
existing sources that introduce
pollutants into a POTW/FOTW
that discharge less than 38,000
L (10,000 gal) per calendar day
of pollutants in process
wastewaters resulting from
electroless plating, are subject
to certain pretreatment
standards (40 CFR 413 70,
413 74(a), 413 74(b), and
413 74(0)
(NOTE Electroless plating refers to electroless plating of a metallic layer on a
metallic or nonmetallic substrate )
Determine if the facility has existing sources that introduce pollutants into a
POTW/FOTW that discharges less than 38,000 L (10,000 gal) per calendar day of
process wastewaters resulting from the electroless plating
Verify that the source's wastewater meets the limitations listed in Chart 2 of Appendix
2-2
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that the source's wastewater TTO is limited to 4 57 mg/L maximum
Phase 1 - Section 2
Water Pollution Control
2-38
-------
Compliance Category:
Water Polutkm Control
Regulatory Requirements:
Reviewer Cheeks:
WP41 Facilities that have
existing sources that discharge
pollutants into a POTW/FOTW
that discharge 38,000 L (10,000
gal) or more per calendar day of
pollutants in process
wastewaters resulting from
electroless plating, are subject
to certain pretreatment
standards (40 CFR 413 70,
413 74(a), 413 74(c) through
413 74(e), and 413 74(g))
(NOTE Electroless plating refers to electroless plating of a metallic layer on a
metallic or nonmetalfic substrate)
Determine if the facility has existing sources that introduce pollutants into a
POTW/FOTW that discharges 38,000 L (10,000 gal) or more per calendar day of
process wastewaters resulting from electroless plating
Verify that the source's wastewater meets the limitations listed in Chart 3 of Appendix
2-2
(NOTE' Mass-based standards are equivalent to and may be applied in place of those
listed in Chart 3 upon prior agreement between the facility ana die treatment works
receiving the wastes)
Verify that the facility does not augment the use of process wastewater or otherwise
dilute it as a partial or total substitute for adequate treatment to achieve compliance
with the limitations
Verify that if there is an absence of chelating agents in the pretreatment process after
reduction of hexavalent chromium wastes, and after neutralization using calcium
oxide (or hydroxide), the limitations listed in Chart 4 of Appendix 2-2 are met
Verify that the source's wastewater TTO is limited to 2 13 mg/L maximum for any
one day
Effluent Limitations for Metal Finishing Point Sources
General
WP 42 Facilities that have
shops performing
electroplating, electroless
plating, anodizing, coating
(chromating, phosphating and
coloring), chemical etching and
milling, and printed circuit
board manufacture are subject
to certain point source effluent
limitation (40 CFR 433 10
through 433 12(c))
Determine if the facility has shops performing electroplating, electroless plating,
anodizing, coating (chromating, phosphating and coloring), chemical etching and
milling, and printed circuit board manufacture
(NOTE If any of the listed processes are performed, then refer to Appendix 2-3 for
an additional listing of process operations subject to limitations under this regulation)
Verify that self-monitoring of cyanide is conducted after cyanide treatment and before
dilution with other streams
WP 43 Facilities that have
shops performing
electroplating, electroless
plating, anodizing, coating
(chromating, phosphating and
coloring), chemical etching and
milling, and printed circuit
board manufacture are subject
to certain BPT point source
effluent limitation (40 CFR
433 13)
Verify that the pollutants discharged from metal finishing point sources meets the
limitations listed in Chart 1 of Appendix 2-3
Verify that oil and grease does not exceed the following
- Maximum for any one day of 52 mg/L
- Monthly average of 26 mg/L
Verify that TSS does not exceed the following-
- Maximum for any one day of 60 mg/L
- Monthly average of 31 mg/L
Verify that the facility does not augment the use of process wastewater or otherwise
dilute the wastewater as a partial or total substitute tor adequate treatment to achieve
compliance
Phase 1 - Section 2
Water Pollution Control
2-39
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Cheeks:
WP 44 Facilities that have
shops performing
electroplating, electroless
plating, anodizing, coating
(chromating, phosphating and
coloring), chemical etching and
milling, and printed circuit
board manufacture are subject
to certain BAT point source
effluent limitation (40 CFR
433.14)
Determine if the facility has shops performing electroplating, electroless plating,
anodizing, coating (chromating, phosphating and coloring), chemical etching and
milling, and printed circuit board manufacture
Verify that the pollutants in discharge from metal finishing point sources meet the
limitations listed in Chart 1 of Appendix 2-3
(NOTE- Alternately, if the facility does cyanide treatment and if permitted by the
appropriate authority, the following amenable limits may apply for cyanide
- Maximum for any 1 day = 0 86 mg/L,
- Maximum monthly average = 0 32 mg/L.)
Verify that the facility does not augment the use of metal finishing process wastewater
or otherwise dilute it as a partial or total substitute for adequate treatment to achieve
compliance with the limitations
Effluent Limitations for Metal Finishing Point Sources
Existing Sources
WP 45 Facilities that introduce
pollutants from existing metal
finishing point sources into a
POTW/FOTW are subject to
certain pretreatment standards
(40 CFR 433 15)
Determine if the facility introduces pollutants from existing metal finishing point
sources into a POTW/FOTW
Verify that pollutants introduced from existing metal finishing point sources (except
from job shops and independent printed circuit board manufacturers) into a
POTW/FOTW meet the standards listed in Chart 1 of Appendix 2-3.
(NOTE Alternately, if the facility does cyanide treatment and if permitted by the
appropriate authority, the following amenable limits may apply for cyanide-
- Maximum for any 1 day = 0 86 mg/L
- Maximum monthly average = 0 32 mg/L)
Verify that the facility does not augment the use of metal finishing process wastewater
or otherwise dilute it as a partial or total substitute for adequate treatment to achieve
compliance with the limitations
Verify that any existing source subject to the criteria listed here meets the daily
maximum pretreatment standard for TTO of 4 57 mg/L
New Sources
WP 46 Facilities that introduce
pollutants from new metal
finishing point sources into a
POTW/FOTW are subject to
certain performance standards
(40 CFR 433 16)
Determine if the facility introduces pollutants from new metal finishing point sources
into a POTW/FOTW
Verify that pollutants introduced from new metal finishing point sources into a
POTW/FOTW meet the standards listed in Chart 2 of Appendix 2-3.
(NOTE Alternately, if the facility does cyanide treatment and if permitted by the
appropriate authority, the following amenable limits may apply for cyanide.
- Maximum for any 1 day = 0 86 mg/L
- Maximum monthly average = 0 32 mg/L )
Verify that the facility does not augment the use of metal finishing process wastewater
or otherwise dilute it as a partial or total substitute for adequate treatment to achieve
compliance with the limitations.
Phase 1 - Section 2
Water Pollution Control
2-40
-------
Compliance Category:
Water PoHution Control
Regulatory Requirements:
Reviewer Cheeks:
WP 47 Facilities that introduce
pollutants from new metal
finishing point sources into a
POTW/FOTW are subject to
certain pretreatment standards
(40CFR433 17)
Determine if the facility introduces pretreated pollutants from new metal finishing
point sources into a POTW/FOTW
Verify that the pretreated pollutants introduced from new metal finishing point
sources into POTWs meet the standards listed in Chart 3 of Appendix 2-3
(NOTE Alternately, if the facility does cyanide treatment and if permitted by the
appropriate authority, the following amenable limits may apply for cyanide:
- Maximum for any 1 day = 0 86 mg/L
- Maximum monthly average = 0 32 mg/L )
Verify that the facility does not augment the use of metal finishing process wastewater
or otherwise dilute it as a partial or total substitute for adequate treatment to achieve
compliance with the limitations
Effluent Limitations for Hospitals
WP 48 Facilities that have
hospital point source effluents
are subject to certain discharge
standards (40 CFR 460 10)
Determine if the facility has a hospital point source
Verify that the hospital point source effluent is limited in the quality or quantity of
pollutants discharged as described in Appendix 2-4
NOTE The standards apply to discharges after application of BAT.)
Effluent Limitations for Photo Labs
WP 49 Facilities that have
point source discharges
resulting from the development
or printing of paper prints,
slides, negatives, enlargements,
movie film, and other sensitized
materials are subject to certain
limitations (40 CFR 459 10 and
459.12).
Determine if the facility has point source discharges resulting from the development
or printing of paper prints, slides, negatives, enlargements, movie film, and other
sensitized materials
Verify that the photographic processing point source effluent is limited according to
the specifications in Appendix 2-4
(NOTE Photo labs processing 150 m2 (16,000 ft2) per day or less are not covered )
Effluent Limitations for Feedlots
Phase 1 - Section 2
Water Pollution Control
2-41
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Compliance Category;
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 50 Feed lots, except those
for ducks, are required to meet
specific effluent limitation
standards (40 CFR 412 12
through 412 16).
Determine if the facility operates a feedlot
Verify that there is no discharge of process wastewater pollutants to navigable waters
(NOTE. For existing sources, when best practicable control technology (BPT)
currently available is used, process waste pollutants may be discharged to navigable
waters whenever rainfall events, either chronic or catastrophic, cause an overflow of
process wastewater from a facility designed, constructed, and operated to contain all
process generated wastewaters plus the runoff from a 10-year, 24-hour rainfall event
for the location of the point source If the best available technology economically
achievable is used, it is a 25-year, 24-hour rainfall event)
(NOTE. For new sources, process waste pollutants may be discharged to navigable
waters whenever rainfall events, either chronic or catastrophic, cause an overflow of
process wastewater from a facility designed, constructed, and operated to contain all
process generated wastewaters plus the runoff from a 25-year, 24-hour rainfall event
for the location of the point source)
Verify that for existing sources the following pretreatment standard is met for
discharge to a POTW-
- Fecalcolifomr no irritation
- BOD5- no irritation
Phase 1 - Section 2
Water Pollution Control
2-42
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Water FoHutioa^ontroI
Regulatory Requirements:
Reviewer Cheetts:
Land Application of Sludge
General
WP 51 Representative samples
of sewage sludge applied to the
land, placed on a surface
disposal site, or fired in a
sewage sludge incinerator are
required to be collected and
analyzed (40 CFR 503 8)
(NOTE Checklist items WP 51 through WP 57 apply only to sludge generated
during the treatment of domestic sewage in a treatment works For exclusions see the
definitions of the term Excluded Sludge A summary of the important compliance
dates is found in Appendix 2-5 )
Verify that the following types of facilities meet the standards outlined in 40 CFR
503
- The treatment works treats only domestic sewage
- The treatment works is designed for domestic sewage treatment but also treats some
industrial wastewaters
- The treatment works is designed for industrial wastewater treatment and it only
treats domestic sewage at any one time during operations and then the resulting
sewage sludge has to meet 40 CFR 503
- The treatment works generates domestic septage only
- The installation further changes the quality or treats (e g , composting of sewage
sludge) the sewage sludge of domestic septage received from a generator of sewage
sludge /domestic septage for land application and is therefore a preparer of sewage
sludge
(NOTE If the facility treatment works meets any of the following, the requirements
in 40 CFR 503 do not apply
- It treats industrial wastewaters only
- It is an industrial wastewater treatment plant that also treats domestic sewage along
with the industrial wastewater
- It generates a combination of
- domestic septage and commercial septage (i e , grease from grease traps)
-- domestic septage and industrial septage
- commercial septage and industrial septage)
Determine if the facility applies sewage sludge to the land, places it on a surface
disposal site, or fires it in a sewage sludge incinerator
Verify that the sludge is analyzed prior to application, placement, or firing for the
following
- Enteric viruses
- Fecal coliforms
- Helminth ova
- Inorganic pollutants
- Salmonella bacteria
- SOUR
- Total, fixed, and volatile solids
Phase 1 - Section 2
Water Pollution Control
2-43
-------
Compliance Category:
WaterPoHution Control
Regulatory Re^ulremeots;
Reviewer Checks;
WP 52 Depending on when
the last time bulk sewage sludge
subject to the cumulative
loading rates in Appendix 2-6
was last applied to a site (40
CFR 503)
Verify that personnel contacted the permitting authority in the State to determine if
bulk sewage sludge that has to meet the standards in Appendix 2-6 has been applied
to the site since 20 July 1993
(NOTE If sludge subject to these standards has not been applied to the site since 20
July 1993, the cumulative amount for each pollutant in Appendix 2-6 may be
applied )
Verify that if bulk sewage sludge subject to these standards has been applied since 20
July 1993 and the cumulative amount of each pollutant applied to the site is known,
the known cumulative amount is used to determine the additional amount of each
pollutant that can be applied
(NOTE If the cumulative amount is not known, there shall be no further application
to the site)
Phase 1 - Section 2
Water Pollution Control
2-44
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 53 Bulk sewage sludge or
sewage sludge sold or given
away in a bag or other container
must meet specific standards
(40CFR503 10(e), 503 10(0,
503 13(a)(1), 503 13(a)(4), and
503 14(e))
Verify that if the facility gives or sells bulk sewage sludge or sewage sludge in a bag
or other container, it meets the pollutant concentration limits in Appendix 2-7
Verify that if the facility gives or sells bulk sewage sludge in a bag or other container
it meets one of the following
- Pollutant concentrations ao not exceed Appendix 2-8
- The product of the concentration of each pollutant in the sewage sludge and the
annual whole sludge application rate for the sewage sludge does not cause the
annual pollutant loading rates in Appendix 2-9 to be exceeded
Verify that a label is affixed to the bag or container or an information sheet provided
to the person who receives the sewage sludge
Verify that the label or information sheet states
- The name and address of the person who prepared the sewage sludge
- A statement that the application to land is prohibited except in accordance with the
instructions on the label or information sheet
- The annual whole sludge application rate for the sewage sludge that does not cause
any exceedence of the annual pollutant loading rates in Appendix 2-9
(NOTE When sewage sludge or material derived from sewage sludge is sold or
given away in a bag or other container and meets the requirements in Appendix 2-8,
Class A pathogen requirements (see definitions), and vector attraction reduction
requirements as follows, it is exempt from the labeling requirements
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
— for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH or higher for two hours and then
at pH 11 5 or higher for an additional 22 hours )
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials )
Phase 1 - Section 2
Water Pollution Control
2-45
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Cheeks:
WP 54 The application of bulk
sewage sludge is not permitted
in specific circumstances (40
CFR 503 14(a) through
503 14(c))
Verify that bulk sewage sludge is not applied to the land if it is likely to adversely
threaten an endangered species or its designated critical habitat
Verify that bulk sewage sludge is not applied to agricultural land, forest, a public
contact site, or reclamation site that is flooded, frozen, or snow-covered so that the
bulk sewage sludge enters a wetland or other waters of the United States
Verify that bulk sewage sludge is not applied to agricultural land, forest, or a
reclamation site that is 10 m (32 81 ft) or less from waters of the United States unless
allowed by the permitting authority
(NOTE. When bulk sewage sludge or bulk material derived from sewage sludge is
applied to the land that meets the requirements in Appendix 2-8, Class A pathogen
requirements (see definitions), and vector attraction reduction requirements as
follows, it is exempt from these requirements
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 "C (68 °F). When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials)
Phase 1 - Section 2
Water Pollution Control
2-46
-------
Compliance Category:
Water Pofrution Control
Regulatory Requirements:
Reviewer Checks;
WP 55 Bulk sewage sludge
applied to agricultural land,
forest, a public contact site, or a
reclamation site must meet
specific standards (40 CFR
503.12(b), 503.13(a)(2) and
503 14(d))
Verify that the cumulative loading rate for each pollutant does not exceed the limits
outlined in Appendix 2-6
Verify that the concentration of each pollutant in the sewerage sludge does not exceed
the concentration for the pollutant in Appendix 2-8
Verify that bulk sewage sludge is applied at a whole sludge application rate that is
equal to or less than the agronomic rate for the bulk sewage sludge unless otherwise
specified by a permitting authority
(NOTE When bulk sewage sludge is applied to the land that meets the requirements
in Appendix 2-8, Class A pathogen requirements (see definitions), and vector
attraction reduction requirements as follows, it is exempt from the requirements
concerning Appendix 2-6 and the agronomic rate application'
- The mass or volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials)
WP 56. Bulk sewage sludge
applied to a lawn or home
garden must not contain
pollutants in excess of the limits
in Appendix 2-8 (40 CFR
503 13(a)(3))
Verify that if bulk sewage sludge is applied to a lawn or home garden, it does not
contain pollutants in excess of the limits in Appendix 2-8
Phase 1 - Section 2
Water Pollution Control
2-47
-------
Compliance Category:
Water PoUutioH Contra!
Regulatory Requirements!;
Reviewer Cheeks;
WP 57. The annual application
rate for domestic septage
applied to agricultural land,
forest or a reclamation site must
not exceed specific limits (40
CFR503 12(c) and 503 13(c)).
Verify that the annual application rate for domestic septage applied to agricultural
lands, forest or a reclamation site do not exceed the annua! application rate calculated
using the following equation
N
AAR =
0.0026
AAR = Annual application rate in gallons per acre per 365-day period
N = amount of nitrogen in pounds per acre per 365-day period needed by the crop or
vegetation grown on the land
Land Application of Sludge
Vectors and Pathogens
WP 58 Bulk sewage sludge
applied to agricultural land,
forest, a public contact site or a
reclamation site is required to
meet specific standards for
pathogens (40 CFR
503 15(a)(1), 503 32(a), and
503 32(b))
Verify that the sewage sludge meets the Class A or the Class B pathogen requirements
(see definitions) and the following site restrictions:
- Food crops with harvested parts that touch the sewage sludge soil mixture and are
totally above the land surface are not harvested for 14 months after application of
sewage sludge
- Food crops with harvested parts below the surface of the land are not harvested for
20 months after the application of sewage sludge when the sewage sludge remains
on the land surface for four months or longer prior to incorporation into the soil
- Food crops with harvested parts below the surface of the land are not harvested for
38 months after application of sewage sludge when the sewage sludge remains on
the land surface for less than four months prior to incorporation into the soil
- Food crops, feed crops, and fiber crops are not harvested for 30 days after
application of the sewage sludge
- Animals are not allowed to graze for 30 days after application
- Turf grown on land where sewage sludge is applied is not harvested for one year
after application of sewage sludge when the turf is placed on either land with a high
potential for public exposure or a lawn, unless otherwise specified by the permitting
authority
- Public access to land with a high potential for public exposure is restricted for one
year after application
- Public access to land with a low potential for public exposure is restricted for 30
days after application
Phase 1 - Section 2
Water Pollution Control
2-48
-------
pry:
ontrol
Regulatory Requirements:
Reviewer Checks;
WP 59 Bulk sewage sludge
applied to agricultural land,
forest, a public contact site or a
reclamation site is required to
meet specific standards for
vector attraction reduction (40
CFR 503 15(c)(1) and 503 33
(b)(1) through 503 33(b)(10))
Verify that one of the following vector reduction requirements are met'
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end or four
days, the volatile solids m the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 6C (68 °F). When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials
- Sewage sludge is injected below the surface of the land
-- no significant amount of the sewage sludge is present on the land surface within
1 hour after injection
-- when the sludge that is injected in Class A with respect to pathogens, the sludge
is injected below the land surface within eight hours after being discharged from
the pathogen treatment process
- Sewage sludge applied to a land surface or placed on a surface disposal site is
incorporated into the soil within six hours after application to or placement on the
land When sludge incorporated into the soil is Class A, the sewage sludge is
applied to or placed on the land within eight hours after being discharged from the
pathogen treatment process
Phase 1 - Section 2
Water Pollution Control
2-49
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 60 Bulk sewage sludge
applied to a lawn or home
garden must meet the Class A
pathogen requirements and
specific vector reduction
requirements (40 CFR
503 15(a)(2), 503 32(a), and
503 33(b)(1) through
503 33(b)(8))
Verify that for bulk sewage sludge the Class A pathogen requirements (see
definitions) are met
Verify that one of the following vector reduction requirements are met
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent if this cannot be done
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 DC (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids ofsewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials
Phase I - Section 2
Water Pollution Control
2-50
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 61 Sewage sludge that is
sold or given away in a bag or
container must meet Class A
pathogen requirements and
specific vector reduction
requirements (40 CFR
503 15(a)(3), 503 32(a), and
503.33(b)(1) through
503 33(b)(8))
Verify that for sewage sludge that is sold or given away in a bag or container, it meets
the Class A pathogen requirements (see Definitions)
Verify that one of the following vector reduction requirements are met
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent
- A 17 percent reduction of volatile solids when the 38 percent volatile solids
reduction requirements cannot be met for an anaerobically digested sewage sludge
and the vector reduction attraction is demonstrated by digesting a portion of the
previously digested sewage sludge anaerobically in the laboratory in a bench-scale
unit for 40 additional days at a temperature between 30 and 37 °C (86 and 98 6 °F)
- A 15 percent reduction of volatile solids when the 38 percent volatile solids
reduction requirements cannot be met for an aerobicafly digested sewage sludge
and the vector attraction reduction is demonstrated by digesting a portion of the
previously digested sewage sludge that has percent solids of two percent or less
aerobically in the laboratory in a bench-scale unit for 30 additional days at 20 8C
(68 °F)
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer and the
temperature is higher than 40 °C (104 F) and the average temperature of the
sewage sludge is higher than 45 °C (113 °F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition and,
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11.5 or higher for an additional 22 hours
- The percent solids of sludge that does not contain unstabilized solids generated in a
primary wastewater treatment process is equal to or greater than 75 percent based
on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstabilized solids generated in a
primary wastewater treatment process is equal to or greater than 90 percent based
on the moisture content and total solids prior to mixing with other materials
Phase 1 - Section 2
Water Pollution Control
2-51
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 62 Domestic septage that
is applied to agricultural land,
forest, or a reclamation site
must meet specific pathogen
requirements and vector
reduction requirements (40 CFR
503 15(b), 503 15(d),
503 32(c)(1), 503 32(c)(2),
503.33(b)(9), 503 33(b)(10),
and 503 33(b)(12))
Verify that one of the following requirements is met for pathogen control
- The pH of the domestic septage is raised to 12 or higher by alkali addition,
remaining at pH 12 or higher Tor 30 minutes, and the following land restrictions are
met
- food crops with harvested parts that touch the sewage sludge soil mixture and
are totally above the land surface are not harvested Tor 14 months after
application of sewage sludge
- food crops with harvested parts below the surface of the land are not harvested
for 20 months after the application of sewage sludge when the sewage sludge
remains on the land surface for four months or longer prior to incorporation into
the soil
- food crops with harvested parts below the surface of the land are not harvested
for 38 months after application of sewage sludge when the sewage sludge
remains on the land surface for less than four months prior to incorporation into
the soil
- food crops, feed crops, and fiber crops are not harvested for 30 days after
application of the sewage sludge
- Site restrictions are followed
- food crops with harvested parts that touch the sewage sludge soil mixture and
are totally above the land surface are not harvested Tor 14 months after
application of sewage sludge
- food crops with harvested parts below the surface of the land are not harvested
for 20 months after the application of sewage sludge when the sewage sludge
remains on the land surface for four months or longer prior to incorporation into
the soil
- food crops with harvested parts below the surface of the land are not harvested
for 38 months after application of sewage sludge when the sewage sludge
remains on the land surface for less than four months prior to incorporation into
the soil
-- food crops, feed crops, and fiber crops are not harvested for 30 days after
application of the sewage sludge
- animals are not allowed to graze for 30 days after application
-- turf grown on land where sewage sludge is applied is not harvested for one year
after application of sewage sludge when the turf is placed on either land with a
high potential for public exposure or a lawn, unless otherwise specified by the
permitting authority
- public access to land with a high potential for public exposure is restricted for
one year after application
- public access to land with a low potential for public exposure is restricted for 30
days after application
Verify that one of the following vector attraction reduction requirements is met
- Sewage sludge is injected below the surface of the land
- no significant amount of the sewage sludge is present on the land surface within
1 hour after injection
- when the sludge that is injected in Class A with respect to pathogens, the sludge
is injected below the land surface within eight hours after being aiscnarged from
the pathogen treatment process
- Sewage sludge applied to a land surface or placed on a surface disposal site is
incorporated into the soil within six hours after application to or placement on the
land When sludge incorporated into the soil is Class A, the sewage sludge is
applied to or placed on the land within eight hours after being discharged from the
pathogen treatment process
- The pH of domestic septage is raised to pH 12 or higher by alkali addition and,
without the addition of more alkali, remains at pH 12 or higher for 30 minutes
Notifications
Phase 1 - Section 2
Water Pollution Control
2-52
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 63 Persons who prepare
bulk sewage sludge are required
to provide specific notifications
(40CFR503 10(b), 503 12(f),
and 503 12(g))
Verify that if the facility prepare bulk sewage sludge, it provides the person applying
the bulk sewage sludge the notices and necessary information needed to comply with
the land application regulations
(NOTE When bulk sewage sludge or bulk material derived from sewage sludge is
applied to the land that meets the requirements in Appendix 2-8, Class A pathogen
requirements (see definitions), and vector attraction reduction requirements as
follows, it is exempt from these requirements
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
— for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials )
WP.64 Persons who prepare
bulk sewage sludge that is
applied to agricultural land,
forest, a public contact site, or a
reclamation site are required to
provide users written
notification of the total nitrogen
on a dry weight basis (40 CFR
503 12(d))
Determine if the facility prepares sewage sludge for application to agricultural land,
forest, a public contact site, or a reclamation site
Verify that the facility provides users with written notification of the total nitrogen on
a dry weight basis
Phase 1 - Section 2
Water Pollution Control
2-53
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP.65 Persons who apply
bulk sewage sludge to the land
are required to provide notice to
the land owner or lease holder
(40 CFR 503.10(b), 503 10(c),
and 503 12(h))
Verify that notice is given that includes the information needed to verify compliance
with the land application regulations.
(NOTE When bulk sewage sludge or bulk material derived from sewage sludge is
applied to the land that meets the requirements in Appendix 2-8, Class A pathogen
requirements (see definitions), and vector attraction reduction requirements as
follows, it is exempt from these requirements.
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent. If this cannot be done.
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F). When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
Based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials )
WP 66 Facilities that prepare
bulk sewage sludge that is used
in a different state are required
to provide written notice (40
CFR 503 12(0)
Determine if the facility prepares sewage sludge for land application that is used in
another state
Verify that written notification is prepared and provided to the permitting authority in
the state of application that includes the following
- The location of each land application site
- The approximate time period bulk sewage sludge will be applied to the site
- The name, address, telephone number, and NPDES permit number (if appropriate)
for the facility preparing the sludge
- The name, address, telephone number, and NPDES permit number (if appropriate)
for the facility applying the sludge.
Phase 1 - Section 2
Water Pollution Control
2-54
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Compliance Category:
Water Poflution Control
Regulatory Requirements:
Reviewer Cheeks:
WP 67 Facilities that apply
bulk sewage sludge subject to
the cumulative loading rates in
Appendix 2-6 are required to
provide written notice prior to
the initial application of the
sludge (40 CFR 503 10(b),
503 10(c), and 503 12(j))
Verify that prior to the initial application of bulk sewage sludge that is subject to the
cumulative loading rates in Appendix 2-6, notice is provided to the permitting
authority for the state that includes-
- The location of the land application site
- The name, address, telephone number, NPDES permit number (if appropriate) of
the facility applying the sludge
(NOTE When bulk sewage sludge or bulk material derived from sewage sludge is
applied to the land that meets the requirements in Appendix 2-8, Class A pathogen
requirements (see definitions), and vector attraction reduction requirements as
follows, it is exempt from these requirements
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent if this cannot be done
- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
— for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials )
Monitoring
WP 68 Monitoring for the
limitations in Appendices 2-6
through 2-9, pathogen density
in Class A and Class B
pathogens, and vector attraction
reduction requirements must be
done according to the frequency
in Appendix 2-10 (40 CFR
503 16(a))
Verify that monitoring for the limitations in Appendices 2-6 through 2-9, pathogen
density in Class A and Class B pathogens, and vector attraction reduction
requirements is done according to the frequency in Appendix 2-10
(NOTE After the sewage sludge has been monitored for two years, the permitting
authority may reduce the frequency of monitoring.)
Phase 1 - Section 2
Water Pollution Control
2-55
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Chectcsr
WP 69. In specific instances,
when domestic sewage is
applied to agricultural land,
forest, or a reclamation site,
each container of domestic
septage applied to the land is
required to be monitored for
compliance (40 CFR
503.16(b)).
Verily that each container of domestic septage is monitored if the pH has been raised
to 12 or higher by alkali addition, and kept there for 30 minutes
Recordkeeping and Reporting
WP.70 When bulk sewage
sludge is applied to the land or
sold in a bag or container and it
meets the requirements in
Appendix 2-8, Class A
patnogen requirements, and
vector attraction reduction
requirements, specific
recordkeeping requirements
must be met (40 CFR
503 17(a)(1)).
Determine if the facility applies bulk sewage sludge or sells or gives it away in a bag
or container
Verify that it meets the requirements in Appendix 2-8, Class A pathogen requirements
(see definitions) and one of the following vector attraction reduction requirements.
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98.6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
~ for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 "C (86 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
I 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(86 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time tne temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11.5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabihzed solids
generated in a primary wastewater treatment process is equal to or greater than 75
Based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
Erimary wastewater treatment process shall be equal to or greater than 90 percent
ased on the moisture content and total solids prior to mixing with other materials.
Verify that the following information is retained for 5 years
- The concentration of each pollutant listed in Appendix 2-8
- A statement certifying which form of vector attraction reduction is being used and
that Class A pathogen requirements are being met
- A description of how the Class A pathogen requirements are being met
- A description of how the vector attraction reduction is being met.
Phase 1 - Section 2
Water Pollution Control
2-56
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Compliance Category:
WaterPoUufcioH Control
Regulatory Requirements:
Reviewer Checks:
WP71 When the facility
derives material from sewage
sludge for application and/or to
sell or give away in a bag or
container and it meets the
requirements in Appendix 2-8,
Class A pathogen requirements,
and vector attraction reduction
requirements, specific record
keeping requirements must be
met (40 CFR 503 17(a)(2))
Determine if the facility derives material from bulk sewage sludge or sells or gives
away material derived from sewage sludge in a bag or container
Verify that it meets the requirements in Appendix 2-8, Class A pathogen requirements
(see definitions), and one of the following vector attraction reduction requirements
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
— for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (86 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1.5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(86 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials
Verily that the following information is retained for 5 years
- The concentration of each pollutant listed in Appendix 2-8
- A statement certifying which vector attraction reduction is being used and that
Class A pathogen requirements are being met
- A description of how the Class A pathogen requirements are being met
- A description of how the vector attraction reduction is being met.
Phase 1 - Section 2
Water Pollution Control
2-57
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checksr
WP 72 When the bulk sewage
sludge meets the limitations in
Appendix 2-8, the requirements
concerning Class A pathogens,
the vector attraction reduction
requirements and is applied to
agricultural land, forest, a
public contact site, or
reclamation site specific
reporting requirements must be
met (40 CFR 503 17(a)(3))
Determine if the facility applies bulk sewage sludge to agricultural land, forest, a
public contact site or reclamation site
Verify that it meets the requirements in Appendix 2-8, Class A pathogen requirements
(see definitions) and one of the following vector attraction reduction requirements.
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of 2twopercent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (68 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(68 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 °C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11.5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials
Verify that the following information is retained for five years by the person who
prepares the sludge
- The concentration of each pollutant listed in Appendix 2-8
- A statement certifying which vector attraction reduction is being used and that
Class A pathogen requirements are being met
- A description of how the Class A pathogen requirements are being met
- A description of how the vector attraction reduction is being met
Verify that the following information is retained for five years by the person who
applies the sludge.
- A statement certifying that appropriate management practices and application
procedures are being used
- A description of how required management practices are implemented
- A description of how the vector reduction requirements are met
Phase 1 - Section 2
Water Pollution Control
2-S8
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements: [ Reviewer Checks;
WP 73 When the bulk sewage
sludge meets the limitations in
Appendix 2-8, the requirements
concerning Class B pathogens,
and is applied to agricultural
land, forest, a public contact
site, or reclamation site, specific
reporting requirements must be
met (40 CFR 503 17(a)(4))
Determine if the facility applies bulk sewage sludge to agricultural land, forest, a
public contact site, or reclamation site
Verify that it meets the requirements in Appendix 2-8 and Class B pathogen
requirements (see definitions)
Verify that the following information is retained for five years by the person who
prepares the sludge'
- The concentration of each pollutant listed in Appendix 2-8
- A statement certifying which form of vector attraction reduction is being used and
that Class A pathogen requirements are being met
- A description of how the Class B pathogen requirements are being met
- A description of how the vector attraction reduction is being met when it is used
Verify that the following information is retained for five years by the person who
applies the sludge
- A statement certifying that appropriate management practices and application
procedures are being used
- A description of how required management practices are implemented
- A description of how site restrictions are being met
- A description of how the vector reduction requirements are met when they are used
WP 74 When bulk sewage
sludge that meets the limitations
in Appendix 2-6, is applied to
agricultural land, forest, a
public contact site, or
reclamation site, specific
reporting requirements must be
met (40 CFR 503 17(a)(5))
Determine if the facility applies bulk sewage sludge to agricultural land, forest, a
public contact site, or reclamation site
Verify that it meets the requirements in Appendix 2-6
Verify that the following information is retained for five years by the person who
prepares the sludge:
- The concentration of each pollutant listed in Appendix 2-6
- A statement certifying which form of vector attraction reduction is being used and
that pathogen requirements are being met
- A description of now the pathogen requirements are being met
- A description of how the vector attraction reduction is being met when used.
Verify that the following information is retained indefinitely by the person who
applies the sludge
- The concentration of each pollutant listed in Appendix 2-6
- The number of hectares in each site upon whicn bulk sewage sludge is applied
- The date and time bulk sewage sludge is applied to each site
- The cumulative amount of each pollutant from Appendix 2-6 in the bulk sewage
sludge applied to each site
- Amount applied to each site
- A certification statement indicating that required information for each site has been
obtained
- A description of how the requirements to obtain information were met
Verify that the following information is retained for five years by the person applying
the sludge*
- A statement certifying that appropriate management practices and application
procedures are being used
- A description of how required management practices are implemented
- A certification statement that Class B pathogen requirements are being met
- A description of how site restrictions are being met
- A certification statement that vector reduction requirements are met
- A description of how vector reduction requirements are being met
Phase 1 - Section 2
Water Pollution Control
2-59
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Cheeks;
WP 75 When bulk sewage
sludge is given away or sold in
a bag or container and it meets
the requirements in Appendix
2-9, specific record keeping
requirements must be met (40
CFR 503 17(a)(6))
Determine if the facility sells or gives bulk sewage sludge away in a bag or container
Verify that it meets the requirements in Appendix 2-9
Verify that the following information is retained for 5 years by the person who
prepares the sludge:
- The annual whole sludge application rate for the sewage sludge that does not cause
the annual pollutant rates in Appendix 2-9 to be exceeded
- The concentration of each pollutant listed in Appendix 2-9
- A statement certifying which vector attraction reduction is being used and that
Class A pathogen requirements are being met
- A description of how the Class A pathogen requirements are being met
- A description of how the vector attraction reduction is being met
WP 76 When domestic
septage is applied to
agricultural land, forest, or a
reclamation site, specific
reporting requirements must be
met (40 CFR 503 17(b))
Determine if the facility applies domestic septage to agricultural land, forest, a public
contact site, or reclamation site
Verify that the following information is retained for five years by the person who
applies the domestic septage
- The location of each site on which domestic septage is applied
- The number of acres in each site on which domestic septage is applied
- The date and time of application at each site
- The nitrogen requirements for the crop or vegetation grown on each site during a
365-day period
- The rate in gal/acre per 365-day period at which domestic septage is applied to each
site
• A statement certifying which vector attraction reduction is being used and that
pathogen requirements are being met
- A description of how the pathogen requirements are being met
- A description of how the vector attraction reduction is being met
WP 77 Class I sludge
management facilities,
POTW/FOTWs with a design
flow rate equal to or greater
than one million gal/day
(3,785,412 L/day), and
POTW/FOTWs that serve
10,000 people or more are
required to submit specific
information to the permitting
authority (40 CFR 503.18).
Verify that the following information is submitted to the permitting authority by 19
February of each year
- The concentration of each pollutant listed in Appendix 2-8
- A statement certifying which form of vector attraction reduction is being used and
that Class A pathogen requirements are being met
- A description of how the Class A pathogen requirements are being met
- A description of how the vector attraction reduction is being met
Verify that the following information is submitted on 19 February of each year when
90 percent or more of any of the cumulative loading rates in Appendix 2-6 are met-
- The concentration of each pollutant listed in Appendix 2-6
- The number of hectares in each site upon which bulk sewage sludge is applied
- The date and time bulk sewage sludge is applied to each sites
- The cumulative amount of each pollutant from Appendix 2-6 in the bulk sewage
sludge applied to each site
- Amount applied to each site
- A certification statement indicating that required information for each site has been
obtained
- A description of how the requirements to obtain information were met.
Phase 1 - Section 2
Water Pollution Control
2-60
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Compliance Category:
Water Pollution Control
Regulatory Requirements: j Reviewer Checks:
Surface Disposal of Sludge
General
(NOTE The requirements concerning surface disposal of sludge do not apply to sewage sludge stored on the land or to
the land on which sewage sludge is stored It also does not apply to sewage sludge that remains on the land for longer
than 2 years when the facility that prepares the sewage sludge demonstrates that the land on which the sewage sludge
remains is not an active sewage sludge unit It also does not apply to sewage treated on the land or to the land on wmch
the sewage sludge is treated (40 CFR 503 20(b) and 503 20(c))
WP 78 An active sewage
sludge unit that is located
within 60 m (196 85 ft) of a
fault that has displacement in
Holocene time, is located in an
unstable area, or located in a
wetland is required to close by
19 February 1994 (40 CFR
503 22(b))
Determine if the facility has a sewage sludge unit that is located within 60 m (196 85
ft) of a fault that has displacement in Holocene time, is located in an unstable area, or
is located in a wetland
Verify that the unit was closed by 19 February 1994 unless otherwise stipulated by the
permitting authority
WP 79 The facility is required
to submit a written closure and
post-closure plan that meets
specific requirements to the
permitting authority 180 days
prior to the date of closure (40
CFR 503 22(c))
Determine if the facility is planning on closing an active sewage sludge unit or has
recently closed a sewage sludge unit
Verify that the closure and post-closure plan was submitted to the permitting authority
at least 180 days in advance of closure and the plan contained the following
- A discussion of how the leachate collection system will be operated and maintained
for 3 years after closure if the unit has a liner and leachate collection system
- A description of the system used to monitor for methane gas in the air in any
structure within the surface disposal site and in the air at the property line
- A discussion of how public access will be restricted for three years after closure
Verify that if there are plans to turn the surface disposal site over to another owner,
the facility notifies the subsequent owner that sewage sludge was placed on the land
WP 80 Active sewage sludge
units without a liner and
leachate collection system are
required to met specific
standards (40 CFR 503 23(a)(1)
and 503 23(b))
Verify that following concentrations are not exceeded in sewage sludge placed on an
active sewage sludge unit
- Arsenic 73 mg/kg
- Chromium 600 mg/kg
- Nickel 420 mg/kg
(NOTE Amounts are based on a dry weight basis )
WP 81 Active sewage sludge
units without a liner and
leachate collection system with
a boundary less than 150 m
(492 13 ft) from the property
line of the surface disposal site
are required to meet specific
requirements (40 CFR
503 23(a)(2) and 503 23(b))
Verify that the concentration of each pollutant listed in Appendix 2-11 is not
exceeded in relation to the listed distances
(NOTE At the time of the permit application, the owner/operator of the site may ask
for site-specific pollutant limits)
Phase 1 - Section 2
Water Pollution Control
2-61
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Cheeks:
WP 82. Sewage sludge units
are required to be operated
according to specific operation
and management standards (40
CFR 503 24)
Verify that sewage sludge is not placed in an active sewage sludge unit if it is likely to
adversely affect a threatened or endangered species or its critical habitat
Verify that active sewage sludge units
- Do not restrict the flow of a case flood
- Are located 60 m (196 85 ft) or more from a fault that has displacement in
Holocene time, unless otherwise specified by the permitting authority
- Are not located in an unstable area
- Will not contaminate an aquifer
- Are not located in a wetland unless by permit
(NOTE- The results of a groundwater monitoring program developed by a qualified
groundwater scientist or a certification by a qualified groundwater scientist will be
used to demonstrate that sewage sludge placed on an active sewage sludge unit does
not contaminate an aquifer)
Verify that when a surface disposal site is located in a seismic impact zone, the unit is
designed to withstand the maximum recorded horizontal ground level acceleration
Verify that for runoff the following occurs
- The runoff is collected and disposed of in accordance with an NPDES permit
- The runoff collection system has the capacity to handle runoff from a 24-hour, 25-
year storm event.
Verify that leachate is handled so that
- The leachate collection system for an active sewage sludge unit that has a liner and
leachate collection system is operated and maintained during the period the sewage
sludge unit is active and for three years thereafter
- Leachate from an active sewage sludge unit that has a liner and a leachate collection
system is collected and disposed of in accordance with the applicable requirements
from when the unit is active and for three years thereafter
Verify that the following occurs when a cover is placed on a sewage sludge unit
- The concentration of methane gas in the air in any structure within the surface
disposal site of an active unit does not exceed 25 percent of the lower explosive
limit for methane gas during the period that the unit is active and the concentration
of the methane gas in air at the property line of the surface disposal site does not
exceed the lower explosive limit for methane gas during the period that the sewage
sludge unit is active
- The concentration of methane gas at closure when the final cover is placed in air in
any structure within any structure within the surface disposal site does not exceed
25 percent of the lower explosive limit for methane gas for three years after the unit
closes and the concentration of methane gas in air at the property line of the unit
does not exceed the lower explosive limit for methane gas three years after closure
unless otherwise specified by the permitting authority
Verify that a food or feed crop or a fiber crop is not grown on an active sewage sludge
unit unless it has been demonstrated to the permitting authority that through
management practices, public health and the environment are protected from any
reasonably anticipated adverse effects
Verify that animals do not graze on an active sewage sludge unit unless it has been
demonstrated to the permitting authority that through management practices, public
health and the environment are protected from any reasonably anticipated adverse
effects.
Verify that public access is restricted for the period that the surface disposal site
contains an active unit, and for 3 years after the last active sewage sludge unit in the
surface disposal site closes.
Phase 1 - Section 2
Water Pollution Control
2-62
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks,*
WP 83 Class A or one of the
Class B pathogen requirements
(see definitions) must be met
when placing sewage sludge on
an active sewage sludge unit
unless it is covered with soil or
other material at the end of each
operating day (40 CFR
503 25(a))
Determine if the sewage sludge meets Class A or one of the Class B pathogen
requirements
Verify that if the sludge does not meet pathogen requirements, it is covered with soil
or other material at the end of each operating day
WP 84 Vector attraction
reduction must be done when
sewage sludge or domestic
septage is placed on an active
sewage sludge unit (40 CFR
503 25(b) and 503 25(c))
Verify that when sewage sludge is placed on an active sewage sludge unit, one of the
following vector attraction reduction requirements is done
- The mass of volatile solids in the sewage sludge is reduced by a minimum of 38
percent If this cannot be done
-- for an anaerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
anaerobically in the laboratory in a bench-scale unit for 40 additional days at a
temperature between 30 and 37 °C (86 and 98 6 °F) When at the end of 40
days, the volatile solids in the sewage sludge at the beginning of that period is
reduced by less than 17 percent, vector attraction reduction is achieved
-- for an aerobically digested sewage sludge, vector attraction reduction is
demonstrated by digesting a portion of the previously digested sewage sludge
that has a percent solids of two percent or less aerobically in the laboratory in a
bench scale unit for 30 additional days at 20 °C (86 °F) When at the end of the
30 days, the volatile solids in the sewage sludge at the beginning of the period is
reduced by less than 15 percent, vector attraction reduction is achieved
- The SOUR for sewage sludge treated in an aerobic process is equal to or less than
1 5 mg oxygen/h/g total solids (dry weight basis) at a temperature of 20 °C
(86 °F)
- Sewage sludge is treated in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is higher than 40 °C (104 °F) and the
average temperature is higher than 45 "C (113 F)
- The pH of the sewage sludge is raised to pH 12 or higher by alkali addition, and
without the addition of more alkali, remains at pH 12 or higher for two hours and
then at pH 11 5 or higher for an additional 22 hours
- The percent solids of sewage sludge that does not contain unstabilized solids
generated in a primary wastewater treatment process is equal to or greater than 75
Based on the moisture content and total solids prior to mixing with other materials
- The percent solids of sewage sludge that contains unstablized solids generated in a
primary wastewater treatment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mixing with other materials
- Sewage sludge is injected below the surface of the land
- no significant amount of the sewage sludge is present on the land surface within
one hour after injection
-- when the sludge that is injected in Class A with respect to pathogens, the sludge
is injected below the land surface within eight hours after being discharged from
the pathogen treatment process
- sewage sludge applied to a land surface or placed on a surface disposal site is
incorporatedinto the soil within six hours after application to or placement on
the land When sludge incorporated into the soil is Class A, the sewage sludge
is applied to or placed on the land within eight hours after being discharged
from the pathogen treatment process
- The sewage sludge placed on an active sewage sludge unit is covered with soil or
other material at the end of each operating day
Phase 1 - Section 2
Water Pollution Control
2-63
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Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Cheeks;
WP 84 Continued
Verify that when domestic septage is placed on an active sewage sludge unit, one of
the following vector attraction reduction requirements is done
- Sewage sludge is injected below the surface of the land such that:
- no significant amount of the sewage sludge is present on the land surface within
one hour after injection
- when the sludge that is injected in Class A with respect to pathogens, the sludge
is injected below the land surface within eight hours after being discharged from
the pathogen treatment process
- Sewage sludge applied to a land surface or placed on a surface disposal site is
incorporated into the soil within six hours after application to or placement on the
land. When sludge incorporated into the soil is Class A, the sewage sludge is
applied to or placed on the land within eight hours after being discharged from the
pathogen treatment process
- The sewage sludge placed on an active sewage sludge unit is covered with soil or
other material at the end of each operating day
- The pH of the domestic septage is raised to pH 12 or higher by alkali addition and,
without the addition of more alkali, remains at pH 12 or higher for 30 mm
Monitoring and Documentation
WP 85 Monitoring for
pollutants, pathogens, and
vector attraction reduction
requirements for sewage sludge
placed on an active sewage
sludge unit must be done
according to the frequency in
Appendix 2-10(40 CFR
503.26(a)).
Verify that monitoring for pollutants, pathogens, and vector attraction reduction
requirements for sewage sludge placed on an active sewage sludge unit is done
according to the frequency in Appendix 2-10
(NOTE The permitting authority may reduce the frequency of monitoring)
WP 86 If, when domestic
septage is placed on an active
sewage sludge unit, the pH of
the septage is raised to 12 or
higher by alkali addition and
remains at 12 or higher without
alkali addition for 30 mm, each
container of domestic septage
must be monitored (40 CFR
503 26(b))
Verify that when domestic septage is placed on an active sewage sludge unit, the pH
of the septage is raised to pH 12 or higher by alkali addition and remains at pH 12 or
higher without alkali addition for 30 min each container of domestic septage is
monitored
WP.87. In specific
circumstances, air in structures
within a surface disposal site
and at property lines of the
surface disposal site are
required to be monitored
continuously for methane gas
(40 CFR 503 26(c))
Verify that continuous monitoring occurs during the period that the surface disposal
site contains an active sewage sludge unit on which tne sewage sludge is covered and
for three years after a unit closes when a final cover is placed on the sewage sludge.
Phase 1 - Section 2
Water Pollution Control
2-64
-------
Compliance Category:
Water Pollution Control
Regulatory Requirements:
Reviewer Checks:
WP 88 Specific recordkeeping
requirements must be met when
sewage sludge, other than
domestic septage, is placed on
an active sewage sludge unit
(40 CFR 503 27(a))
Verify that the person who prepares sewage sludge retains the following information
for five years
- The concentration of arsenic, chromium, and nickel in the sludge
- A statement certifying that pathogen and vector attraction reduction requirements
are being met
- A description of how the pathogen requirements are being met when done
- A description of how the vector attraction reduction requirements are being met
when done
Verify that the operator of the surface disposal site retains the following for five
years-
- The concentrations of the pollutants listed in Appendix 2-11
- A statement certifying that management practices and vector attraction reduction
requirement are being met
- A description of how the management practices are being met
- A description of how the vector attraction reduction requirements are being met
when they are done
WP 89. Specific recordkeeping
requirements must be met when
domestic septage is placed on
an active sewage sludge unit
(40 CFR 503 27(b))
Verify that the person who applies domestic septage with a pH of greater than 12
retains the following information for five years
- A statement certifying that vector attraction reduction requirements are being met
- A description of how the vector attraction reduction requirements are being met
when done.
Verify that the operator of the surface disposal site retains the following for five
years.
- A statement certifying that management practices and vector attraction reduction
requirement are being met
- A description of how the management practices are being met
- A description of how the vector attraction reduction requirements are being met
when they are done
WP 90. Class I sludge
management facilities,
POTWs/FOTWs with a design
flow rate equal to or greater
than 1,000,000 gal/day
(3,785,412 L/day), and
POTW/FOTWs that serve
10,000 people or more are
required to submit specific
information to the permitting
authority on 19 February of
each year (40 CFR 503 28).
Verify that the following information is submitted to the permitting authority on 19
February of each year
- The concentration of arsenic, chromium and nickel in the sludge
- A statement certifying that management practices and pathogen and vector
attraction reduction requirements are being met
- A description of how the pathogen requirements are being met when done
- A description of how the vector attraction reduction requirements are being met
when done
- The concentrations of the pollutants listed in Appendix 2-11
- A description of how the management practices are being met
Phase 1 - Section 2
Water Pollution Control
2-65
-------
Section 2
Water Pollution Control
Appendices
-------
Appendix 2-1
Steam Electric Power Generating Point Sources
(40 CFR 423)
Chart 1
| v. -
: "¦ ¦» .. % w. v ^
r ^ v."--. s
Mst&ffi&kftt*ft- :
*
Naxs»«jt wxm
mmm8wtityi$:
TSS
Oil and Grease
100 0
20 0
30 0
15 0
From 40 CFR 423 12(b)(3), 423 12(b)(4), 423 15(c), and 423 15(0
Chart 2
ss \ •. s\\4s% VI v.
S S j
v.5-. "s *¦ % ^
% %>Vi V| s f ^ssss ¦
v. \ "" ^ I
fcrMltftMt PrOJWrty '
1 day (rajjSj)-
Maxfommavsrage vftlaes^at 36
TSS
100 00
20 0
Oil and Grease
20 0
15 0
Copper, total
1 0
1 0
Iron, total
1 0
1 0
From 40 CFR 423 12(b)(5) and 423 12(b)(6)
Chart 3
¦,¦ ¦ ¦¦ ¦ " " - v.,
'¦"»AT ma t*m itmmt LiatfctfaMs
•»
\ - -
Maximum i5&r smy 1 day {#ag&)
Maxtawstt awnra$ft values fer3ft
*• "s
The 126 priority pollutants (see page A2-4)
(0
(i)
contained in chemicals added for cooling tower
maintenance, except
Chromium, total
0 2
0 2
Zinc, total
1 0
1 0
(l>No detectable amount
Form 40 CFR 423 13(d)(1) and 423 16(j)(l)
Chart 4
-.v.-. "" s
9A? Ltaft&tt&m i
fqttafott 0? SwiPtrty
Maximum for any i day
fcfeudmam awra^i vsftuiws
i
e«»«<3rtJY* days
Copper, total
1 0
1 0
Iron, total
1 0
1 0
From 40 CFR 423 13(e)
A2-1
-------
Appendix 2-1 (continued)
Steam Electric Power Generating Point Sources
(40 CFR 423)
Chart 5
s V, -A ' s*. ^
s s Wntt-fif-n-Mi- ¦••• -Miihii 11I#|| s "" s
W rvumSSM \
\<"* s
s XT-.* s
is s ' "¦ ** *1%
"¦ "• "-.wo ¦* , s f % s ¦. sV. >
- •*
s s s ¦* -S v "* "¦ ^ f
TSS
Oil and Grease
Copper, total
Iron, total
100 0
20 0
1 0
1 0
30 0
15 0
1 0
1 0
From 40 CFR 423 12(b)(3) and 423 12(b)(4)
Chart 6
The 126 priority pollutants (see page A2-4) contained in
chemicals added for cooling tower maintenance, except
Chromium, total
Zinc, total
m No detectable amount
(J)
02
1 0
From 40 CFR 423 16(d)(1)
Chart 7
The 126 priority pollutants (see page A2-4) contained in
chemicals added for cooling tower maintenance, except
Chromium, total
Zinc, total
(l> No detectable amount
(i)
02
1 0
From 40 CFR 423 17(d)(1)
A2-2
-------
Appendix 2-1 (continued)
Steam Electric Power Generating Point Sources
(40 CFR 423)
The 126 Priority Pollutants
Acenaphthene
Acrolein
Acrylonitrile
Benzene
Benzidine
Carbon tetrachloride
(tetrachloromethane)
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,2-Tnchloroethane
1,1,2,2-Tetrachloroethane
Chloroe thane
Bis (2-chloroethyl)ether
2-Chloroethyl vinyl ether (mixed)
2-Chloronaphthalene
2,4,6-T richlorophenol
Parachlormeta-cresol
Chloroform (tnchloromethane)
2-Chlorophenol
1.2-Dichlorobenzene
1.3-Dichlorobensens
1.4-Dichlorobenzene
3,3-Dichlorobenzidine
1.1-Dichloroethylene
1.2-T rans-dichlorothylene
2.3-Dichlorophenol
1.2-Dichloropropane
1.3-Dichloropropylene (1,3-
dichloropropene)
2.4-Dimethylphenol
2,4-Dinurotoluene
2,6-Dimtrotoluene
1,2-Diphenylhydrazine
Ethylbenzene
Fluoranthene
4-Chlorophenyl phenyl ether
4-Bromophenyl phenyl ether
Bis (2-chloroisopropyl) ether
Bis (2-chloroethoxy) methane
Methylene chloride (dychloromethane
Methyl chloride (dichloromethane)
Methyl bromide (bromomethane)
Bromoform (tribromomethane)
Dichlorobromomethane
Chlorodibromomethane
Hexachlorobetadiene
Hexachlorocyclo-entadiene
Isophorone
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2,4-Dimtrophenol
4,6-Dinitro-o-cresol
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propulamine
Pentachlorophenol
Phenol
Bis (2-ethylhexyl) phthalate
Butyl benzyl phthalate
D\-n-butyl phthalate
Di-n-octyl phthlate
Diethyl phthlate
Dimethyl phthlate
I,2-Benzanthracene
(benzo(a)anth racene)
Benzo(a)pyrene (3,4-benzopyrene)
3,4-Benzofluoranthene
(benzo(b)fluoranthene)
II,12-Benzofluoroanthene
(benzo(k)fluoranthene)
Chrysens
Acenaphthylene
Anthracene
1,12-Benzopery lene
(benzo(gh)perylene)
Fluorene
Phenanthrene
1,2,5,6-Dibenzamhracene
(dibenso(a.h)anth racene)
Indeno(l ,2,3-cd) pyrene (2,3-0-
phenlene pyrene)
Pyrene
Tetrachloroethylene
Toluene
Tnchloroethylene
Vinyl chloride (chloroethylene)
Aldrin
Chlordane (technical mixture and
metabolites)
4,4-DDT
4,4-DDE (p,p-DDX)
4,4-DDD (p,p-TDE)
Alpha-endosulfa
Beta-endosulfan
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide (BHC-
hexachloro-cyclohexane)
Alpha-BHC
Beta-BHC
Gamma-BHC
Delta-BHC
PCB-polychlorinated biphenyls
PCB-1242 (Arochlor 1242)
PCB-1254 (Arochlor 1254)
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB 1248 (Srochlor 1248)
PCB-1260 (Arochlor 1260)
PCB-1016 (Arochlor 1016)
Toxaphene
Antimony
Arsenic
Asbestos
Beryllium
Cadmium
Chromium
Copper
Cyanide, total
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
2,3,7,8-T etrachlorodibenzo-p-dioxin
(TCDD)
Dieldrin
A2-3
-------
Appendix 2-2
Operations Excepted from Electroplating Point Source Effluent Limitations
(40 CFR 413)
Operations similar to electroplating but which are specifically excepted include
1 Electrowinning and electrorefining conducted as part of nonferrous metal smelting and refining
2 Metal surface preparation and conversion coating conducted as part of coil coating
3 Metal surface preparation and immersion plating or electroless plating conducted as part of
porcelain enameling
4 Electrodeposition of active electrode materials, electroimpregnation, and electroforming conducted
as a part of battery manufacturing
5. Metallic platemaking and gravure cylinder preparation conducted with or for printing and
publishing facilities, and continuous strip electroplating conducted within iron and steel
manufacturing facilities that introduce pollutants into a publicly owned treatment works
Chart 1
^ „ ...j
06
04
03
1 2
7
.5
1 9
1
.55
4 1
2 6
1 8
4 2
26
1 8
4 2
2 6
1 8
4 5
2 7
1 8
5 0
2 7
1 5
70
4
25
10 5
6 8
5
20 0
13 4
10
23
16
12
47
29
20
53
36
27
74
39
21
107
65
45
169
89
49
160
100
70
164
102
70
176
105
70
273
156
98
365
229
160
374
232
160
401
241
160
410
267
195
623
257
223
935
609
445From 40 CFR 413 04
A2-4
-------
Appendix 2-2 (continued)
Operations Excepted from Electroplating Point Source Effluent Limitations
(40 CFR 413)
Chart 2
All subcategory facilities discharging less than 38,000 L (10,000 gal) per day PSES limitations (mg/L)
¦> If MutBsittuwti Jfosf mxjf itey Jte
CN,A
5 0
2 7
Pb
06
04
Cd
1 2
0 7
From 40 CFR 413 14(b), 413 54(b), and 413 74(b)
Chart 3
All subcategory facilities discharging 38,000 L (10,000 gal) or more per day limitations (mg/L)
i it w tot -totty o>>&.ffiy fe
CN,T
1 9
1 0
Cu
4 5
2 7
Ni
4 1
26
Cr
70
4 0
Zn
4 2
2 6
Pb
06
04
Cd
1 2
07
Total metals
10 5
68
From 40 CFR 413 14(c), 413 54(c), and 413 74(c)
Chart 4
All subcategory facilities dischargin
g 38,000 L (10,000 gal) or more ter day PSES limitations (mg/L)
¦%7 ¦¦ •»
: Afctil ilUt AtJtikii ±itb&hiUi to
: Vm HgV
tM L , I .y-'' iu ^ \
I flvR iW say
CN,T
1 9
1 0
Pb
06
04
Cd
1 2
07
TSS
20 0
13 4
PH
*
*
~Within the range 7.5 to 10 0
From 40 CFR 413 14(e), 413 54(e), and 413 74(e)
A2-5
-------
Appendix 2-3
Metal Finishing Point Sources
(40 CFR 433)
¦Z" " -
Nonferrous metal smelting and refining
Aluminum forming
Coil coating
Copper forming
Porcelain enameling
Plastic molding and forming
Battery manufacturing
Nonferrous forming
Iron and steel
Electrical and electronic components
Metal casting foundries
Chart 1
BAT
•• v ¦¦v ,
Vllf T m'}1
..A-
¦¦ w ¦¦ ¦
-
Cadmium (T)
0 69
0 26
Chromium (T)
2 77
1 71
Copper (T)
3 38
2 07
Lead (T)
0 69
0 43
Nickel (T)
3 98
2 38
Silver (T)
0 43
0 24
Zinc (T)
2 61
1 48
Cyanide (T)
1 20
0 65
TTO
2 13
...
From 40 CFR 433 14(a) and 40 CFR 433 14(a)
Chart 2
NSPS
u&u
iWIIMHlM
T*
Cadmium (T)
Chromium (T)
Copper (T)
Lead (T)
Nickel (T)
Silver (T)
Zinc (T)
Cyanide (T)
TTO
Oil and Grease
TSS
pH
0 11
2 77
3 38
0 69
3 98
0 43
2 61
1 20
2 13
52.00
60 00
0 07
1 71
2 07
0 43
2 38
0 24
1 48
0 65
26 00
31 00
•Wiihm 6 0-9 0
From 40 CFR 433 16(a)
A2-6
-------
Appendix 2-3 (continued)
Metal Finishing Point Sources
(40 CFR 433)
Chart 3
PSNS
*SS\ ^ s S S S S
s
4\V
Cadmium (T)
0 11
0 07
Chromium (T)
2 77
1 71
Copper (T)
3 38
2 07
Lead (T)
0 69
0 43
Nickel (T)
3 98
2 38
Silver (T)
0 43
0 24
Zinc (T)
2 61
1 48
Cyanide (T)
1 20
0 65
TTO
2 13
...
From 40 CFR 433 17(a)
A2-7
-------
Appendix 2-4
Effluent Standards for Hospitals and Photographic Point Sources
(40 CFR 459.12 and 460.10)
Chart 1
Effluent Standards for Hospitals
MW&uifo am*# ftr n
BOD5
TSS
pH
41 0
55 6
Metric units (kg/1000 occupied beds)
33 6
33 8
English units (lb/1000 occupied beds)
BOD5
TSS
pH
904
122 4
74 0
74 5
*
*Wiihm the range 6 0-9 0
From 40 CFR 460 10
Chart 2
Effluent Limitations for Photographic Point Sources
: \ s s s s "V* v %
- ' "
t# mi 4m
Metric units (kg/1000 m:of product)
Afi
0 14
0 07
CN
0 18
009
pH
*
*
English units (lb/1000 ft2 of product)
Ag
0 030
0 015
CN
0 038
0 109
pH
*
*
•Within the range 6 0-9 0
From 40 CFR 459 12
A2-8
-------
Appendix 2-5
Relevant Dates for the Sewage Sludge Program
- - -
Publication of Part 503 in 58 FR 9248
19 February 1993
Publication of amendments to Sewage Sludge Permit Program regulations in 58 FR 9404
19 February 1993
Effective date of Part 503
22 March 1993
Requirements for monitoring and recordkeeping under Part 503 become effective (except
for THC)
20 July 1993
Permit applications due from facilities required to have (or
requesting) site-specific limits
18 August 1993
Compliance date for part 503 requirements other than
monitoring, recordkeeping and reporting (where construction
is not required)
19 February 1993
Requirements for monitoring, recordkeeping and reporting
for THC under Part 503 become effective (where construction
is not required)
19 February 1993
Requirements for reporting under Part 503 become effective
19 February 1993
Limited permit application information due from sludge-only
facilities (not needing site-specific limits)
19 February 1993
Due for closure of active sewage sludge units
• Located within 60 m of a fault that has displacement in Holocene time (unless
authorized by the permitting authority)
• Located in a wetland (unless authorized under an NPDES permit)
• Located in an unstable area
22 March 1993
Compliance date for Part 503 requirements other than monitoring, recordkeeping, and
reporting (where construction is required)
19 February 1993
Requirements for monitoring, recordkeeping, and reporting for THC under Part 503
become effective (where construction is required)
19 February 1993
Date when active sewage sludge unit owners/operators must submit closure plans
180 days prior to the date the unit
closes
Permit application information due from facilities with NPDES permits (not needing
site-specific limits)
At the time of the next NPDES permit
renewal
Permit application information due from facilities who commence operations after 19
February 1993
180 days prior to the date proposed for
commencing operation
A2-9
-------
Appendix 2-6
Cumulative Pollutant Loading Rates for Sludge
(40 CFR 503.13(b)(2))
Arsenic
41
Cadmium
39
Chromium
3000
Copper
1500
Lead
300
Mercury
17
Nickel
420
Selenium
100
Zinc
2600
A2-10
-------
Appendix 2-7
Ceiling Concentrations for Sludge
(40 CFR 503.13(b)(1))
pKippilll
Arsenic
75
Cadmium
85
Chromium
3000
Copper
4300
Lead
640
Mercury
57
Molybdenum
75
Nickel
420
Selenium
100
Zinc
7500
A2-11
-------
Appendix 2-8
Pollutant Concentrations for Sludge
(40 CFR 503.13(b)(3))
V. *• s
Arsenic
41
Cadmium
39
Chromium
1200
Copper
1500
Lead
300
Mercury
17
Nickel
420
Selenium
100
Zinc
2800
A2-12
-------
Appendix 2-9
Annual Pollutant Loading Rates
(40 CFR 503.13(b)(2))
Arsenic
2 0
Cadmium
1 0
Chromium
150
Copper
75
Lead
15
Mercury
0 85
Nickel
21
Selenium
50
Zinc
140
-------
Appendix 2-10
Frequency of Monitoring - Land Application and Surface Disposal
(40 CFR 503.16 Table 1, 503.26 Table 1, 503.46 Table 1)
; K Abhwh* : - - , :'
.. ..
j "
!»pw*«e <>- ' - ¦¦ "" " '
i* ^ ~
; --
Greater than zero but less than 290 (285 42)
Once per year
Equal to or greater than 290 (285 42) but less than 1500
(1476 31)
Once per quarter (four times per year)
Equal to or greater than 1500 (1476 31) but less than 15,000
(14,763 1)
Once per 60 days (six times per year)
Equal to or greater than 15,000 (14,763 1)
Once per month
~Either the amount of bulk sewage sludge applied to the land or the amount of sewage sludge received by a person who
prepares sewage sludge that is sold or given away in a bag or other container for application to the land (dry weight basis).
A2-14
-------
Appendix 2-11
Pollutant Concentrations for an Active Sewage Sludge Unit
(40 CFR 503.23, Table 1)
210
0 to less Lhan 25
200
240
25 to less than 50
220
50 to less than 75
260
270
300
320
75 to less than 100
390
100 to less than 125
360
420
125 to less than 150
450
"'Dry weight basis
A2-15
-------
Appendix 2-12
Effluent Guidelines and Pretreatment Standards Categories
40CFR 401
General provisions
40 CFR 403
General pretreatment regulations for existing and new sources of pollution
40 CFR 405
Dairy products processing point source category
40 CFR 406
Grain mills point source category
40 CFR 407
Canned and preserved fruits and vegetables processing point source category
40 CFR 408
Canned and preserved seafood processing point source category
40 CFR 409
Sugar processing point source category
40 CFR 410
Textile mills point source category
40 CFR 411
Cement manufacturing point source category
40 CFR 412
Feedlots point source category
40 CFR 413
Electroplating point source category
40 CFR 414
Organic chemicals, plastics, and synthetic fibers
40 CFR 415
Inorganic chemicals manufacturing point source category
40 CFR 416
[Reserved]
40 CFR 417
Soap and detergent manufacturing point source category
40 CFR 418
Fertilizer manufacturing point source category
40 CFR 419
Petroleum refining point source category
40 CFR 420
Iron and steel manufacturing point source category
40 CFR 421
Nonferrous metals manufacturing point source category
40 CFR 422
Phosphate manufacturing point source category
40 CFR 423
Steam electric power generating point source category
40 CFR 424
Ferroalloy manufacturing point source category
40 CFR 425
Leather tanning and finishing point source category
40 CFR 426
Glass manufacturing point source category
40 CFR 427
Asbestos manufacturing point source category
40 CFR 428
Rubber manufacturing point source category
40 CFR 429
Timber products processing point source category
40 CFR 430
Pulp, paper, and paperboard point source category
40 CFR 431
The builders' paper and board mills point source category
A2
-------
Appendix 2-12 (continued)
Effluent Guidelines and Pretreatment Standards Categories
40 CFR 432
Meat products point source category
40 CFR 433
Metal finishing point source category
40 CFR 434
Coal mining point source category, BPT, BAT, BCT limitations and new source performance standards
40 CFR 435
Oil and gas extraction point source category
40 CFR 436
Mineral mining and processing point source category
40 CFR 439
Pharmaceutical manufacturing point source category
40 CFR 440
Ore mining and dressing point source category
40 CFR 443
Effluent limitations guidelines for existing sources and standards for performance and pretreatment standards for
new sources for the paving and roofing materials (tars and asphalt) point source category
40 CFR 446
Paint formulating point source category
40 CFR 447
Ink formulating point source category
40 CFR 454
Gum and wood chemicals manufacturing point source category
40 CFR 455
Pesticide chemicals
40 CFR 457
Explosives manufacturing point source category
40 CFR 458
Carbon black manufacturing point source category
40 CFR 459
Photographic point source category
40 CFR 460
Hospital point source category
40 CFR 461
Battery manufacturing point source category
40 CFR 463
Plastics molding and forming point source category
40 CFR 464
Metal molding and casting point source category
40 CFR 465
Coil coating point source category
40 CFR 466
Porcelain enameling point source category
40 CFR 467
Aluminum forming point source category
40 CFR 468
Copper forming point source category
40 CFR 469
Electrical and electronic components point source category
40 CFR 471
Nonferrous metals forming and metal powders point source category
A2-17
-------
Phase 1
Section 3
Nonhazardous Waste Management
-------
Phase 1
Section 3
Table of Contents
Nonhazardous Waste Management
A. Applicability 3-1
B. Federal Legislation 3-1
C. State/Local Regulations 3-2
D. Key Compliance Requirements 3-2
E. Key Compliance Definitions 3-5
F. Records to Review 3-13
G. Physical Features to Inspect 3-13
H. Guidance for Checklist Users 3-14
Appendices
A3-1. Compliance Dates for MSWLFs and 40 CFR 258 A3-1
A3-2. MSWLF Units Exempt from Compliance with 40 CFR 258 A3-2
A3-3. Constituents for Detection Monitoring A3-3
A3-4. List of Hazardous Inorganic Constituents A3-6
A3-5. Design Criteria Concentration Values A3-22
-------
A. Applicability
This section addresses the collection, storage,and disposal of solid waste at facilities.
Solid waste is considered to be non-hazardous trash, rubbish, garbage, bulky wastes,
liquids,or sludges. The handling and disposal of asbestos waste materials are addressed in the
Air Pollution Control protocol.
Recycling and resource recovery activities are also included in this section because they
are considered a form of solid waste management.
Assessors are required to review agency, Federal, state,and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. Resource Conservation and Recovery Act (RCRA) of 1976
This is the Federal law which governs the disposal of solid waste. Subtitle D of this Act,
as last amended in November 1984 (Public Law (P.L.) 98-616; 42 U.S. Code (USC) 6941-
6949a), establishes Federal standards and requirements for state and regional authorities
respecting solid waste disposal. The objectives of this subtitle are to assist in developing and
encouraging methods for the disposal of solid waste which are environmentally sound and
which maximize the utilization of valuable resources recoverable from solid waste. The
objectives are to be achieved through Federal, technical, and financial assistance to states and
regional authorities for comprehensive planning (42 USC 6941)
2. The Solid Waste Disposal Act of 1965, as amended
This Act requires that Federal facilities comply with all Federal, state, interstate, and local
requirements concerning the disposal and management of solid wastes. These requirements
include permitting, licensing, and reporting.
3. The Occupational Safety and Health Act (OSHA)
The general purpose of this Act is to assure, as much as possible, that every individual
working in the United States has safe and healthful working conditions. The control of
medical waste is one aspect of assuring safe and healthy working conditions.
4. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to
comply with applicable Federal, state, and local pollution control standards. It makes the head
of each executive agency responsible for seeing to it that the agencies, facilities, programs,
and activities the agency funds meet applicable Federal, state, and local environmental
requirements or to correct situations that are not in compliance with such requirements. In
addition, the EO requires that each agency ensure that sufficient funds for environmental
compliance are included in the agency budget.
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S. EO 12873, Federal Agency Recycling and the Council on Federal Recycling and
Procurement Policy
This EO, dated 31 October 1991, requires Federal agencies to promote cost-effective
waste reduction and recycling of reusable materials from wastes generated at their activities.
Federal agencies are required to initiate a program to promote cost-effective waste reduction
through: (1) practices that reduce waste generation and (2) the recycling of materials such as
paper, plastic metals, glass, used oil, lead acid batteries, and tires and the composting of
organic materials such as yard waste.
C. State/Local Regulations
The Federal government sets minimum national standards for municipal solid waste
landfilling in 40 CFR Part 258, but state and local governments are responsible for
implementing and enforcing waste programs. States are required to develop their own
programs based on the Federal regulations. Most states and municipalities have already
developed their own regulations governing the permitting, licensing, and operations of
landfills, incinerators, and source separation/recycling programs.
States are required to incorporate revised criteria for Municipal Solid Waste Landfills
(MSWLF) into their permit programs and gain approval from EPA. States that apply for and
receive EPA approval of their programs have the opportunity to provide a lot of flexibility in
implementing the regulations. This flexibility allows states to take local conditions into
account and gives them the authority to alter some of the requirements. Evaluators will need to
determine if a state has been granted approval for the 40 CFR Part 258 Program in order to
accurately assess compliance with the criteria. Many states have also instigated categories of
special wastes which cannot be placed in landfills or dumps, or may only be disposed of under
specific circumstances.
D. Key Compliance Requirements
1. Storage/Collection
Facilities are required to store all solid wastes and materials separated for recycling so that
it does not cause a fire, safety, or health hazard. All facilities are required to operate their
collection systems in a manner to protect the health and safety of personnel associated with the
operation. All collection equipment is required to have a suitable cover to prevent spillage;
and the equipment is required to be constructed, operated, and maintained adequately. All
facilities are required to collect solid wastes or materials separated for recycling, according to
a certain schedule, and in a safe efficient manner (40 CFR 243.200-1, 243.201-1, 243.202-
1(a) through 243.202 1(c), 243.203-1, 243.204-1).
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2. Solid Waste Containers
Facility personnel should be periodically informed about materials that are prohibited from
disposal in solid waste receptacles (MP).
3. Recycling
Facilities should establish a program to implement state or local recycling requirements
and reduce the volume of solid waste materials at the source whenever practical. Facilities
with offices of over 100 office workers are required to recover high-grade paper. Facilities at
which more than 500 families reside are required to recycle newspapers. Any facility
generating 10 tons (10,160.5 kg) or more of waste corrugated containers per month is required
to segregate or collect them separately for recycling or alternate energy use (40 CFR 246.200-
1 and 246.202-1).
4. Specific Wastes
Bulky wastes must be disposed of according to certain methods which differ depending on
the variety of waste (i.e., automobile bodies, furniture and appliances) are required to be
salvaged or crushed and pushed onto the working face near the bottom of the cell. Water
treatment plant sludges containing no free moisture and digested or heat treated wastewater
treatment plant sludges, must be disposed of by covering them with soil or municipal solid
wastes. Incinerator and air pollution control residues must be disposed of by covering them as
necessary to prevent their becoming airborne (40 CFR 241.200-3).
5. Land Disposal Site Operations other than a MSWLF
Facilities are required to place cover material over landfilled waste at the end of each
operating day. Land disposal sites that accept special wastes must have approval from the
responsible agency. Facilities that operate land disposal sites are required to provide a list of
excluded materials to regular users, to operate the sites in a manner that will protect water
quality and air quality, and control decomposition gases and vectors. Land disposal sites are
required to be designed and operated in an aesthetically acceptable manner, and to be
designed, constructed, and operated to protect the health and safety of personnel. Land
disposal site cover material is required to minimize fire hazards, infiltration of precipitation,
odors and litter, control gas venting and vectors, discourage scavenging, and provide a
pleasing appearance. Municipal solid waste and cover material must be compacted to the
smallest practicable volume. The operators of land disposal sites are required to maintain
records and monitoring data (40 CFR 241.200-3(a), 241.201-2, 241.201-3, 241.204-3,
241.205-3 241 206-241 211, and 241 212-3(a))
6. Land Disposal Site Closure other than a MSWLF
Upon closure of a site, a detailed description is required to be recorded with the area's
land recording authority (40 CFR 241.212-3(b)).
7. New Landfills other than MSWLFs
New landfills are required to meet certain location and design criteria, which include
evaluation of hydrogeology and onsite soil characteristics and verification of easy access to
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vehicles. Plans for the design, construction, and operation of new sites or modification to
existing sites are required to be prepared or approved by a professional engineer (40 CFR
241.202-2 and 40 CFR 241.203-1).
8. Municipal Solid Waste Landfills (MSWLF)
MSWLFs must meet restrictions for location, the types of waste to be placed in them, and
the types of monitoring required. Limitations, design criteria, and closure requirements vary
depending on whether it is a new or existing MSWLF (40 CFR 258).
9. Thermal Processing Facilities
Facilities that are designed to process or are processing 50 tons (45,359.24 kg) or more
per day of municipal solid wastes must be operated in a manner that prevents water and/or air
contamination. Additionally there must be an operating plan that specifies procedures and
precautions to be taken if unacceptable wastes are delivered to or left at the thermal processing
facility. The residue and solid waste resulting from the thermal processing must be disposed
of in a manner that prevents environmental damage (40 CFR 240).
10. Resource Recovery Facilities
Resource recovery facilities have to be designed to process at least 65 percent by wet
weight of the input solid waste to recycled material, fuel, or energy (40 CFR 245).
11. Medical Waste
Contaminated reusable sharps and other regulated wastes are required to be placed in
puncture resistant, color coded, leakproof containers as soon as possible after use until
properly reprocessed. Specimens of blood or other potentially infectious material are required
to be placed in a container that prevents leakage during collection, handling, processing,
storage, transport, or shipping and specific labeling and handling requirements are to be
followed (29 CFR 1910.1030(d)).
12. Medical Waste Containers
All bins, cans, and other receptacles intended for reuse that have the likelihood of
becoming contaminated with blood or other potentially infectious materials are required to be
inspected and decontaminated on a regularly scheduled basis. Labels affixed to containers of
regulated wastes, refrigerators and freezers containing blood, and other containers used to
store, transport, or ship blood or other potentially infectious materials must meet specific
standards, which include the biohazard symbol, and being colored a fluorescent orange with
contrasting-colored lettering and symbols (29 CFR 1910.1030(d)(4)(ii)(c) and
1910.1030(g)(l)(i)).
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E. Key Compliance Definitions
1. Active Life
The period of operation beginning with the initial receipt of solid waste and ending with
the completion of closure activities (40 CFR 258.2).
2. Active Portion
That part of a facility or unit that has received or is receiving wastes and has not been
closed (40 CFR 258.2).
3. Aquifer
A geological formation, group of formations, or a portion of a formation capable of
yielding significant quantities of groundwater to wells or springs (40 CFR 258.2).
4. Blood
Human blood, human blood components, and products made from human blood (29 CFR
1910.1030(a))
5. Bottom Ash
The solid material that remains on a hearth or falls off the grate after thermal processing is
complete (40 CFR 240 101(b)).
6. Bulky Wastes
Large items of solid waste such as household appliances, furniture, large auto parts, trees,
branches, stumps, and other oversize wastes which large size precludes or complicates their
handling by normal solid waste collection, processing, or disposal methods (40 CFR 243.101)
7. Cell
Compacted solid wastes that are enclosed by natural soil or cover material in a land
disposal site (40 CFR 241.101).
8. Collection
The act of removing solid waste (or materials which have been separated for the purpose
of recycling) from a central storage point (40 CFR 243.101).
9. Commercial Solid Waste
All types of solid waste generated by stores, offices, restaurants, warehouses, and other
non-manufacturing activities, excluding residential, and industrial wastes (40 CFR 243.101).
10. Construction and Demolition Wastes
The waste building materials, packaging, and rubble resulting from the construction,
renovation, repair, and demolition operation on pavements, houses, commercial buildings, and
other structures (40 CFR 243.101).
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11. Contaminated
The presence or the reasonably anticipated presence of blood or other potentially
infectious materials on an item or surface (29 CFR 1910.1030(a)).
12. Contaminated Sharps
Any contaminated object that can penetrate the skin, including but not limited to, needles,
scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires (29 CFR
1910.1030(a)).
13. Corrugated Container Waste
Discarded corrugated boxes (40 CFR 246.101).
14. Cover Material
Soil or other suitable material that is used to cover compacted solid wastes in a land
disposal site (40 CFR 241.101).
15. Daily Cover
Cover material that is spread and compacted on the top and side slopes of compacted solid
wastes at least at the end of each operating day in order to control vectors, fire, moisture, and
erosion and to assure an aesthetic appearance (40 CFR 241.101).
16. Decontamination
The use of physical or chemical means to remove, inactivate, or destroy bloodborne
pathogens on a surface or item to the point where they are no longer capable of transmitting
infectious particles and the surface of item is rendered safe for handling, use, or disposal (29
CFR 1910.1030(a)).
17. Design Capacity
The weight of solid waste of a specified gross caloric value that a thermal processing
facility is designed to process in 24 hours of continuous operation (40 CFR 240.101(d)).
18. Existing MSWLF Unit
Any MSWLF unit that is receiving solid waste as of the appropriate dates specified in (40
CFR 258.1(e) see Appendix 3-1). Waste placement in existing units must be consistent with
past operating practices or modified practices to ensure good management (40 CFR 258.2).
19. Facility
All contiguous land and structures, other appurtenances and improvements on the land use
for the disposal of solid waste (40 CFR 258.2).
20. Final Cover
Cover materials that serve the same function as daily cover but, in addition, may be
permanently exposed on the surface (40 CFR 241.101).
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21. Fly Ash
Suspended particles, charred paper, dust, soot, and other partially oxidized matter carried
in the products of combustion (40 CFR 240.101).
22. Food Waste
The organic residues generated by the handling, storage, sale, preparation, cooking, and
serving of foods, commonly called garbage (40 CFR 243.101).
23. Garbage
In relation to solid waste coming from outside the continental United States, it is all waste
material derived in whole or in part from fruits, vegetables, meats, or other plant or animal
material, and other refuse of any character whatsoever that has been associated with any such
material on board any means of conveyance including: food scraps, table refuse, galley refuse,
food wrappers, or packaging materials, and other water materials from stores, food
preparation areas, passengers; or crews quarters, dining rooms, or any other areas or means of
conveyance. It also means meals and other food that were available for consumption by
passengers and crew on an aircraft but were not consumed (7 CFR 330.400(b)).
24. Groundwater
Water present in the unsaturated zone of an aquifer (40 CFR 241.101).
25. High-grade Paper
Letterhead, dry copy papers, miscellaneous business forms, stationary, typing paper,
tablet sheets, and computer printout paper and cards commonly sold as "white ledger",
"computer printout," and "tab card" grade by the wastepaper industry (40 CFR 246.101).
26. Household Waste
Any solid waste (including garbage, trash, and sanitary waste in septic tanks) derived
from households (including single and multiple residences, hotels and motels, bunkhouses,
ranger stations, crew quarters, campgrounds, picnic grounds, and day-use-recreation areas)
(40 CFR 258.2).
27. Indian Lands of Indian Country
This means (40 CFR 258.2):
a. All land within the limits of any Indian reservation under the jurisdiction of the U.S.
Government, notwithstanding the issuance of any patent, and including rights-of-way
running throughout the reservation;
b All dependent Indian communities within the borders of the U. S. whether within the
original or subsequently acquired territory thereof, and whether within or without the
limits of the state; and
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c. All Indian allotments, the Indian titles to which have not been extinguished, including
rights of way running through the same.
28. Indian Tribe
Any Indian tribe, band, nation, or community recognized by the Secretary of the Interior
(SOI) and exercising substantial governmental duties and powers on Indian lands (40 CFR
258.2).
29. Industrial Solid Waste
The solid waste generated by industrial processes and manufacturing that is not a
hazardous waste (40 CFR 243.101).
30. Industrial Solid Waste
In relation to MSWLF, solid waste generated by manufacturing or industrial processes
that is not a hazardous waste regulated under Subtitle C of RCRA. Such waste may include,
but is not limited to, waste resulting from the following manufacturing processes: electric
power generation; fertilizer/agricultural chemicals; food and related products/byproducts;
inorganic chemicals; iron and steel manufacturing; leather and leather products; nonferrous
metals manufacturing/foundries; organic chemicals; plastics and resins manufacturing; pulp
and paper industry; rubber and miscellaneous plastic products; stone, glass, clay, and concrete
products; textile manufacturing; transportation equipment; and water treatment. This term
does not include mining waste or oil and gas waste (40 CFR 258.2).
31. Infectious Waste
This includes (40 CFR 240.101):
a. Equipment, instruments, utensils, and fomites of a disposable nature from the rooms
of patients who are suspected to have or have been diagnosed as having a
communicable disease and must, therefore, be isolated as required by public health
agencies;
b. Laboratory wastes such as pathological specimens and disposable fomites (any
substance that may harbor or transmit pathological organisms);
c. Surgical operating room pathological specimens and disposable fomites attendant
thereto and similar disposable materials from outpatient areas and emergency rooms.
32. Institutional Solid Waste
Solid wastes generated by educational, health care, correctional, and other institutional
facilities (40 CFR 243.101).
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33. Intermediate Cover
Cover material that serves the same function as daily cover but must resist erosion for a
longer period of time, because it is applied in areas where additional cells are not to be
constructed for extended periods of time (40 CFR 241.101).
34. Lateral Expansion
A horizontal expansion of the waste boundaries of an existing municipal solid waste
landfill unit (40 CFR 258.2).
35. Leachate
Liquid that has percolated through solid waste and has extracted, dissolved, or suspended
materials from it (40 CFR 241.101).
36. Leachate
In relation to MSWLFs, this is a liquid that has passed through or emerged from solid
waste and contains soluble, suspended, or miscible materials removed from such waste (40
CFR 258.2).
37. Management Practice (MP)
Practices that although not mandated by law, are encouraged to promote responsible
operating procedures.
38. Medical/Pathological Wastes
Any solid waste that is generated in the diagnosis, treatment, or immunization of human
beings or animals, in research pertaining thereto, or in the production or testing of biologicals.
This does not include hazardous waste or household waste (40 CFR 259 10).
39. Municipal Solid Waste
Residential and commercial solid wastes generated within a community (40 CFR
240.101).
40. Municipal Solid Waste Landfill (MSWLF) Unit
A discrete area of land or an excavation that received household waste and that is not a
land application unit, surface impoundment, injection well, or waste pile. It may also receive
other types of RCRA Subtitle D wastes, such as commercial solid waste, nonhazardous sludge,
conditionally exempt small quantity generator waste, and industrial solid waste. Such a
landfill may be publicly or privately owned. A MSWLF unit may be a new MSWLF unit, an
existing MSWLF unit, or a lateral expansion (40 CFR 258 2).
41. New MSWLF Unit
Any MSWLF unit that has not received wastes prior to 9 October 1993 or prior to 9
October 1995 if the MSWLF unit disposes of less than 20 tons (18,143,699 kg) of municipal
solid waste daily based on an annual average and the MSWLF unit serves either (40 CFR
258.2):
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a. A community that experiences an annual interruption of at least three consecutive
months of surface transportation that prevents access to a regional waste management
facility; or
b. A community that has no practicable waste management alternative and the landfill is
located in an areas that annually receives less than or equal to 25 in (62.5 cm) of
precipitation.
42. Open Burning
In relation to MSWLFs, the combustion of solid waste without (40 CFR 258.2):
a. Control of combustion air to maintain adequate temperature for efficient combustion;
b. Containment of the combustion reaction in an enclosed device to provide sufficient
residence time and mixing for complete combustion; and
c. Control of the emission of the combustion products.
43. Open Burning
Burning of solid wastes in the open (such as in an open dump) (40 CFR 240.101(r)).
44. Open Dump
A land disposal site at which solid wastes are disposed of in a manner that does not
protect the environment, are susceptible to open burning, and are exposed to the elements,
vectors, and scavengers (40 CFR 240.101).
45. Recoverable Resource
Materials that still have useful physical, chemical, or biological properties after serving
their original purpose and can, therefore, be reused or recycled for the same or other purposes
(40 CFR 245.101).
46. Recycled Material
A material that is utilized in place of a primary, raw, or virgin material in manufacturing
a product (40 CFR 245.101).
47. Recycling
The process by which recovered materials are transformed into new products (40 CFR
245.101).
48. Regulated Wastes
Liquid or semi-liquid blood or other potentially infectious materials; contaminated items
that would release blood or other potentially infectious materials in a liquid or semi-liquid state
if compressed; items that are caked with dried blood or other potentially infectious materials
and are capable of releasing these materials during handling, contaminated sharps, and
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pathological and microbiological wastes containing blood or other potentially infectious
materials (29 CFR 1910.1030(a)).
49. Residential Solid Waste
The wastes generated by the normal activities of households, including, but not limited to,
food wastes, rubbish, ashes, and bulky wastes (40 CFR 243.101).
50. Resource Recovery Facility
Any physical plant that processes residential, commercial, or institutional solid waste
biologically, chemically, or physically, and recovers useful products (40 CFR 245.101).
51. Runoff
The portion of precipitation that drains from an area as surface flow (40 CFR 241.101).
52. Runoff
In relation to MSWLF, any rainwater, leachate, or other liquid that drains over land from
any part of a facility (40 CFR 258.2).
53. Runon
Any rainwater, leachate, or other liquid that drains over land onto any part of a facility
(40 CFR 258.2).
54. Sanitary Landfill
A land disposal site employing an engineered method of disposing of solid wastes on land
in a manner that minimizes environmental hazards by spreading the solid wastes in thin layers;
compacting the solid wastes to the smallest practical volume; and applying and compacting
cover material at the end of each operating day (40 CFR 240 101).
55. Separate Collection
Collection of recyclable materials which have been separated at the point of generation
and keeping those materials separated from other collected solid waste in separate
compartments of a single collection vehicle or through the use of separate collection vehicles
(40 CFR 246.101).
56. Sludge
The accumulated semiliquid suspension of settled solids deposited from wastewaters or
other fluids in tanks or basins (40 CFR 240.101).
57. Sludge
In relation to MSWLF, any solid, semi-solid, or liquid waste generated from a municipal,
commercial, or industrial wastewater treatment plant, water supply treatment plant, or air
pollution control facility exclusive of the treated effluent from a wastewater treatment plant (40
CFR 258 2)
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58. Solid Waste
In relation to MSWLF, any garbage, or refuse, sludge from a wastewater treatment plant,
water supply treatment plant, or air pollution control facility and other discarded materials,
including solid, liquid, semi-solid, or contained gaseous material resulting from industrial,
commercial, mining and agricultural operations, and from community activities, but does not
include solid or dissolved materials in domestic sewage, or solid or dissolved materials in
irrigation return flows or industrial discharges that are point sources subject to permit under
33 USC 1342, or source, special nuclear, or byproduct material as defined by the Atomic
Energy Act of 1954, as amended (68 Stat. 932) (40 CFR 258.2).
59. Solid Waste
Garbage, refuse, sludge, and other discarded solid materials resulting from industrial and
commercial operations and from community activities. It does not include solids or dissolved
materials in domestic sewage or other significant pollutants in water resources (40 CFR
240.101)
60. Source Separation
The setting aside of recyclable materials at their point of generation by the generator (40
CFR 246.101).
61. Special Wastes
Nonhazardous solid wastes requiring handling other than that normally used for municipal
solid wastes (40 CFR 240.101).
62. Thermal Processing
Processing of waste material by means of heat (40 CFR 240 101).
63. Transfer Station
A station at which solid wastes are concentrated for transport to a processing facility or
land disposal site. A transfer station may be fixed or mobile (40 CFR 243.101).
64. Universal Precautions
An approach to infection control. According to the concept of Universal Precautions, all
human blood and certain human body fluids are treated as if known to be infectious for HIV,
HBV, and other bloodborne pathogens (29 CFR 1910.1030(a)).
65. Uppermost Aquifer
The geologic formation nearest the natural ground surface that is an aquifer, as well as,
lower aquifers that are hydraulically interconnected with this aquifer within the facility's
property boundary (40 CFR 258.2).
66. Vector
A carrier, usually an arthropod, that is capable of transmitting a pathogen from one
organism to another (40 CFR 240.202).
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67. Waste Management Unit Boundary
A vertical surface located at the hydraulically downgradient limit of the unit. This vertical
surface extends down into the uppermost aquifer (40 CFR 258.2).
68. Working Face
That portion of the land disposal site where solid wastes are discharged and are spread and
compacted prior to the placement of cover material (40 CFR 241.101).
F. Records to Review
• Inventory of solid waste streams generated;
• Record of current non-hazardous solid waste management practices;
• Documentation of locations (map) and descriptions of all nonhazardous waste storage, and
disposal sites;
• Records of operational history of all active and inactive disposal sites;
• State and Federal inspection reports;
• Environmental monitoring procedures or plans;
• Records of resource recovery practices, including the sale of materials for the purpose of
recycling;
• Solid waste removal contracts and inspection records;
• Operating record for onsite MSWLFs;
• Facility procedures for quantifying and classifying generation of solid wastes;
• Facility procedures for determining whether solid wastes are hazardous or nonhazardous;
• Procedures to ensure that only allowable wastes are accepted at nonhazardous waste;
treatment and disposal facilities; and
• Site plans and drawings.
G. Physical Features to Inspect
• Resource recovery facilities;
• Incineration and land disposal sites (active and inactive);
• Areas where nonhazardous waste is collected;
• Construction debris areas;
• Waste receptacles,
• Solid waste vehicle storage and washing areas;
• Compost facilities;
• Transfer stations,
• Recycling centers, and
• Solid waste collection vehicles and trailer.
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H. Guidance For Checklist Users
Refer To
Oieefelfetiferos
JPsge Numbers
All Facilities
SW 1 through SW 3
3-16
Storage/Collection of Solid Waste
SW 4 through SW.6
3-17
SW.7 through SW 11
3-18
SW.12
3-29
Recycling
SW 13 through SW 16
3-19
SW 17
3-20
Land Disposal
Specific Wastes
SW 18 through SW21
3-20
Operations
SW 22
3-20
SW 23 through SW 25
3-21
SW.26 through SW.30
3-22
SW 31 through SW 33
3-23
SW 34 through SW 36
3-24
SW. 37 through SW 39
3-25
SW 40
3-26
Closure
SW 41
3-26
Site Criteria For New Landfills Other
Than MSWLFs
SW 42 through SW 43
3-26
SW 44
3-27
Municipal Solid Waste Landfills
Location Restrictions
SW 45 through SW.46
3-27
SW 47 through SW 49
3-28
SW 50
3-29
Operating Criteria
SW 51 through SW 52
3-29
SW 53 through SW.57
2-30
SW 58 through SW 61
3-31
Groundwater Monitoring Criteria
SW.62
3-32
SW 63 through SW 64
3-33
SW.65
3-34
SW 66 through SW 67
3-35
SW.68 through SW 69
3-36
SW 71
3-37
SW 72 throught SW.73
3-38
SW 74
3-39
Closure Criteria
SW 75 through SW 78
3-40
SW 79
3-41
Post-closure Care Requirements
SW 79 through SW81
3-41
Design Criteria
SW 83 through SW 84
3-42
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Refer To
Checklist items
Fage pfyroters
Thermal Processing Facilities
SW 85 through SW 86
3-42
SW 87 through SW 89
3-43
SW 90 through SW 93
3-44
SW 94 through SW 96
3-45
SW.97
3-46
SW 98
3-47
Resource Recovery Facilities
SW 99 and SW 100
3-48
Disposal of Refuse From Outside the
SW 101
3-49
United States
Medical Waste
SW.102 through SW 103
3-49
SW 104 through SW 106
3-50
SW 107
3-51
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Compliance Category;
Noob*2ft?4o«t$ Waste Mftaagenteitl
Regulatory Requirements;
| Reviewer
All Facilities
SW 1. The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation.)
Determine if noncompliance issues have been resolved by reviewing a copy
of the previous report, Consent Orders, Compliance Agreements, NOVs,
Interagency agreements or equivalent state enforcement actions
If there are open items, document what corrective action is planned and
review progress on the plan to ensure that it is being implemented
SW 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist.
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding.)
Determine if any new regulations have been issued since the finalization of
the guide.
Determine if the facility has activities or facilities which are federally
regulated, but not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations.
SW 3 Facilities are required to
comply with state and local
solid waste regulations
concerning solid waste
management (EO 12088, Sect.
1-1)
Verify that the facility is abiding by state and local solid waste requirements
Verify that the facility is operating according to permits issued by the state or
local agencies
(NOTE: Issues typically regulated by state and local agencies include
- License or permit requirements for existing onsite landfills
- Requirements for filing a closure plan for onsite landfills specifying
monitoring and inspection procedures
- Design and operation specifications for solid waste receptacles
- Disposal of solid waste off-site only at licensed or permitted facilities
- Design and operating requirements for thermal processing of solid waste
- Characterization of ash residues and sludge from air pollution control
devices at coal-fired facility heating plant operations and waste
combustion facilities before sale or disposal
- Handling and disposal of medical, pathological, and infectious waste
- Recycling requirements
- Disposal of household wastes
- Yard waste
- Disposal of used tires, sludge, construction and demolition waste, and
other special wastes
- Prescribed burning.)
Phase 1 - Section 3
Nonhazardous Waste Management
3-16
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Compliance Category:
Noaltazardoas Waste Management
Regulatory Requirements;
| Bevie*erCfcet&
Storage/Collection of Solid Waste
SW 4 Facilities are required to
store all solid wastes and all
materials separated for
recycling according to specific
guidelines (40 CFR 243 200-1)
(NOTE Federal agencies that have decided not to adopt the requirements
contained in 40 CFR 243 are required to provide a report of the analysis and
rationale used)
Verify that all solid wastes are stored so as not cause a fire, health or safety
hazard or provide a harbor for vectors
Verify that all solid waste containing food wastes are stored in covered or
closed containers which are nonabsorbent, leakproof, durable, easily cleaned,
and designed for safe handling
Verify that waste is contained or bundled so as to not result in spillage
Verify that solid waste containers are of an adequate size and number to
contain all waste generated between collections
Verify that bulky wastes are stored so as not to create a nuisance and to
avoid the accumulation of solid waste and water in and around the bulky
items
Verify that reusable containers are capable of being serviced without the
collector coming into contact with the waste
SW 5 All facilities are
required to operate their
collection systems in a manner
to protect the health and safety
of personnel associated with the
operation (40 CFR 243 201-1)
Verify that the collection system is operated safely
SW 6 Facilities are required to
maintain collection equipment
according to certain standards if
such equipment is considered to
be operating in interstate or
foreign commerce (40 CFR
243 202-1(a))
Verify that all vehicles used by the Federal agency for the collection and
transportation of solid waste meet all applicable standards established by the
Federal Government including
- Motor Carrier Safety Standards (49 CFR Parts 390 through 396)
- Noise Emission Standards for Motor Carriers Engaged in Interstate
Commerce (40 CFR Part 202)
- Federal Motor Vehicle Safety Standards (49 CFR Parts 500 through 580)
federally owned collection equipment only)
Phase 1 - Section 3
Nonhazardous Waste Management
3-17
-------
Coatpiiaitc? Category:
Noafcazawtoos Waste Maaageateat
Reviewer Checks
SW.7. All collection equipment
is required to meet specific
criteria (40 CFR 243 202-l(b)
and 243 202-1(d))
Verify that all vehicles used for collection and transportation of solid wastes
or materials separated for recycling are enclosed or have other provisions to
prevent spillage.
Verify that equipment used in the compaction, collection, and transportation
of solid waste or materials separated for recycling are constructed, operated,
and maintained adequately
Verify that the following types of equipment meet the standards established
by the American National Standards Institute (ANSI)'
- Rear-loading compaction equipment
- Side-loading compaction equipment
- Front-loading compaction equipment
- Tilt-frame equipment
- Hoist-type equipment
- Satellite vehicles
- Special collection compaction equipment
- Stationary compaction equipment
SW.8 All facilities are
required to collect solid wastes
or materials separated for
recycling according to a certain
schedule (40 CFR 243.203-1)
Verify that solid wastes which contain food wastes are collected at a
minimum of once during each week
Verify that bulky wastes are collected at a minimum of once every 3 months
Verify that all wastes are collected with sufficient frequency to inhibit the
propagation or attraction of vectors and the creation of nuisances
SW 9 Facilities are required to
collect solid wastes in a safe,
efficient manner (40 CFR
243 204-1)
Verify that solid wastes or materials separated for recycling are collected in a
safe efficient manner
Verify that the collection vehicle operator immediately cleans up any
spillage caused by his operations
SW 10. As a management
practice, facility industrial shop
waste receptacles should be
inspected quarterly to verify
that hazardous wastes and
recyclables are not being
deposited (MP)
Verify that receptacles were inspected by reviewing records and interviewing
personnel
Verify that corrective actions were taken where indicated
Verify that hazardous waste is not present in the solid waste receptacles at
shops by a visual check
SW.ll Facility personnel
should be periodically informed
about materials that are
prohibited from disposal in
solid waste receptacles (MP).
Verify that a program exists at the facility to keep personnel informed about
proper waste disposal practices
Phase 1 - Section 3
Nonhazardous Waste Management
3-18
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Compliance Category:
Noabazardottt Waste Maaageweat
Regulatory Requirements;
Reviewer Checks:
SW 12 Solid waste storage
should meet certain design
criteria to discourage litter,
leachate discharge, and odors
Verify that waste containers are leakproof
Verify that containers are stored on a firm, level, well drained surface
Verify that single use bags containing food waste are stored within the
confines of a building or container
Verify that waste does not remain in collection vehicles for over 24 hours
Recycling
SW 13 Facilities should
participate in any state or local
recycling programs and reduce
the volume of solid waste
materials at the source
whenever practical (state and
local regulations)
Verify that a solid waste reduction program exists
Verify that records or solid waste generation, reduction, and recycling are
maintained
Verify that recycling programs are in compliance with applicable state or
local requirements
Verify that reusable or marketable materials are collected at regular intervals
SW 14 Facilities with office
facilities of over 100 office
workers are required to recover
high grade paper (40 CFR
246 200-1)
Determine if the facility has over 100 office workers
Verify that highgrade paper is separated at the source of generation
Verify that highgrade paper is separately collected
Verify that highgrade paper is sold for recycling
SW 15 Commercial facilities
should collect and recycle
newspapers (MP)
Verify that used newspapers are separated at the source of generation
Verify that used newspapers are separately collected
Verify that used newspapers are sold for recycling
SW 16 Facilities should
maximize recycling plan (MP)
Verify that facilities with less than 100 office workers recover high grade
paper; with less than 500 families on-site recovery newspapers, and that
generate less than 10 tons per month of corrugated containers have a
corrugated recycling program
Verify that the facility has performed an analysis to determine the feasibility
of recycling specific solid waste streams (e g, aluminum, plastics, glass,
etc)
Phase 1 - Section 3
Nonhazardous Waste Management
3-19
-------
Compliance Category:
Noatotttattfcttt Waste Maaagewent
Regtifetory Requirements:
Reviewer Checks:
SW 17 Facilities generating 10
tons (10,160 47 kg) or more of
waste corrugated containers per
month are required to
segregate/separately collect for
recycling or alternative energy
use (40 CFR 246 202-1)
Determine if the facility generates 10 tons (10,160 47 kg) or more of waste
corrugated containers per month
Verify that waste corrugated containers are collected separately
Verify that waste corrugated containers are recycled or used as an alternative
energy resource
Land Disposal Facilities other than a MSWLF
Specific Wastes
SW 18 Facilities will identify
what wastes can and cannot be
accepted at the disposal facility
in conjunction with the
responsible agency (40 CFR
241.200-1)
Verify that the facility has specifically identified what wastes can and cannot
be accepted for disposal at the site
SW 19. Bulky wastes should be
disposed of according to certain
methods (MP)
Verify that automobile bodies, furniture, appliances and other bulky wastes
are either salvaged or crushed
(NOTE This MP is based on recommendations found in 40 CFR 241-200-
3(b))
SW 20 Water treatment plant
sludges containing no free
moisture and digested or heat
treated wastewater treatment
plant sludges should be
disposed of according to certain
methods (MP)
Verify that water treatment plant sludges containing no free liquids and
digested or heat treated wastewater treatment plant sludges are covered with
soil or municipal solid wastes
(NOTE This MP is based on recommendations found in 40 CFR 241 200-
3(d))
SW 21 Incinerator and air
pollution control residues
should be disposed of according
to certain methods (MP)
Verify that incinerator residues contain no free moisture and are covered as
necessary to prevent them from becoming airborne
(NOTE: This MP is based on recommendations found in 40 CFR 241 200-
3(e).)
Operations
SW.22 Facilities should place
cover material on waste at the
end of each operating day (MP)
Verify that daily cover material is put in place by arriving at the site before it
opens or after it closes
(NOTE This MP is based on recommendations in 40 CFR 241 200-3(a))
Phase 1 - Section 3
Nonhazardous Waste Management
3-20
-------
Compliance Category:
Noohtzardoiw Waste MaaageaietK
Regulatory Requlremeats;
Reviewer Checks:
SW 23 Using information
from the generation sources on
the facility, the disposal site
operator and the responsible
agency are required to
determine specific wastes that
are excluded from disposal and
identify them in plans (40 CFR
241.201-1)
Verify that the disposal site has designated what wastes are excluded from
disposal at the site
Verify that the list of excluded wastes is documented in a plan
SW 24 Facilities which
operate land disposal facilities
should provide a list of
excluded materials to regular
users (MP).
Verify that a list of excluded materials is displayed prominently at the site
entrance
Verify that a list of excluded materials is given to all regular users of the site
(NOTE This MP is based on recommendations found in 40 CFR 241.201-
3)
SW 25 The location,
construction, and design of land
disposal sites are required to
meet the most stringent of
applicable water quality
standards and/or be constructed,
located, designed, and operated
in a manner to provide adequate
protection to ground and
surface waters used as drinking
water supplies (40 CFR
241 204-1).
Verify that applicable water quality standards are met and ground and
surface water used as drinking water supplies are protected
Verify that the land disposal site is linked with a clay or artificial liner and
that groundwater and surface waters are periodically monitored for
contaminants
Phase 1 - Section 3
Nonhazardous Waste Management
3-21
-------
Compliance Category;
Noot»*2*r4ott$ Waste Management
Regulatory JteqairettwatSf
1 Reviewer Checfcst
SW 26 Land disposal sites
should be operated in a manner
which will protect water quality
(MP)
Verify that surface water is diverted from the land disposal site
Verify that the land disposal site is constructed and graded to promote rapid
surface water runoff without excessive erosion
Verify that regrading is done as necessary to avoid ponding of precipitation
and to maintain cover material integrity
Verify that siltation or retention basins or other approved methods of
retarding runoff are used where necessary to avoid stream siltation or
flooding problems.
Verify that leachate collection and treatment systems are used where
necessary to protect groundwater and surface water resources
Verify that municipal solid wastes and leachate are not in contact with
groundwater or surface water
(NOTE. This MP is based on recommendations found in 40 CFR 241.204-
3.)
SW 27. Land disposal sites
should operate in a manner
which will protect air quality
(MP)
Verify that there is no open burning of municipal solid wastes.
Verify that dust control measures are initiated as necessary.
NOTE This MP is based on recommendations found in (40 CFR 241.205-
3.)
SW 28. Land disposal sites are
required to control
decomposition gases as
necessary to avoid posing a
hazard to occupants of adjacent
property (40 CFR241 206-1)
Verify that land disposal sites are controlling decomposition gases
SW 29 Land disposal sites
should control decomposition
gases according to the
following recommended
procedures (MP)
Verify that decomposition gases are not allowed to migrate laterally from the
land disposal site.
Verify that decomposition gases do not pose an explosion or toxicity hazard
(NOTE: This MP is based on recommendations found in 40 CFR 241 206-
3)
SW 30 Land disposal facilities
are required to control vectors
(40 CFR 241.207-1)
Verify that conditions are maintained that are unfavorable for the harboring,
feeding, and breeding of vectors
Phase 1 - Section 3
Nonhazardous Waste Management
3-22
-------
Compliance! Category:
NdttJtftOkrtkm Waste Maattgcaeet
Regulatory Requirements;
Reviewer Chectwt
SW 31 Land disposal facilities
are required to be designed and
operated in an aesthetically
acceptable manner (40 CFR
241 208-1).
Verify that the disposal facility is designed and operated in an aesthetically
acceptable manner.
SW 32 For the land disposal
facility to be aesthetically
acceptable, specific practices
should be followed (MP)
Verify that the facility has a litter control program
Verify that blowing litter is controlled through portable litter fences or other
devices
Verify that wastes that are easily moved by wind are covered as necessary to
prevent their becoming airborne
Verify that onsite vegetation is cleared only as necessary
Verify that natural windbreaks are maintained
Verify that buffer strips and/or berms are used to screen the site from nearby
residences and major roadways
Verify that salvage material is removed from the site frequently
(NOTE This MP is based on recommendations found in 40 CFR 208-3 )
SW 33 Land disposal facility
cover material must meet
certain criteria
(40 CFR 241 205-1)
Verify that cover material is applied as necessary to.
- Minimize fire hazards
- Minimize infiltration of precipitation
- Minimize odors
- Minimize blowing litter
- Control gas venting
- Control vectors
- Discourage scavenging
- Provide a pleasing appearance
Phase 1 - Section 3
Nonhazardous Waste Management
3-23
-------
Compliance Category:
Noatewardoas Waste Maaagemeot
Regulatory Requireineots;
Reviewer Cbecbs:
SW 34 Cover material should
be applied according to specific
recommendations (MP)
Verify that plans specify (1) cover material sources and soil classification,
(2) surface grades and sideslopes needed to promote maximum runoff, (3)
procedures to promote negative growth, and (4) procedures to maintain
cover material integrity
Verify that cover material is applied daily regardless of weather
Verify that the thickness of the compacted daily cover is no less than 6
inches (15 24 cm)
Verify that intermediate cover is applied on areas where additional cells are
not to be constructed for extended periods of time (between one week and
one year).
Verify that final cover is applied on each area as it is completed or if the area
is to remain idle for over one year
Verify that the surface grade promotes surface water runoff without erosion
to minimize infiltration
Verify that intermediate cover is at least 1 ft (0 30 m) thick and final cover is
at least 2 ft (0 61 m) thick
(NOTE This MP is based on recommendations found in 40 CFR 205-3.)
SW.35 Municipal solid waste
and cover material must be
compacted to the smallest
practicable volume (40 CFR
241.210-1).
Verify that the solid waste and cover material is compacted to the smallest
practicable volume
SW 36 Compaction of wastes
and cover materials should be
done according to
recommended procedures (MP).
Verify that on an operating day municipal solid waste handling equipment is
capable of performing the following functions
- Spread solid waste in layers no more than 2 ft (0 61 m) thick while
confining it to the smallest practicable area
- Compact the spread solid wastes to the smallest practicable volume
- Place, spread, and compact the cover material daily
Verify that procedures have been established to provide substitute
equipment, maintenance facilities, and equipment
Verify that compacting equipment is subject to a preventative maintenance
program.
(NOTE. This MP is based on recommendations found in 40 CFR 214.210-
2.)
Phase 1 - Section 3
Nonhazardous Waste Management
3-24
-------
Compliance Category:
Noafcazsa^os Wasfe Maaageaeat
Regulatory JtequJireaieatSf
Reviewer Checks:
SW 37 Land disposal facilities
are required to be designed,
constructed, and operated to
protect the health and safety of
personnel (40 CFR 241 211-1)
Verify that the health and safety of personnel are a consideration in the
design, construction and operation of the site
SW 38 Specific health and
safety procedures should be
followed in order to protect
personnel at land disposal sites
(MP)
Verify that a safety manual is available to employees.
Verify that personal safety devices such as hearing and eye protection, are
provided to facility employees
Verify that equipment is provided with safety devices
Verify that provisions to extinguish fires exist
Verify that communications equipment is available onsite
Verify that scavenging is prohibited
Verify that access to the site is controlled
Verify that traffic signs or markers are provided to promote an orderly traffic
pattern to and from the discharge area
(NOTE This MP is based on recommendations found in 40 CFR 241 211-2
and 241 211-3)
SW 39 Operators of land
disposal sites are required to
maintain records and
monitoring data to be provided,
upon request, to the responsible
agency (40 CFR 241 212)
Verify that required records are available
NOTE Recommended records and monitoring data include
- Records of major operational problems, complaints, or difficulties
- Qualitative and quantitative evaluations of the environmental impact of the
land disposal site
- Vector control efforts
- Dust and litter control efforts
- Quantitative measurements of the solid wastes handled
- Descriptions of the solid waste materials received, identified by source of
materials
- List monitoring data
Phase 1 - Section 3
Nonhazardous Waste Management
3-25
-------
Compliance Category:
NotrittttftftfotK Waste Maaageweot
Regulatory Requlrej&eots;
Reviewer Checks*
SW 40 Records being
maintained at land disposal site
should cover specific topics
(MP)
Verify that records are maintained and cover at least
- Major operational problems, complaints, or difficulties
- Results of leachate sampling and analyses
- Results of gas sampling and analyses
- Results of groundwater and surface water quality sampling and analyses
upstream and downstream of the site
- Vector control efforts
- Dust and litter control efforts
- Source and quantity of the solid wastes handled
(NOTE This MP is based on recommendations found in 40 CFR 241 212-
3(a))
Closure
SW 41 Upon closure of a site,
a detailed description should be
recorded with the area's land
recording authority (MP)
Verify that upon closure of a site a detailed description is recorded with the
area's land recording authority
(NOTE This MP is based on recommendations found in 40 CFR 241 212-
3(b))
Site Criteria For New Landfills Other than MSWLFS
SW 42 Site selection and
utilization are required to be
consistent with public health
and welfare, and air and water
quality standards and adaptable
to appropriate land-use plan (40
CFR 241 202-1)
Verify that the site and utilization are consistent with public health and
welfare and other necessary environmental standards
SW 43. New landfills should
meet certain location and design
criteria (MP)
Verify that the hydrogeology of the site has been evaluated
Verify that onsite soil characteristics have been evaluated
Verify that environmental factors, climatological conditions, and
socioeconomic factors have been considered in site selection
Verify that the site is easily accessible to vehicles
Verify that the site location will not attract birds and pose a hazard to low-
flying aircraft
(NOTE. This MP is based on recommendations found in 40 CFR 241 202-
2)
Phase 1 - Section 3
Nonhazardous Waste Management
3-26
-------
Compliance Category;
NoatjazawtotK Waste Management
Regulatory Rwjuiremeatst
Reviewer Checks;
SW 44 Plans for the design,
construction, and operation of
new sites or modifications to
existing sites are required to be
prepared or approved by a
professional engineer (40 CFR
241 203-1)
Verify that plans have been prepared or approved by a professional engineer
Municipal Solid Waste Landfills (MSWLF)
Location Restrictions
(NOTE See Appendix 3-2 for a list of MSWLFs that are exempt from meeting the standards found in 40 CFR
258, except for the standards for final cover in 40 CFR 258 60(a) See Appendix 3-1 for a list of compliance
dates for non-exempt MSWLFs )
SW 45 Facilities are subject to
limitations regarding the
location of new, existing, or
lateral expansions of MSWLFs
within 10,000 ft (3048 m) of
any airport runway end used by
turbojet aircraft or within 5000
ft (1524 m) of any airport
runway end used by only
pistontype aircraft (40 CFR
258 10(a) through 258 10(c),
and 258 16)
Verify that the facility has demonstrated that the MSWLF is designed and
operated so as to not pose a bird hazard to aircraft.
Verify that the facility has notified the Federal Aviation Administration
(FAA) and the affected airport as to presence of the MSWLF
Verify that the demonstration has been placed in the operating record and the
state Director has been notified that it has been placed in the operating
record
Verify that existing MSWLF units that cannot make this demonstration, are
closed by 9 October 1996, unless a delay is approved by the Director
SW 46. Facilities are subject to
limitations regarding the
location of new, existing, and
lateral expansions of MSWLFs
in 100 yr floodplains (40 CFR
258 11(a) and 258 16)
Verify that the facility has demonstrated that the MSWLF will not restrict the
flow of the 100 year flood, reduce the temporary water storage capacity of
the floodplain, or result in a washout of solid waste.
Verify that existing MSWLF units that cannot make this demonstration, are
closed by 9 October 1996, unless a delay is approved by the Director.
Phase 1 - Section 3
Nonhazardous Waste Management
3-27
-------
Compliance Category:
Waste Maaageweat
Regulatory K&jalremeats?
JtevfewerOtecfcK
SW.47 Facilities are required
to comply with limitations
regarding the location of new
MSWLFs and lateral
expansions in wetland (40 CFR
258 12(a)(1) through
258.12(a)(3), and 258 16)
Verify that if the facility is planning to place a MSWLF or a lateral
expansion in a wetlands, it has demonstrated to the Director that the
construction of the MSWLF will not
- Cause or contribute to violations of any applicable state water quality
standard
- Violate any applicable toxic effluent standard or prohibition
- Jeopardize the continued existence of endangered or threatened species or
result in the destruction or adverse modification of a critical protected
habitat
- Violate any requirement under the Marine Protection, Research, and
Sanctuaries Act of 1973
- Cause or contribute to significant degradation of wetlands
Verify that the facility has demonstrated the integrity of the MSWLF and its
ability to protect ecological resources by addressing the following factors
- Erosion, stability, and migration potential of native wetland soils, muds
and deposits used to support the MSWLF unit
- Erosion, stability, and migration potential of dredged and fill materials
used to support the MSWLF unit
- The volume and chemical nature of the wastes managed in the MSWLF
- Impacts on fish, wildlife, and other aquatic resources and their habitat
from release of the solid waste
- The potential effects of catastrophic release of waste to the wetland and the
resulting impacts on the environment
- Any additional factors, as necessary, to demonstrate that ecological
resources in the wetland are sufficiently protected.
SW 48 Facilities are subject to
limitations regarding the
location of new NSWLFs and
lateral expansions in fault areas
that have had displacement in
Holocene time (40 CFR
258 12(a) and 258 16)
Verify that if the facility is planning to construct a MSWLF or lateral
expansions within 200 ft (60 m) of a fault, it has demonstrated to the
Director that an alternative setback distance of less than 200 ft (60 m) will
prevent damage to the structural integrity of the MSWLF unit and will be
protective of human health and the environment
SW.49 Facilities are subject to
limitations regarding the
placement of new MSWLFs
and lateral expansions in
seismic impact zones (40 CFR
258 14(a) and 258 16)
Verify that if the facility is planning to construct a MSWLF or lateral
expansion in a seismic impact zone, it has demonstrated to the Director that
all containment structures, including liners, leachate collection systems, and
surface water control systems, are designed to resist the maximum horizontal
acceleration in lithified earth material for the site.
Verify that the demonstration has been placed in the operating record and the
state Director has been notified that it has been placed in the operating
record
Phase 1 - Section 3
Nonhazardous Waste Management
3-28
-------
Compliance Category:
Noafcazardons Waste Management
Regulatory Requirements;
Reviewer Checks:
SW 50 Facilities are subject to
limitations regarding the
location of new, existing, or
lateral expansion of MSWLFs
in unstable areas (40 CFR
258 15(a) and 258 16)
Verify that if the facility has or is planning to construct a MSWLF or lateral
expansion in an unstable area, it has demonstrated to the Director that
engineering measures have been incorporated into the MSWLF unit's design
to ensure that the integrity of the structural components will not be disrupted
Verify that the following criteria, at a minimum, are considered in judging
whether or not an area is unstable-
- Onsite or local soil conditions that may result in significant differential
settling
- Onsite or local geologic or geomorphic features
- Onsite or local human-made features or event (both surface and
subsurface)
Verify that the demonstration has been placed in the operating record and the
state Director has been notified that it has been placed in the operating
record
Verify that existing MSWLF units that cannot make this demonstration are
closed by 9 October 1996, unless a delay is approved by the Director
Operating Criteria
SW.51 MSWLFs are subject
to requirements pertaining to
procedures for excluding
hazardous wastes from the
landfills (40 CFR 258 20(a))
Verify that the MSWLF has a program for detecting and preventing the
disposal of regulated hazardous wastes, as defined in 40 CFR 261, and
Polychlonnated Biphenyls (PCB) wastes that includes the following.
- Random inspections of incoming loads, unless other steps are taken to
ensure incoming loads do not contain hazardous wastes or PCBs wastes
- Records of any inspections
- Training of facility personnel to recognize hazardous wastes and PCB
wastes
- Notification of State Director of authorized states or the EPA Regional
Administrator if a regulated hazardous waste or PCB waste is discovered
at the facility
SW 52 MSWLFs are subject
to requirements pertaining to
cover materials (40 CFR
25821)
Verify that all MSWLF units have solid waste covered with 6 in (15.24 cm)
of earthen material, or another approved material at an alternative thickness,
at the end of each operating day or more frequently, if necessary, in order to
control disease vectors, fires, odors, blowing litter, and scavenging
(NOTE. Alternative cover material and thickness must be approved by the
appropriate authority and a temporary waiver may be granted by the
appropriate authority under particular extreme climatic conditions )
Phase 1 - Section 3
Nonhazardous Waste Management
3-29
-------
Compliance Category:
Noatoaantttoos Waste Maaageiaeat
Regulatory Requirements:
Reviewer Checks:
SW.53 MSWLFs are subject
to requirements pertaining to
the control of disease vectors
(40 CFR 258 22(a)).
Verify that at the MSWLF there is prevention or control of onsite
populations of disease vectors using techniques appropriate for the protection
of human health and the environment
List examples of vector population controls
SW 54. MSWLFs are subject
to specific requirements
pertaining to the production and
monitoring of methane gases
(40 CFR 258 23(a) and
258 23(b))
Verify that at the MSWLF the concentration of methane gas generated by the
MSWLF does not exceed 25 percent of the lower explosive limit for
methane in facility structures (excluding gas control or recovery system
components)
Verify the concentration of methane gas at the MSWLF property boundary
does not exceed the lower explosive limit for methane
Verify that the MSWLF implements a routine methane monitoring program
of a type and frequency that is based on the following factors'
- Soil conditions
- Hydrogeological conditions surrounding the MSWLF
- Hydraulic conditions surrounding the MSWLF
- Locations of MSWLF structures and property boundaries
Verify that monitoring occurs quarterly at a minimum
SW 55 MSWLFs are subject
to notification criteria
pertaining to excessive methane
gas releases (40 CFR
258 23(c))
Verify that if methane gas monitoring detects levels of gas exceeding the
allowed limits, the following measures are taken.
- All necessary steps are taken to ensure protection of human health
- The Director is notified, of the protective measures
- Within seven days of detection, the level of methane gas detected and the
steps taken to protect human health is noted in the operating record
- Within 60 days of detection, a remediation plan for the methane gas
release is placed in the operating record and the Director is notified that
the plan has been implemented
(NOTE The Director of an approved state may establish alternative
schedules for demonstrating compliance with these requirements)
SW.56. MSWLFs are required
to control emissions (40 CFR
258 24)
Verify that there is no open burning of solid waste, except for the infrequent
burning of agricultural wastes, silvicultural wastes, landclearmg debris,
diseased trees, or debris from emergency cleanup
SW 57 MSWLFs are subject
to access limitations (40 CFR
258 25)
Verify that the facility controls public access to the MSWLF and prevents
unauthorized vehicular traffic and illegal dumping of wastes through the use
of artificial barriers, natural barriers, or both
Phase 1 - Section 3
Nonhazardous Waste Management
3-30
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Compliance Category:
JVoatojtftatttoos Waste Management
Regulatory Requirements:
Reviewer Checks
SW 58 MSWLFs are subject
to surface water control
requirements (40 CFR 258 27)
Verify that the MSWLF does not cause a discharge of pollutants into waters
of the United states, including wetlands, that causes noncompliance with the
CWA or NPDES requirements
(NOTE This includes discharges of a nonpoint source of pollution that
violates any approved area-wide or state-wide water quality management
plan)
SW 59 The disposal of liquids
at MSWLFs is restricted (40
CFR 258 28)
Verify that bulk or non-containerized liquid waste is not placed in MSWLF
unless.
- The waste is household waste other than septic waste
- The liquid waste is in a small container similar in size to that normally
found in household waste
- The container holding the waste is designed to hold liquids for use other
than storage
- The waste is leachate or gas condensate derived from the MSWLF (as long
as the MSWLF is designed with a composite liner and leachate collection
system).
Verify that if the waste is leachate or gas condensate derived from a MSWLF
designed with composite liner and leachate collection system, the facility
demonstrates to the Director that the MSWLF is of such a design and the
demonstration is recorded in the operating record
SW 60 MSWLFs are required
to maintain records (40 CFR
258 29(a) and 258 29(c))
Verify that the following records are retained in an operating record near the
MSWLF or at an approved alternate location
- Any location restriction demonstration
- Inspection records, training procedures, and notification procedures
- Gas monitoring results from monitoring and any remediation plans
- Any MSWLF unit design documentation for placement of leachate or gas
condensate in MSWLF
- Any demonstration, certification, finding, monitoring, testing, or related
analytical data
- Closure and post-closure care plans and any monitoring, testing, or related
analytical data
- Any information demonstrating compliance with small community
exemption
Verify that the facility notifies the Director when the above listed documents
have been placed in or added to the operating record
(NOTE The Director of an approved state can set alternative schedules for
recordkeeping and notification requirements )
SW 61 MSWLF records are
subject to inspection by certain
authorities (40 CFR 258 29(b))
Verify that all information in the operating record is furnished upon request
from the Director and is available at all times for inspection by the Director
Phase 1 - Section 3
Nonhazardous Waste Management
3-31
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Compliance Category:
Noabtttfttttotts Waste Management
Regulatory Requirements;
[ Reviewer Checks
Groundwater Monitoring Criteria
SW 62. MSWLFs are required
to comply with groundwater
monitoring schedules (40 CFR
258 50(c) and 258 50(e)).
Verily that groundwater monitoring complies with the following schedule
- Existing MSWLFs and lateral expansions less than one mile (161 km)
from a drinking water intake (surface or subsurface) must be in
compliance with these requirements by 9 October 1996
- Existing MSWLFs and lateral expansions greater than one mile (161 km)
but less than two miles (3 22 km) from a drinking water intake (surface or
subsurface) must be in compliance with these groundwater monitoring
requirements by 9 October 1995
- Existing MSWLFs and lateral expansions greater than two miles (3 22 km)
from a drinking water intake (surface or subsurface) must be in
compliance with these groundwater monitoring requirements by 9 October
1996
- New MSWLFs must be in compliance with the groundwater monitoring
requirements before waste can be place m the unit
(NOTE- The Director of an approved state may approve of alternate
schedules.)
Verify that new MSWLF units, existing MSWLF units, and lateral
expansions that dispose of less than 20 tons (18,143 69 kg) of municipal
solid waste daily, based on annual average as long as there is no evidence of
groundwater contamination from the MSWLF unit and the MSWLF unit
serves either of the following and are less than two miles (3 22 km) from a
drinking water intake (surface or subsurface) comply with groundwater
monitoring requirements by 9 October 1995*
- A community that experiences an annual interruption of at least three
consecutive months of surface transportation that prevents access to a
regional waste management facility
- A community that has no practicable waste management alternative and
the landfill is located in an areas that annually receives less than or equal
to 25 inches (62 5 cm) of precipitation.
Verify that new MSWLF units, existing MSWLF units, and lateral
expansions that dispose of less than 20 tons (18,143 69 kg) of municipal
solid waste daily, based on annual average as long as there is no evidence of
groundwater contamination from the MSWLF unit and the MSWLF unit
serves either of the following and are more than two miles (3.22 km) from a
drinking water intake (surface or subsurface) comply with groundwater
monitoring requirements by 9 October 1996
- A community that experiences an annual interruption of at least three
consecutive months of surface transportation that prevents access to a
regional waste management facility
- A community that has no practicable waste management alternative and
the landfill is located in an areas that annually receives less than or equal
to 25 inches. (62.5 cm) of precipitation
Phase 1 - Section 3
Nonhazardous Waste Management
3-32
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Compliance Category;
Waste MaBftgemetM
Regulatory Rfejulreaieats:
Reviewer Checks;
SW 63 MSWLFs that are
exempted from groundwater
monitoring are required to
document the reasons for
exemption in the operating
record and notify the State
Director if contamination does
occur (40 CFR258 1(0)
(NOTE A MSWLF exempted from groundwater monitoring is any new
MSWLF units, existing MSWLF units, and lateral expansions that dispose of
less than 20 tons (18,143 69 kg) of municipal solid waste daily, based on
annual average as long as there is no evidence of groundwater contamination
from the MSWLF unit and the MSWLF unit serves either
- A community that experiences an annual interruption of at least three
consecutive months of surface transportation that prevents access to a
regional waste management facility
- A community that has no practicable waste management alternative and
the landfill is located in an areas that annually receives less than or equal
to 25 inches of precipitation )
Verify that the operating record indicates the reason for exemption
Verify that the owner or operator of the MSWLF exempt from groundwater
monitoring notifies the State Director if they become aware of groundwater
contamination and starts a groundwater monitoring program
SW 64 Groundwater
monitoring systems at
MSWLFs are subject to
requirements (40 CFR
258 51(a), 258 51(c), and
258 51(d)(2)).
Verify that the groundwater monitoring system complies with the following
requirements
- It consists of a sufficient number of wells, installed at appropriate locations
and depths, to yield groundwater samples from the uppermost aquifer
- It represents the quality of background groundwater that has not been
affected by leakage from a MSWLF
- It represents the quality of groundwater passing the relevant point of
compliance specified by the Director or at the waste management unit
boundary
- Monitoring wells are cased in a manner that maintains the integrity of the
monitoring well bore hole
- It is certified by a qualified groundwater scientist or approved by the
Director (within 14 days of this certification, the owner or operator has
notified the Director that certification has been placed in the operating
record).
(NOTE- When physical obstacles preclude installation of groundwater
monitoring wells at the relevant point of compliance at existing units, the
downgradient monitoring system may be installed at the closest practicable
distance hydraulically downgradient from the relevant point of compliance
specified by the Director)
Phase 1 - Section 3
Nonhazardous Waste Management
3-33
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Compliance Category:
ftoaJi*2*r4oo$ Waste Maaageweaf
Regulatory Reijuirttneats;
Reviewer Checks;
SW 65 Groundwater sampling
and analysis at MSWLFs is
subject to requirements (40
CFR 258 53(a), and 258.53(c)
through 258 53(g))
Verify that groundwater monitoring sampling and analysis procedures are
designed to ensure monitoring results provide an accurate representation of
groundwater quality at the background and downgradient well
Verify that the sampling procedures and frequency are protective of human
health and the environment
Verify that groundwater elevations are measured in each well immediately
prior to purging, and that the facility has determined the rate and direction of
groundwater flow each time groundwater is sampled
Verify that groundwater elevations in wells which monitor the same waste
management area are measured within a period of time short enough to avoid
temporal variation in groundwater flow that could preclude accurate
determination of groundwater flow rate and direction
Verify that the facility has established a background groundwater quality in a
hydraulically upgradient or background well for each of the monitoring
parameters or constituents required by its monitoring program
Verify that the number of samples collected to establish groundwater quality
data is consistent with the approved statistical procedures
Verify that the facility specifies in the operating plan one of the following
statistical methods to be used in evaluating groundwater monitoring data for
each hazardous constituent.
- An analysis of variance
- A tolerance or prediction interval procedure
- A control chart approach
- An equivalent statistical test method.
Phase 1 - Section 3
Nonhazardous Waste Management
3-34
-------
Compliance Category:
Noah*Z)»r4otts Waste Management , ^
Regulatory B^ulremeats;
Reviewer Checks
SW 66 Detection monitoring
at MSWLFs is subject to
specific requirements (40 CFR
258 54(a) and 258 54(b))
Verify that, at a minimum, a detection monitoring program includes the
constituents listed in Appendix 3-3
Verify that monitoring occurs at least semiannually during the active life of
the MSWLF (including closure) and during the post-closure period
Verify that a minimum of four independent samples (from each well
background and downgradient) are collected and analyzed for the
constituents listed in Appendix 3-3 during the first semiannual sampling
event.
Verify that at least one sample (from each well background and
downgradient) is collected and analyzed during subsequent semiannual
sampling events
(NOTE The Director of an approved state may delete some constituents and
establish an alternate test)
SW 67 MSWLFs are subject
to requirements pertaining to
the detection of groundwater
contamination (40 CFR
258 54(c))
Verify that in the event that there is a statistically significant increase over
background for one or more of the constituents listed in Appendix 3-3, the
following steps are taken
- Within 14 days of the finding, the facility places a notice in the operating
record indicating which constituents have shown statistically significant
changes from background levels
- The Director is notified that the finding has been placed in the operating
record
- Within 90 days an assessment monitoring program is established
(NOTE The facility may demonstrate that a source other than the MSWLF
caused the contamination or that the statistically significant increase resulted
from error in sampling, analysis, statistical evaluation, or natural variation in
groundwater quality This demonstration report must be certified by a
qualified groundwater scientist or approved by the Director and be placed in
the operating record)
Phase 1 - Section 3
Nonhazardous Waste Management
3-35
-------
Compliance Category:
Waste Maaagemeat
Regulatory Requirements;
Reviewer Checks:
SW 68 MSWLFs are subject
to requirements pertaining to
assessment monitoring
programs (40 CFR 258.55(a)
through 258 55(c))
Verify that an assessment monitoring program is established whenever a
statistically significant increase over background has been detected for one
or more of the constituents listed in Appendix 3-3.
Verify that within 90 days of establishing an assessment monitoring
program, and annually thereafter, the facility samples and analyzes the
groundwater for all constituents identified in Appendix 3-4.
Verify that a minimum of one sample from each downgradient well is
collected and analyzed during each sampling event
Verify that for any constituent detected in the downgradient wells as a result
of the complete Appendix 3-4 analysis, a minimum of four independent
samples (from each well background and downgradient) is collected and
analyzed to establish background for the constituents
(NOTE: The Director of an approved state may specify an appropriate
alternate frequency for repeated sampling and analysis for the full set of
constituents during the active life (including closure) and post closure care of
the unit.)
SW 69. MSWLFs are subject
to notification requirements
pertaining to assessment
monitoring (40 CFR 258.55(d)
and 258 55(e))
Verify that after obtaining the results from the initial or subsequent sampling
events required, the following steps are taken
- Within 14 days a notice is placed in the operating record identifying the
Appendix 3-4 constituents that have been detected
- The Director is notified that the notice has been placed in the record
- Within 90 days, and on at least a semiannual basis thereafter, the
background and downgradient monitoring wells are resampled and
analyses conducted for all constituents in Appendix 3-3 and for those
constituents in Appendix 3-4 that are detected in the assessment
monitoring program
- The results of these analyses are placed in the operating record
- At least one sample (from each well background and downgradient) is
collected and analyzed during these sampling events.
(NOTE The Director of an approved state may specify an alternate
monitoring frequency)
Verify that if the concentrations of all Appendix 3-4 constituents are shown
to be at or below background values, using an approved statistical procedure,
for two consecutive sampling events, the facility notifies the Director of the
finding and returns to detection monitoring
Phase 1 - Section 3
Nonhazardous Waste Management
3-36
-------
Compliance Category:
Nonhazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
SW 70 MSWLFs are subject
to notification requirements
pertaining to noncompliance
with the groundwater protection
standard (40 CFR 258 55(g))
Verify that if during detection monitoring one or more Appendix 3-4
constituents are detected at statistically significant levels above the
groundwater protection standards specified according to the following, the
Director and all appropriate local government officials are notified and a
notice is placed in the operating record
- For constituents that have a Maximum Contamination Level (MCL) listed
in the Safe Drinking Water Act (SDWA), use the MCL for that constituent
- For constituents that are not included in the SDWA, use the background
level established for that constituent in the detection monitoring program
- For constituents for which the background level is higher than the MCL
identified in the SWDA, use the background concentration
Verify that the facility also takes the following steps
- The nature and extent of the release is investigated by the installation of
additional monitoring wells
- At least one additional monitoring well is installed at the MSWLF
boundary in the direction of contamination migration
- Notification of all persons who own land or reside on land that directly
overlies any part of the plume of contamination that has migrated offsite
- Initiation of an assessment of corrective measures within 90 days
(MOTE The facility may demonstrate that a source other than the MSWLF
caused the contamination or that the statistically significant increase resulted
from error in sampling, analysis, statistical evaluation, or natural variation in
groundwater quality This demonstration report must be certified by a
qualified groundwater scientist or approved by the Director and be placed in
the operating record.)
SW71 MSWLFs are subject
to criteria for assessing
potential groundwater
remediation actions (40 CFR
258 56)
Verify that within 90 days of finding Appendix 3-4 constituents at significant
levels exceeding the groundwater protection standards, an assessment of
potential remedial actions is made and includes the following
- Analysis of effectiveness of potential corrective measures in meeting all
the requirements and objectives of the remedy, such as
- the performance, reliability, ease of implementation, and potential
impacts of potential remedies
-- the time required to begin and complete the remedy
— the cost of the remedy implementation
-- State and local requirements affecting remediation
- Discussion of corrective measures with the public or interested parties
Phase 1 - Section 3
Nonhazardous Waste Management
3-37
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Compliance Category:
JVoefcistmttotks Waste Management
Regulatory Btequircttt
-------
Compliance Category;
Ndafc)i2a«fcB$ Waste M»a«gta«B4
Regulatory RequJrcnwats:
Reviewer Checksi
SW 74 Facilities are required
to implement corrective action
programs according to specific
parameters (40 CFR 258 58(a)
through 258 58(d)).
Verify that, based on the established schedule for initiation and completion
of activities, the facility
• Establishes and implements a corrective action groundwater monitoring
program that:
- at a minimum meets the assessment monitoring requirements of 40
CFR 258.55 (see checklist items SW.68 through SW 70)
-- indicates the effectiveness of the selected corrective action remedy
-- demonstrates compliance with groundwater protection standards
- Implements to selected corrective action program
- Takes any interim measure necessary to ensure the protection of human
health and the environment.
Verify that if the facility determines that compliance is not being achieved
with the selected remedy, it selects another method or technique that can
practicably achieve compliance
Verify that if compliance cannot be practicably achieved with currently
available methods, the facility.
- Obtains certification of a qualified groundwater scientist or approval of a
Director of an approved state substantiating this claim
- Implements alternate measures to control exposure of humans or the
environment to residual contamination as necessary to protect human
health and the environment
- Implements alternate measures for control of the sources of contamination,
or for removal of decontamination of equipment, units, devices, or
structures that are:
~ technically practicable
- consistent with the overall objective of the remedy
- Notifies the State Director within 14 days that a report justifying the
alternative measures prior to implementation has been placed in the
operating record
Verify that all solid wastes managed in relation to a remedy or an interim
measure are managed as follows.
- In a manner that is protective of human health and the environment
- In a manner that complies with applicable RCRA requirements
Phase 1 - Section 3
Nonhazardous Waste Management
3-39
-------
Compliant Cafegury;
NdttbatAKEottt Waste Maaageateai
Regulatory JteplrenHMtte:
[ Reviewer Ctocfett
Closure Criteria
SW.75. MSWLFs are subject
to specific final cover design
requirements (40 CFR
258.60(a) and 258 60(b))
Determine if the facility has plans to close a MSWLF
Verify that the final cover is designed to minimize infiltration and erosion
according to the following criteria
- It has a permeability less than or equal to the permeability of any bottom
liner system or natural subsoils present, or a permeability no greater then 1
x 10"4 cm/sec, whichever is less
- It minimizes infiltrations through the closed MSWLF by use of an
infiltration layer that contains a minimum 18 inches (45 cm) of earthen
material
- It minimizes erosion of the final cover by the use of an erosion layer that
contains a minimum 6 inches (15 cm) of earthen material that is capable of
sustaining native plant growth
(NOTE: The Director of an approved state may approve alternate final cover
design)
SW 76 MSWLFs are subject
to specific closure plan
requirements (40 CFR
258 60(c)).
Verify that the facility has prepared a written closure plan that includes the
following information.
- A description of the final cover and methods and procedures to be used to
install the cover
- An estimate of the largest area of the MSWLF unit ever requiring a final
cover any time during its active life
- An estimate of the maximum inventory of wastes ever onsite over its
active life
- A schedule for completing all activities necessary to satisfy closure
requirements
SW 77 MSWLFs are subject
to specific closure notification
requirements (40 CFR
258 60(d))
Verify that the facility has notified the Director of the intent to close the
MSWLF.
Verify that the notice of intent to close has been placed in the operating
record
SW 78 MSWLFs are subject
to specific closure criteria (40
CFR 258 60(f) and 258.60(g)).
Verify that the facility begins closure activities no later than 30 days after the
date the MSWLF receives the final receipt of waste, or no later than one year
after the most recent receipt of waste if the unit has remaining capacity
Verify that the facility completes closure activities of each MSWLF unit
within 180 days following the beginning of closure.
Phase 1 - Section 3
Nonhazardous Waste Management
3-40
-------
Compliance Category:
Noataazardoas Waste Management
Regulatory RwjuirettKMts:
Jtevtewer Checkst
SW 79 MSWLFs are subject
to specific post-closure
notification requirements (40
CFR 258 60(h))
Verify that the facility notifies the Director that a certification signed by an
independent registered professional engineer has been completed and placed
in the operating record
Verify that the facility records a notation on the deed to the landfill facility
property, (or equivalent instrument examined in a title search), that the
property has been used as a landfill, and its use is restricted
Verify that the notation is placed in the operating record, and the Director is
notified of its placement
Post-Closure Care Requirements
SW 80 MSWLFs are subject
to specific post-closure care
requirements (40 CFR
258 61(a))
Verify that the facility conducts post-closure care of its MSWLF in the
following manner for 30 years
- Maintains the integrity and effectiveness of any final cover, including
making repairs to the cover as necessary to correct the effects of
settlement, subsidence, erosion, or other events, and to prevent runon and
runoff from eroding or otherwise damaging the final cover
- Maintains and operates the leachate collection system
- Monitors the groundwater and maintains the groundwater monitoring
system
- Maintains and operates the gas monitoring system
SW81 MSWLFs are subject
to specific post-closure plan
criteria (40 CFR 258 61(c) and
258 61(d)).
Verify that the facility has prepared a post-closure plan that includes the
following information
- A description of the monitoring and maintenance activities
- The name, address, and telephone number of the person or office to
contact about the facility during the post-closure period
- A description of the planned uses of the property during the post-closure
period
Verify that the post-closure plan has been placed in the operating record and
the Director has been notified of its placement
SW 82 MSWLFs are subject
to specific post-closure
certification requirements (40
CFR 258 61(e))
Verify that following completion of the post-closure care period, a
certification signed by an independent registered professional engineer is
completed, placed in the operating record, and the Director is notified of its
placement
Design Criteria
Phase 1 - Section 3
Nonhazardous Waste Management
3-41
-------
Compliance Category;
Noafcjmttkm Waste Maaageweet . \
Regulatory Rfequircmeatst
Jtevlewer Checks
SW 83 New MSWLFs and
lateral expansions are required
to meet specific design criteria
(40 CFR 258 40(a))
Verify that the MSWLF is of an approved design that ensures that the
concentration values listed in Appendix 3-5 are not exceeded in the
uppermost aquifer at the relevant point of compliance
Verify that the MSWLF has a composite liner and a leachate collection
system that is designed and constructed to maintain less than a 30 cm depth
of leachate over the liner
SW 84 Runon/runoff control
systems at MSWLFs are
required to meet specific design
requirements (40 CFR 258 26)
Verify that the runon control system is designed and maintained to prevent
flow onto the active portion of the landfill during the peak discharge from a
25 year storm.
Verify that the runoff control system from the active portion of the landfill is
designed and maintained to collect and control at least the water volume
resulting from a 24 hour, 25 year storm
Verify the runoff does not cause a discharge of pollutants into waters of the
United States, including wetlands, that causes noncompliance with the CWA
or NPDES requirements
Thermal Processing Facilities
SW.85. Facilities with thermal
processing facilities designed to
process or are processing 50
tons (45,359 24 kg) or more per
day of municipal solid wastes
are required to provide special
areas for special wastes while
they await processing (40 CFR
240 100(a), 240 200-2(b),
240 200-3(a))
Verify that storage areas for bulky wastes, digested and dewatered sludges
from waste water treatment facilities, raw sewage sludges, and septic tank
pumpings are clearly marked
(NOTE, This does not apply to hazardous, agricultural, or mining wastes)
SW 86 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359.24 kg) or more
per day of municipal solid
wastes are required to train
personnel in any unusual
handling required by
acceptance of special wastes
(40 CFR 240 100(a),
240 200-3(b))
Verify that personnel are thoroughly trained to handle bulky wastes, digested
and dewatered sludges from waste water treatment facilities, raw sewage
sludges, and septic tank pumpings
(NOTE This does not apply to hazardous, agricultural, or mining wastes )
Phase 1 - Section 3
Nonhazardous Waste Management
3-42
-------
Compliance Category:
Noafcazardoos Waste Maaagfemeat
Regulatory Requirements;
Reviewer Cheetts!
SW 87 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to inform
regular users about materials
which are excluded (40 CFR
240 100(a), 240 201-3(a))
Verify that regular users are given a list of excluded materials
Verify that a list of excluded materials is posted prominently at the thermal
processing facility
(NOTE: This does not apply to hazardous, agricultural, or mining wastes)
SW 88 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to have
certain procedures and
precautions to deal with
unacceptable wastes which are
delivered to or left at the facility
(40 CFR 240 100(a),
240 201-3(b))
Verify that there is an operating plan which specifies procedures and
precautions to be taken if unacceptable wastes are delivered to or left at the
thermal processing facility
Verify that operating personnel are thoroughly trained in such procedures
(NOTE This does not apply to hazardous, agricultural, or mining wastes)
SW 89 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to meet
certain site selection criteria (40
CFR 240 100(a), 240 202(a),
240 202(b))
Verify that the thermal processing facility is located in an area zoned for
industrial use and has adequate utilities to serve it
Verify that the site is accessible by permanent roads leading from the public
road system
(NOTE This does not apply to hazardous, agricultural, or mining wastes)
Phase 1 - Section 3
Nonhazardous Waste Management
3-43
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Compliance Category:
Noahazardous Waste Management
Regulatory Requiretneats;
Reviewer Checfci:
SW.90 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to have
plans for the design of new
facilities or modifications to
existing facilities prepared or
approved by a professional
engineer (40 CFR 240 100(a),
240 203-1)
Verify that plans for the design of new thermal processing facilities or
modifications to existing thermal processing facilities are prepared or
approved by a professional engineer
Verify that the plan has been approved by the responsible regulatory
authorities and that construction was not initiated until approval was
received
(NOTE This does not apply to hazardous, agricultural, or mining wastes )
SW 91 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to operate in
a manner which will protect
water quality (40 CFR
240 100(a), and 240 204)
Verify that all waters discharged from the thermal processing facility are
treated to meet the most stringent of applicable water quality standards.
Verify that when monitoring instrumentation indicates excessive discharge
contamination, appropriate adjustments are made to lower the concentrations
to acceptable levels
Verify that in the event of an accidental spill, the local regulatory agency is
notified immediately
(NOTE' This does not apply to hazardous, agricultural, or mining wastes)
SW 92 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to operate in
a manner which protect air
quality (40 CFR 240 100(a) and
240 205)
Verify that emissions do not exceed applicable existing emission standards
Verify that all emissions, including dust from vents, are controlled
Verify that when monitoring instrumentation indicates excessive emissions,
appropriate adjustments are made to lower the emission to acceptable levels
(NOTE This does not apply to hazardous, agricultural, or mining wastes.)
SW 93. Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to control
vectors (40 CFR 240 100(a) and
240 206)
Verify that a housekeeping schedule is established and maintained
Verify that solid wastes and residues do not accumulate at the thermal
processing facility for more than one week
(NOTE This does not apply to hazardous, agricultural, or mining wastes)
Phase 1 - Section 3
Nonhazardous Waste Management
3-44
-------
Compliance Category:
Noabazardons Waste Management
Regulator)' Requirements;
Reviewer Cheeks:
SW 94 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to operate in
an aesthetically acceptable
manner (40 CFR 240 100(a)
and 240 207)
Verify that a routine housekeeping and litter removal schedule is established
and implemented
Verify that solid wastes which cannot be processed by the thermal
processing facility are removed on a weekly basis
(NOTE This does not apply to hazardous, agricultural, or mining wastes )
SW 95 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to dispose
of residue and other solid waste
products resulting from the
thermal process in an
environmentally acceptable
manner (40 CFR 240 100(a)
and 240 208)
Verify that the furnace operator records the estimated percentage of
unburned combustibles in a log
Verify that if residue or fly ash is collected in a wet condition it is drained of
free moisture
Verify that residue and fly ash are transported by means that prevent the
loads from shifting, falling, or blowing from the container
(NOTE This does not apply to hazardous, agricultural, or mining wastes)
SW 96 Facilities with thermal
processing facilities designed to
process or which are processing
50 tons (45,359 24 kg) or more
per day of municipal solid
wastes are required to be
designed, operated, and
maintained in a manner to
protect the health and safety of
personnel (40 CFR 240 100(a)
and 240 209)
Verify that procedures are developed for operation in emergency situations
Verify that approved respirators or self-contained breathing apparatus is
available at convenient locations
Verify that training in first aid practices and emergency procedures is given
to all personnel
Verify that personal safety devices are provided to all personnel
Verify that any regular user or employee that poses a safety hazard is barred
from the thermal processing facility and reported to the responsible agency
(NOTE This does not apply to hazardous, agricultural, or mining wastes )
Phase 1 - Section 3
Nonhazardous Waste Management
3-45
-------
Compliance Category:
N0Btii2iu-
-------
Compliance Category:
lVoab*2ar
-------
Compliance Categ«ry;,
Noabmi'doas Waste Maaageweat
Regulatory Requiraneats:
: Reviewer Chedtfc
SW 98 .(continued)
Verify that an annual report is prepared and it includes the following
information.
- Minimum, average, and maximum daily volume and weight of waste
received and processed, summarized on a monthly basis
- A summary of the laboratory analyses including at least monthly averages
- Number and qualifications of personnel in each job category
- Total man hours per week
- Number of state certified or licensed personnel
- Staffing deficiencies
- Serious injuries, their cause, and preventive measures instituted
- An identification and brief discussion of major operational problems and
solutions
- Adequacy of operation and performance with regard to environmental
requirements, the general level of housekeeping and maintenance, testing
and reporting proficiency, and recommendations for corrective actions
- A copy of all significant correspondence, reports, inspection reports, and
any other communications from enforcement agencies
Verify that a methodology for evaluating the thermal processing facility's
performance has been developed
(NOTE: This does not apply to hazardous, agricultural, or mining wastes )
Resource Recovery Facilities
SW 99 Facilities are required
to establish or utilize resource
recovery facilities (40 CFR
245 200-1).
Verify that a resource recovery facility has been established or utilized
unless the facility has made a determination not to utilize or establish a
resource recovery facility
(NOTE Federal agencies that make the determination not to establish or
utilize a resource recovery facility must make a report to the Administrator
fully explaining that determination )
SW.100 Facilities which
establish or utilize a resource
recovery facility are required to
design such facilities to process
a standard amount of solid
waste (40 CFR 245 200-1(e))
Verify that the resource recovery facility is designed to process at least 65
percent by wet weight of the input solid waste into recycled material, fuel, or
energy.
Disposal of Refuse from Outside the United States
Phase 1 - Section 3
Nonhazardous Waste Management
3-48
-------
Compliance Category:
Noattastardoos Waste Maaagement
Regulatory Requirements;
Reviewer Checks;
SW 101 Garbage from outside
the United States which is on or
unloaded from vessels or
aircraft arriving in the United
States and certain territories and
possessions is subject to
inspection and disposal
requirements to prevent
dissemination of pests and
diseases (7 CFR 330 400(d) and
330 400(g)( 1 ) and
300 400(g)(2))
Verify that garbage on or unloaded from vessels or aircraft arriving in the
places listed below complies with inspection and disposal requirements
- The United States from any place outside of the United States
- The continental United States from Hawaii or any territory or possession
- Any territory or possession from any other territory or possession or
Hawaii
- Hawaii from any territory or possession
Verify that in arriving vessels and aircraft
- The garbage is contained in tight leakproof covered receptacles inside
guard rails on vessels
- The garbage is removed in tight, leakproof covered containers under
direction of U S Department of Agriculture (USDA) inspector to an
approved facility for incineration, sterilization, or grinding into an
approved sewage system, or
- The garbage is removed for other handling and under supervision
approved by the USDA
Verify that the facility has received approval from Administrator, Animal
and Plant Health Inspection Service, USDA for use of sewage system for
disposal.
Medical Waste
SW 102 Contaminated
reusable sharps are required to
be placed in containers which
meet specific requirements as
soon as possible after use until
properly reprocessed (29 CFR
1910 1030d)(2)(vin) and
1910 1030(d)(4)(n)(E))
Verify that contaminated reusable sharps are placed in containers that are
- Puncture resistant
- Labeled or color coded
- Leakproof on the sides and bottom
Verify that reusable sharps that are contaminated with blood or other
potentially infectious materials are not stored or processed in a manner that
requires employees to reach by hand into the containers
SW 103 Specimens of blood
or other potentially infectious
material are required to be
placed in a container that
prevents leakage during
collection, handling,
processing, storage, transport,
or shipping and specific
labeling and handling
requirements followed (29 CFR
1910 I030(d)(2)(xm))
Verify that containers are
- Labeled and color coded
- Closed prior to being stored, transported or shipped
(NOTE When the facility utilizes Universal Precautions in the handling of
all specimens, the labeling/color coding of specimens is not necessary if the
containers are recognizable as containing specimens)
Verify that if outside contamination of the primary container occurs it is
placed in a second container
Verify that if the specimens could puncture the primary container, the
primary container is placed in a secondary container which is puncture
resistant.
Phase 1 - Section 3
Nonhazardous Waste Management
3-49
-------
Compliance Category:
Waste Maaagewtot
Regulatory Rfeptenwaita;
Iteviewer Check#
SW 104 Contaminated sharps
are to be discarded immediately
in containers meeting specific
requirements (29 CFR
1910 1030d)(4)(iii)(A))
Verify that contaminated sharps are placed in containers that are
- Closable
- Puncture resistant
- Leakproof on sides and bottoms
- Labeled or color-coded
Verify that during use, containers for contaminated sharps are.
- Easily accessible
- Maintained upright throughout use
- Replaced routinely and not be allowed to overfill.
Verify that when the containers of contaminated sharps are being moved
from the area of use, the containers.
- Are closed
- Placed in a secondary container if leakage is possible
Verify that reusable containers are not opened, emptied, or cleaned manually
or handled in any other manner that would expose employees to risk.
SW 105 Regulated wastes (see
definitions) are required to be
handled and placed in
containers that meet specific
standards (29 CFR
1910.1030(dX4)(inXB))
Verify that regulated wastes are placed in containers that are
- Closable
- Constructed to contain all contents and prevent leakage of fluids
- Labeled or color-coded
- Closed prior to removal
(NOTE Regulated wastes which have been decontaminated need not be
labeled or color-coded)
Verify that if outside contamination of the regulated waste occurs, it is
placed in a second container
SW 106 All bins, pails, cans,
and similar receptacles intended
for reuse, that have the
likelihood of becoming
contaminated with blood or
other potentially infectious
materials are required to be
inspected and decontaminated
on a regularly scheduled basis
(29 CFR
1910.1030d)(4)(n)(C))
Verify that receptacles with the potential for contamination are regularly
inspected and decontaminated.
Phase 1 - Section 3
Nonhazardous Waste Management
3-50
-------
Compliance Category:
NoBfcazitfdotK Waste Maaageweot
Regulatory Requirements;
Reviewer Checks:
SW 107 Labels affixed to
containers of regulated wastes,
refrigerators and freezers
containing blood or other
potentially infectious materials,
and other containers used to
store, transport, or ship blood or
other potentially infectious
materials must meet specific
standards (29 CFR
1910 1030(g)(1)(i))
Verify that the labels
- Include the biohazard symbol
- Are fluorescent orange or orange-red or predominantly so, with lettering
and symbols in contrasting color
- Are affixed as closely as possible to the container to prevent loss or
removal
(NOTE Red bags or containers may be used as a substitute for labels)
(NOTE The following are exempt from labeling requirements
- Containers of blood, blood components, or blood products that are labeled
as to their contents and have been released for transfusion or other clinical
use
- Individual containers of blood or other potentially infectious materials that
is placed in a labeled container during storage, transport, shipment, or
disposal.)
(NOTE Regulated waste that has been decontaminated need not be labeled
and color-coded)
Phase 1 - Section 3
Nonhazardous Waste Management
3-51
-------
Section 3
Nonhazardous Waste Management
Appendices
-------
Appendix 3-1
Compliance Dates for MSWLFs and 40 CFR 258
(40 CFR 258.1(e))
In general, compliance with 40 CFR 258 was required by 9 October 1993. The following is a list
of MSWLFs which have had their compliance deadline with 40 CFR 258 extended.
1. 9 April 1994 for existing MSWLF units or a lateral expansion of an existing MSWLF that
meets the following conditions:
a. The MSWLF unit disposed of 100 tons per day or less of solid waste during a
representative period prior to 9 October 1993;
b. The unit does not dispose of more than an average of 100 TPD of solid waste each
month between 9 October 1993 and 9 April 1994;
c The MSWLF is located in a state that has submitted an application for permit program
approved by the USEPA by 9 October 1993, is located in the state of Iowa, or is located
on Indian Lands or Indian Country, and
d. The MSWLF is not on the National Priorities List (NPL).
2. The compliance date has been extended for existing MSWLF unit or lateral expansion if an
existing MSWLF units receiving flood-related waste from the federally-designated areas
within the major disasters declared for the states of Iowa, Illinois, Minnesota, Wisconsin,
Missouri, Nebraska, Kansas, North Dakota, and South Dakota by the President during the
summer of 1993:
a. Until 9 April 1994 if the state in which the MSWLF is located has determined that the
MSWLF unit is needed to receive flood-related wastes from a federally designated
disaster area.
b. Until 9 October 1994 if the state in which the MSWLF is located has determined that
the MSWLF unit is needed to receive flood-related wastes from a federally designated
disaster area.
3. 9 October 1995 for new MSWLF units, existing MSWLF units, and lateral expansions that
dispose of less than 20 tons of municipal solid waste daily, based on an annual average.
A3-1
-------
Appendix 3-2
MSWLF Units Exempt From Compliance With 40 CFR 258
(40 CFR 258.1(c) and 258.1(d))
1. MSWLFs that did not receive waste after 9 October 1991
2. Existing MSWLF units or a lateral expansion of an existing MSWLF that received waste
after 9 October 1991 but stop receiving waste before 9 April 1994 that meet the following
conditions:
a. The MSWLF unit disposed of 100 tons per day or less of solid waste during a
representative period prior to 9 October 1993;
b. The unit does not dispose of more than an average of 100 TPD of solid waste each
month between 9 October 1993 and 9 April 1994;
c. The MSWLF is located in a state that has submitted an application for permit program
approved by the USEPA by 9 October 1993, is located in the state of Iowa, or is located
on Indian Lands or Indian Country; and
d. The MSWLF is not on the National Priorities List (NPL).
(NOTE: If these units have not installed a final cover according to the standards in 40 CFR
258.60(a) by 9 October 1994, the unit is required to meet all the requirements found in 40 CFR
258.)
3. Existing MSWLF units or lateral expansions if an existing MSWLF unit is receiving flood-
related waste from the federally-designated areas within the major disasters declared for the
states of Iowa, Illinois, Minnesota, Wisconsin, Missouri, Nebraska, Kansas, North Dakota,
and South Dakota by the President during the summer of 1993 and receive waste after 9
October 1991 but stops receiving waste before the date designated by the state
(NOTE: If these units have not installed a final cover according to the standards in 40 CFR
258.60(a) within one year of the date designated by the state, the unit is required to meet all the
requirements in 40 CFR 258.)
4. New MSWLF units, existing MSWLF units and lateral expansions that dispose of less than
20 tons of municipal solid waste daily, based on an annual average that receive waste after 9
October 1991 but stopped receiving waste before 9 October 1995.
(NOTE: If these units have not installed a final cover according to the standards in 40 CFR
258.60(a) by 9 October 1996, the unit is required to meet all the requirements of 40 CFR 258.)
5. MSWLF units that receive waste after 9 October 1991 but stop receiving wastes before 9
October 1993.
(NOTE: If these units have not installed a final cover according to the standards in 40 CFR
258.60(a) by 9 October 1994, the unit is required to meet all the requirements of 40 CFR 258.)
A3-2
-------
Appendix 3-3
Constituents for Detection Monitoring1
(40 CFR 258, Appendix I)
Common Name1
CAS RNl
Inorganic Constituents
(1) Antimony
(Total)
(2) Arsenic
(Total)
(3) Barium
(Total)
(4) Beryllium
(Total)
(5) Cadmium
(Total)
(6) Chromium
(Total)
(7) Cobalt
(Total)
(8) Copper
(Total)
(9) Lead
(Total)
(10) Nickel
(Total)
(11) Selenium
(Total)
(12) Silver
(Total)
(13) Thallium
(Total)
(14) Vanadium
(Total)
(15) Zinc
(Total)
Organic Constituents
(16) Acetone
67-64-4
(17) Acrylonitrile
107-13-1
(18) Benzene
71-43-1
(19) Bromochloromethane
74-97-5
(20) Bromodichloromethane
75-27-4
(21) Bromoform, Tribromomethane
75-25-2
(22) Carbon disulfide
75-15-0
(23) Carbon tetrachloride
56-23-5
(24) Chlorobenzene
108-90-7
(25) Chloroethane, Ethyl chloride
75-00-3
(26) Chloroform, Tnchloromethane
67-66-3
A3-3
-------
Appendix 3-3 (continued)
Constituents for Detection Monitoringl
(40 CFR 258, Appendix I)
Common Name1
CAS RN3
(27) Dibromochloromethane, Chlorodibromomethane
124-48-1
(28) l;2-Dibromo-3-chlorpropane, DBCP
96-12-8
(29) 1,2-Dibromoethane; Ethylene dibromide;
106-93-4
EDB
(30) o-Dichlorobenzene, 1,2-Dichlorobenzene
95-50-1
(31) p-Dichlorobenzene, 1,4-Dichlorobenzene
106-46-7
(32) trans-1,4-Dichloro-2-butene
110-57-6
(33) 1,1-Dichloroethane, Ethyhdene chloride
75-34-3
(34) 1,2-Dichloroethane; Ethlyene dichloride
107-06-2
(35) 1,1-Dichloroethylene; 1-1-Dichloroethene;
Vinylidene chloride
75-35-4
(36) cis-1,2-Dichloroethylene; cis-l,2-Dichloroethene
156-59-2
(37) trans- 1,2-Dichloroethylene; trans-1,2-
Dichloroethene
156-60-5
(38) 1,2-Dichlorpropane, Propylene dichlonde
78-87-5
(39) cis-l,3-Dichlorpropene
10061-01-5
(40) trans-1,3-Dichlorpropene
10061-02-6
(41) Ethylbenzene
100-41-4
(42) 2-hexanone; Methyl butyl ketone
591-78-6
(43) Methyl bromide; Bromomethane
74-83-9
(44) Methyl chloride, Chloromethane
74-87-3
(45) Methylene bromide Dibromomethane
74-95-3
(46) Methylene chloride; Dichloromethane
75-09-2
(47) Methyl ethyl ketone; MEK, 2-Butanone
74-93-3
(48) Methyl iodide, Iodomethane
74-88-4
(49) 4-Methyl-2-pentanone; Methyl isobutyl isobutyl
ketone
108-10-1
(50) Styrene
100-42-5
(51) 1,1,1,2-TetrachIoroethane
630-20-6
(52) 1,1,2,2-Tetrachloroethane
79-34-5
A3-4
-------
Appendix 3-3 (continued)
Constituents for Detection Monitoringl
(40 CFR 258, Appendix I)
Common Name2
CAS RN5
(53) Tetrachloroethylene, Tetracholorethene,
Perchloroethylene
127-18-4
(54) Toluene
108-88-3
(55) 1,1,1-Trochlorethane, Methylchloroform
71-55-6
(56) 1,1,2-Tnchloroethane
79-00-5
(57) Tnchloroethylene; Tnchlorethene
79-01-6
(58) Trichlorofluoromethane; CFC-11
75-69-4
(59) 1,2,3-TnchIoropropane
96-18-4
(60) Vinyl acetate
108-05-4
(61) Vinyl chloride
75-01-4
(62) Xylenes
1330-20-7
1 This list contains 47 volatile organics for which possible analytical procedures provided in USEPA Report SW-846
"Test Methods for Evaluating Solid Waste," third edition, November 1986, as revised December 1987, includes
Method 8260, and 15 metals for which SW-846 provides either Method 6010 or a method from the 7000 series of
methods
2 Common names are those widely used in government regulations, scientific publications, and commerce,
synonyms exist for many chemicals.
3 Chemical Abstracts Service registry number Where "Total" is entered, all species in the groundwater that contain
this element are included
A3-5
-------
Appendix 3-4
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CASRN
Suggested Methods
PQL (mg/L)
Acenaphthene
83-32-9
8100
200
8270
10
Acenaphthylene
208-96-8
8100
200
8270
10
Acetone
67-64-1
8260
100
Acetonitrile; Methyl cyanide
75-05-8
8015
100
Acetophenone
98-86-2
8270
10
2-Acetylaminofluorene; 2-AAF
53-96-3
8270
20
Acrolein
107-02-8
8030
5
8260
200
Aldrin
309-00-2
8080
0.05
8270
10
Ally) chloride
107-05-1
8010
5
8260
10
4-Aminobiphenyl
92-67-1
8270
20
Anthracene
120-12-7
8100
200
8270
10
Antimony
(Total)
6010
300
7040
2000
7041
30
Barium
(Total)
6010
20
7080
1000
Benzene
71-43-2
8020
2
8021
0 1
8260
5
Benzo[a]anthracene, Benzanthracene
56-55-3
8100
200
8270
10
Benzo[b]fluoranthene
205-99-2
8100
200
A3-6
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
8270
10
Benzo[k]fluoranthene
207-08-9
8100
200
8270
10
Benzo[ghi]perylene
191-24-2
8100
200
8270
10
Benzo[a]pyrene
50-32-8
8100
200
8270
10
Benyl alcohol
100-51-5
8270
20
Beryllium
(Total)
6010
3
7090
50
7091
2
alpha-BHC
319-84-6
8080
0.05
8270
10
beta-BHC
319-85-7
8080
0 05
8270
20
delta-BHC
319-86-8
8080
0 1
8270
20
gamma-BHC, Lindane
58-89-9
8080
0.05
8270
20
Bis(2-chloroethoxy)methane
111-91-1
8110
5
8270
10
Bis(2-chloroethyl)ether; Dichloroethyl ether
111-44-4
8110
3
8270
10
Bis-(2-chlror-l-methyl) ether, 2,2-
Dichloro- dusopropyl ether, DCIP, See note
7
108-60-1
8110
10
8270
10
Bis(2-ethylhexyl) phthalate
117-81-7
8060
20
Bromochloromethane,
Chlorobromomethane
74-97-5
8021
0 1
A3-7
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CASRM
Suggested Methods
PQL (mg/L)
8260
5
Bromodichloromethane,
Dibromochloromethane
75-27-4
8010
1
8021
02
8260
5
Bromoform, Tribromom ethane
75-25-2
8010
2
8021
15
8260
5
4-Bromophenyl phenyl ether
101-55-3
8110
25
8270
10
Butyl benzyl phthalate; Benzyl butyl
phthalate
85-68-7
8060
5
8270
10
Cadmium
(Total)
6010
40
7130
50
7131
1
Carbon disulfide
75-15-0
8260
100
Carbon tetrachloride
56-23-5
8010
1
8021
0.1
8260
10
Chlordane
See NOTE 8
8080
0.1
8270
50
p-Chloroaniline
106-47-8
8270
20
Chlorobenzene
108-90-7
8010
2
8020
2
8021
0 1
8260
5
Chlorobenzilate
510-15-6
8270
10
p-Chloro-m-cresol; 4-ChIoro-3-
methylphenol
59-50-7
8040
5
A3-8
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
8270
20
Chloroethane; Ethyl chloride
75-00-3
8010
5
8021
1
8260
5
Chloroform, Tnchloromethane
67-66-3
8010
05
8021
02
8260
5
2-Chloronaphthalene
91-58-7
8120
10
8270
10
2-Chlorophenol
95-57-8
8040
5
8720
10
4-Chlorophenyl phenyl ether
7005-72-3
8110
40
8270
10
Chloroprene
126-99-8
8010
50
8260
20
Chromium
(Total)
6010
70
7190
500
7191
10
Chrysene
8100
200
8270
10
Cobalt
218-01-9
8100
200
7200
500
7201
10
Copper
(Total)
6010
60
7210
200
7211
10
m-Cresol; 3-methylphenol
108-39-4
8270
10
o-Cresol, 2-methlphenol
95-48-7
8270
10
p-Cresol, 4-methylphenol
106-44-5
8270
10
A3-9
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CASRN
Suggested Methods
PQL (mg/L)
Cyanide
57-12-5
9010
200
2,4-D; 2,4-Dichlorophenoxyacetic acid
94-75-7
8150
10
4,4-DDD
72-54-8
8080
0 1
8270
10
4,4-DDE
72-55-9
8080
0 05
8270
10
4,4-DDT
50-29-3
8080
0 1
8270
10
Diallate
2303-16-4
8270
10
aDibenz[a,h]anthracene
53-70-3
8100
200
8270
10
Dibenzofuran
132-64-9
8270
10
Dibromochloromethane,
Chlorodibromomethane
124-48-1
8010
1
8021
0.3
8260
5
1,2-Dibromo-30chloropropane, DBCP
96-12-8
8011
0.1
8021
30
8260
25
1,2-Dibromoethane; Ethylene dibromide,
EDB
106-93-4
8011
0 1
8021
10
8260
5
Di-n-butyl phthalate
84-74-2
8060
5
8270
10
o-Dichlorobenzene; 1,2-Dichlorobenzene
95-50-1
8010
2
8020
5
8021
05
8120
10
8260
5
A3-10
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
8270
10
m-Dichlorobenzene; 1,3-Dichlorobenzene
541-73-1
8010
5
8020
5
8021
0.2
8120
10
8120
10
8260
5
p-Dichlorobenzene, 1,4-Dichlorobenzene
106-46-7
8010
2
8020
5
8021
0 1
8120
15
8260
5
8270
10
3,3-D'chlorobenzidine
91-94-1
8270
20
trans-l,4-Dich!oro-2-butene
110-57-6
8260
100
Dichlorodifluoromethane, CFC 12;
75-71-8
8021
05
8260
5
1,1-Dichloroethane chloride
75-34-3
8010
1
8021
05
8260
5
1,2-Dichloroethane, Ethylene dichloride
107-06-2
8010
05
8021
03
8260
5
1,1 -Dichloroethylene, 1,1 -Dichloroethane,
Vinylidene chloride
75-35-4
8010
1
8021
0.5
8260
5
cis-1,2-Dichloroethylene; cis-1,2-
Dichloroethene
156-59-2
8021
02
8260
5
A3-11
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CASRN
Suggested Methods
PQL (mg/L)
trans-1,2-Dichloroethylene trans-1,2-
Dichloroethene
156-60-5
8010
1
8021
0.5
0260
5
2,4-Dichlorophenol
120-83-2
8040
5
8270
10
2,6-Dichlorophenol
120-83-2
8040
5
1,2-Dichloropropane; Propylene dichloride
78-87-5
8010
8021
0.05
8260
5
1,3-Dichloropropane; Isopropylidene
chloride
594-20-7
8021
03
8260
5
2,2-Dichloropropane, Isopropylidene
chloride
594-20-7
8021
05
8260
15
1,1 -Dichloropropene
563-58-6
8021
0.2
8260
5
cis-l,3-Dichloropropene
10061-01-5
8010
5
8260
10
trans-1,3-Dichloropropene
10061-02-6
8010
5
8260
10
Dieldrin
60-57-1
8080
0.05
8270
10
Diethyl phthalate
84-66-2
8060
5
8270
20
0,0-DiethyI 0-2-pyrazinyl
phosphorothioate, Thionazin
297-97-2
8141
5
8270
20
Dimethoate
60-51-5
8141
3
8270
20
A3-12
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
p-(Dimethylam ino)azobenzene
60-11-7
8270
10
7,12-Dimethy lbenxz[a]anthracene
57-97-6
8270
10
3,3-Dimethylbenzidine
119-93-7
8270
10
2,4-Dimethlphenol, m-Xylenol
105-87-9
5
8040
5
Dimethyl phthalate
131-11-3
8060
10
8270
10
m-Dinitrobenzene
99-65-0
8270
20
4,6-Dinitro-o-cresol 4,6-Dinitro-2-
methylphenol
534-52-1
8040
150
8270
50
2,4-Dinitrophenol
51-28-54
8040
150
8270
50
2,4-Dinitrotoluene
121-14-2
8090
0.2
8270
10
2,6-Dinitrotoluene
606-20-2
8090
0 1
8270
10
Dinoseb, DNBP, 2-sec-Butyl-4,6-
dinitrophenol
88-85-7
8150
1
8270
20
Di-n-octyl phthalate
117-84-0
8060
30
8270
10
Diphenylamine
122-39-4
8270
10
Disulfoton
298-04-4
8140
2
8141
05
8270
10
Endosulfan I
959-98-8
8080
0 1
8270
20
Endosulfan II
33213-65-9
8080
0.05
8270
20
A3-13
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
Endodulfan sulfate
1031-07-8
8080
0.5
8270
10
Endrin
72-20-8
8080
0.1
8270
20
Endrin aldehyde
7421-93-4
8080
0.2
8270
10
Ethylbenzene
100-41-4
8020
2
8221
0.05
8260
5
Ethyl methacrylate
97-63-2
8015
5
8260
10
8270
10
Ethyl methanesulfonate
62-50-0
8270
20
Famphur
52-85-7
8270
20
Fluoranthene
206-44-0
8100
200
8270
10
Fluorene
86-73-7
8100
200
8270
10
Heptachlor
76-44-8
8080
0 05
8270
10
Heptachlor epoxide
1024-57-3
8080
1
8270
10
Hexachlorobenzene
118-74-1
8120
0.5
8270
10
Hexach lorobutadiene
87-68-3
8120
0.5
8120
5
8260
10
8270
10
Hexachlorocyclopentadiene
77-47-4
8120
5
A3-14
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 2S8, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
8270
10
Hexachloroethane
67-72-1
8120
05
8260
10
8270
10
Hexachloropropene
188-71-7
8270
10
2-Hexanone, Methyl butyl ketone
591-78-6
8260
50
Indenol( 1,2,3-cd)pyrene
193-39-5
8100
200
8270
10
Isopbutyl alcohol
78-83-1
8015
50
8240
100
Isodrin
465-73-6
8270
20
8260
10
Isophorone
78-59-1
8090
60
8270
10
Isosafrole
78-59-1
8090
60
8270
10
Isosafrole
120-58-1
8270
10
Kepone
143-50-0
8270
20
Lead
(Total)
6010
400
7420
1000
7421
10
Mercury
(Total)
7470
2
Methacrylonitrile
126-98-7
8015
5
8260
100
Methapyrilene
91-80-5
8270
100
Methoxychlor
72-43-5
8080
2
8270
10
Methyl bromide, Bromomethane
74-83-9
8010
20
8021
10
A3-15
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 2S8, Appendix D)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
Methyl chloride, Chloromethane
74-87-3
8010
20
8021
0.3
3-Methylcholanthrene
56-49-5
8270
10
Methyl ethyl ketone; MEK; 2-Butanone
78-93-3
8015
10
8260
100
Methyl iodide, lodomethane
74-88-4
8010
40
8260
10
Methyl methacrylate
80-62-6
8015
2
8260
30
Methyl methanesulfonate
66-27-3
8270
10
2-Methylnaphthalene
91-57-6
8270
10
Methyl parathion; Parathion methyl
298-00-0
8140
0.5
8141
1
8270
10
4-Methyl-2-pentanone; Methyl isobutyl
ketone
108-10-1
8015
5
8260
100
Methylene bromide; Dibromomethane
74-95-3
8010
15
8021
20
8260
10
Methylene chloride, Dichloromethane
75-09-2
8010
5
8021
0.2
8260
10
Naphthalene
91-20-3
8021
0.5
8100
200
8260
5
8270
10
1,4-Naphthoquinone
130-15-4
8270
10
1-Naphthylamme
134-32-7
8270
10
A3-16
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
2-Naphthylamine
91-59-8
8270
10
Nickel
(Total)
6010
150
7520
400
o-Nitroaniline, 2-Nitroaniline
88-74-4
8270
50
m-Nitroaniline, 3-Nitroanile
99-09-2
8270
50
p-Nitroaniline; 4-Nitroaniline
100-01-6
8270
20
Nitrobenzene
98-95-3
8090
40
8270
10
o-Nitrophenol; 2-Nitrophenol
88-75-5
8040
5
8270
10
p-Nitrophenol, 4-Nitrophenol
100-02-7
8040
10
8270
50
N-N itrosodi-n-butylam ine
924-16-3
8270
10
N-Nitrosodiethylamine
55-18-5
8270
20
N-Nitrosodimethylamine
62-75-9
8070
2
N-Nitrosodiphenylamine
86-30-6
8070
5
N-Nitrosodipropylamine; N-Nitroso-N-
dipropylamine;
Di-n-propylnitrosamine
86-30-6
8070
10
N-N itrosomethy lethalam ine
10595-95-6
8070
10
N-Nitrosopiperidine
100-75-4
8270
20
N-N itrosopyrrolidine
930-55-8
8270
40
5-Nitro-o-toluidine
99-55-8
8270
10
Parathion
56-38-2
8141
05
8270
10
Pentachlorobenzene
608-93-5
8270
10
Pentachloronitrobenzene
82-68-8
8270
20
Pentachlorophenol
87-86-5
8040
5
8270
50
A3-17
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
Phenacetin
62-44-2
8270
20
Phenanthrene
85-01-8
8100
200
8270
10
Phenol
108-95-2
8040
1
p-Phenylenediamine
106-50-3
8270
10
Phorate
298-02-2
8140
2
8141
0.5
8270
10
Polychlonnated biphenyls (PCBs); Aroclors
see NOTE 9
8080
50
8270
200
Pronamide
23950-58-5
8270
10
Propionitrile, Ethyl cyanide
107-12-0
8015
60
8260
150
Pyrene
129-00-0
8100
200
8270
10
Safrole
94-59-1
8270
10
Selenium
(Total)
6010
750
7740
20
7741
20
Silver
(Total)
6010
70
7760
100
7761
10
Silvex; 2,4,5-TP
93-72-1
8150
2
Styrene
100-42-5
8020
1
8021
0 1
8260
10
Sulfide
18496-25-8
9030
4000
2,4,5-T; 2,4,5-Trichlorophenoxyacetic acid
93-76-5
8150
2
1,2,4,5-Tetrachlorobenzene
95-94-3
8270
10
A3-18
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
1,1,1,2-Tetrachloroethane
630-20-6
8010
5
8021
0 05
8260
5
1,1,2,2-Tetrachloroethane
79-34-5
8010
05
8021
0.5
8260
5
Tetrach loroethylene, Tetrach loroethene,
Perchloroethylene
127-18-8
8010
05
8021
05
8260
5
2,3,4,6-TetrachlorophenoI
58-90-2
8270
10
Thallium
(Total)
6010
40
7840
1000
7841
10
Tin
(Total)
6010
40
Toluene
108-88-3
8020
2
8021
0 1
8260
5
o-Toluidine
95-53-4
8270
10
Toxaphene
See NOTE 10
8080
2
1,2,4-Trichlorobenzene
120-82-1
8021
03
8120
05
8260
10
8270
10
1,1,1 -Tnchloroethane, Methylchloroform
71-55-6
8010
0.3
8021
03
8260
5
1,1,2-Trichloroethane
79-00-5
8010
03
8260
5
A3-19
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
Common Name
CAS RN
Suggested Methods
PQL (mg/L)
Trichloroethylene, Trichloroethene
79-01-6
8010
1
8021
02
8260
5
Tnchlorrofluoromethane, CFC-11
75-69-4
8010
10
8021
03
8260
5
2,4,5-Trichlorophenol
95-95-4
8270
10
2,4,6-Trich lorophenol
88-06-2
8040
5
8270
10
1,2,3-Tnchloropropane
96-18-4
8010
10
8021
5
8260
15
0,0,0-Triethyl phosphorothioate
126-68-1
8270
10
sym-T rinitrobenzene
99-35-4
8270
10
Vanadium
(Total)
6010
80
7910
2000
7911
40
Vinyl acetate
106-05-4
8260
50
Vinyl chloride, Chloroethene
75-01-4
8010
2
8021
04
8260
10
Xylene (total)
See NOTE 11
8020
5
8021
0.2
8260
5
Zinc
(Total)
6010
20
7950
50
7951
05
NOTES
1 The regulatory requirements pertain only to the list of substances, the right hand columns (Methods and Practical
Quantitation Limits (PQL)) are given for informational purposes only See also footnotes 5 and 6
A3-20
-------
Appendix 3-4 (continued)
List of Hazardous Inorganic and Organic Constituents
(40 CFR 258, Appendix II)
2 Common names are those widely used in government regulations, scientific publications, and commerce, synonyms exist
for many chemicals
3 Chemical Abstracts Service registry number Where "Total" is entered, all species in the ground water that contain this
element are included
4 CAS index are those used in the 9th Collective Index
5 Suggested Methods refer to analytical procedure numbers used in USEPA Report SW-846 Test Methods for Evaluating
Solid Waste, Third edition, November 1986, as revised, December 1987 Analytical details can be found in SW-846 and in
documentation on file at the agency CAUTION The methods listed are representative SW-846 procedures and may not
always be the most suitable method(s) for monitoring an analyte under the regulations
6 PQLs are the lowest concentrations of analytes in ground waters that can be reliably determined within specified limits of
precision and accuracy by the indicated methods under routine laboratory operating conditions The PQLs listed are
generally stated to one significant figure PQLs are based on 5 mL samples for volatile orgamcs and 1 L samples for
semivolatile orgamcs CAUTION The PQL values in many cases are based only on a general estimate for the method and
not on a determination for individual compounds, PQLs are not a part of the regulation
7 This substance is often called Bis(2-chloroisopropyl) ether, the name Chemical Abstracts Service applies to its
noncommercial isomer, Propane, 2,2"-oxybis[2-chloro-(CAS RN 39638-32-9)
8 Chlordane This entry includes alpha-chlordane (CAS RN 5103-71 -9), beta-chlordane (CAS RN 5103-74-2), gamma-
chlordane (CAS RN 5566-34-7), and constituents of chlordane (CAS RN 57-74-9 and CAS RN 12789-03-6) PQL shown
is for technical chlordane PQLs of specific isomers are about 20 mg/L by method 8270
9 Polychlorinated biphenyls (CAS RN 1336-36-3) This category contains congener chemicals, including constituents of
Aroclor 1016 (CAS RN 12674-11-2), Arooclor 1221 (CAS RN 11104-28-2), Aroclor 1232 (CAS RN11141-16-5), Aroclor
1242 (CAS RN 53469-21-9), Aroclor 1248 (CAS RN 12672-29-6), Aroclor 1254 (CAS RN 11097-69-1), and Aroclor
1260 (CAS RN 11096-82-5) The PQL shown is an average value for PCB congeners
10 Toxaphene This entry includes congener chemicals contained in technical toxaphene (CAS RN 8001-35-2), i e,
chlorinated camphene
11 Xylene (total) This entry includes o-xylene (CAS RN 96-47-6), m-xylene (CAS RN 108-38-3), p-xylene (CAS RN 106-
42-3), and unspecified xylenes (dimethylbenzenes) (CAS RN 1330-20-7) PQLs for method 8021 are 0 2 for o-xylene and
0 1 for m- or p-xylene The PQL for m-xylene is 2 0 mg/L by method 8020 or 8260
A3-21
-------
Appendix 3-5
Design Criteria Concentration Values
(40 CFR 258.40)
Chemical
MCL (mg/L)
Arsenic
0.50
Barium
1.0
Benzene
0 005
Cadmium
0.01
Carbon tetrachloride
0 005
Chromium (hexavalent)
0.05
2,4-Dichlorophenoxy acetic acid
0 1
1,4-Dichlorobenzene
0 075
1,2-Dichloroethand
0 005
1,1 -Dichloroethy lene
0 007
Endrin
0.0002
Fluoride
4.0
Lindane
0 004
Lead
0 05
Mercury
0 002
Methoxychlor
0 1
Nitrate
100
Selenium
001
Silver
0 05
Toxaphene
0 005
1,1,1 -Tnchloromethane
0.2
Thrichloroethylene
0 005
2,4,5-Trichlorophenoxy acetic acid
001
Vinyl Chloride
0 002
A3-22
-------
Phase 1
Section 4
Hazardous Waste Management
-------
Phase 1
Section 4
Table of Contents
Hazardous Waste Management
A. Applicability 4-1
B. Federal Legislation 4-1
C. State/Local Regulations 4-2
D. Key Compliance Requirements 4-2
E Key Compliance Definitions 4-5
F Records to Review 4-19
G. Physical Features to Inspect 4-20
H. Guidance for Checklist Users 4-21
Appendices
A4-1. Identification and Listing of Hazardous Waste A4-1
A4-2. Commercial Chemical Products or Manufacturing Chemical Intermediates
Identified as Toxic Wastes A4-8
A4-3. Toxicity Characteristics Constituents and Regulatory Levels A4-24
A4-4. Identification of Hazardous Waste Hazardous Constituents A4-26
A4-5. Commercial Chemical Products or Manufacturing Chemical Intermediates
Identified as Acute Hazardous Waste A4-42
A4-6. Potentially Incompatible Hazardous Wastes A4-49
A4-7. Land Disposal Restricted Wastes and Their Effective Dates A4-51
A4-8. Constituent Concentrations in Waste Extract A4-70
A4-9. Treatment Methods Expressed as Specific Technologies A4-76
A4-10. Constituent Concentrations in Wastes A4-99
A4-11. Maximum Concentrations of Constiuents for Graoundwater Protection A4-132
A4-12. Used Oil Classifications A4-133
-------
A. Applicability
This section applies to facilities that generate, store, transport, treat, or dispose of hazardous
waste. This section and its associated checklists are more complex than other sections in this
volume Not all checklist items will be applicable to a facility Guidance is provided on the
checklists to direct the assessor to the regulations concerning the type of hazardous waste
activities/facilities on the facility Information on hazardous waste storage tanks is in the section
titled Storage Tank Management.
Assessors are required to review agency, Federal, state and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. The Resource Conservation and Recovery Act (RCRA), Subtitle C, (1976).
Public Law (PL) 98616; 42 USC 6921-6939b, establishes standards and procedures for the
handling,, storage, treatment, and disposal of hazardous waste. Specifically, RCRA prohibits
the placement of bulk or noncontainerized liquid hazardous waste or free liquids containing
hazardous waste into a landfill. It also prohibits the land disposal of specified wastes and
disposal of hazardous waste through underground injection within 1/4 mi (0.40 km) of an
underground source of drinking water.
The law also provides for the management of used oil Under RCRA, used oil is not a
listed hazardous waste, but regulations promulgated under RCRA (40 CFR 279) establish
management standards for used oil generators, collection center aggregation points,
transporters, transporter facilities, used oil processors, rerefinerys, used oil burners who burn
off-specification used oil for energy recovery, used oil fuel marketers, and for use and disposal
of used oil used as a dust suppressant
2. The Federal Facility Compliance Act (FFCA) of 1992.
This act provides for a waiver of sovereign immunity with respect to Federal, state, and
local procedural and substantive requirements relating to RCRA solid and hazardous waste
laws and regulations. Additionally, it defines hazardous waste in relation to public vessels,
expands the definition of mixed waste, addresses the issue of munitions, and discusses waste
discharges to Federally Owned Treatment Works (FOTWs).
3. Executive Order (EO) 12088, Federal Compliance with Pollution Standards.
This EO, dated 13 October 1978, requires federally owned and operated facilities to
comply with applicable Federal, state, and local pollution control standards It makes the head
of each executive agency responsible for seeing to it that the agencies, facilities, programs,
and activities the agency funds meet applicable Federal, state, and local environmental
requirements and for correcting situations that are not in compliance with such requirements.
In addition, the EO requires that each agency ensure that sufficient funds for environmental
Phase 1 - Section 4
Hazardous Waste Management
4-1
-------
compliance are included in the agency budget.
C. State/Local Regulations
Many states have met the EPA requirements in 40 CFR 271 and have been authorized to
manage their own state programs. RCRA encourages states to develop their own hazardous
waste statutes and to operate regulatory programs. Many states have adopted the EPA
regulations by reference or have promulgated regulations that are identical to the EPA
regulations, while other states have promulgated regulations more stringent than the Federal
RCRA. These differences between individual state regulations and the Federal program require
that assessors check the status of the state's authorization and then determine which regulations
apply. For example, some states have listed additional waste as hazardous waste (used oil,
PCBs, asbestos). Since the section checklists are based exclusively on the requirements of the
Federal RCRA/EPA program, it is necessary to determine in what ways the applicable state
program differs from the RCRA/EPA program.
D. Key Compliance Requirements
1. Generator Requirements
Responsibilities of facilities are based on the amount of waste being generated in one
month. Typical wastes include solvents, paint, contaminated antifreeze or oil, and sludges. In
some states, waste oil and other substances have been classified as a hazardous waste and
therefore need to be included in the total amount of waste being generated. Within Federal
regulations there are three classifications:
a A Conditionally Exempt Small Quantity Generator (CESQG) produces no more than
100 kg (220.46 lb) of hazardous waste or 1 kg (2.20 lb) of acutely hazardous waste in
a one month period. They also do not accumulate onsite more than 1,000 kg (2204.62
lb) of waste at any one time. When either the volume of waste produced in one month
exceeds 100 kg (220.46 lb) or more than 1,000 kg (2204.62 lb) of waste has
accumulated onsite, the facility is required to comply with the more stringent
standards applicable to a Small Quantity Generator (SQG);
b. A SQG produces between 100 (220.46 lb) and 1,000 kg (2204.62 lb) of hazardous
waste in a month. The waste cannot accumulate onsite for more than 180 days unless
the waste is transported more than 200 mi (321.87 km) to a Treatment, Storage, and
Disposal Facility (TSDF). In that situation, the waste can accumulate for 270 days.
But at no time is there to be more than 6,000 kg (13,227.73 lb) of waste accumulated
at the facility. When the volume of waste generated in one month exceeds 1,000 kg
(2204.62 lb) of hazardous waste or 1 kg (2.20 lb) of acutely hazardous waste or the
accumulation time limit is exceeded, the facility is required to comply with the
standards for a Generator. When more than 6,000 kg (13,227 73 lb) of waste is
stored onsite, the SQG is required to obtain a permit and comply with the
requirements of 40 CFR 264 and 40 CFR 265;
Phase 1 - Section 4
Hazardous Waste Management
4-2
-------
c A Generator produces more than 1,000 kg (2204.62 lb) of hazardous waste in a
month. (NOTE: Using water, which weighs approximately 8 lbs/gal (3 63 kg/gal) as
a basis of measurement, 100 kg (220.46 lb) would equal about 28 gal (105.99 L)
(one-half of a 55 gal (208.20 L) drum), 1,000 kg (2204.62 lb) would equal about 273
gal (1036.15 L) (almost five 55 gal drums)
Whether the facility is a CESQG, SQG, or a Generator determines recordkeeping
requirements and design standards for storage areas. Storage areas connected with generation
points are often referred to as accumulation points. Regardless of the amount of hazardous
waste generated, every facility is required to test or use knowledge of materials or processes
used to determine if it is a listed hazardous waste or has hazardous characteristics
Comparison of RCRA Generator Requirements
Requirement
CESQG
SQG
Generator
Identify HW
Yes
Yes
Yes
Quantity Limits
* 100 kg/mo (220 46
Ib/m)
100 kg/mo (220 46 lb)
1,000 kg/mo (2204 62 lb)
>1,000 kg/mo (2204 62
lb/ mo)
Acute Waste Limits
n 1 kg/mo (2 20 lb/mo)
s 1 kg/mo (2 20 lb/mo)
None
Facility Receiving
Waste
State approved or RCRA
permitted
RCRA permitted facility
RCRA permitted facility
EPA ID Number
Not Required
Required
Required
RCRA Personnel
Training
Not Required
Basic Training Required
Required
DOT Training
Required
Required
Required
Exception Report
Not Required
Required >60 days
Required >45 days
Biennial Report
Not Required
Not Required
Required
Onsite Accumulation
Limits (without permit)
1,000 kg (2204 62 lb)
6,000 kg (13,227 73 lb)
Any quantity
Accumulation Time
Limits (without permit)
None
180 days or
270 days (>200 mi
(321 87 km))
90 days +
30 days granted by EPA
Storage Requirements
None
Basic requirements with
technical standards for
containers or tanks
Full compliance with
management of
containers or tanks
Use Manifests
No
Yes*
Yes*
*Unless the waste is reclaimed under contractual agreement and properly marked and labeled
Phase 1 - Section 4
Hazardous Waste Management
4-3
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2. Transport Requirements
Containers of hazardous waste shipped offsite must be labeled to identify the waste and its
hazard class.
3. Accumulation Point Management
An accumulation point is an area in or near the workplace where hazardous waste is
accumulated or stored before being turned in for disposal. Storage in these areas is temporary
and the permissible length of time for accumulation depends on what size generator the facility
is.
4. Satellite Accumulation Point Management
A satellite accumulation point is an area where no more than 55 gal (208.20 L) of a
hazardous waste or 1 qt (0.95 L) of acute hazardous waste is accumulated at or near the point
of generation. The satellite accumulation point is under the control of one operator. When the
55 gal (208.20 L) limit is reached the operator has 3 days to move the waste to a 90 day
storage area or a permitted TSDF. These standards only apply to a SQG or a Generator.
5. Permitted TSDF Requirements
The operation of a TSDF is subject to regulation and permitting under Federal and state
regulations These regulations are both administrative as well as technical in nature. The
administrative standards require that various plans be developed to ensure that emergencies can
be dealt with, waste received is properly identified, and operating personnel are adequately
trained to operate the TSDF and respond to emergencies. These administrative standards also
include requirements that the TSDF be inspected routinely, records of operations are compiled
and maintained, and reports of both routine and contingency operations are made to the
applicable regulatory agency. The administrative standards also require that a plan for ceasing
operations and closing the TSDF be developed, kept on-hand, and updated frequently.
The technical standards which are applicable to TSDFs fall into two classes: general
standards which apply to all TSDFs and specific standards which apply to various types of
facilities, e.g , container storage areas, tanks, containment buildings, surface impoundments,
waste piles, land treatment facilities, incinerators, landfills, thermal treatment facilities, and
chemical, physical, biological treatment facilities.
Administrative and technical standards are applied to a particular facility through a RCRA
permit issued to a facility. Existing TSDFs which have applied for a permit but not yet been
issued a RCRA permit are considered to be in interim status if they applied for a part A and
part B permit and can continue to operate if they comply with the RCRA mandated Interim
Status Standards (ISS) of 40 CFR 265.
6. Waste Minimization/Pollution Prevention
Waste minimization and pollution prevention programs are being increasingly discussed
and implemented by both environmental managers and environmental policy makers. Usually
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defined as a reduction in the volume and toxicity of waste, waste minimization often pays for
itself through reduced environmental costs, operating costs, and liability. While these cost
savings are often enough to justify a program, there are an increasing number of voluntary and
mandatory programs that drive waste minimization/pollution prevention
Under RCRA, large quantity generators are required to sign a certification on each
manifest stating that they have a program in place to reduce waste to the degree that is
economically feasible and select a disposal method that minimizes threats to human health and
the environment. Small quantity generators must show a "good faith effort" to minimize waste
and to select the best waste management method available.
EPA has also developed nonbinding guidelines on a waste minimization program for
generators. Issued in 58 FR 31114 on May 28, 1993, the Interim Final Guidance to Hazardous
Waste Generators on the Elements of a Waste Minimization Program is intended to provide
nonbinding, and nonenforceable guidance to generators of regulated hazardous wastes. The
program includes:
• Provisions for top management assurance that waste minimization is a company-wide
effort;
• Characterization of waste generation and waste management costs;
• Periodic waste minimization assessments;
• A cost allocation system;
• Promotion of technology transfer; and
• Procedures for program implementation and evaluation.
7. Ordnance
Under the provisions of 40 CFR 261.23(a)(6) through 261.23(a)(8) ordnance is classified
as a reactive hazardous waste. The open burning and detonation (OB/OD) of waste explosives
is allowed at interim status TSDFs as long as a minimum distance is kept from the property
line of the property of others. The length of this distance is based on the amount of explosive
being OB/OD. For permitted TSDFs, OB/OD activities are regulated by permit to operate a
miscellaneous unit. This is often referred to as a Subpart X permit.
E. Key Compliance Definitions
1. Active Life
The period from the initial receipt of hazardous waste at the facility until the Regional
Administrator receives certification of final closure (40 CFR 260.10).
2. Active Portion
That portion of a facility where treatment, storage, or disposal operations are being or
have been conducted and which is not a closed portion (40 CFR 260.10).
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3. Acute Hazardous Waste
Any waste listed under 40 CFR 261.31 through 261.33(c) with a hazard code of H. These
include EPA Hazardous waste numbers: F020, F021, F022, F023, F026, and F027 (if 40 CFR
261.31 and the P listed wastes in 40 CFR 261.33(e)).
4. Aquifer
A geologic formation or group of formations, or part of a formation capable of yielding a
significant amount of groundwater to wells or springs (40 CFR 260.10).
5. Boiler
An enclosed device using controlled flame combustion and having the following
characteristics (40 CFR 260.10):
a. The unit has physical provisions for recovering and exporting thermal energy in the
form of steam, heated fluids, or heated gases;
b. The unit's combustion chamber and primary energy recovery section(s) must be of
integral design;
c. While in operation the unit maintains a thermal energy recovery efficiency of at least
60 percent; and
d. The unit has been approved by the EPA's Administrator.
6. Certification
A statement of professional opinion based upon knowledge and belief (40 CFR 260.10).
7. Characteristics of Hazardous Waste
The characteristics of ignitibility, corrosivity, reactivity, and toxicity which identify
hazardous waste (40 CFR 261.20 through 261.24).
8. Closed Portion
The portion of a facility which has been closed in accordance with the approved closure
plan and all applicable closure requirements (40 CFR 260.10).
9. Consignee
The ultimate treatment, storage, or disposal facility in a receiving country to which the
hazardous waste will be sent (40 CFR 262.51).
10. Container
Any portable device in which a material is stored, transported, treated, disposed of, or
otherwise handled (40 CFR 260.10).
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11. Containment Building
A hazardous waste management unit that is used to store or treat hazardous waste under
40 CFR 264.1100 through 264.1103 and 40 CFR 265.1100 through 265.1103 (40 CFR
260.10).
12. Contingency Plan
A document setting out an organized, planned, and coordinated course of action to be
followed in case of a fire, explosion, or release of hazardous waste or hazardous waste
constituents which could threaten human health or the environment (40 CFR 260.10).
13. Corrective Action Management Unit (CAMU)
An area within a facility that is designated by the Regional Administrator under 40 CFR
264 Subpart S, for the purpose of implementing corrective action requirements under 264.101
and RCRA section 3008(h). A CAMU shall only be used for the management of remediation
wastes pursuant to implementing such corrective action requirements at the facility (40 CFR
264.10)
14. Debris
Solid material exceeding a 60 mm particle size that is intended for disposal and that is: a
manufactured object; or plant or animal matter; or natural geologic material. The following
materials are not debris: any material for which a specific treatment standard is provided,
process residuals such as smelter slag and residues from the treatment of waste, wastewater,
sludges, or air emissions residues; and intact containers of hazardous waste that are not
ruptured and retain at least 75 percent of their original volume (40 CFR 268.2).
15. Designated Facility
A hazardous waste TSDF that is identified on a manifest as the destination of a hazardous
waste shipment. The facility must have an appropriate permit, interim status, or be regulated
under specific recycling requirements (40 CFR 260.10).
16. Detonation
An explosion in which chemical transformation passes through the material faster than the
speed of sound (0 33 km/sec at sea level) (40 CFR 265.382).
17. Dike
An embankment or ridge of either natural or man-made materials used to prevent the
movement of liquids, sludges, solids, or other materials (40 CFR 260.10).
18. Discharge or Hazardous Waste Discharge
The accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or
dumping of hazardous waste into or on any land or water (40 CFR 260.10).
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19. 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 such solid waste or hazardous waste or
any constituent thereof may enter the environment or be emitted into the air or discharged into
any waters, including groundwaters (40 CFR 260.10)
20. Do-it-Yourselfer (DIY) Used Oil Collection Center
Any site or facility that accepts/aggregates and stores used oil collected only from
household do-it-yourselfers.
21. Elementary Neutralization Unit
A device used for neutralizing only those hazardous wastes that exhibit corrosivity (as
defined in 40 CFR 261.22) or are listed in Subpart D of 40 CFR 261 only because of
corrosivity and meet the definition of tank, tank system container, transport vehicle, or vessel
in 40 CFR 261.10 (40 CFR 260.10).
22. EPA Acknowledgement of Consent
The cable sent to the EPA from the U.S. Embassy in a receiving country that
acknowledges the written consent of the receiving country to accept the hazardous waste and
describes the terms and conditions of the receiving country's consent to the shipment (40 CFR
262.51).
23. EPA Hazardous Waste Number
The number assigned by EPA to each hazardous waste listed in Part 261, Subpart D and to
each characteristic identified in Part 261, Subpart C (40 CFR 260.10).
24. EPA Identification Number
The number assigned by EPA to each generator, transporter, and treatment, storage, or
disposal facility (40 CFR 260.10).
25. Existing Hazardous Waste Management Facility or Existing Facility
A facility which was in operation or for which construction commenced on or before 19
November 1980 (40 CFR 260.10).
26. Existing Portion
The land surface area of an existing waste management unit, included in the original Part
A permit application, on which wastes have been placed prior to the issuance of a permit (40
CFR 260.10).
27. Facility
All contiguous land and structures, other appurtenances, and improvements on the land,
used for treating, storing, or disposing of hazardous waste. A facility may consist of several
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treatment, storage, or disposal operational units (e.g. one or more landfills, surface
impoundments, or combination of them) (40 CFR 260.10).
28. Final Closure
The closure of all hazardous waste management units at the facility in accordance with all
applicable closure requirements so that hazardous waste management activities under 40 CFR
Parts 264 and 265 are no longer conducted at the facility unless subject to the provisions of
262.34 (40 CFR 260.10).
29. Food-Chain Crops
Tobacco, crops grown for human consumption, and crops grown for feed for animals
whose products are consumed by humans (40 CFR 260.10).
30. Free Liquids
Liquids which readily separate from the solid portion of a waste under ambient
temperature and pressure (40 CFR 260.10).
31. Generator
Any person, by site, whose act or process produces hazardous waste identified or listed in
40 CFR Part 261, or whose act first causes a hazardous waste to become subject to regulation
(40 CFR 260.10). (NOTE: This typically is used to refer to a facility producing hazardous
waste in quantities greater than 1,000 kg/mo (2204.62 lb/mo)).
32. Groundwater
Water below the land surface in a zone of saturation (40 CFR 260.10).
33. Haiogenated Organic Compounds (HOC)
Those compounds having a carbon-halogen bond which are listed in Appendix 4-1 (40
CFR 268.2).
34. Hazardous Debris
Debris that contains a hazardous waste or that exhibits a characteristic of hazardous waste
(40 CFR 268.2)
35. Hazardous Waste
A solid waste identified as a characteristic or listed hazardous waste in 40 CFR 261.3 (40
CFR 260.10).
36. Hazardous Waste Constituent
A constituent that caused the hazardous waste to be listed in 40 CFR Part 261, Subpart D
(lists of hazardous wastes from non-specific and specific sources, and listed hazardous wastes),
or a constituent listed in the table of maximum concentrations of contaminants for the toxicity
characteristic) (40 CFR 260.10).
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37. Hazardous Waste Management Unit
A contiguous area of land on or in which hazardous waste is placed, or the largest area in
which there is significant likelihood of mixing hazardous waste constituents in the same area.
Examples are a surface impoundment, a waste pile, a treatment area, a landfill cell, an
incinerator, a tank and its associated piping and underlying containment system, and a
container storage area. A container alone does not constitute a unit, the unit includes
containers and the land or pad upon which they are placed (40 CFR 260.10).
38. Incinerator
An enclosed device using controlled flame combustion that neither meets the criteria for
classification as a boiler nor is listed as an industrial furnace (40 CFR 260.10).
39. Incompatible Waste
A hazardous waste that is unsuitable for (40 CFR 160.10)-
a. Placement in a particular device or facility because it may cause corrosion or decay
of containment materials (e.g., container liners or tank walls); or
b. Commingling with another waste or material under uncontrolled conditions because
the commingling conditions produce heat or pressure, fire or explosion, violent
reaction, toxic dusts, mist, fumes, or gases, or flammable fumes or gases.
40. Individual Generation Site
The contiguous site at or on which one or more hazardous wastes are generated. An
individual generation site, such as a large manufacturing plant, may have one or more sources
of hazardous waste, but is considered a single or individual generation site if the site or
property is contiguous (40 CFR 260.10).
41. Industrial Furnace
Any of the following enclosed devices that are integral components of manufacturing
processes and that use controlled flame devices to accomplish recovery of materials or energy;
cement kilns, lime kilns, aggregate kilns, phosphate kilns, coke ovens, blast furnaces,
smelting, melting and refining furnaces, titanium dioxide chloride process oxidation reactors,
methane reforming furnaces, pulping liquor recovery furnaces, combustion devices used in the
recovery of sulfur values from spent sulfuric acid, halogen acid furnaces, and other devices
designated by the Administrator (40 CFR 260.10)
42. Injection Wells
A well into which fluids are injected (40 CFR 260.10).
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43. Inner Liner
A continuous layer of material placed inside a tank or container which protects the
construction materials of the tank or container from the contained waste or reagents used to
treat the waste (40 CFR 260.10).
44. International Shipment
The transportation of hazardous waste into or out of the jurisdiction of the United States
(40 CFR 260.10).
45. Land Disposal
Includes, but is not limited to, any placement of hazardous waste in a landfill, surface
impoundment, waste pile, injection well, land treatment facility, salt dome formation,
underground mine or cave, or placement in a concrete vault or bunker intended for disposal
purposes (40 CFR 268 2)
46. Land Treatment Facility
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 will remain after closure
(40 CFR 260.10).
47. 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 facility, a surface impoundment, an underground injection well,
a salt bed formation, an underground mine, or a cave (40 CFR 260.10).
48. Landfill Cell
A discrete volume of a hazardous waste landfill which uses a liner to provide isolation of
wastes from adjacent cells or wastes. Examples are trenches and pits (40 CFR 260.10).
49. Large Quantity Generator
See Generator.
50. Leachate
Any liquid, including any suspended components in the liquid, that has percolated through
or drained from hazardous waste (40 CFR 260.10)
51. Leak Detection System
A system capable of detecting the failure of either the primary or secondary containment
structure or the presence of a release of hazardous waste or accumulated liquid in the
secondary structure. Such a system must employ operational controls (e.g., daily visible
containment for releases into the secondary containment system of aboveground tanks) or
consist of an interstitial monitoring devise designed to detect continuously and automatically
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the failure of the primary or secondary containment structure or the presence of a release of
hazardous waste into the secondary containment structure (40 CFR 260.10).
52. Liner
A continuous layer of natural 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 (40 CFR 260.10).
53. Management or Hazardous Waste Management
The systematic control of the collection, source separation, storage, transportation,
processing, treatment, recovery, and disposal of hazardous waste (40 CFR 260.10).
54. Management Practice (MP)
Practices which, although not mandated by law, are encouraged to promote safe operating
procedures.
55. Manifest
The shipping document originated and signed by the generator containing the information
required by 40 CFR 262, Subpart B (40 CFR 260.10).
56. Manifest Document Number
The EPA 12-digit number assigned to the generator plus a unique five digit number
assigned to the manifest by the generator for recording and reporting purposes (40 CFR
260.10).
57. Miscellaneous Unit
A hazardous waste management unit where hazardous waste is treated, stored, or disposed
of and that is not a container, tank, surface impoundment, pile, land treatment unit, landfill,
incinerator, boiler, industrial furnace, underground injection well with appropriate technical
standards under 40 CFR 146, containment building, or unit eligible for a research development
and demonstration permit under 40 CFR 270.65 (40 CFR 260.10
58. Movement
That hazardous waste transported to a facility in an individual vehicle (40 CFR 260.10).
59. New Hazardous Waste Management Facility
A facility which began operation, or for which construction commenced after 21 October
1976(40 CFR 260.10).
60. Nonwastewaters
Wastes that do not meet the criteria for wastewaters (40 CFR 268.2).
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61. Onsite
The same or geographically continuous property which may be divided by a public right-
of-way, provided the entrance and exit between the properties is at a cross-roads intersection
and access is obtained by crossing rather than going along the right-of-way (40 CFR 260.10).
62. Open Burning
The combustion of any material without the following characteristics (40 CFR 260.10):
a. Control of combustion air to maintain adequate temperature for efficient combustion,
b. Containment of the combustion-reaction in an enclosed device to provide sufficient
residence time and mixing for complete combustion,
c Control of emission of the gaseous combustion products
63. Ordnance
See Waste Explosives
64. Partial Closure
The closure of a hazardous waste management unit in accordance with the applicable
closure requirements of 40 CFR 264 and 265 at a facility that contains other active hazardous
waste management units. For example, partial closure may include the closure of a tank
(including its associated piping and underlying containment systems) while other units of the
same facility continue to operate (40 CFR 260.10).
65. Pile
Any non-containerized accumulation of solid, nonflowing hazardous waste that is used for
treatment or storage that is not a containment building (40 CFR 260.10).
66. 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 floating craft, from which pollutants are or may be
discharged. This term does not include return flows from irrigated agriculture (40 CFR
260 10).
67. Pollution Prevention
The term includes: equipment or technology modifications, process or procedure
modifications, reformulation or redesign of products, substitution of raw materials, and
improvements in housekeeping, maintenance, training or inventory control as defined in the
Pollution Prevention Act.
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68. Primary Exporter
Any person who is required to originate the manifest for a shipment of hazardous waste in
accordance with 40 CFR 262, Subpart B or an equivalent state provision, that specifies
treatment, storage, or disposal facility in a receiving country as the facility to which the
hazardous waste will be sent and any intermediary arranging for the export (40 CFR 262.51).
69. Processing
Chemical or physical operations designed to produce from used oil, or to make used oil more
amenable for production of, fuel oils, lubricants, or other used oil-derived product. Processing
includes, but is not limited to: blending used oil with virgin petroleum products, blending used
oils too meet the fuel specification, filtration, simple distillation, chemical or physical separation
and re-refining.
70. Publicly Owned Treatment Works (POTW)
Any device or system used in the treatment (including recycling and reclamation) of
municipal sewage or industrial wastes of a liquid nature which is owned by a state or
municipality (as defined by section 502(4) of the CWA). This definition includes sewers,
pipes, or other conveyances only if they convey wastewater to a POTW providing treatment
(40CFR 260.10).
71. Pump Operating Level
A liquid level proposed by the owner or operator and approved the Regional
Administrator based on pump activation level, sump dimensions, and level that avoids backup
into the drainage layer and minimizes head in the sump (40 CFR 264.226(d)(3)).
72. Qualified Groundwater Scientist
A scientist or engineer who has received a baccalaureate or postgraduate degree in the
natural sciences or engineering and has sufficient training and experience in ground water
hydrology and related fields as may be demonstrated by state registration, professional
certification, or completion of accredited university courses that enable that individual to make
sound professional judgements regarding groundwater monitoring and contaminant fate and
transport (40 CFR 260.10).
73. Receiving Country
A foreign country to which a hazardous waste is sent for the purpose of treatment,
storage, or disposal (except short-term storage incidental to transportation) (40 CFR 262.51).
74. Replacement Unit
A landfill, surface impoundment or waste pile unit (40 CFR 260.10):
a. From which all or substantially all of the waste is removed, and
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b. That is subsequently reused to treat, store, or dispose of hazardous waste. This does
not apply to a unit from which waste is removed during closure, if the subsequent
reuse solely involves the disposal of waste from that unit and other closing units or
corrective action areas at the facility, in accordance with an approved closure plan or
EPA or state approved corrective action
75. Representative Sample
A sample of a universe or whole (e g , waste pile, lagoon, groundwater) which can be
expected to exhibit the average properties of the umverse or whole (40 CFR 260.10).
76. Re-Refining Distillation Bottoms
The heavy fraction produced by vacuum distillation of filtered and dehydrated used oil.
The composition of still bottoms varies with column operation and feedstock.
77. Restricted Wastes
Those categories of hazardous wastes that are prohibited from land disposal the dates
established in RCRA Section 3004 (40 CFR 268).
78. Runoff
Any rainwater, leachate, or other liquid that drains over land from any part of a facility
(40 CFR 260.10).
79. Runon
Any rainwater, leachate, or other liquid that drains over land onto any part of a facility
(40 CFR 260.10).
80. Sludge
Any solid, semi-solid, or liquid waste generated from a municipal, commercial, or
industrial wastewater treatment plant, water supply treatment plant, or air pollution control
facility exclusive of the treated effluent from a wastewater treatment plant (40 CFR 260.10).
81. Small Quantity Generator
A generator who generates less than 1,000 kg (2204.62 lb) of hazardous waste in a
calendar month but more than 100 kg (220.46 lb)(40 CFR 260 10)
82. Storage
The holding of hazardous wastes for a temporary period, at the end of which the
hazardous wastes are treated, disposed of, or stored elsewhere (40 CFR 260.10).
83. Sump
Any pit or reservoir that meets the definition of tank and those troughs/trenches connected
to it that serve to collect hazardous waste for transport to hazardous waste TSDF except that as
used in the landfill, surface impoundment, and waste pile rules. Sump means any lined pit or
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reservoir that serves to collect liquids drained from a leachate collection and removal system
or leak detection system for subsequent removal from the system (40 CFR 260.10).
84. Surface Impoundment
A facility or part of a facility that is a natural topographic depression, manmade
excavation, or diked area formed primarily of earthen materials designed to hold an
accumulation of liquid wastes or wastes containing free liquids and which is not an injection
well (40 CFR 260.10).
85. Thermal Treatment
The treatment of hazardous waste in a device that uses elevated temperature as the primary
means to change the chemical, physical, or biological character or composition of the
hazardous waste (40 CFR 260.10).
86. Transfer Facility
Any transportation related facility including loading docks, parking areas, storage areas
and other similar areas where shipments of hazardous wastes are held during the normal
course of transportation (40 CFR 260.10).
87. Transit Country
Any foreign country, other than a receiving country, through which a hazardous waste is
transported (40 CFR 260.10).
88. Transport Vehicle
A motor vehicle or rail car used for the transportation of cargo by any mode. Each cargo-
carrying body (trailer, railroad freight car, etc.) is a separate transport vehicle (40 CFR
260.10).
89. Transporter
A person engaged in the offsite transportation of hazardous wastes by air, rail, highway,
or water (40 CFR 260.10).
90. Treatability Study
A study in which a hazardous waste is subjected to a treatment process to determine (40
CFR 260.10):
a. Whether the waste is amenable to the treatment process,
b. What pretreatment (if any) is required,
c. The optimal process conditions needed to achieve the desired treatment,
d. The efficiency of a treatment process for a specific waste or wastes, or
e. The characteristics and volumes of residuals from a particular treatment process.
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Also included in this definition for the purpose of the 40 CFR 261.4(e) and (f) exemptions
are liner compatibility, corrosion, and other material compatibility studies and toxicological
and health effects studies. A treatability study is not a means to commercially treat or dispose
of hazardous waste.
91. 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 such waste, or so as to recover energy or material resources from the waste, or so
as to render such waste nonhazardous, or less hazardous; safer to transport, store, or dispose
of; or amenable for recovery, amenable for storage, or reduced in volume (40 CFR 260.10).
92. Treatment Zone
A soil area of the unsaturated zone of a land treatment unit within which hazardous
constituents are degraded, transformed, or immobilized (40 CFR 260.10).
93. Underground Injection
The subsurface emplacement of fluids through a bored, drilled or driven well; or through
a dug well, where the depth of the dug well is greater than the largest surface dimension (40
CFR 260 10).
94. Unsaturated Zone or Zone of Aeration
The zone between the land surface and the water table (40 CFR 260.10).
95. United States
The 50 states, the District of Columbia, the Commonwealth of Puerto Rico, the US Virgin
Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands (40
CFR 260.10).
96. Uppermost Aquifer
The geologic formation nearest the natural ground surface that is an aquifer, as well as
lower aquifers that are hydraulically interconnected with this aquifer within the facility's
property boundary (40 CFR 260.10).
97. Used Oil
Any oil that has been refined from crude oil or any synthetic oil that has been used and as
a result of such use is contaminated by physical or chemical impurities (40 CFR 279.1)
Although used oil has not been declared a hazardous waste at the Federal level, it does
need to be stored, handled, and documented according to specific requirements depending on
whether the facility is a used oil generator, a used oil collection center and aggregation point,
a used oil transporter, a used oil burner, or a used oil marketer.
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98. Used Oil Aggregation Point
Any site or facility that accepts, aggregates, and/or stores used oil collected only from
other used oil generation sites owned or operated by the owner or operator of the aggregation
point, from which used oil is transported to the aggregation point in shipments of no more than
55 gal (208.20 L). Used oil aggregation points may also accept used oil from household DIYs
(40 CFR 279.1)
99. Used Oil Burner
A facility where used oil not meeting the specification requirements is burned for energy
recovery (40 CFR 279.1).
100. Used Oil Collection Center
Any site or facility that is registered, licensed, permitted, or recognized by a state, county,
or municipal government to manage used oil and accepts or aggregates and stores used oil
collected from used oil generators who bring used oil to the collection centers in shipments of
no more than 55 gal (208.20 L). Used oil collection centers may accept used oil from
household DIYs (40 CFR 279.1).
101. Used Oil Fuel Marketer
Any person who conducts either of the following activities (40 CFR 279.1):
a. Directs a shipment of off-specification used oil from their facility to a used oil
burner, or
b First claims that used oil that is to be burned for energy recovery meets used oil fuel
specifications.
102. Used Oil Generator
Any person, by site, whose act or process produces used oil or whose act first causes used
oil to become subject to regulation (40 CFR 279.1).
103. Used Oil Processor/Re-refiner
A facility that processes used oil (40 CFR 279.1).
104. Used Oil Transfer Facility
Any transportation related facility, including loading docks, parking areas, storage areas,
and other areas where shipments of used oil are held for more than 24 hours during the normal
course of transportation and not longer than 35 days (40 CFR 279.2).
105. Used Oil Transporter
Any person who transports used oil, any person who collects used oil from more than one
generator and transports the collected oil, and owners and operators of used oil transfer
facilities. Used oil transporters may consolidate or aggregate loads of used oil for purposes of
transportation, but with the following exception, may not process used oil. Transporters may
Phase 1 - Section 4
Hazardous Waste Management
4-18
-------
conduct incidental processing operations that occur in the normal course of used oil
transportation (e.g., settling and water separation), but that are not designed to produce or
make more amenable for production used oil derived products or used oil fuel (40 CFR
279.1).
106. Waste Explosives
This includes waste which has the potential to detonate and bulk military propellants which
cannot be safely disposed of through other modes of treatment (40 CFR 265.382).
107. Wastewater Treatment Unit
A device that is part of a wastewater treatment facility subject to regulation under section
402 or 307 of the CWA and receives and treats or stores an influent wastewater that is a
hazardous waste (as defined in 40 CFR 261 3) or that generates and accumulates a wastewater
treatment sludge that is a hazardous waste, or treats or stores a wastewater treatment sludge
and meets the definition of tank or tank system (40 CFR 260.10).
108. Wastewaters
Wastes that contain less than one percent by weight total organic compounds (40 CFR
268 2)
109. Zone of Engineering Control
An area under the control of the owner/operator that upon detection of a hazardous waste
release, can be readily cleaned up before the release of hazardous waste or hazardous
constituents to groundwater or surface water (40 CFR 260 10)
110. Section 6002
a. Application of Section. Except as provided in subsection
b. A procuring agency shall comply with the requirements set forth in this section and
any regulations issued under this section, with respect to any purchase or acquisition
of a procurement item where the purchase price of the item exceeds $10,000 or
where the quantity of such items or of functionally equivalent items purchased or
acquired in the course of the preceding fiscal year was $10,000 or more. (42 USC
6962)
F. Records to Review
Generator (including TSDFs if they are also generators):
• Notification of Hazardous Waste Activity (EPA ID No.),
• Hazardous waste manifests;
Phase 1 - Section 4
Hazardous Waste Management
4-19
-------
• Manifest exception reports;
• Biennial reports;
• Inspection Logs;
• Delistings;
• Speculative accumulation records;
• Land disposal restriction certifications;
• Employee training documentation;
• Contingency plan; and
• Notifications of hazardous waste oil fuel marketing or blending activity.
In addition to the above, TSDFs would require:
• Permits, if issued, otherwise Part A Application;
• Unmanifested waste reports;
• TSDF audit reports (Inspection log);
• Waste analysis plan(s);
• Operating record;
• Groundwater monitoring records and annual reports (where required);
• Biennial reports Closure/Post Closure Plans Closure/Post Closure Notices (where
applicable); and
• Other documents as required by the Permit.
G. Physical Features to Inspect
• Disposal sites;
• Accumulations points;
• Incinerators;
• Vehicles used for transport;
• Storage facilities (including drums);
• Surface impoundments;
• OB/OD sites;
• Used oil storage sites;
• Marshaling facilities; and
• Generation points.
Phase 1 - Section 4
Hazardous Waste Management
4-20
-------
H. Guidance for Checklist Users
Refer To
Checklist items
Page Numbers
All Facilities
HW I through HW 2
4-25
HW 3 through HW 4
4-26
All Sizes of Generators
HW.5
4-27
HW 6 through HW 7
4-28
Conditionally Exempt Small Quantity
HW 8
4-29
Generators (CESQG)
HW 9 through HW 10
4-30
HW 11 through HW 13
4-31
Small Quantity Generators (SQG)
General
HW 14 through HW 16
4-32
HW 17 through HW 19
4-33
Personnel Training
HW 20 through HW 21
4-34
Containers
HW 22 through HW 23
4-34
HW 24 through HW 27
4-35
Satellite Accumulation Points
HW 28
4-36
Container Storage Areas
HW 29
4-36
HW 30 through HW 31
4-37
Disposal of Restricted Wastes
HW 32
4-38
HW 33
4-38
HW 34 through HW 35
4-39
HW 36
4-40
Phase 1 - Section 4
Hazardous Waste Management
4-21
-------
Refer To
Checklist Items
Pagefltamfcm
Generators
General
HW.37
4-40
HW 38 through HW 42
4-41
HW 43
4-42
Personnel Training
HW 44 and HW.45
4-43
Contingency Plans and
Emergency Coordinators
HW 46 through HW 47
4-44
Containers
HW.48 through HW.49
4-45
HW.50 through HW.53
4-46
HW 54 through HW 55
4-47
Satellite Accumulation Points
HW.56
4-48
Container Storage Areas
HW 57 through HW .59
4-48
Containment Buildings
HW.60
4-49
HW.61
4-50
HW 62 through HW 63
4-51
HW.64 through HW.66
4-52
HW 67
4-52
Disposal of Restricted Waste
HW.68 through HW 69
4-53
HW.70 through HW 72
4-54
Transportation of Hazardous Waste
HW.73 through HW 74
4-55
HW.76 through HW.77
4-56
Phase 1 - Section 4
Hazardous Waste Management
4-22
-------
Refer To
Chemist Jtews
Page lumbers
TSDFs
General
HW 78 through HW 79
4-56
HW 80 through HW 81
4-57
HW 82 through HW 84
4-58
HW 85 through HW 87
4-59
Personnel Training
HW 88 through HW 89
4-60
Containers
HW.90 through HW 93
4-61
HW 94 through HW 95
4-62
Container Storage Areas
HW 96 through HW.98
4-62
Containment Buildings
HW 99
4-63
HW 100
4-64
HW 101
4-65
HW.102 through HW 105
4-66
Restricted Wastes
HW 106 through HW 107
4-67
HW.108 through HW 109
4-68
HW 110 through HW.lll
4-69
Emissions from Process Vents
HW 112 through HW 113
4-70
HW 114
4-71
Air Emissions Standards for
HW 115
4-72
Equipment Leaks
HW.116
4-73
HW 117 through HW 118
4-74
HW.119
4-75
HW 120
4-76
HW 121 through HW 122
4-77
Documentation Requirements
HW 123 through HW 124
4-78
HW 125 through HW 126
4-79
HW 127
4-80
HW.128 through HW 130
4-81
HW 131 through HW.133
4-82
HW 134
4-83
Surface Impoundments
HW 135
4-83
Waste Piles
HW.136
4-84
Land Treatment Units
HW 137
4-85
Hazardous Waste Landfills
HW 138
4-85
Closure
HW 139 through HW 143
4-86
Phase 1 - Section 4
Hazardous Waste Management
4-23
-------
Refer To
Checklist Items
JPsge Numbers
Additional Requirements for Permitted
TSDFs
General
HW 144
4-86
HW 145 through HW 148
4-87
HW 149 through HW 150
4-88
HW 152 through HW 156
4-89
Surface Impoundments
HW 157
4-90
HW 158 through HW 159
4-91
HW 160 through HW. 165
4-92
HW 166
4-93
Waste Piles
HW 167
4-93
HW.168
4-94
HW.169 through HW 171
4-95
Land Treatment Units
HW 172 through HW. 174
4-96
HW.175 through HW 176
4-97
HW 177 through HW 178
4-98
Hazardous Waste Landfills
HW.179
4-99
HW 180
4-100
HW 181 through HW 182
4-101
Incinerators
HW 183 through HW 185
4-102
HW 186
4-103
Miscellaneous Units
HW 187
4-103
HW 188 through HW 189
4-104
Additional Requirements for Interim
Status TSDFs
General
HW 190 through HW 191
4-110
HW 192 through HW 194
4-111
HW 195 through HW 198
4-112
Surface Impoundments
HW 199
4-113
HW 200 through HW 202
4-114
Waste Piles
HW.203
4-115
HW 204 through HW 205
4-116
HW 206
4-117
Land Treatment Units
HW.207
4-117
HW 208 through HW 210
4-118
Hazardous Waste Landfills
HW 211
4-119
Incinerators
HW 212 through HW.213
4-120
HW.214 through HW.216
4-121
Thermal Treatment
HW 217 through HW 218
4-122
HW.219
4-123
Chemical/Physical/Biological
HW 220
4-123
Treatment
HW 221 through HW.222
4-124
Phase 1 - Section 4
Hazardous Waste Management
4-24
-------
Refer To
Checklist Items
Winters
Export/Import of Hazardous Waste
HW 223
4-124
HW 224 through HW 227
4-125
HW 228 through HW 230
4-126
Used Oil
General
HW 231
4-127
Used Oil Generators
HW 232 through HW 233
4-127
HW 234 through HW 238
4-128
Used Oil Collection Centers and
HW 239 through HW 241
4-129
Aggregation Points
Used Oil Transportation
HW 242
4-129
HW 243 through HW 247
4-130
HW 248 through HW 250
4-131
Used Oil Burners
HW 251 through HW 253
4-132
HW 254 through HW 256
4-133
HW 257
4-134
Used Oil Marketing
HW 258 through HW 260
4-134
HW 261 through HW 263
4-135
Waste Minimization/Pollution
Prevention
HW 264
4-136
Phase 1 - Section 4
Hazardous Waste Management
4-25
-------
Compliance Category:
Hazardous Waste Maeag^iweat
Regulatory Re
-------
Compliance Category:
Bajtardoas Waste Management
Regulatory Requirements:
Reviewer Cheeks:
HW 3 Facilities are required
to comply with state and
local regulations concerning
hazardous waste
management (EO 12088,
Sect 1-1, Federal Facilities
Compliance Act, Section
102)
Verify that the facility is abiding by state and local hazardous waste
requirements
Verify that the facility is operating according to permits issued by the state or
local agencies where approved
(NOTE Issues typically regulated by state and local agencies include
- Additional manifesting requirements
- More frequent reporting requirements
- Transportation
- Identification of special waste or waste categories
- Regulation of specific substances as hazardous waste such as medical,
pathological, and infectious waste, used oil, explosives, used batteries
- Small and very small quantity generator requirements
- RCRA permitting of oil/water separators
- Disposal requirements
- Construction and operation of storage and disposal facilities
- Satellite accumulation point requirements
- Container marking and labeling requirements)
Verify that the actions detailed in compliance agreements are being taken
according to the schedule established in the agreements
HW 4 Specific persons
should be designated
responsible for hazardous
waste storage areas, and the
precise nature of their
responsibilities should be
specified (MP)
Verify that specific individuals have been designated responsible for
hazardous waste storage areas
Verify that the individuals designated responsible for hazardous waste storage
areas are aware of the precise nature of their responsibilities
Verify that required hazardous waste handling training is in personnel file
Ail Sizes or Generators
Phase 1 - Section 4
Hazardous Waste Management
4-27
-------
Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Cheeks:
HW 5 Facilities that
generate solid wastes must
determine if the wastes are
hazardous wastes (40 CFR
261 3,261 4(b), 261 24,
262 11)
Determination of whether or not a waste is a hazardous waste can be done
through one of the following
- Knowledge of all the constituents of the waste (MSDSs)
- Laboratory analysis
- Knowledge of processes used
- A sample which is collected for the sole purpose of testing to determine
characteristics or composition (SW 846))
(NOTE Determination of whether or not a waste is a hazardous waste can be
done through one of the following
- Knowledge of all the constituents of the waste (MSDSs) and whether it is
listed in 40 CFR 261
- Laboratory analysis
- Knowledge of processes and/or materials used)
(NOTE Unidentified waste materials and spilled hazardous materials may
have to be disposed of as hazardous waste depending on their constituents or
characteristics.)
Discuss with staff how wastes generated on the facility were identified and
classified
Determine if the facility followed EPA criteria for identifying the
characteristics of hazardous waste and EPA's listed wastes in 40 CFR 261 (see
Appendices 4-1,4-2, 4-3, and 4-4)
Determine whether the facility generates, transports, treats, stores, or disposes
of any hazardous waste (see Appendices 4-1, 4-2,4-3, and 4-4 for guidance)
and the quantity
Waste documentation must be in facility records
(NOTE. The following solid wastes are not considered to be hazardous
wastes
- Household waste
- Fly ash waste, bottom ash waste, and flue gas emission control waste
generated primarily from the combustion of coal or other fossil fuels
except for facilities that burn hazardous waste
- Drilling fluids, produced waters and other wastes affiliated with the
explorations, development, or production of crude oil, natural gas, or
geothermal energy
- Solid waste which consists of discarded arsenical-treated wood or wood
products which fail the test for Toxicity Characteristics for arsenic and
which is not a hazardous waste for any other reason if the waste is
generated by persons who utilize the arsenical treated wood and wood
products for those materials intended end use
- Petroleum contaminated media and debris that fail the test for Toxicity
Characteristic (Hazardous Waste Codes DO 18 through D043 only) and are
required to meet the corrective action regulations under 40 CFR part 280
(see the Section titled Storage Tank Management)
Phase 1 - Section 4
Hazardous Waste Management
4-28
-------
Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Cheeks:
HW 5 Continued
- Used chlorofluorocarbon refrigerants from totally enclosed heat transfer
equipment, including mobile air conditioning systems, mobile refrigeration
and commercial and industrial air conditioning and refrigeration systems
that use chlorofluorocarbons as the heat transfer fluid in a refrigeration
cycle, provided that the refrigerant is reclaimed for further use
- Non-tern plated used oil filters that are not mixed with a listed hazardous
waste if these oil filters have been gravity hot-drained using one of the
following methods
— puncturing the filter anti-drain back valve or the filter dome end and
hot-draining
— hot-draining and crushing
-- dismantling and hot-draining
— any other equivalent hot-draining method which will remove used oil)
Verify that listed wastes are tested for reactivity, corrosivity, ignitibility, and
toxicity characteristics
Determine if wastes contain contaminants in greater concentrations than the
toxicity characteristics listed in Appendix 4-3
Verify that all data used for determination, including quality assurance data, is
maintained and kept available for reference or inspection
HW 6 Facilities which
claim that a particular
material is not a solid waste
or is conditionally exempt
from regulation as a
hazardous waste are required
to provide specific
documentation (40 CFR
261 2(0)
Determine if the facility has any wastes that are typically handled as
hazardous wastes that it claims are exempt
Verify that for these wastes, the facility can demonstrate that there is a known
market or distribution for the material and that they meet the terms of the
exclusion or exemption
Verify that documentation is provided that indicates the material is not a
waste, or is exempt from regulation
(NOTE One example of documentation are contracts showing that a second
person uses the material as an ingredient in a production process.)
Verify that if the facility is claiming to recycle material, the equipment for the
recycling is actually at the facility and in working order
HW 7 Areas where
containers of hazardous
waste are stored should have
secondary containment
(MP)
Verify that the areas where containers of hazardous waste are stored have
secondary containment
Phase 1 - Section 4
Hazardous Waste Management
4-29
-------
Compliance Category:
Hazardous Waste Management
Regulatory Reqt»lrem
-------
Compliance Category:
Bazai'does Waste Mauageateat
Regulatory Requlrenteats;
Ifcviewer Chafes:
HW 9 CESQG personnel
who handle hazardous waste
should meet certain training
requirements (MP)
Verify that the training program is directed by a person trained in hazardous
waste management procedures
Verify that the training program includes the following
- Contingency plan implementation (emergency procedures, equipment, and
systems)
- Key parameters for automatic waste feed cut-off system
- Procedures for using, inspecting, and repairing emergency and monitoring
equipment
- Operation of communications and alarm systems
- Response to fire or explosion
- Response to leaks or spills
- Waste turn in procedures
- Identification of hazardous wastes
- Container use, marking, labeling, and on-base transportation
- Manifesting and off-base transportation
- Accumulation point management
- Personnel health and safety and fire safety
- Shutdown procedures
Verify that new employee training is completed within six months of
employment
Verify that an annual review of initial training is provided
Verify that employees do not work unsupervised until training is completed
Verify specifically that accumulation point managers and hazardous waste
handlers have been trained
HW 10 Training records
must be maintained for all
CESQG staff who manage
hazardous waste (MP)
Examine training records and verify they include the following
- Job title and description for each employee by name
- Written description of how much training each position will obtain
- Documentation of training received by name
Determine if training records are retained for three years after employment at
the facility
Phase 1 - Section 4
Hazardous Waste Management
4-31
-------
Compliance Category:
Hazardous Waste Maoageineat
Regulatory Requirements?
Itevtewr Cheeks:
HW 11 Empty containers at
CESQGs previously holding
hazardous wastes must meet
the regulatory definition of
empty before they are
exempted from hazardous
waste requirements (40 CFR
261 7)
Verify that for containers or inner liners holding hazardous wastes-
- Wastes are removed that can be removed using common practices
- No more than 2 5 cm (1 in ) of residue remains
- If the container is less than or equal to 110 gal (416 40 L), no more than 3
percent by weight of total container capacity remains
- When the container is greater than 110 gal (416 40 L), no more than 0 3
percent by weight of the total container capacity remains
Verify that for containers that hold a compressed gas, the pressure in the
container approaches atmosphere
Verify that for containers or inner liners that held an acute hazardous waste
listed in Appendix 4-5, that one of the following is done
- It is triple rinsed
- It is cleaned by another method identified through the literature or testing
as achieving equivalent removal
- The inner liner is removed
HW 12 Containers at
CESQGs should be managed
in accordance with specific
management practices (MP)
Verify the following by inspecting storage areas
- Containers are not stored more than two high and have pallets between
them
- Containers of highly flammable wastes are electrically grounded (check
for clips and wires and make sure wires lead to ground rod or system)
- At least 3 ft (0 91 m) of aisle space is provided between rows of
containers
HW.13 Containers of
hazardous waste should be
kept in designated storage
areas at CESQGs (MP)
Verify that all hazardous waste containers are identified and stored in
appropriate areas
(NOTE Any unidentified contents of solid waste containers and/or
containers not in designated storage areas must be tested to determine if solid
or hazardous waste requirements apply )
Small Quantity Generators (SQGs)
General
Phase 1 - Section 4
Hazardous Waste Management
4-32
-------
Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 14 Generators of more
than 100 kg (220 46 lb) but
less than 1000 kg (2204 62
lb) of hazardous waste per
month may qualify as a SQG
which can accumulate
hazardous waste onsite for
180 days without a permit if
specific conditions are met
(40CFR262 34(d)(1),
262 34(d)(4), 262 34(e) and
262 34(0)
Inspect containers, storage, and records
Verify that no more than 1000 kg (2204 62 lb) of hazardous waste is
generated in any month
Verify that the onsite accumulation time does not exceed 180 days
(NOTE For a SQG the accumulation start date begins when the first waste is
poured/placed into the waste container, except for at satellite accumulation
points)
(NOTE The 180 day time period is extended to 270 days if the waste must
be transported more than 200 miles to a TSDF This extension does not apply
if a TSDF is available within 200 miles and the facility chooses to transport
the waste to a farther away TSDF)
Verify that no more than 6000 kg (13,227 73 lb) is allowed to accumulate at
the facility
Verify that containers are marked with the date accumulation began and the
words HAZARDOUS WASTE
Verify that the containers and the areas where containers are stored meet the
requirements outlined in the subsections pertaining to SQG
(NOTE. When a SQG exceeds the quantity generation or amount
accumulation it becomes subject to either Generator or TSDF requirements
When a SQG exceeds the storage time limitation, the SQG becomes subject to
all storage facility and permitting requirements )
HW 15 SQGs that generate,
transport, or handle
hazardous wastes must
obtain an EPA identification
number (40 CFR 262 12(a)
and 262 12(b); 40 CFR
265 11)
Examine documentation from EPA for the facility's generator identification
number
Verify that correct identification number is used on all appropriate
documentation (i e , manifests)
HW 16 A SQG must not
offer its hazardous waste to
transporters or to TSDFs that
have not received an EPA
identification number (40
CFR 262 12(c))
Verify that all transporters of hazardous waste of TSDFs have an EPA
identification number by examining records pertaining to disposal contract
awards
Phase 1 - Section 4
Hazardous Waste Management
4-33
-------
Compliance Category;
Bazardoas Waste Maaagwneat
Regulatory Kequlremeats;
Ch
-------
Compliance Category:
Hazardous Waste Maaagemeat
Regulatory Requirements:
Reviewer Cheeks:
HW 20 SQG personnel are
required to be thoroughly
familiar with proper waste
handling and emergency
procedures (40 CFR
234(d)(5)(m))
Verify that personnel are thoroughly familiar with waste handling and
emergency procedures relevant to their responsibilities during normal facility
operation and emergencies
HW21 Training records
must be maintained for all
SQG staff who manage
hazardous waste (MP)
Examine training records and verify they include the following
- Job title and description for each employee by name
- Written description of how much training each position will obtain
- Documentation of training received by name
Determine if training records are retained for three years after employment at
the facility
Containers
HW 22 Empty containers at
SQGs previously holding
hazardous wastes must meet
the regulatory definition of
empty before they are
exempted from hazardous
waste requirements (40 CFR
261 7)
Verify that for containers or inner liners holding hazardous waste.
- Wastes are removed that can be removed using common practices
- No more than 2 5 cm (1 in ) of residue remains
- If the container is less than or equal to 110 gal (416 40 L), no more than 3
percent by weight of total container capacity remains
- When the container is greater than 110 gal (416 40 L), no more than 0 3
percent by weight of the total container capacity remains
Verify that for containers that held a compressed gas, the pressure in the
container approaches atmosphere
Verify that for containers or inner liners that held an acute hazardous waste
listed in Appendix 4-5, one of the following is done
- It is triple rinsed
- It is cleaned by another method identified through the literature or testing
as achieving equivalent removal
- The inner liner is removed
HW 23 Containers used to
store hazardous waste at
SQGs must be in good
condition and not leaking
(40 CFR 262 34 (d)(2) and
40 CFR 265 171)
Verify that containers are not leaking, bulging, rusting, damaged or dented
Verify that waste is transferred to a new container or managed in another
appropriate manner when necessary
Phase 1 - Section 4
Hazardous Waste Management
4-35
-------
Compliance Category:
Razardoas Waste Ma oagetneat
Regulatory Requirements:
Review* Checks:
HW 24 Containers used at
SQGs must be made of or
lined with materials
compatible with the waste
stored in them (40 CFR
262 34(d)(2) and 40 CFR
265 172)
Verify that containers are compatible with waste, in particular, check that
strong caustics and acids are not stored in metal drums
HW 25 Containers of
hazardous waste at SQGs
must be closed during
storage and handled in a safe
manner (40 CFR
262 34(d)(2) and 40 CFR
265 173)
Verify that containers are closed except when it is necessary to add or remove
waste (check bungs on drums, look for funnels)
Verify that handling and storage practices do not cause damage to the
containers or cause them to leak
HW 26 The handling of
incompatible wastes, or
incompatible wastes and
materials in containers at
SQGs must comply with
safe management practices
(40 CFR 262 34(d)(2) and
40 CFR 265 177)
Verify that incompatible wastes or incompatible wastes and materials are not
placed in the same containers unless it is done so that it does not
- Generate extreme heat or pressure, fire, or explosion, or violent reaction
- Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient
quantities to threaten human health
- Produce uncontrolled flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosions
- Damage the structural integrity of the device or facility
- By any other like means threaten human health
(NOTE Incompatible wastes as listed in Appendix 4-6 should not be placed
in the same drum )
Verify that hazardous wastes are not placed in an unwashed container that
previously held an incompatible waste or material
Verify that containers holding hazardous wastes incompatible with wastes
stored nearby in other containers, open tanks, piles, or surface impoundments
are separated or protected from each other by a dike, berm, wall or other
device
HW.27 Containers of
hazardous waste at SQGs
should be managed in
accordance with specific
management practices (MP)
Determine the following by inspecting containers and storage areas
- Containers are not stored more than 2 high and have pallets between them
- Containers of highly flammable wastes are electrically grounded (check
for clips and wires and make sure wires lead to ground rod or system)
- At least 3 ft (0 91 m) of aisle space is provided between rows of
containers
Satellite Accumulation Points
Phase 1 - Section 4
Hazardous Waste Management
4-36
-------
Compliance Category:
Hazardons Waste Management
Regulatory Requirements;
Reviewer Cheeks:
HW 28 All SQGs may
accumulate as much as 55
gal of hazardous waste or 1
qt of acutely hazardous
waste in containers at or near
any point of initial
generation without
complying with the
requirements for onsite
storage if specific standards
are met (40 CFR 262 34(c))
(NOTE This type of storage is often referred to as a satellite accumulation
point)
Verify that the satellite accumulation point is at or near the point of generation
and is under the control of the operator of the waste generating process
Verify that the containers are in good condition and are compatible with the
waste stored in them and that the containers are kept closed except when
waste is being added or removed
Verify that the containers are marked HAZARDOUS WASTE or other
appropriate identification
(NOTE- See Appendices 4-1,4-2, 4-3, 4-4, and 4-5 for a guidance list of
hazardous and acute wastes )
Verify that when waste is accumulated in excess of quantity limitations the
following actions are taken by interviewing the shop managers
- The excess container is marked with the date the excess amount began
accumulating
- The waste is transferred to a 90 day or permitted storage area within three
days
Container Storage Areas
HW 29. Containers of
hazardous waste at SQGs
should be kept in storage
areas designated in the
management plan (MP)
Verify that all containers are identified and stored in appropriate areas
(NOTE Any unidentified contents of solid waste containers and/or
containers not in designated storage areas must be tested to determine if solid
or hazardous waste requirements apply )
Phase 1 - Section 4
Hazardous Waste Management
4-37
-------
Compliancy Category:
Hazardous Waste Maaagsweat
Regulatory Requirenwwts:
Reviewer Checks:
HW.30 SQG storage areas
must be designed,
constructed, maintained, and
operated to minimize the
possibility of a fire,
explosion, or any unplanned
release of hazardous waste
(40 CFR 262 34(d)(4) and
40 CFR 265 30 through
265 37)
Determine if the following required equipment is easily accessible and in
working condition by inspecting the SQG storage areas.
- Internal communications or alarm system capable of providing immediate
emergency instruction to facility personnel
- A telephone or hand-held two way radio
- Portable fire extinguishers and special extinguishing equipment (foam,
inert gas, or dry chemicals)
- Spill control equipment
- Decontamination equipment
- Fire hydrants or other source of water (reservoir, storage tank, etc ) with
adequate volume and pressure, foam producing equipment, or automatic
sprinklers, or water spray systems.
Determine if equipment is tested and maintained as necessary to insure proper
operation in an emergency
Verify that sufficient aisle space is maintained to allow unobstructed
movement of personnel, fire protection equipment, spill control equipment,
and decontamination equipment to any area of the operation
Verify that police, fire departments, and emergency response teams are
familiar with the layout of the facility, properties of the waste being handled,
and general operations as appropriate for the type of waste and potential need
for such services
Verify that the hospital is familiar with the site and the types of injuries that
could result in an emergency as appropriate for the type of waste and potential
need for such services
HW.31 SQGs must conduct
weekly inspections of
container storage areas (40
CFR 262.34(d)(2) and
265 174).
Verify that inspections are conducted at least weekly to look for leaking
containers and signs of deterioration of containers
Disposal of Restricted Wastes
HW 32 SQGs must test their
wastes or use process
knowledge to determine if
they are restricted from land
disposal (40 CFR 268 7)
Determine whether the generator tests for restricted wastes
Determine if the facility generates restricted wastes by reviewing test results
(see Appendix 4-7)
Phase 1 - Section 4
Hazardous Waste Management
4-38
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 33. When a SQG is
managing a restricted waste
a notice must be issued to
the TSDF in writing of the
appropriate treatment
standards and prohibition
levels (40CFR 268 7(a)(1)
through 268 7(a)(3),
268 7(a)( 10))
Verify that for restricted waste that does not meet the applicable treatment
standards or exceeds the applicable prohibition levels, the notice is issued and
includes
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- For hazardous debris, the contaminants subject to treatment and the
following statement "This hazardous debris is subject to the alternative
treatment standards of 40 CFR 268 45"
- The waste analysis data, when available
Verify that for restricted waste that can be land disposed without further
treatment (this does not include debris that does not contain hazardous waste)
the notice includes
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- The waste analysis data, when available
- The signature of an authorized representative certifying that the waste
complies with the treatment standards of 40 CFR 268
Verify that for restricted waste that is subject to an exemption from a
prohibition of the type of land disposal used, the notice states that the waste is
not prohibited from land disposal and includes
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- The waste analysis data, when available
- For hazardous debris, the contaminant subject to treatment
- The date the waste is subject to prohibitions
(NOTE SQGs with tolling agreements are required to comply with
notification and certification requirements for the initial shipment of waste
subject to the agreement)
Phase 1 - Section 4
Hazardous Waste Management
4-39
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 34 SQGs that are
managing prohibited wastes
in tanks, containers, or
containment buildings and
treating the waste to meet
applicable treatment
standards, must develop and
follow a written waste
analysis plan (40 CFR
268 7(a)(4) and
268 7(a)(10))
Verify that the plan describes the procedures that the generator will carry out
to comply with treatment standards
(NOTE' SQGs treating hazardous debris under the alternative treatment
standards are not required to conduct waste analysis)
Verify that the plan is kept onsite and
- The plan is based on a detailed chemical and physical analysis of
representative sample of the prohibited waste being treated
- The plan is filed with the EPA Regional Administrator or State authorized
official at least 30 days prior to the treatment activity, with delivery
verified
(NOTE SQGs with tolling agreements are required to comply with
notification and certification requirements for the initial shipment of waste
subject to the agreement)
HW 35. SQGs are required
to keep specific documents
pertaining to restricted
wastes onsite (40 CFR
268 7(a)(5) through
268 7(a)(7) and
268 7(a)(10))
Verify that if the facility is using generator knowledge to determine whether a
waste meets land disposal restriction requirements, the supporting data used in
making this determination is retained in the facility operating record
Verify that if the facility has determined whether a waste is restricted using
appropriate test methods, the waste analysis data is retained
Verify that if the facility has determined that they are managing a restricted
waste that is excluded from the definition of a hazardous waste or solid waste
or exempt from RCRA Subtitle C, a one-time notice is placed in the facilities
files stating that the generated waste is excluded.
Verify that a copy of all notices, certifications, demonstrations, waste analysis
data and other documentation is kept for at least five years from the date that
the waste was last sent to onsite or offsite treatment, storage, or disposal
Verify that SQGs with tolling agreement retain the agreement and copies of
notification and certification for at least three years after the agreement
expires
Phase 1 - Section 4
Hazardous Waste Management
4-40
-------
Compliance Category:
Bamdoas Waste Maoagemeat
Regulatory Requirements;
Iterietyer Checks:
HW 36 The storage of
hazardous waste that is
restricted from land disposal
is not allowed unless
specific conditions are met
(40 CFR 268 50)
Verify that land disposal restricted waste is not stored at the facility unless
the SQG is storing the wastes in tanks, containers, or containment buildings
onsite only for the purpose of accumulating enough quantity of hazardous
waste to facilitate proper recovery, treatment, or disposal and all appropriate
standards for containers, tanks, and containment buildings are met
Verify that transporters do not store manifested shipments of land disposal
restricted wastes for more than 10 days
(NOTE The prohibition on storage does not apply to hazardous wastes that
have met treatment standards )
Verify that liquid hazardous wastes containing PCBs at concentrations greater
than 50 ppm are stored at a site that meets the requirements of 40 CFR
761 65(b) (see the section titled Toxic Substances Management) and is
removed from storage within one year of the date it was first placed into
storage
Generators
General
HW 37 Generators may
accumulate hazardous waste
onsite for 90 days or less
without a permit or interim
status provided they meet
certain conditions (40 CFR
262 34(a)(2), 262 34(a)(3)
and 262 34(b))
Inspect each accumulation point and interview the accumulation point
manager Verify that
- The recorded start date indicates no container or tank has been
accumulating a hazardous waste longer than 90 days (unless granted a 30
day extension)
- Each container and tank is labeled or marked clearly with the words
HAZARDOUS WASTE
(NOTE For a generator the accumulation start date begins when the first
waste is poured/placed into the waste container, except for at satellite
accumulation points)
(NOTE A generator who meets these standards is exempt from meeting the
closure requirements outlined in 40 CFR 265 110 through 265 156, except for
265 111 and 265 114)
(NOTE A generator who accumulates hazardous waste for more than 90
days (without an extension), is subject to all TSDF and permitting
requirements)
Phase 1 - Section 4
Hazardous Waste Management
4-41
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements?
Reviewer Cheefes:
HW.38. A generator that
generates, transports, or
handles hazardous wastes
must obtain an EPA
identification number (40
CFR 262 12(a) and
262 12(b), 40 CFR 264 11,
40 CFR 265 11)
Examine documentation from EPA for the facility's generator identification
number
Verify that the correct identification number is used on all appropriate
documentation (i e., manifests)
HW.39. Generators must not
offer their waste to
transporters or TSDFs that
have not received an EPA
identification number (40
CFR 262 12(c))
Verify that all transporters of hazardous wastes or TSDFs used by the
generator have an EPA identification number by examining records pertaining
to disposal contract awards
HW 40 Generators of
hazardous waste must
submit a biennial report to
the Regional Administrator
by 1 March of even
numbered years (40 CFR
262 40(b) and 262 41(a))
Verify that the biennial report (EPA Form 8700-13A) is complete and was
submitted in a timely manner
Verify that copies are kept for three years
(NOTE Reporting for exports of hazardous waste is not required )
(NOTE This does not apply if an annual report was submitted to the state )
(NOTE Periods of retention of records may be extended automatically
during the course of any unresolved enforcement action or at the request of
the EPA Administrator)
HW41 Generators are
required to use manifests,
file manifest exception
reports, and maintain records
(40 CFR 262 40(b),
262 40(d), 262 42(a))
Verify that manifests are used when shipping the waste offsite
Verify that exception reports are filed with the EPA Regional Administrator if
a copy of the manifest is not received within 45 days of after the waste is
accepted by the initial transporter
Verify that manifests and exception reports are kept for three years
(NOTE Periods of retention for reports may be extended automatically
during the course of any unresolved enforcement action )
HW 42 Generators are
required to keep records of
waste analyses, tests, and
waste determinations (40
CFR 262 40(c))
Verify that the appropriate records are kept for three years from the date the
waste was last sent to the onsite or offsite TSDF
(NOTE Periods of retention for reports may be extended automatically
during the course of any unresolved enforcement action or at the request of
the EPA Administrator)
Phase 1 - Section 4
Hazardous Waste Management
4-42
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Compliance Category:
Hastarctoas Waste Maaag^meot
itertewcr Chafes:
HW 43. Generator storage
areas must be designed,
constructed, maintained, and
operated to minimize the
possibility of a fire,
explosion, or any unplanned
release of hazardous waste
(40 CFR 262 34(a)(4) and
40 CFR 265 30 through
265 37)
Determine if the following required equipment is easily accessible and in
working condition at the storage area'
- Internal communications or alarm system capable of providing immediate
emergency instruction to facility personnel
- A telephone or hand-held two way radio
- Portable fire extinguishers and special extinguishing equipment (foam,
inert gas, or dry chemicals)
- Spill control equipment
- Decontamination equipment
- Fire hydrants or other source of water (reservoir, storage tank, etc ) with
adequate volume and pressure, foam producing equipment, or automatic
sprinklers, or water spray systems
Determine if equipment is tested and maintained as necessary to insure proper
operation in an emergency
Verify that sufficient aisle space is maintained to allow unobstructed
movement of personnel, fire protection equipment, spill control equipment,
and decontamination equipment to any area of the operation
Verily that police, fire departments, emergency response teams are familiar
with the layout of the facility, properties of the waste being handled, and
general operations as appropriate for the type of waste and potential need for
such services
Verify that the hospital is familiar with the site and the types of injuries that
could result in an emergency as appropriate for the type of waste and potential
need for such services
Personnel Training
Phase 1 - Section 4
Hazardous Waste Management
4-43
-------
Compliance Category:
Bazai-dotts Waste Maaagtateat
Regulatory Requirements;
fcevietytr Checks:
HW.44 All facility
personnel who handle
hazardous waste must meet
certain training requirements
(40 CFR 262 34(a)(4), 40
CFR265 16(a) through
265 16(c))
Verify that the training program is directed by a person trained in hazardous
waste management procedures
Verify that the training program includes the following
- Contingency plan implementation (emergency procedures, equipment, and
systems)
- Key parameters for automatic waste feed cut-off system
- Procedures for using, inspecting, and repairing emergency and monitoring
equipment
- Operation of communications and alarm systems
- Response to fire or explosion
- Response to leaks or spills
- Waste turn in procedures
- Identification of hazardous wastes
- Container use, marking, labeling, and on-base transportation
- Manifesting and off-base transportation
• Accumulation point management
- Personnel health and safety and fire safety
- Shutdown procedures
Verify that new employee training is completed within six months of
employment/assignment
Verify that an annual review of initial training is provided
Verify that employees do not work unsupervised until training is completed
Verify specifically that accumulation point managers and hazardous waste
handlers have been trained
HW 45 Training records
must be maintained for all
facility staff who manage
hazardous waste (40 CFR
262.34(a)(4), 40 CFR
265.16(d) and 265 16(e))
Verify that training records include the following by examination:
- Job title and description for each employee by name
- Written description of how much training each position will obtain
- Documentation of training received by name
Determine if training records are retained for three years after employment at
the facility.
Contingency Plans and Emergency Coordinators
Phase 1 - Section 4
Hazardous Waste Management
4-44
-------
Compliance Category:
Hazardous Waste Maaagemeat
Regulatory Requirements;
Reviewer Checks:
HW 46 Generators must
have a contingency plan (40
CFR 262 34(a)(4) and 40
CFR 265 50 through
265 54)
(NOTE Generating activities may be addressed in the facility's SPCC plan or
other emergency plan, or if none exists, in a separate contingency plan )
Verify that the contingency plan is designed to minimize hazards to human
health or the environment from fires, explosions, or any unplanned sudden or
non-sudden release of hazardous waste or hazardous waste constituents
Verify that the plan includes the following
- A description of actions to be taken during an emergency
- A description of arrangements made with local police departments, fire
departments, hospitals, contractors, and State and local emergency
response teams as appropriate
- Names, addresses, and phone numbers of all persons qualified to act as
emergency coordinator
- A list of all emergency equipment at the facility and where this equipment
is required, located, and what it looks like
- An evacuation plan for facility personnel where there is a possibility
evacuation would be needed
Verify that copies of the contingency plan are maintained at the generation
sites and storage areas and also have been submitted to organizations which
may be called upon to provide emergency services
Verify that the contingency plan is routinely reviewed and updated, especially
when the facility is issued a new permit, the plan fails in an emergency, the
emergency coordinators change, the waste being handled changes, and/or the
list of emergency equipment changes
HW 47 Each generator must
have an emergency
coordinator on the facility
premises or on call at all
times (40 CFR 262 34(a)(4)
and 40 CFR 265 55)
Verify that, at all times, there is at least one employee at the facility or on call
with responsibility for coordinating all emergency response measures
Verify that the emergency coordinator is thoroughly familiar with the facility,
the characteristics of the waste handled, and the provisions of the contingency
plan In addition, verify the emergency coordinator has the authority to
commit the resources needed to carry out the contingency plan
Phase 1 - Section 4
Hazardous Waste Management
4-45
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Compliance Category:
fia&trdoas Waste Management
Regulatory Repircmeats:
Review* Checks:
HW.48 Emergency
coordinators at generators
must follow certain
emergency procedures
whenever there is an
imminent or actual
emergency situation (40
CFR 262 34(a)(4) and 40
CFR 265.56(a) through
265 56(0)
Verify that the emergency coordinator is required to follow these emergency
procedures-
- Immediately activate installations/CW facility alarms or communication
systems and notify appropriate base, state, and local response parties
- Identify the character, exact source, amount, and a real extent of any
released materials
- Assess possible hazards to human health or the environment, including
direct and indirect effects (e g , release of gases, surface runoff from water
or chemicals used to control fire or explosions, etc.)
- Stop processes and operations at the facility when necessary to prevent
fires, explosions, or further releases
- Collect and contain the released waste
- Remove or isolate containers when necessary
- Monitor for leaks, pressure buildup, gas generation, or ruptures in valves,
pipes, or other equipment whenever appropriate
- Provide for treatment, storage, or disposal of recovered waste,
contaminated soil, or surface water, or other material
- Ensure that no waste that may be incompatible with the released material is
treated, stored, or disposed of until cleanup is completed
- Ensure that all emergency equipment is cleaned and fit for its intended use
before operations are resumed
- Notify EPA, and appropriate state and local authorities when cleanup is
complete and operation resumes
HW 49 Generator operators
must record the time, date,
and details of any incident
that requires implementing
the contingency plan (40
CFR 262 34(a)(4) and 40
CFR 265 560))
Determine if incidents have been recorded and corrective actions taken
through a review of the facility operating records
Verify that written reports have been submitted to the EPA Regional
Administrator within 15 days after the incident
Containers
Phase 1 - Section 4
Hazardous Waste Management
4-46
-------
Compliance Category:
Hazawloas Waste Maaageweat
J>itotory Ktqulretneatsj
Jteviewtr Checks:
HW 50 Empty containers at
generators previously
holding hazardous wastes
must meet the regulatory
definition of empty before
they are exempted from
hazardous waste
requirements (40 CFR
261 7)
Verify that for containers or inner liners holding hazardous wastes
- Wastes are removed that can be removed using common practices
- No more than 2 5 cm (1 in ) of residue remains
- If the container is less than or equal to 110 gal (416 40 L), no more than 3
percent by weight of total container capacity remains
- When the contamer is greater than 110 gal (416 40 L), no more than 0.3
percent by weight of the total container capacity remains
Verify that for containers that held a compressed gas, the pressure in the
container approaches atmosphere
Verify that for containers or inner liners that held an acute hazardous waste
listed in Appendix 4-5 that one of the following is done
- It is triple rinsed
- It is cleaned by another method identified through the literature or testing
as achieving equivalent removal
- The inner liner is removed
Verify that the rinse water has been tested
HW.51 Containers used to
store hazardous waste at
generators must be in good
condition and not leaking
(40 CFR 262.34(a)(l)(i) and
265 171).
Verify that containers are not leaking, bulging, rusting, damaged or dented
Verify that waste is transferred to a new container or managed in another
appropriate manner when necessary
HW 52 Containers used at
generators must be made of
or lined with materials
compatible with the waste
stored in them (40 CFR
262 34(a)(l)(i) and
265 172)
Verily that containers are compatible with waste, in particular, check that
strong caustics and acids are not stored in metal drums
HW 53 Containers must be
closed during storage and
handled in a safe manner at
generators (40 CFR
262 34(a)(l)(i) and
265 173)
Verify that containers are closed except when it is necessary to add or remove
waste (check bungs on drums, look for funnels)
Verify that handling and storage practices do not cause damage to the
containers or cause them to leak
Phase 1 - Section 4
Hazardous Waste Management
4-47
-------
Compliancy Category:
Hazardoas Waste Management
Regulatory Requirements;
Reviewer Chutes:
HW 54 The handling of
incompatible wastes, or
incompatible wastes and
materials in containers at
generators must comply with
safe management practices
(40 CFR 262 34(a)(l)(i) and
265 177)
Verify that incompatible wastes or incompatible wastes and materials are not
placed in the same containers unless it is done so that it does not:
- Generate extreme heat or pressure, fire, or explosion, or violent reaction
- Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient
quantities to threaten human health
- Produce uncontrolled flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosions
- Damage the structural integrity of the device or facility
- By any other like means threaten human health or the environment
(NOTE Incompatible wastes as listed in Appendix 4-6 should not be placed
in the same drum )
Verify that hazardous wastes are not placed in an unwashed container that
previously held an incompatible waste or material
Verify that containers holding hazardous wastes incompatible with wastes
stored nearby in other containers, open tanks, piles, or surface impoundments
are separated or protected from each other by a dike, berm, wall, or other
device
HW.55 Containers used to
store hazardous waste at
generators should be
managed in accordance with
specific management
practices (MP)
Verify the following by inspecting container storage areas
- Containers are not stored more than 2 high and have pallets between them
- Containers of highly flammable wastes are electrically grounded (check
for clips and wires and make sure wires lead to ground rod or system)
- At least 3 ft (0 91 m) of aisle space is provided between rows of
containers
Satellite Accumulation Points
Phase 1 - Section 4
Hazardous Waste Management
4-48
-------
Compliance Category:
Haxardoas Waste MaoagenjeBt
Regulatory Jtaguittmettt*:
Reviewer Checks:
HW 56 Generators may
accumulate as much as 55
gal of hazardous waste or 1
qt of acutely hazardous
waste in containers at or near
any point of initial
generation without
complying with the
requirements for onsite
storage if specific standards
are met (40 CFR 262 34(c))
(NOTE- This type of storage is often referred to as a satellite accumulation
point)
Verify that the satellite accumulation point is at or near the point of generation
and is under the control of the operator of the waste generating process
Verify that the containers are in good condition and are compatible with the
waste stored in them and the containers are kept closed except when waste is
being added or removed.
Verify that the containers are marked HAZARDOUS WASTE or other
appropriate identification
(NOTE See Appendices 4-1,4-2,4-3,4-4, and 4-5 for a guidance list of
hazardous and acute hazardous wastes)
Verify by interviewing the shop managers that when waste is accumulated in
excess of quantity limitations, the following actions are taken
- The excess container is marked with the date the excess amount began
accumulating
- The waste is transferred to a 90 day or permitted storage area within three
days.
Container Storage Areas
HW 57 At generators,
containers of hazardous
waste should be kept in
designated storage areas
(MP)
Verify that all containers are identified and stored in appropriate areas
(NOTE. Any unidentified contents of solid waste containers and/or
containers not in designated storage areas must be tested to determine if solid
or hazardous waste requirements apply)
HW58 Containers holding
ignitable or reactive waste
must be located 15 m (50 ft)
from the property line of the
facility (40 CFR
262 34(a)(l)(i) and
265 176)
Determine the distance from storage containers holding ignitable or reactive
waste to the property line
HW 59 Generator personnel
must conduct weekly
inspections of container
storage areas (40 CFR
262 34(a)(l)(i) and
265 174)
Verify that inspections are conducted at least weekly to look for leaking
containers and signs of deterioration of containers
Phase 1 - Section 4
Hazardous Waste Management
4-49
-------
Compliance Category:
Hazardous Waste Management
Regulatory Jtequlremeats:
[ Reviewer thectes:
Containment Buildings
(NOTE According to the Background Information' published on page 37221 of the 18 August 1992 edition of
the Federal Register, a hazardous waste containment building involves "the management of a hazardous waste
inside a unit designed and operated to contain the hazardous waste within the unit" This is not a building that
holds drums or tanks filled with hazardous waste, but a building that holds the hazardous waste itself)
HW 60 Generators with
containment buildings that
are in compliance are not
subject to the definition of
land disposal if specific
requirements are met (40
CFR262 34(a)(l)(iv), 40
CFR264 1100,40 CFR
265 1100)
Verify that the containment building meets the following
- It is a completely enclosed, self-supporting structure that is designed and
constructed of manmade materials of sufficient strength and thickness to
support themselves, the waste contents, and any personnel and heavy
equipment that operate within the unit
- It is designed to prevent failure due to pressure gradients, settlement,
compression, or uplift, physical contact with the hazardous wastes,
climatic conditions, and the stress of daily operations
- It has a primary barrier that is designed to be sufficiently durable to
withstand the movement of personnel, wastes, and handling of equipment
within the unit
- If the unit is used to manage liquids
- there is a primary barrier designed and constructed of materials to
prevent migration of hazardous constituents into the barrier
-- there is a liquid collection system designed and constructed of materials
to minimize the accumulation of liquid on the primary barrier
-- there is a secondary containment system designed and constructed of
materials to prevent migration of hazardous constituents into the
barrier, with a leak detection and liquid collection system capable of
detecting, collecting, and removing leaks of hazardous constituents at
the earliest practicable time
- It has controls sufficient to prevent fugitive dust emissions
- It is designed and operated to ensure containment and prevent the tracking
of materials from the unit by personnel and equipment
Phase 1 - Section 4
Hazardous Waste Management
4-50
-------
Compliance Category:
Waste Maaagtaweat
Regulatory Re
-------
Compliance Category:
Hazardous Waste Maoag^weat
Regulatory Requirements;
Reviewer Chetfes:
HW61 Continued
(NOTE. An exception to the structural strength requirement may be made for
lightweight doors and windows based on the nature of the waste management
operations if the following criteria are met
- The doors and windows provide an effective barrier again fugitive dust
emissions
- The unit is designed and operated in a manner that ensures that the waste
will not come in contact with the doors or windows)
(NOTE. A containment building can serve as secondary containment systems
for tanks)
HW 62. Containment
buildings are required to be
operated according to
specific standards (40 CFR
262 34(a)(l)(iv); 40 CFR
264 1101(a)(3),
264 1101(c)(1),
264 1101(c)(4), 40 CFR
265 1101 (a)(3),
265 1101(c)(1), and
265 1101(c)(4))
Verify that incompatible wastes or treatment reagents are not placed in the
building or its secondary containment system if they could cause the unit or
the secondary containment system to leak, corrode, or otherwise fail
Verify that the following operational procedures are done
- Controls and practices are used to ensure the containment of the waste
within the building
- The primary barrier is maintained so that it is free of significant cracks,
gaps, corrosion, or other deterioration that could cause hazardous waste to
be released from the primary barrier
- The level of the stored/treated hazardous waste is maintained so that the
height of any containment wall is not exceeded
- Measures are implemented to prevent the tracking of hazardous waste out
of the unit by personnel or equipment used in the handling of the waste
- There is a designated area for the decontamination of equipment and
collection of nnsate
- Any collected rinsate is managed as needed according to its constituents
- Measures are implemented to control fugitive dust emissions so that no
openings exhibit visible emissions
- Particulate collection devices are maintained and operated according to
sound air pollution control practices
Verify that data is gathered from monitoring equipment and leak detection
equipment and the site is inspected at least once every seven days and the
results recorded in the operating record
Verify that there is a written description of procedures to ensure that waste
does not remain in the building for more than 90 days
Verify that there is documentation that the waste does not remain for more
than 90 days
HW 63. Containment
buildings are required to be
certified by a registered
professional engineer (40
CFR 262.34(a)(l)(iv); 40
CFR 264 1101(c)(2); 40
CFR 265.1101(c)(2))
Verify by reviewing the documentation that the building has been certified
Phase 1 - Section 4
Hazardous Waste Management
4-52
-------
Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 64 Leaks in
containment buildings must
be repaired and reported (40
CFR 262 34(a)(l)(iv), 40
CFR264 1101(c)(3), 40
CFR 265 1101(c)(3))
Verify that if a condition is detected that could lead to a leak or has already
caused a leak, it is repaired promptly
Verify that when a leak is discovered
- The discovery is recorded in the facility operating record
- The portion of the containment building that is affected is removed from
service
- A cleanup and repair schedule is established
- Within 7 days the Regional Administrator is notified and within 14
working days written notice is provided to the Regional Administrator
- The Regional Administrator is notified upon the completion of all repairs
and certification from a registered professional engineer is also submitted
HW 65 Containment
buildings that contain both
areas with and without
secondary containment must
meet specific requirements
(40 CFR 262 34(a)(l)('v),
40 CFR 264 1101(d), 40
CFR 265 1101(d))
Verify that each area is designed and operated according to the appropriate
requirements
Verify that measures are taken to prevent the release of liquids or wet
materials into areas without secondary containment.
Verify that a written description is maintained in the facilities operating log of
operating procedures used to maintain the integrity of areas without secondary
containment
HW 66 When a containment
building is closed specific
requirements must be met
(40 CFR 262 34(a)(l)(iv),
40 CFR 264 1102, 40 CFR
265 1102)
Determine if the facility has closed a containment building recently
Verify that at closure, all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment
contaminated with waste and leachate were removed or decontaminated
Verify that the containment building is closed in accordance with closure and
post-closure requirements for TSDFs as outlined in the subsections pertaining
to all TSDFs titled Documentation Requirements and Closure
Verify that if it is found that not all contaminated subsoils can be practicably
removed or decontaminated, the site is closed and landfill post-closure
requirements are implemented
Disposal of Restricted Waste
HW 67 Facilities that
generate hazardous wastes
must test their wastes or use
process knowledge to
determine if they are
restricted from land disposal
(40 CFR 268 7)
Determine whether the generator tests for restricted wastes
Determine if the facility generates restricted wastes by reviewing test results
(see Appendix 4-7)
Phase 1 - Section 4
Hazardous Waste Management
4-53
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Compliance Category:
Hsutardoos Waste Management
Regulatory Requlremeats:
Reviewer Chetfcs:
HW 68 When a generator is
managing a restricted waste,
a notice must be issued to
the TSDF in writing of the
appropriate treatment
standards and prohibition
levels (40 CFR 268 7(a)(1)
through 268.7(a)(3),
268.7(a)(10)).
Verily that for restricted waste that does not meet the applicable treatment
standards or exceeds the applicable prohibition levels the notice is issued and
includes.
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- For hazardous debris, the contaminants subject to treatment and the
following statement "This hazardous debris is subject to the alternative
treatment standards of 40 CFR 268 45"
- The waste analysis data, when available.
Verify that for restricted waste that can be land disposed without further
treatment (this does not include debris that does not contain hazardous waste)
the notice includes
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- The waste analysis data, when available
- The signature of an authorized representative certifying that the waste
complies with the treatment standards of 40 CFR 268
Verify that, for restricted waste that is subject to an exemption from a
prohibition of the type of land disposal used, the notice states that the waste is
not prohibited from land disposal and includes:
- The EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment
- The waste analysis data, when available
- For hazardous debris, the contaminant subject to treatment
- The date the waste is subject to prohibitions
HW 69 Generators that are
managing prohibited wastes
in tanks, containers, or
containment buildings and
treating the waste to meet
applicable treatment
standards, must develop and
follow a written waste
analysis plan (40 CFR
268.7(a)(4) and
268 7(a)(10»
Verify that the plan describes the procedures that the generator will carry out
to comply with treatment standards
(NOTE Generators treating hazardous debris under the alternative treatment
standards are not required to conduct waste analysis )
Verify that the plan is kept onsite and
- The plan is based on a detailed chemical and physical analysis of
representative sample of the prohibited waste being treated
- The plan is filed with the EPA Regional Administrator or State authorized
official at least 30 days prior to the treatment activity, with delivery
verified
Phase 1 - Section 4
Hazardous Waste Management
4-54
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Compliance Category:
Hazardous Waste Ma aagtaneat
Regulatory Requirements:
Reviewer Cbectts:
HW 70 Generators are
required to keep specific
documents pertaining to
restricted wastes onsite (40
CFR 268 7(a)(5) through
268.7(a)(7) and
268.7(a)(10)).
Verify that if the facility is using generator knowledge to determine whether a
waste meets land disposal restriction requirements, the supporting data used in
making this determination is retained in the facility operating record
Verify that if the facility has determined whether a waste is restricted using
appropriate test methods, the waste analysis data is retained
Verify that if the facility has determined that they are managing a restricted
waste that is excluded from the definition of a hazardous waste or solid waste
or exempt from RCRA Subtitle C, a one-time notice is placed in the facility's
files stating that the generated waste is excluded
Verify that a copy of all notices, certifications, demonstrations, waste analysis
data and other documentation is kept for at least five years from the date that
the waste was last sent to an onsite or offsite TSDF
HW71 Generators who first
claim that hazardous debris
is excluded from the
definition of hazardous
waste are required to meet
specific notification and
certification requirements
(40 CFR 268 7(d))
Verify that a one-time notification is submitted to the Director or authorized
State including the following
- The name and address of the facility receiving the treated waste
- A description of the hazardous debris as initially generated, including the
applicable EPA Hazardous Waste Number
- For excluded debris, the technology used to treat the debris
Verify that the notification is updated if the debris is shipped to a different
facility
Verify that for debris that is excluded, if a different type of debris is treated or
if a different technology is used to treat the debris the notification is updated
HW 72 The storage of
hazardous waste that is
restricted from lard disposal
is not allowed unless
specific conditions are met
(40 CFR 268 50).
Verify that land disposal restricted waste is not stored at the facility unless the
generator is storing the wastes in tanks, containers, or containment buildings
onsite only for the purpose of accumulating enough quantity of hazardous
waste to facilitate proper recovery, treatment, or disposal and all appropriate
standards for containers, tanks, and containment buildings are met.
(NOTE' If the 90 day storage period is exceeded, the generator is required to
be permitted as a TSDF)
Verify that transporters do not store manifested shipments of land disposal
restricted wastes for more than 10 days
(NOTE The prohibition on storage does not apply to hazardous wastes that
have met treatment standards.)
Verify that liquid hazardous wastes containing PCBs at concentrations greater
than 50 ppm are stored at a site that meets the requirements of 40 CFR
761.65(b) (see the section titled Toxic Substances Management) and is
removed from storage within one year of the date it was first placed into
storage
Transportation of Hazardous Waste
Phase 1 - Section 4
Hazardous Waste Management
4-55
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Compliance Category:
Hazardous Waste Maaagwneat
Regulatory Requiremeats;
Itevimr Checks:
HW 73 Transporters of
hazardous waste that is
required to be manifested
must have an EPA
identification number and
must comply with manifest
management requirements
(40CFR263 10(a),
263 10(b), 263 11,263 20(a)
through 263 20(d), 263 21
and 263 22(a))
(NOTE: These requirements do not apply to the onsite transportation of
hazardous waste Nor do they apply to CESQGs)
Determine if the facility transports hazardous waste offsite using their own
vehicles or a contractor.
Verify that the transporter has a EPA identification number
Verify that all waste accepted, transported, or offered for transport is
accompanied by a manifest.
Verify that prior to transport, the transporter signs and dates the manifest and
returns a copy to the generator prior to leaving the facility
Verify that the transporter retains a copy of the manifest after delivery.
Verify that manifests are kept on file for three years.
(NOTE- Special issues involved m the transportation of hazardous waste by
air, rail or water are not addressed in this guide)
HW 74 Before transporting
hazardous waste or offering
hazardous waste for
transportation offsite in the
United States, the facility
must package and label the
waste in accordance with
DOT regulations contained
in 49 CFR 172, 173, 178,
and 179(40 CFR 262 30
through 262 33)
Determine what pretransport procedures for hazardous waste are used
Verify that containers are properly constructed and contain no leaks,
corrosion, or bulges by inspecting a sample of containers awaiting transport.
Examine end-seams for minor weeping that indicates drum failure.
Verify that labeling and marking on each container is compatible with the
manifests.
Verify that the following information is displayed on a random sample of
containers of 110 gal (416.40 L) or less in accordance with 49 CFR 172 304.
HAZARDOUS WASTE Federal Law Prohibits Improper Disposal. If found,
contact the nearest police or public safety authority or the U S Environmental
Protection Agency.
- Generator's name and address
- Manifest Document Number
Verify that proper DOT placarding is available for the transporter.
HW.75 Transporters of
waste offsite must take
immediate notification and
clean-up action if a
discharge occurs during
transport (40 CFR 263 30
and 263 31).
Verify that transport operators have instructions to notify local authorities and
take clean-up action so that the discharge does not present a hazard.
Verify that transporters give notice to the NRC and report in writing as
required by 49 CFR 171.15 and 49 CFR 17116
Phase 1 - Section 4
Hazardous Waste Management
4-56
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Compliance Category:
flastar
-------
Compliance Category:
Haxardoas Waste Management
Regulatory Requirements:
Itevtavcr Chetfcs:
HW.80 All TSDFs that
store, treat, transport, or
handle hazardous wastes
must obtain an EPA
identification number (40
CFR264 11, 40 CFR
265.11).
Examine documentation from EPA for the facility's generator, transporter, or
TSDF identification number
Verify that the correct identification number is used on all appropriate
documentation (i.e., manifests)
HW81 Facilities with
TSDFs must control entry to
the active portion of each
TSDF (40 CFR 264 14 and
40 CFR 265 14)
Inspect each TSDF on the facility.
Verify that unless the TSDF can demonstrate that physical contact with the
waste, structures, and equipment within the active portion of the TSDF will
not injure unknowing or unauthorized person or livestock, and that the waste
would not be disturbed, the following items are in place at the TSDF:
- A 24-hour surveillance system (e g, television monitors, surveillance by
guards)
- A fence or natural barrier, controlled entry is provided (an attendant,
television monitors, locked entrances controlled roadway access)
- Signs with the wording "Danger Unauthorized Personnel Keep Out," are
posted at each entrance and other locations as appropriate
- Signs are legible from 25 ft (7 62 m)
(NOTE These requirements are satisfied if the site in which the active
portion is located has a surveillance system, or a barrier and means to control
entry)
Phase 1 - Section 4
Hazardous Waste Management
4-58
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Compliance Category:
Hazardous Waste Maaagtaneat
Regulatory Requirements:
Revtetvcr Checks:
HW 82 All TSDFs must be
designed, constructed,
maintained, and operated to
minimize the possibility of a
fire, explosion, or any
unplanned release of
hazardous waste (40 CFR
264 30 through 264 37 40
CFR 265 30 through
265 37)
Determine if the following required equipment is easily accessible and in
working condition by inspecting the TSDF
- An internal communications or alarm system capable of providing
immediate emergency instruction to TSDF personnel
- A telephone or hand-held two way radio
- Portable fire extinguishers and special extinguishing equipment (foam,
inert gas, or dry chemicals)
- Spill control equipment
- Decontamination equipment
- Fire hydrants or other source of water (reservoir, storage tank, etc ) with
adequate volume and pressure, foam producing equipment, or automatic
sprinklers, or water spray systems
Determine if equipment is tested and maintained as necessary to insure proper
operation in an emergency
Verify that sufficient aisle space is maintained to allow unobstructed
movement of personnel, fire protection equipment, spill control equipment,
and decontamination equipment to any area of the operation
Verify that police, fire departments, and emergency response teams are
familiar with the layout of the TSDF, properties of the waste being handled,
and general operations unless they have declined such an arrangement
Verify that the hospital is familiar with the properties of hazardous waste
handled and the types of injuries that could result in an emergency
(NOTE When state or local police, fire departments, emergency response
teams, or hospitals decline to enter into arrangements, than the refusal must be
documented)
HW 83 All TSDFs must
take precautions to prevent
accidental ignition or
reaction of ignitable or
reactive wastes (40 CFR
264 17(a) and 40 CFR
265 17(a))
Verify from the operating record and/or observation that the following safe
management practices are used
- Wastes are separated and protected from sources of ignition or reaction
- Smoking and open flame is confined to specially designated locations
when ignitable or reactive wastes is handled
- NO SMOKING signs are used when necessary
HW 84 When TSDFs are
required by specific
treatment, storage, or
disposal sections to prevent
reactions from ignitable,
reactive, or incompatible
wastes, specific standards
must be met (40 CFR
264 17(b) and 40 CFR
265 17(b))
Verify from the operating record and/or observation that during treatment,
storage, or disposal of ignitable or reactive wastes, or during mixing of
incompatible wastes and other materials, precautions are taken to prevent the
following reactions'
- Generation of extreme heat or pressure, fire or explosions, or violent
reactions
- Production of uncontrolled toxic mists, fumes, dusts, or gases sufficient to
threaten human health or the environment
- Production of uncontrolled flammable fumes or gases sufficient to pose a
risk of fire or explosions
- Damage the structural integrity of the device or facility
- Threats to human health or the environment through other like means
Phase 1 - Section 4
Hazardous Waste Management
4-59
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 85 A detailed chemical
and physical analysis of a
representative sample, as
specified in the waste
analysis plan, of the
hazardous waste must be
obtained prior to treatment,
storage or disposal (40 CFR
264 13(a) and 40 CFR
265 13(a))
Verify that a detailed physical and chemical analysis is done of a
representative sample of the wastes prior to treatment, storage, or disposal
(NOTE Prior studies, published information may be included as a part of the
analysis)
Verify that the analysis is repeated as necessary to ensure that it is accurate
and up to date, specifically when the process or operation generating the
waste has changed
HW 86 Each TSDF must
have an emergency
coordinator on the TSDF
premises or on call at all
times (40 CFR 264 55 and
40 CFR 265 55)
Verify that, at all times, there is at least one employee at the TSDF or on call
with responsibility for coordinating all emergency response measures
Verify that the emergency coordinator is thoroughly familiar with the TSDF,
the characteristics of the waste handled, and the provisions of the contingency
plan In addition, verify the emergency coordinator has the authority to
commit the resources needed to carry out the contingency plan
HW 87 TSDF emergency
coordinators must follow
certain emergency
procedures whenever there
is an imminent or actual
emergency situation (40
CFR 264 56(a) through
264 56(i), 40 CFR 265 56(a)
through 265 56(i))
Review the contingency plan for the TSDF
Verify that the emergency coordinator is required to follow these emergency
procedures
- Immediately activate TSDF alarms or communication systems and notify
appropriate facility, state, and local response parties
- Identify the character, exact source, amount, and real extent of any
released materials
- Assess possible hazards to human health or the environment, including
direct and indirect effects (e g., release of gases, surface runoff from water
or chemicals used to control fire or explosions, etc )
- Stop processes and operations at the TSDF when necessary to prevent
fires explosions, or further releases
- Collect and contain the released waste
- Remove or isolate containers when necessary
- Monitor for leaks, pressure buildup, gas generation, or ruptures in valves,
pipes, or other equipment whenever appropriate
- Provide for treatment, storage, or disposal of recovered waste,
contaminated soil, or surface water, or other material
- Ensure that no waste that may be incompatible with the released material is
treated, stored, or disposed of until cleanup is completed
- Ensure that all emergency equipment is cleaned and fit for its intended use
before operations are resumed
- Notify the EPA, and appropriate state and local authorities when cleanup is
complete and operation resumes.
Personnel Training
Phase 1 - Section 4
Hazardous Waste Management
4-60
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 88 All TSDF personnel
who handle hazardous waste
must meet certain training
requirements (40 CFR
264.16(a) through 264 16(c)
and 265 16(a) through
265 16(c))
Verify that the training program is directed by a person trained in hazardous
waste management procedures
Verify that the training program includes the following
- Contingency plan implementation (emergency procedures, equipment, and
systems)
- Key parameters for automatic waste feed cut-off system
- Procedures for using, inspecting, and repairing emergency and monitoring
equipment
- Operation of communications and alarm systems
- Response to fire or explosion
- Response to leaks or spills
- Waste turn in procedures
- Identification of hazardous wastes
- Container use, marking, labeling, and onsite transportation
- Manifesting and offsite transportation
- Accumulation point management
- Personnel health and safety and fire safety
- TSDF shutdown procedures
Verify that new employee training is completed within six months of
employment
Verify that an annual review of initial training is provided
Verify that employees do not work unsupervised until training is completed
Verify specifically that accumulation point managers and hazardous waste
handlers have been trained
HW 89 Training records
must be maintained for all
TSDF staff who manage
hazardous waste (40 CFR
264 16(d) and 264 16(e), 40
CFR 265 16(d) and
265 16(e))
Verify through examination that training records include the following
- Job title and description for each employee by name
- Written description of how much training each position will obtain
- Documentation of training received by name
Determine if training records are retained for three years after employment at
the TSDF
Containers
Phase 1 - Section 4
Hazardous Waste Management
4-61
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Compliance Category:
Waste Maaageaieat
Regulatory Requirements:
Review* Chetkst
HW 90 Empty containers at
TSDFs previously holding
hazardous wastes must meet
the regulatory definition of
empty before they are
exempted from hazardous
waste requirements (40 CFR
261 7)
Verify that for containers or inner liners holding hazardous wastes'
- Wastes are removed that can be removed using common practices
- No more than 2 5 cm (1 in ) of residue remains
- If the container is less than or equal to 110 gal (416 40 L), no more than 3
percent by weight of total container capacity remains
- When the container is greater than 110 gal (416 40 L), no more than 0 3
percent by weight of the total container capacity remains.
Verify that for containers that held a compressed gas, the pressure in the
container approaches atmospheric.
Verify that for containers or inner liners that held an acute hazardous waste
listed in Appendix 4-5 that one of the following is done
- It is triple rinsed
- It is cleaned by another method identified through the literature or testing
as achieving equivalent removal
- The inner liner is removed
- Rinsate management
HW 91 Containers used to
store hazardous waste at
TSDFs must be in good
condition and not leaking
(40 CFR 264 171 and 40
CFR 265 171)
Verify that containers are not leaking, bulging, rusting, damaged or dented.
Verify that waste is transferred to a new container or managed in another
appropriate manner when necessary
HW 92 Containers used at
TSDFs must be made of or
lined with materials
compatible with the waste
stored in them (40 CFR
264 172 and 40 CFR
265 172)
Verify that containers are compatible with waste, in particular, check that
strong caustics and acids are not stored in metal drums
HW.93. Containers at
TSDFs must be closed
during storage and handled
in a safe manner (40 CFR
264 173 and 40 CFR
265.173).
Verify that containers are closed except when it is necessary to add or remove
waste (check bungs and look for open funnels).
Verify that handling and storage practices do not cause damage to the
containers or cause them to leak
Phase 1 - Section 4
Hazardous Waste Management
4-62
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 94 The handling of
incompatible wastes, or
incompatible wastes and
materials in containers at
TSDFs must comply with
safe management practices
(40 CFR264 17(b) and
264 177,40 CFR 265 17(b)
and 265 177)
Verify that incompatible wastes or incompatible wastes and materials are not
placed in the same containers unless it is done so that it does not
- Generate extreme heat or pressure, fire, or explosion, or violent reaction
- Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient
quantities to threaten human health
- Produce uncontrolled flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosions
- Damage the structural integrity of the device or TSDF or by any other like
means threaten human health
(NOTE Incompatible wastes as listed in Appendix 4-6 should not be placed
in the same containers )
Verify that hazardous wastes are not placed in an unwashed container that
previously held an incompatible waste or material
Verify that containers holding hazardous wastes incompatible with wastes
stored nearby in other containers, open tanks, piles, or surface impoundments
are separated or protected from each other by a dike, berm, wall or other
device
HW 95 Containers of
hazardous waste at TSDFs
should be managed in
accordance with specific
management practices (MP)
Verify the following by inspecting the container storage areas
- Containers are not stored more than two high and have pallets between
them
- Containers of highly flammable wastes are electrically grounded (check
for clips and wires and make sure wires lead to ground rod or system)
- At least 3 ft (0 91 m) of aisle space is provided between rows of
containers
Container Storage Areas
HW 96 Containers at
TSDFs should be kept in
storage areas designated in
the management plan and
identified by signs (MP)
Verify that all containers are identified and stored in appropriate areas
(NOTE Any unidentified contents of solid waste containers and/or
containers not in designated storage areas must be tested to determine if solid
or hazardous waste requirements apply)
HW 97 Containers holding
ignitable or reactive waste
must be located 15 m (50 ft)
from the property line of a
TSDF (40 CFR 264 176 and
40 CFR 265.176)
Determine the distance from any storage containers to the property line
(NOTE This restriction does not apply to SQGs)
HW 98 TSDF personnel
must conduct weekly
inspections of container
storage areas (40 CFR
264 174 and 40 CFR
265 174)
Verify that inspections are conducted at least weekly to look for leaking
containers and signs of deterioration of containers
Phase 1 - Section 4
Hazardous Waste Management
4-63
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Compliance Category:
Hazardous Waste Maaageateat
Regulatory Beqairementtt
! Reviewer Cheeks:
Containment Buildings
(NOTE According to the Background Information published on page 37221 of the 18 August 1992 edition of
the Federal Register, a hazardous waste containment building involves "the management of a hazardous waste
inside a unit designed and operated to contain the hazardous waste within the unit" This is not a building that
holds drums or tanks filled with hazardous waste, but a building that holds the hazardous waste itself)
HW 99. TSDFs with
containment buildings that
are in compliance are not
subject to the definition of
land disposal if specific
requirements are met (40
CFR 264.1100 and 40 CFR
265.1100)
Verify that the containment building meets the following
- It is a completely enclosed, self-supporting structure that is designed and
constructed of manmade materials of sufficient strength and thickness to
support themselves, the waste contents, and any personnel and heavy
equipment that operate within the unit
- It is designed to prevent failure due to pressure gradients, settlement,
compression, or uplift, physical contact with the hazardous wastes,
climatic conditions, and the stress of daily operations
- It has a primary barrier that is designed to be sufficiently durable to
withstand the movement of personnel, wastes, and handling of equipment
within the unit
- If the unit is used to manage liquids.
-- there is a primary barrier designed and constructed of materials to
prevent migration of hazardous constituents into the barrier
- there is a liquid collection system designed and constructed of materials
to minimize the accumulation of liquid on the primary barrier
-- there is a secondary containment system designed and constructed of
materials to prevent migration of hazardous constituents into the
barrier, with a leak detection and liquid collection system capable of
detecting, collecting, and removing leaks of hazardous constituents at
the earliest practicable time
- It has controls sufficient to prevent fugitive dust emissions
- It is designed and operated to ensure containment and prevent the tracking
of materials from the unit by personnel and equipment
Phase 1 - Section 4
Hazardous Waste Management
4-64
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Compliance Category:
Hazardoos Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 100 Containment
buildings are required to be
designed according to
specific standards (40 CFR
264 1101(a)(1) through
264 1101(a)(2),
264 1101(b), 40 CFR
265 1101(a)(1) through
265 1101(a)(2), and
265 1101(b))
Verify that containment buildings meet the following design standards
- It is completely enclosed with a floor, walls, and a roof to prevent
exposure to the elements and to assure containment of wastes
- The floor and containment walls, including any required secondary
containment system, are designed and constructed of man-made materials
of sufficient strength and thickness to support themselves, the waste
contents, and any personnel and heavy equipment that operate within the
unit
- It is designed to prevent failure due to pressure gradients, settlement,
compression, or uplift, physical contact with the hazardous wastes,
climatic conditions, and the stress of daily operations
- It has sufficient structural strength to prevent collapse or other failure
- All surfaces in contact with hazardous wastes are compatible with the
wastes
- It has a primary barrier that is designed to be sufficiently durable to
withstand the movement of personnel, wastes, and handling of equipment
within the unit and is appropriate for the chemical and physical
characteristics of the waste
Verify that if the containment building is going to manage hazardous wastes
with free liquids or treated with free liquids the following design requirements
are also met
- There is a primary barrier designed and constructed of materials to prevent
migration of hazardous constituents into the barrier (e g , a geomembrane
covered by a concrete wear surface)
- There is a liquid collection and removal system designed and constructed
of materials to minimize the accumulation of liquid on the primary barrier'
- The primary barrier is sloped to dram liquids to the associated collection
system
- Liquids and wastes are collected and removed to minimized hydraulic head
on the containment system at the earliest practicable time
- There is a secondary containment system, including a secondary barrier,
designed and constructed of materials to prevent migration of hazardous
constituents into the barrier, with a leak detection and liquid collection
system capable of detecting, collecting, and removing leaks of hazardous
constituents at the earliest practicable time
- The leak detection component of the secondary containment system meets
the following
-- it is constructed with a bottom slope of one percent or more
-- it is constructed of a granular drainage materials with a hydraulic
conductivity of lxl 0"2 cm/sec or more and a thickness of 12 in (30 5
cm) or more, or constructed of synthetic or geonet drainage materials
with a transmissivity of 3 x 10"5 m2/sec or more
Phase 1 - Section 4
Hazardous Waste Management
4-65
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Compliance Category:
Waste Management
Regulatory Rtqulremeflts:
Review* Che«ks:
HW 100. Continued
- If treatment is to be conducted in the building, the treatment area is
designed to prevent the release of liquids, wet materials, or liquid aerosols
to other portions of the building
- The secondary containment system is constructed of materials that are
chemically resistant to the waste and liquids managed in the building and
of sufficient strength and thickness to prevent collapse under pressure
exerted by overlaying materials and by any equipment used.
(NOTE An exception to the structural strength requirement may be made for
lightweight doors and windows based on the nature of the waste management
operations if the following criteria are met
- The doors and windows provide an effective barrier again fugitive dust
emissions
- The unit is designed and operated in a manner that ensures that the waste
will not come in contact with the doors or windows )
(NOTE A containment building can serve as secondary containment systems
for tanks within the building if
- It meets the requirements of 264 193(d) (see Storage Tank Management)
- It meets the requirements of 264 193(b) and 264 193(c)(12) (see Storage
Tank Management)
HW 101 Containment
buildings are required to be
operated according to
specific standards (40 CFR
264 1101(a)(3),
264 1101(c)(1),
264 1101(c)(4), 40 CFR
265.1101(a)(3),
265.1101(c)(1), and
265 1101(c)(4))
Verify that incompatible wastes or treatment reagents are not placed in the
building or its secondary containment system if they could cause the unit or
the secondary containment system to leak, corrode, or otherwise fail
Verify that the following operational procedures are done
- Controls and practices are used to ensure the containment of the waste
within the building
- The primary barrier is maintained so that it is free of significant cracks,
gaps, corrosion, or other deterioration that could cause hazardous waste to
be released from the primary barrier
- The level of the stored/treated hazardous waste is maintained so that the
height of any containment wall is not exceeded
- Measures are implemented to prevent the tracking of hazardous waste out
of the unit by personnel or equipment used in the handling of the waste
- There is a designated area for the decontamination of equipment and
collection of rinsate
- Any collected rinsate is managed as needed according to its constituents
- Measures are implemented to control fugitive dust emissions so that no
openings exhibit visible emissions
- Particulate collection devices are maintained and operated according to
sound air pollution control practices
Verify that data is gathered from monitoring equipment and leak detection
equipment and the site is inspected at least once every seven days and the
results recorded in the operating record
Phase 1 - Section 4
Hazardous Waste Management
4-66
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Compliance Category:
Hazardous Waste Maaagemeet
Regulatory R&juiremeots:
Itevtewjr Chafes:
HW 102 Containment
buildings are required to be
certified by a registered
professional engineer (40
CFR264 1101(c)(2) and 40
CFR265 1101(c)(2))
Verify that the building has been certified
HW 103 Leaks in
containment buildings must
be repaired and reported (40
CFR264 1101(c)(3) and 40
CFR265 1101(c)(3))
Verify that if a condition is detected that could lead to a leak or has already
caused a leak, it is repaired promptly
Verify that when a leak is discovered
- The discovery is recorded in the TSDF operating record
- The portion of the containment building that is affected is removed from
service
- A cleanup and repair schedule is established
- Within seven days the Regional Administrator is notified and within 14
working days written notice is provided to the Regional Administrator
- The Regional Administrator is notified upon the completion of all repairs
and certification from a registered professional engineer is also submitted
HW 104 Containment
buildings that contain both
areas with and without
secondary containment must
meet specific requirements
(40 CFR264 1101(d) and 40
CFR265 1101(d))
Verify that each area is designed and operated according to the appropriate
requirements
Verify that measures are taken to prevent the release of liquids or wet
materials into areas without secondary containment
Verify that a written description is maintained in the TSDF operating log of
operating procedures used to maintain the integrity of areas without secondary
containment
HW 105 When a
containment building is
closed specific requirements
must be met (40 CFR
264 1102 and 40 CFR
265 1102)
Determine if the TSDF has closed a containment building recently
Verify that at closure, all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment
contaminated with waste and leachate were removed or decontaminated
Verify that the containment building is closed in accordance with closure and
post-closure requirements for TSDFs as outlined in the subsections pertaining
to all TSDFs titled Documentation Requirements and Closure
Verify that if it is found that not all contaminated subsoils can be practicably
removed or decontaminated, the site is closed and landfill post-closure
requirements are implemented
Restricted Wastes
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Muxurtom Waste Maaagomeat
Regulatory Rfopirematte
Reviewer Checks:
HW 106 TSDFs must not
dispose of the wastes listed
in Appendix 4-7 on land
unless specific parameters
are met (40 CFR 268 1,
268 4, and Appendix VII)
Verify that the wastes listed in Appendix 4-7 are not land disposed after the
indicated dates in the Appendix unless
- The TSDF was granted an extension
- The waste is hazardous only because it exhibits a hazardous characteristic,
and is otherwise prohibited from land disposal, but
-- is disposed of into a nonhazardous or hazardous injection well
- does not exhibit any prohibited characteristic of a hazardous waste at
the point of injection
- Disposal is done in a surface impoundment and treatment of the wastes
occurs at the
impoundment
- Sampling, testing, and removal procedures and design requirements
outlined in 40 CFR 268.4 are followed
- The waste is treated
(NOTE The following are exempted from all of the requirements concerning
restricted wastes found in 40 CFR 268
- Waste generated by a SQG of less than 100 kg (220 46 lb) of hazardous
waste or less than 1 kg of acute hazardous waste per month
- Waste pesticides that a farmer disposes of
- Wastes identified or listed as hazardous after 8 November 1984 for which
EPA has not promulgated land disposal prohibitions or treatment standards
- De minimis losses to wastewater treatment systems of commercial
chemical product or chemical intermediates that are ignitable (D001) or
corrosive (D002) and that contain underlying hazardous constituents
- Laboratory wastes displaying the characteristic of ignitibility (D001), or
corrosivity (D002), that are commingled with other plant wastewaters
under designated circumstances
- Laboratory wastes that are ignitable and corrosive containing underlying
hazardous constituents from laboratory operations that are mixed with
other plant wastewaters at TSDFs whose ultimate discharge is subject to
CWA regulations if the annualized flow of laboratory wastewater into the
facility's headwork does not exceed one percent or the laboratory wastes
combined annualized sewage concentration does not exceed one ppm in
the facility's headwork)
(NOTE. As of 8 May 1993 debris that is contaminated with the wastes listed
in Appendix 4-7 and debris that is contaminated with any characteristic waste
for which there are treatment standards are prohibited from land disposal)
HW. 107 Wastes that are
restricted from land disposal
or the residual from the
treatment of a waste
restricted from land disposal
shall not be diluted as a
substitute for adequate
treatment (40 CFR 268 3)
Verify that restricted wastes or the residual from the treatment of restricted
wastes are not diluted unless they are hazardous only because they exhibit a
characteristic in a treatment system which treats wastes that are then
discharged into a water of the United States by permit or which treats wastes
for the purpose of pre-treatment or unless the waste is a D003 reactive
cyanide wastewater or nonwastewater.
Phase 1 - Section 4
Hazardous Waste Management
4-68
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Compliant Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Cheeks:
HW 108. A restricted waste
may be land disposed only if
the constituent
concentrations in the waste
or waste treatment residue
meet applicable treatment
standards, or if the waste is
treated using a specified
treatment technology or
equivalent treatment method
(40 CFR 268 40 through
268 43)
Verify that for restricted wastes identified in Appendix 4-8 that are land
disposed, the associated constituent concentrations in the extract of the waste
or waste treatment residual do not exceed the values shown in Appendix 4-8
Verify that for restricted wastes listed in Appendix 4-9 that are land disposed,
the waste is treated using the treatment technology specified in Appendix 4-9
or an equivalent treatment method approved by the Administrator
Verify that for restricted wastes identified in Appendix 4-10 that are land
disposed, the associated constituent concentrations in the waste or waste
treatment residue do not exceed the values shown in Appendix 4-10
(NOTE As used in Appendices 4-9, and 4-10, the term wastewater has the
following meaning wastes that contain less than 1 percent by weight Total
Organic Carbon (TOC) and less than 1 percent by weight total suspended
solids (TSS), with the following exceptions
- F001, F002, F003, F004, F005 wastewaters are solvent-water mixtures that
contain less than 1 percent by weight TOC or less than 1 percent by weight
total F001, F002, F003, F004, F005 solvent constituents listed in Appendix
4-8
- K011, KOI3, KOI4 wastewaters contain less than 5 percent by weight TOC
and less than 1 percent by weight TSS, as generated
- K103 and K104 wastewaters contain less than 4 percent by weight TOC
and less than 1 percent by weight TSS
- Waste analysis plan compliance )
HW 109 Treatment
facilities are required to
follow specific procedures
for restricted wastes (40
CFR 268 7(b))
Verify that treatment facilities are testing their waste according to the
procedures outlined in their waste analysis plan
Verify that the treatment facility sends a notice with each waste shipment
going to a land disposal facility, except for debris excluded from the
definitions of hazardous waste, that includes the following
- EPA hazardous waste number
- Treatment standards
- The manifest number associated with the shipment of waste
- Waste analysis data, where available
Verify that the treatment facility submits a certification with each shipment of
waste or treatment residue of a restricted waste, except for debris excluded
from the definitions of a hazardous waste, to the land disposal facility stating
that the waste has been treated in compliance with applicable standards
(NOTE: If waste or treatment residues will be further managed at a different
treatment or storage facility, the TSDF sending the waste or treatment residue
offsite must comply with notice and certification requirements )
(NOTE. Where the wastes are recyclable materials used in a manner
constituting disposal, the treatment facility is not required to notify the
receiving facility)
Phase 1 - Section 4
Hazardous Waste Management
4-69
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Compliance Category:
fiazardoas W$$tt MBtMgmeBt
Regulatory Requirements:
Reviewer Checks:
HW 110 Land disposal
facilities for restricted
wastes are required to
maintain copies of notices
and certifications and test
the waste except when
disposing of waste that is
recycled material used in a
manner constituting disposal
(40 CFR 268 7(c))
Verify that copies of the certifications and notification are kept on hand
Verify that the facility is testing waste as specified in the facilities waste
analysis plan.
HW 111. The storage of
hazardous waste that is
restricted from land disposal
is not allowed unless
specific conditions are met
(40 CFR 268 50)
Verify that land disposal restricted waste is not stored at the TSDF unless the
TSDF is storing the wastes in tanks, containers, or containment buildings in
order to accumulate the necessary quantities for proper recovery, treatment or
disposal and
- Each container is marked to identify contents and the date accumulation
began
- Each tank is clearly marked with a description of the contents, the quantity
of each hazardous waste received, and the start date of accumulation or a
record of such information is maintained
Verify that transporters do not store manifested shipments of land disposal
restricted wastes for more than 10 days
(NOTE A TSDF may store the land disposal restricted wastes for up to one
year if they can prove that the reason for storage is to accumulate such
quantities of hazardous waste as are necessary to facilitate proper treatment
and disposal.)
(NOTE. The prohibition on storage does not apply to hazardous wastes that
have met treatment standards )
Verify that liquid hazardous wastes containing PCBs at concentrations greater
than 50 ppm are stored at a site that meets the requirements of 40 CFR
761 65(b) (see PCB Management) and is removed from storage within one
year of the date it was first placed into storage.
Emissions from Process Vents
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Maaagemeat
Regulatory Requirement^;
Reviewer Checks:
HW 112 TSDFs with
process vents associated
with distillation,
fractionation, thin-film
evaporation, solvent
extraction, or air or steam
stripping operations that
manage hazardous wastes
with organic concentrations
of at least 10 ppmw are
required to meet specific
standards (40 CFR
264 1030(b) and 264 1032,
40 CFR 265 1030(b) and
265 1032)
Verify that one of the following is met
- Total organic emissions from the process vents do not exceed 1 4 kg/h (3
Ib/h) and 2 8 Mg/yr (3 1 tons/yr)
- Total organic emissions are reduced by use of a control device from all
process vents by 95 weight percent
(NOTE These standards apply to
- TSDFs that are required to have a permit
- Hazardous waste recycling units that are located on a hazardous waste
management facility that is required to have a permit)
HW 113 When a TSDF uses
a closed vent system and
control device to meet the
standards for total organic
emissions, the closed vent
system and control device
must meet certain minimum
requirements (40 CFR
264.1033 and 265 1033)
Verify that control devices involving vapor recovery are designed and
operated to recovery the organic vapors vented to the air with an efficiency of
95 weight percent or greater unless the total organic emission limit can be
attained at an efficiency of less than 95 weight percent
Verify that if an enclosed combustion device is used (i e. vapor incinerator,
boiler, or process heater), it is designed and operated to reduce the organic
emissions vented to it by 95 weight percent or greater, to achieve a total
organic compound concentration of 20 ppmv or to provide a minimum
residence time of 0 50 seconds at a minimum temperature of 760°C
Verify that if a boiler or process heater is used as the control device, the vent
stream is introduced into the flame zone of the boiler or process heater
Verify that if flares are used
- They are designed and operated with no visible emissions except for
periods not in excess of five minutes during any two consecutive hours
- It is operated with a flame present at all times
- It is used only if the net heating value of the gas being combusted is 11 2
MJ/scm (300 Btu/scf) or greater if the flare is steam assisted or air-assisted
- That are nonassisted, the net heating value of the gas being combusted is
7.45 MJ/scm (200 Btu/scf) or greater
- That are nonassisted or steam assisted, they have an exit velocity less than
18 3 m/s (60 ft/s) except'
- When the net heating value of the gas being combusted is greater than 37 3
MJ/scm (1000 Btu/scf) and the exit velocity is equal to or greater than 18 3
m/s (60 ft/s) but less than 122 m/s (400 ft/s)
Verify that each monitor and control device is inspected on a routine basis
Phase 1 - Section 4
Hazardous Waste Management
4-71
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Compliance Category:
Hastardoos Waste Maaageiweat
Regulatory Rfequirfettteate
Review Chetfest
HW 114 TSDFs are
required to maintain specific
records pertaining to process
vent emissions (40 CFR
264.1035 and 265 1035)
Verify that the following information is kept in the operating record
- An implementation schedule
- Up-to-date documentation of compliance
- The test plan if test data is used to determine the organic removal
efficiency or total organic compound concentration achieved by a control
device
- Design documentation
- Monitoring and inspection results
- Notations of exceedences
Verify that records of monitoring operations and inspection information are
kept for three years
Air Emission Standards for Equipment Leaks
Phase 1 - Section 4
Hazardous Waste Management
4-72
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Compliance Category:
Hazardoas Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 115 TSDFs with pumps
in light liquid service that
contain or contact hazardous
wastes with organic
concentrations of at least 10
percent by weight are
required to meet specific
standards (40 CFR
264 1050(b) and 264 1052,
265 1050(b) and 265 1052)
Verify that pumps in light liquid service are monitored monthly according to
designated reference methods and inspected visually weekly
(NOTE A leak is detected if there is an instrument reading of 10,000 ppm or
greater or if there is an indication of liquid dripping from the pump seal)
Verify that when a leak is detected, the first attempt at repair is made within
five calendar days and repair is completed within 15 calendar days
(NOTE Pumps equipped with dual mechanical seal systems and pumps
designated for no detectable emissions that meet standards outlined below do
not have to be monitored monthly or visually checked weekly )
Verify that pumps equipped with a dual mechanical seal system meet the
following design and operation requirements
- The dual mechanical seal system is operated with barrier fluid at a pressure
that is at all times greater than the pump stuffing box or equipped with a
barrier fluid degassing reservoir that is connected by a closed vent system
to a control device or equipped with a system that purges the barrier fluid
into a hazardous waste stream with no detectable emission to the
atmosphere
- The barrier fluid system has no hazardous waste with organic
concentrations 10 percent or greater by weight
- The barrier fluid system is equipped with a sensor that will detect failure if
the seal is broken
- Pumps are checked by visual inspection weekly
- Sensors are checked daily or equipped with an audible alarm that is
checked monthly
Verify that pumps that are designated for no detectable emissions as indicated
by an instrument reading of 500 ppm above background or less meet the
following'
- They are operated with no detectable emissions
- They are tested for compliance initially upon designation, annually, and at
other times as requested by the Regional Administrator
(NOTE Any pump that is equipped with a closed-vent system capable of
capturing and transporting any leakage from the seal or seals to a control
device is exempt from these requirements )
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
Phase 1 - Section 4
Hazardous Waste Management
4-73
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Compliance Category:
Bazardoas Waste Maoagemeat
Regulatory Requirements;
K&ttemr Checks:
HW.116 TSDFs with
compressors that contain or
contact hazardous wastes
with organic concentrations
of at least 10 percent by
weight are required to meet
specific standards (40 CFR
264 1050(b) and 264 1053,
40 CFR 265 1050(b) and
265 1053)
Verify that each compressor is equipped with a seal system that includes a
barrier fluid system and that prevents leakage of total organic emissions to the
atmosphere except if
- It is equipped with a closed-vent system capable of capturing and
transporting any leakage from the seal to a control device
- It is designated for no detectable emission and
- It operates at an instrument reading of less than 500 ppm above
background
- It is tested for compliance initially upon designation, annually, and at times
as requested by the Regional Administrator
Verify that compressor seal systems meet one of the following-
- It is operated with the barrier fluid at a pressure that is at all times greater
than the compressor stuffing box pressure
- It is equipped with a barrier fluid system that is connected to a closed-vent
system to a control device
- It is equipped with a system that purges the barrier fluid into a hazardous
waste stream with no detectable emissions to the atmosphere
Verify that the barrier fluid is not a hazardous waste with organic
concentrations 10 percent or greater by weight
Verify that each barrier fluid system is equipped with a sensor that will detect
failure of the seal system, barrier fluid system, or both.
Verify that each sensor is checked daily or it is equipped with an audible
alarm that is checked monthly
(NOTE Sensors on compressors located within the boundary of an
unmanned site must be checked daily)
Verify that when a leak is detected, the first attempt at repair is made within
five calendar days and the repair is made within 15 calendar days
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
Phase 1 - Section 4
Hazardous Waste Management
4-74
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Rwietver Chafes:
HW 117 TSDFs with
pressure relief devices in
gas/vapor service that
contain or contact hazardous
wastes with organic
concentrations of at least 10
percent by weight are
required to meet specific
standards (40 CFR
264 1050(b) and 264 1054,
40 CFR 265 1050(b) and
265 1054)
Verify that except during pressure releases, each pressure relief device in
gas/vapor service is operated with no detectable emissions as indicated by an
instrument reading of less than 500 ppm above background
Verify that if there is a pressure release, the device is returned to a no
detectable emission status Verify that each sampling connection system is
equipped with a closed purge system or closed-vent system
(NOTE Any pressure relief device that equipped with a closed-vent system
capable of capturing and transporting leakage from the pressure relief device
to a control device is exempt from these requirements )
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
HW 118 TSDFs with
sampling connecting
systems that contain or
contact hazardous wastes
with organic concentrations
of at least 10 percent by
weight are required to meet
specific standards (40 CFR
264 1050(b) and 264 1055,
40 CFR 265 1050(b) and
265 1055)
Verify that each sampling connection system is equipped with a closed purge
system or closed-vent system
Verify that each closed purge system or closed-vent system does one of the
following
- Returns the purged hazardous waste stream directly to the hazardous waste
management process line with no detectable emissions to atmosphere
- Collects and recycles the purged hazardous waste stream with no
detectable emissions to the atmosphere
- Is designed and operated to capture and transport all the purged hazardous
waste stream to a control device
(NOTE In-situ sampling systems are exempt from these requirements)
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
Phase 1 - Section 4
Hazardous Waste Management
4-75
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Compliance Category:
Hazardous Waste Management
RegyJatory tteqtiirettnMtts;
HW 119 TSDFs with open-
ended valves or lines that
contain or contact hazardous
wastes with organic
concentrations of at least 10
percent by weight are
required to meet specific
operation standards (40 CFR
264.1050(b) and 264 1056,
40 CFR 265 1050(b) and
265 1056)
Verify that each open-ended valve or line is equipped with a cap, blind flange,
plug, or a second valve
Verify that the cap, blind flange, plug, or second valve seals the open end at
all times except during operations requiring hazardous waste stream flow
through the openended valve of line.
Verify that each open-ended valve of line equipped with a second valve is
operated so that the valve on the hazardous waste stream end is closed before
the second valve is closed
Verify that when a double block and bleed system is being used, the bleed
valve is shut or plugged except during operations that require venting the line
between the block valves
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit.)
Phase 1 - Section 4
Hazardous Waste Management
4-76
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Compliance Category:
Hazards Waste Management
Regulatory Requirements:
Jtevtover Chwfes:
HW 120 TSDFs with valves
in gas/vapor service or light
liquid service that contain or
contact hazardous wastes
with organic concentrations
of at least 10 percent by
weight are required to meet
specific monitoring and
repair standards (40 CFR
264 1050(b), 264 1057,
264 1061, 40 CFR
265 1050(b), 265 1057,
265 1061)
Verify that valves in gas/vapor service or light liquid service are monitored
monthly to detect leaks
(NOTE A leak is detected if an instrument reading of 10,000 ppm or greater
is measured But, if a leak is not detected for two consecutive months,
monitoring may be cut back to quarterly until a leak is detected.)
Verify that the first attempt at repairing a leak is done with 5 calendar days
after detection and leak repair is completed within 15 days after detection
(NOTE Valves that are designated for no detectable emissions, as indicated
by an instrument reading of less than 500 ppm above background, do not have
to be monitored monthly if
- The valve has no external actuating mechanism on contact with the
hazardous waste stream
- The valve is operated with emission less than 500 ppm above background
- The valve is tested initially upon designation, annual, and at the request of
the Regional Administrator)
(NOTE Valves that are designated as unsafe-to-monitor are exempt from the
requirement for monthly monitoring if.
- The valve is unsafe to monitor because monitoring personnel would be
exposed to an immediate danger
- A written monitoring plan is followed that requires monitoring as often as
is reasonably practicable during safe-to-monitor times )
(NOTE Valves that are designated as difficult-to-monitor are exempt from
monthly monitoring requirements if
- The valve cannot be monitored without elevating the monitoring personnel
more than 2 m above a support surface
- The hazardous waste management unit within which the valve is located
was in operation before 21 June 1990
- A written monitoring plan is followed that requires the monitoring of the
valve at least once per calendar year)
(NOTE. The TSDF may elect to have all valves within a hazardous waste
management unit comply with an alternative standard of no greater than 2
percent of the valves to leak)
(NOTE. These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
Phase 1 - Section 4
Hazardous Waste Management
4-n
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Compliance Category:
Hazardous Waste Maaagemeet
Regulatory Requirements:
RMewer Checlts:
HW 121 TSDFs with pumps
and valves in heavy liquid
service, pressure relief
devices in light liquid
service or heavy liquid
service, and other connectors
that contain or contact
hazardous wastes with
organic concentrations of at
least 10 percent by weight
are required to meet specific
monitoring and repair
standards (40 CFR
264 1050(b) and 264 1058,
40 CFR 265 1050(b) and
265 1058).
Verify that pumps and valves in heavy liquid service, pressure relief devices
in light liquid service or heavy liquid service and other connectors are
required to be monitored within five days if evidence of a potential leak is
found by visual, olfactory, audible, or other detection method.
(NOTE A leak is detected if an instrument reading of 10,000 ppm or greater
is measured)
Verify that when a leak is detected the first attempt at repair occurs within
five days and repair is done within 15 days after discovery.
(NOTE These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit)
HW 122 TSDFs are
required to keep specific
records pertaining to the
valves, pumps pressure
relief devices, and
connecting systems being
monitored for leaks and
submit certain reports (40
CFR 264.1050(b), 264 1064,
264 1065; 40 CFR
265 1050(b), 265 1064)
Verify that the following information is maintained in the TSDF operating
record
- Equipment identification number and hazardous management unit
identification
- Approximate locations
- Type of equipment
- Percent-by-weight total organics in the hazardous waste stream at the
equipment
- Hazardous waste state at the equipment (gas, liquid, vapor)
- Method of compliance
- Implementation schedule if needed
- A performance plan for control devices as needed
- Documentation of compliance
- Documentation of repair
Verify that permitted TSDFs submit a semiannual report indicating leaks and
repairs to the Regional Administrator.
(NOTE If repairs are made and the control device does not exceed or operate
outside of the design specifications for more than 24 hours, a report to the
Regional Administrator is not required.)
(NOTE- These standards apply to TSDFs that are required to have a permit
and hazardous waste recycling units that are located on hazardous waste
management facilities that are required to have a permit.)
Documentation Requirements
Phase 1 - Section 4
Hazardous Waste Management
4-78
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Compliance Category:
£to5tar
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Revkw«r Checks:
HW 125 Facilities with TSDFs
must have a contingency plan
(40 CFR 264.50 through
264 54, 40 CFR 265 50
through 265 54)
(NOTE TSDFs may be addressed in the facility's SPCC plan or other emergency
plan, or if none exists, in a separate contingency plan )
Verify that the contingency plan is designed to minimize hazards to human health
or the environment from fires, explosions, or any unplanned sudden or non-
sudden release of hazardous waste or hazardous waste constituents
Verify that the plan includes the following
- A description of actions to be taken during an emergency
- A description of arrangements, as appropriate, agreed to by local police
departments, fire departments, hospitals, contractors, and State and local
emergency response teams
- Names, addresses, and phone numbers of all persons qualified to act as
emergency coordinator
- A list of all emergency equipment at the TSDF and where this equipment is
required, located, and what it looks like an evacuation plan for TSDF
personnel where there is a possibility evacuation would be needed
Verify that copies of the contingency plan are maintained at the TSDF and also
have been submitted to organizations which may be called upon to provide
emergency services
Verify that the contingency plan is routinely reviewed and updated, especially
when the TSDF is issued a new permit, the plan fails in an emergency, the
emergency coordinators change, the waste being handled changes, and/or the list
of emergency equipment changes.
HW 126 TSDF operators must
record the time, date, and
details of any incident that
requires implementing the
contingency plan (40 CFR
264 560) and 265 560))
Determine if incidents have been recorded and corrective actions taken through a
review of TSDF operating records
Verify that written reports have been submitted to the EPA Regional
Administrator within 15 days after the incident
Phase 1 - Section 4
Hazardous Waste Management
4-80
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 127 TSDF operators must
keep written operating records
at the facility (40 CFR 264 73
through 264.74, 40 CFR
265 73 through 265 74)
Verify that the TSDF has a written operating record
Determine if the operating record includes
- A description and quantity of each hazardous waste received at the TSDF and
the method(s) and date(s) of treatment, storage, or disposal of each waste
received at the TSDF
- The location of each hazardous waste within the TSDF (cross-referenced to
specific manifest document numbers and the quantity at each location)
- For disposal facilities, the location and quantity is recorded on a map or
diagram of each cell or disposal area
- Records and results of waste analyses
- Reports of all the incidents that required the implementation of the
contingency plan
- Records and results of inspections (only a 3 year retention period)
- Monitoring, testing, and analytical data (where required)
- For offsite facilities, notices to the generator
- Annual certification that the TSDF has a program in place to reduce the
volume and toxicity of hazardous waste, and that the proposed method of
treatment, storage, or disposal minimizes the present and future threat to
human health and the environment
- The record of the quantities and date of placement for each shipment of
hazardous waste placed in land disposal units under an extension granted by
40 CFR 268.5, a petition granted under 40 CFR 268.6, or a certification
granted under 40 CFR 268 8
- A copy of the applicable notice, demonstration, and certification required for
any restricted hazardous wastes
- Certifications and demonstrations provided to generators or received from
generators
(NOTE. This information must be recorded and maintained in the operating
record until closure of the TSDF)
(NOTE- The retention period for all records is extended automatically during the
course of any unresolved enforcement action or as required by the EPA
Administrator.)
Phase 1 - Section 4
Hazardous Waste Management
4-81
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks: -
HW 128 Facilities with TSDFs
must prepare and submit a
single copy of a biennial report
to the EPA Regional
Administrator by March 1 of
each even numbered year (40
CFR 264.75 and 40 CFR
265 75)
Obtain a copy of the biennial report (EPA Form 8700-13D or applicable state
form)
Verify that biennial reports are prepared and submitted and contain the following
information
- EPA identification number
- TSDF name and address
- Calendar year covered by report
- Description and quantity of each waste received
- Method of treatment, storage, or disposal for each waste
- Certification signed by owner or operator of the TSDF
- Offsite facilities must also report EPA identification number for each
hazardous waste generator from which waste was received
- Description of efforts undertaken during the year to reduce the volume and
toxicity of waste generated
- Description of changes in volume and toxicity of waste actually achieved
during the year in comparison to previous years to the extent that information
is available for the years prior to 1984
(NOTE This is not required if annual or biennial reports are submitted to the
state)
HW 129 Facilities with TSDFs
must have a written closure
plan for each TSDF (40 CFR
264 110.264.112(a), and
264 112(b), 40 CFR 265 110,
265 112(a), and 265 112(b))
Determine if the TSDF has a written closure plan
Determine, by review, if the closure plan addresses
- How the TSDF will be closed
- Estimates of the maximum amount of wastes in storage and in treatment
during the life of the TSDF
- Description of decontamination procedures to be used during closure
- Schedule for closure of each unit
HW 130. TSDFs with
hazardous waste disposal units
are required to have a written
post-closure plan (40 CFR
264 118 and 40 CFR
265 118(a) through
265 118(d)).
Verify that the plan includes the following information
- Identifies the activities that will be carried on after closure of each disposal
unit and the frequency of these activities
- Name address and phone number of the person or office to contact during
post-closure care
Verify that the plan is amended if there is a change in the expected year of final
closure, events occur during the life of the TSDF that impact closure care, or a
change in TSDF design
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hawrdows Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 131 Facilities that have
TSDFs that receive waste from
offsite sources must comply
with manifest requirements (40
CFR 264 70 and 264 71,40
CFR 265 70 and 265 71)
Determine if the TSDF receives waste from offsite sources and if their permit
allows for the receipt of offsite waste
Determine if manifests contain the following by reviewing a random number of
manifests
- Proper signature
- Date of receipt
- Wastes received are listed on permit
Verify that a copy was sent to the generator within 30 days of receipt of waste
Verify that copies are retained at the TSDF for three years
Verify that exclusion certification from CESQGs are kept on file
Verify that wastes received by the TSDF are included in their permit
(NOTE Periods of retention of records are extended automatically during the
course of any unresolved enforcement action or as requested by the EPA
Administrator)
HW 132 TSDFs receiving
hazardous waste from a foreign
source must notify the
Regional Administrator (40
CFR 264 12(a) and 40 CFR
265 12(a))
Verify that notification is sent in writing at least four weeks before delivery is
expected
HW 133 Facilities with TSDFs
which receive waste form
offsite sources are required to
attempt to resolve manifest
discrepancies when they occur
(40 CFR 264 72 and 40 CFR
265 72)
Determine if significant discrepancies existed between the quantity or type of
waste designated on the manifest or shipping paper, and the quantity or type of
waste the TSDF received
Verify that on discovery of a significant discrepancy, an attempt was made to
reconcile the discrepancy with the generator and/or the transporter
Verify that if the discrepancy could not be resolved within 15 days after receipt of
the waste, the Regional Administrator was notified by mail and the following was
included
- A letter describing the discrepancy and the attempts to reconcile it
- Copy of the manifest or shipping paper at issue
(NOTE For bulk waste, variations greater than 10 percent in weight, and for
batch waste, any variation in piece count is a significant discrepancy Significant
discrepancies in type are obvious differences which can be discovered by
inspection or waste analysis, such as waste solvent substituted for waste acid, or
toxic constituents not reported on the manifest or shipping paper These
discrepancies may only be discovered after waste analysis )
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Check#:
HW 134 Reports must be
submitted to the EPA when a
TSDF accepts an unmanifested
waste shipment (40 CFR
264 76 and 40 CFR 265.76)
Determine if unmanifested shipments have been accepted
Verify that reports (Form 8700-13B) are submitted within 15 days
(NOTE When small quantities (i e , waste from CESQGs) are received without
certification that the waste is excluded from manifest requirements, an
unmanifested waste report is required to be filed)
Surface Impoundments
HW 135. TSDFs must follow
specific restrictions concerning
the types of wastes placed in
any surface impoundment (40
CFR 264 229, 264 230, 40
CFR 265 229 and 265 230)
Verify that incompatible wastes or incompatible wastes and materials are not
placed in the same surface impoundment unless precautions are taken to prevent.
- Generation of extreme heat or pressure, fire or explosions, or violent reactions
- Production of uncontrolled toxic mists, fiimes, dusts, or gases in quantities
that would Threaten human health or the environment
- Production of uncontrolled flammable fumes or gases in quantities that would
pose a risk of fire or explosion
- Damage to structural integrity of the device or TSDF
- Threats to human health or the environment through other means
Verify that ignitable or reactive wastes are not placed in surface impoundments
unless the wastes and impoundments satisfy the restrictions in 40 CFR 268 (see
checklist items HW 105 through HW 110) and they are treated, rendered or
mixed so that it is no longer ignitable or reactive
Verify that and one of the following conditions is met for the surface
impoundment.
- Precautions are taken so that the following are prevented
- Generation of extreme heat or pressure, fire or explosions, or violent reactions
- Production of uncontrolled toxic mists, fumes, dusts, or gases in quantities
that would threaten human health or the environment
- Production of uncontrolled flammable fumes or gases in quantities that would
pose a risk of fire or explosion
- Gamage to structural integrity of the device or TSDF
- Threats to human health or the environment through other means
- The waste is managed so that it is protected from any materials or conditions
which may cause it to ignite or react
- The surface impoundment is used only for emergencies
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Haaardowf Waste M
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Compliance Category:
Haiwirdowjf Waste Management
Regulatory Requirements:
Reviewer Checks:
HW. 137 All land treatment
facilities must follow specific
guidelines for ignitable or
reactive wastes and
incompatible wastes (40 CFR
264.281 and 264 282,40 CFR
265 281 and 265 282)
Determine if the land treatment facility handles any ignitable or incompatible
waste
Verify that ignitable or reactive waste are not land treated unless
- The waste is immediately incorporated into the soil so that the resulting
mixture no longer meets the definition of ignitable or reactive waste
- The following are prevented
- generation of extreme heat or pressure, fire or explosions, or violent
reactions
- production of uncontrolled toxic mists, fumes, dusts, or gases in quantities
that would threaten human health or the environment
~ production of uncontrolled flammable fumes or gases in quantities that
would pose a risk of fire or explosion
-- damage to structural integrity of the device or facility
- threats to human health or the environment through other means
- The waste is managed in such a way that it is protected from any materials
that may cause it to react
Hazardous Waste Landfills
HW.138 All hazardous waste
landfills are required to have a
runon control system, a runoff
management system and
control the wind dispersal of
particulate matter (40 CFR
264 301(g) through
264.30l(k), 40 CFR 265.301(0
through 265 301 (i))
Verify that
- The runon control system has the capacity to prevent flow onto the active
portion of the landfill during peak discharge of 25 year storm
- The runoff management system has adequate capacity to collect and control
water from a 24 hour, 25 year storm and the contents tested to determine
correct disposal methodology
- Collection and holding tanks or basins for runon and runoff control systems
are emptied expeditiously after storms
- There are analyses of runon/off to determine required treatment, if any
- There is adequate control of wind dispersal and no blowing debris
- There is adequate cover of waste material
(NOTE. For permitted TSDFs, the permit will specify all design and operating
practices necessary to ensure compliance.)
Closure
HW 139. TSDFs must comlply
with certian closure schedules
(40 CFR 264 113(a) through
264 113(d), and 264 114,40
CFR 113(d), and 265.114)
Verify that within 90 days after receiving final volume of waste, all hazardous
waste has been treated and removed or disposed of onsite in accordance with the
closure plan
Verify that partial and final closure activities are completed in accordance with
approved closure plan within 180 days after receiving the final volume of waste.
(NOTE. The Regional Administrator may grant variances on the time period )
(NOTE During partial and final closure periods all contaminated equipment,
structures and soils must be properly disposed of By removing any hazardous
wastes or constituents during closure, the TSDF becomes a hazardous waste
generator and is subject to the requirements of 40 CFR 262 )
Phase 1 - Section 4
Hazardous Waste Management
4-86
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 140 All TSDFs are
required to follow certain
notification procedures for
partial and final closure (40
CFR 264 112(d)(1) and 40
CFR265 112(d)(1))
Verify that TSDFs with surface impoundments, waste piles, land treatment or
landfill units notify the Regional Administrator
- 180 days prior to expected date of beginning closure of the first unit for
interim status TSDFs without an approved closure plan, 60 days with an
approved closure plan
- 60 days prior to expected date of beginning closure for all permitted TSDFs
Verify that TSDFs with only tanks, containers, or incinerator units notify the
Regional Administrator within 45 days prior to the date of beginning final
closure
HW 141 Within 60 days of
completion of closure of each
hazardous waste surface
impoundment, waste pile, land
treatment, and landfill unit
facilities must submit a
certification of closure to the
Regional Administrator (40
CFR 264 115 and 40 CFR
265 115)
Verify that a certification of closure was sent to the Regional Administrator by
registered mail
HW 142 By the time that
certification of closure has
been submitted, TSDFs are
required to submit a survey plat
indicating the location and
dimensions of landfill cells in
relationship to permanently
surveyed landmarks to specific
authorities (40 CFR 264 116
and 40 CFR 265 116)
Verify that a survey plat was submitted to the local zoning authorities or the
authority with jurisdiction over local land use, and the Regional Administrator
HW 143 Post-closure care of
hazardous waste management
units must meet specific
requirements (40 CFR 264 117
and 40 CFR 265 117)
Verify that post-closure care last for 30 years after closure and consists of the
following-
- Monitoring and reporting as required in other sections
- Maintenance of waste containment systems
- Use of the property is not allowed to disturb the integrity of the final cover,
liner, or any other components
Additional Requirements for Permitted TSDFs
General
HW.144. Permitted TSDFs that
receive hazardous waste from
offsite sources must inform the
generator in writing that the
TSDF has the appropriate
permit and will accept the
waste (40 CFR 264 12(b))
Verify that notification is sent and a copy is kept in the operating record
Phase 1 - Section 4
Hazardous Waste Management
4-87
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Compliance Category;
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW.145. Permitted TSDFs that
treat, store, or dispose of
hazardous waste with solid
waste management units are
required to institute corrective
actions as outlined in the
permit to protect human health
and the environment from
releases (40 CFR 264.90(a) and
264 101)
(NOTE: This applies regardless of when the waste was placed in solid waste
management units)
Verify that corrective actions required by the permit are being done
(NOTE The Regional Administrator may identify the unit as not having to
comply with this requirement.)
HW 146 Container storage
areas at TSDFs must have a
containment system that meets
specific standards (40 CFR
264 175(a) and 264.175(b))
Verify that all container storage areas meet the following criteria
- Containers are stored on a base that is free from cracks or gaps and is
impervious so that leaks, spills, and precipitation are contained
- The base is slopedfor otherwise designed) to drain and remove liquids
resulting from lews, spills, or precipitation unless the containers are elevated
- Spilled or lea|e6d waste and accumulated precipitation is removed in a timely
manner
- The containment system has adequate capacity to contain 10 percent of the
volume of the containers or the volume of the largest container whichever is
greater
- Runpn into the containment system is prevented unless the system has
sufficient capacity to contain any runon that might enter the system in
addition to the already required capacity
(NOTE: If the collected material is a hazardous waste, it must be handled
accordingly. If it is discharged through a point source, it is subject to the Clean
Water requirements.)
HW 147 Containment at
permitted TSDFs for containers
holding wastes that do not
contain free liquids must meet
specific criteria which is lesser
than that for general
containment areas ,(40 CFR
264 175(c))
Verify that one of the following storage area criteria is met.
- The area is sloped or able to drain and remove liquid resulting from
precipitation
- Containers are elevated or protected from contact with accumulated liquid.
(NOTE. Storage areas must have complete containment systems when the
containers holding F020, F022, F023, F026, and F027 do not contain free
liquids)
HW.148 When container
storage areas are closed at
permitted TSDFs, specific
conditions must be met (40
CFR 264 178)
Verify that closure criteria were met
- All hazardous waste and residues were removed from the containment system
- Remaining containers, liners, bases, and soils (containing or contaminated
with hazardous waste or hazardous waste residues) were decontaminated or
removed
- All hazardous wastes (including materials removed from the containment
system) were managed appropriately.
Phase 1 - Section 4
Hazardous Waste Management
4-88
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 149 TSDFs with
permitted surface
impoundments, waste piles,
and land treatment units or
landfills that received
hazardous waste after 26 July
1982 are required to conduct
monitoring and response pro-
gram under specific
circumstances (40 CFR
264 90(a)(2) and 264 91)
Verify that whenever hazardous constituents specified in the permit by the
Regional Administrator are detected at designated compliance points, a
compliance monitoring program is started
Verify that whenever groundwater protection limits are exceeded, a corrective
action program is initiated
Verify that whenever hazardous constituents specified in the permit by the
Regional Administrator exceed concentration limits under 40 CFR 264 94 (see
Appendix 4-11) in groundwater between a designated compliance point and the
downgradient property boundary, a corrective action program or a detection
monitoring program is started at the TSDF
Verify that the TSDF is meeting the elements of the monitoring and response
program specified by the Regional Administrator in the permit
HW 150 TSDFs with
permitted surface
impoundments, waste piles,
and land treatment units or
landfills that received
hazardous waste after 26 July
1982 are required to comply
with specific concentration
limits in the groundwater for
hazardous constituents as
designated by the Regional
Administrator in the permit (40
CFR 264 94)
Verify that the concentration of hazardous constituents
- Do not exceed the background level of that constituent in the groundwater at
the time that limit is specified in the permit
- Do not exceed the limits outlined in Appendix 4-11
- Do not exceed an alternate limit set by the Regional Administrator
HW 151 TSDFs with
permitted surface
impoundments, waste piles,
and land treatment units or
landfills that received
hazardous waste after 26 July
1982 and that detect
statistically significant
evidence of contamination for
chemical parameters or
hazardous constituents
designated in the permit must
meet specific requirements (40
CFR 264 98(g))
Verify that the following steps are taken if there is significant evidence of
contamination
- The Regional Administrator is notified in writing within seven days
- The groundwater in all monitoring wells is immediately sampled and analyzed
for constituents in Appendix IX of 40 CFR Part 264
- Sampling is repeated after one month for any compounds detected that are
listed in Appendix IX of 40 CFR Part 264
- Within 90 days an application for a permit modification is submitted to the
Regional Administrator to establish a compliance monitoring program
Phase 1 - Section 4
Hazardous Waste Management
4-89
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 152. If during a
compliance monitoring
program the TSDF determines
that the concentration limits
listed in 40 CFR 264 94 are
being exceeded at any
monitoring well at the point of
compliance, specific actions
are required (40 CFR
264 99(h))
Verify that the following actions are taken when concentration are exceeded
- The Regional Administrator is notified in writing within seven days
• An application for a permit modification to establish a corrective action
program is submitted within 180 days
HW.153 TSDFs operating
corrective actions programs are
required to report semi-
annually to the Regional
Administrator on their
effectiveness (40 CFR
264 100(g)).
Determine if the TSDF operates a corrective action program
Verify that a semi-annual progress report is sent to the Regional Administrator
HW 154. TSDFs that are
seeking a permit for the
treatment, storage, or disposal
of hazardous waste must
initiate the corrective actions
needed to protect human health
and the environment from all
releases of hazardous waste of
constituents from any solid
waste management unit,
regardless of when the waste
was placed in the unit (40 CFR
264 101)
Verify that the corrective actions specified in the permit are being done and the
compliance schedule is being met
(NOTE As a part of the corrective action program the Regional Administrator
may designate an area of the TSDF as a Corrective Action Management Unit
(CAMU) or a Temporary Unit (TU))
HW 155. All permitted TSDFs
are required to document
compliance with igmtable,
reactive, or incompatible waste
management requirements (40
CFR 264 17(c))
Verify that compliance documentation is maintained at the TSDF, and that it is
based on published scientific or engineering literature, data from field tests, or the
results of the treatment of similar wastes by similar treatment processes or similar
operating conditions
HW 156. Permitted TSDFs
with process vents associated
with distillation, fractionation,
thinfilm evaporation, solvent
extraction, or air or steam
stripping operations that
manage hazardous wastes with
organic concentrations of at
least 10 ppmw are required to
submit a semi-annual report
concerning process vent
emissions (40 CFR 264 1036)
Verify that a semi-annual report is submitted to the Regional Administrator and
that it includes the following
- The EPA identification number, name, and address of the TSDF
- Dates when the control device exceeded or operated outside of design
specification and the exceedences were not corrected within 24 hours
- Dates when a flare operated with visible emissions
- The duration and cause of exceedences and corrective measures taken
(NOTE If there are no exceedences a report is not required )
Phase 1 - Section 4
Hazardous Waste Management
4-90
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
Surface Impoundments
HW 157 Permitted surface
impoundments must be
designed according to specific
parameters (40 CFR
264 221 (a), 264 221 (g) through
264 221(i))
Determine if the TSDF has a permitted surface impoundment
Verify that surface impoundments have a liner for all portions of the
impoundment
Verify that the impoundment is designed, constructed, maintained, and operated
to prevent overtopping, overfilling, wind and wave action, rainfall, runon,
malfunctions of level controllers, alarms and other equipment, and human error
Verify that the impoundment has dikes that are designed and constructed and
maintained to prevent massive failure of the dikes
(NOTE The Regional Administrator will specify in the permit all design and
operating practices that are necessary )
Phase 1 - Section 4
Hazardous Waste Management
4-91
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 158 New permitted
surface impoundments that
started construction after 29
January 1992, lateral
expansions of permitted
surface impoundments which
started construction after 29
July 1992, and replacements of
existing surface impoundments
where reuse started after 29
July 1992 are required to meet
specific design and operating
criteria (40 CFR264 19,
264 221(c) through 264 221(0,
264 222,264 223, and
264 226(d))
Verify that the impoundment has two or more liners and a leachate collection and
removal system between liners, or the double liner requirement has been waived
by the EPA Regional Administrator
Verify that the liner meets the specifications stated in 40 CFR 264 221(c)
Verify that the TSDF has a Construction Quality Assurance (CQA) program to
ensure that constructed units meet or exceed all design criteria and specifications
in the permit
Verify that the designated CQA officer is a registered professional engineer.
Verify that the TSDF has a written CQA plan that addresses the following
- Identification of applicable units and a description of how they will be
constructed
- Identification of key personnel
- A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator
Verify that these surface impoundments comply with the action leakage rate
assigned by the Regional Administrator
Verify that the surface impoundment facility has an approved response action
plan prior to the receipt of waste
Verify that the amount of liquid removed from each leak detection system sump
is recorded at least once a week during the active life and closure period
Verify that after a final cover is installed, the amount of liquids removed from
each leak detection system sump is recorded at least monthly or
- If the liquid level in the sump stays below the pump operating level of two
consecutive months, then the liquid amounts may be recorded quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, then the liquid amounts may be recorded semiannually
(NOTE TSDFs with replacement surface impoundments may be exempt from
these requirements if the existing unit was constructed in compliance with the
design standards of sections 3004(o)(l)(A)(i) and (o)(5) of RCRA and there is no
reason to believe the liner is not functioning as designed )
HW 159 Permitted TSDFs
must inspect liners and cover
systems during construction
and installation of liners (40
CFR 264 226(a))
(NOTE This excludes existing portions of surface impoundments exempt from
264 221(a))
Verify that liners and covers are inspected for uniformity, damage, and
imperfections
Phase 1 - Section 4
Hazardous Waste Management
4-92
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 160 TSDFs must conduct
inspections while surface
impoundments are in operation
(40 CFR 264 226(b))
Verify that inspections are conducted at least weekly and after storms to detect
evidence of the following
- Deterioration, malfunctions, or improper operation of overtop piping control
systems
- Sudden drops in the level of the impoundment contents
- Severe erosion or other signs of deterioration in dikes or other containment
devices
HW 161 Prior to the issuance
of a permit and/ or after any
period of greater than six
months of disuse, the TSDF
must obtain certification from a
qualified engineer that surface
impoundment dikes have
structural integrity (40 CFR
264 226(c))
Determine if the TSDF is permitted or if any impoundment has been out of
service for six months or more
Verify that the certification of structural integrity includes
- Verification that the impoundment can withstand the amounts and types of
waste it will contain
- That without dependence on any liner system the impoundment will not fail
due to scouring or piping
HW 162 TSDFs must follow
specific restrictions concerning
the types of wastes placed in
permitted surface
impoundments (40 CFR
264 231)
Verify that hazardous waste F020, F021, F022, F023, F026, and F027 are not
placed in the impoundment unless it is done according to a management plan
approved by the Regional Administrator
HW 163 Permitted surface
impoundments are required to
be removed from service under
specific circumstances (40
CFR 264 227(a))
Verify that surface impoundments have been removed from service if any of the
following circumstances exist.
- The level of liquid suddenly drops and the drop is not known to be cause by
changes in flow
- The dike leaks
HW 164 In order to remove a
permitted surface
impoundment from service,
specific parameters have to be
met (40 CFR 264 227(b),
264 227(c), and 264 227(e))
Verify that when a surface impoundment is removed from service the following
requirements are met
- The flow or addition of waste is immediately shut off or stopped
- Surface leakage is immediately contained
- Leaks are stopped or empty the impoundment
- The Regional Administrator is notified within seven days of problems
Verify that the contingency plan specifies a procedure for taking a surface
impoundment out of service
Verify that if a surface impoundment is removed from service and it is not being
repaired, it is closed
HW 165 Surface
impoundments may not be
restored to service unless
specific standards are met (40
CFR 264 227(d))
Verify that prior to being returned to service the following is done-
- The portion of the impoundment that was failing is repaired
- The dike is recertified if the reason for removal from service was faulty dike
integrity
- Liners are correctly installed and operating.
Phase 1 - Section 4
Hazardous Waste Management
4-93
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Compliance Category:
Baajrdous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 166 TSDFs that have
surface impoundments must
follow certain closure and post-
closure requirements (40 CFR
264 228(a) and 264 228(b))
Determine if the TSDF has closed or plans to close any surface impoundments
Verify that at closure the TSDF does one of the following
- Removes or decontaminates all waste residues, contaminated containment
system components, contaminated subsoils, and structures and equipment
contaminated with waste and leachate and manages them as hazardous waste
- Eliminates the free liquids by removing liquid wastes or solidifying the
remaining wastes and water residue and stabilizes remaining wastes to a
bearing capacity sufficient to support final cover and cover the surface
impoundment with a final cover designed and constructed to:
- provide long-term minimization of the migration of liquids
- function with minimum maintenance
~ promote drainage and minimized erosion or abrasion of the final cover
- accommodate settling and subsidence so that the cover's integrity is
maintained
-- have a permeability less than or equal to the permeability of any bottom
liner system or natural subsoils present
Verify that if waste residues or contaminated materials are left in place, the
TSDF meets post-closure requirements outlined in 40 CFR 264 117 through
264 120 and
- Maintains the integrity and effectiveness of the final cover
- Maintains and monitors the leak detection system
- Maintains and monitors the groundwater monitoring system
- Prevents runon and runoff from eroding or otherwise damaging the final
cover.
Waste Piles
HW.167. Permitted TSDFs that
store or treat hazardous waste
in waste piles must meet
specific design and operating
standards (40 CFR 264 250
and 264.251(a), 264 251(b),
and 264 251(g) through
264.25 l(k)).
(NOTE. Waste piles closed with wastes left in place are regulated as landfills
Waste piles inside or under a protective structure are exempt from the standards
in 40 CFR 264.250 through 264 259 if they contain no liquids, are protected
from runon, are designed and operated to control dispersal of waste by wind, and
do not generate leachate through decomposition or other reactions.)
Determine if the TSDF treats or stores hazardous waste in waste piles.
Verify that the following standards are met for each waste pile'
- The pile has a liner and is located on a foundation that provides support
- The liner is installed to cover all surrounding earth likely to be in contact with
the waste or leachate
- A leachate collection and removal system is located immediately above the
liner
- Leachate depth over the liner does not exceed 30 cm (1 ft)
- Protection from wind and runon is provided
- A runoff management system is in place and in operating condition
- Tanks and basins associated with the runon and runoff control systems are
emptied.
(NOTE The permit will designate all design and operating practices necessary
to ensure that the requirements are satisfied)
Phase 1 - Section 4
Hazardous Waste Management
4-94
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 168 Permitted waste piles
constructed after 29 January
1992, lateral expansions that
started after 29 July 1992, and
replacement of existing waste
piles where reuse started after
29 July 1992 are required to
meet specific design and
operating requirements (40
CFR264 19, 264 251(c)
through 264 251(0, 264 252,
264 253)
Verify that the described waste piles have two or more liners and a leachate
collection and removal system above and between the liners
Verify that the liner is designed and constructed of materials to prevent the
migration of hazardous constituents into the liner during the active life and post-
closure care period
(NOTE See 40 CFR 264 251(c)(1) and 264 251(c)(2) for details on the design
of the liner and the leachate collection system )
Verify that the TSDF has a CQA program to ensure that constructed units meet
or exceed all design criteria and specifications in the permit
Verify that the designated CQA officer is a registered professional engineer
Verify that the TSDF has a written CQA plan that addresses the following
- Identification of applicable units and a description of how they will be
constructed
- Identification of key personnel
- A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator
Verify that the pumpable liquids in the leak detection sumps are removed to
minimize the head on the bottom liner
Verify that the TSDF is complying with the action leakage rate assigned by the
Regional Administrator
Verify that the TSDF has an approved response action plan prior to the receipt of
waste
(NOTE The Regional Administrator may approve alternative designs or grant a
waiver)
Phase 1 - Section 4
Hazardous Waste Management
4-95
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Compliance Category:
Hawittlaws Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 169. TSDFs must conduct
inspections of permitted waste
piles during construction and
while they are in operation (40
CFR264 254).
Verify that if construction of a waste pile is occurring at the TSDF the following
are taking place*
- Liners and cover systems are inspected for uniformity, damage, and
imperfection
- Synthetic liners and covers are inspected for tight seams and joints
immediately after construction
- Soil based and admixed liners and covers are inspected for imperfections
Verify that the waste pile is inspected at least weekly and after storms to detect
evidence of the following
- Deterioration, malfunctions, or improper operation in runon and runoff
systems
- Proper functioning of wind dispersal control system
- Presence of leachate in, and proper functioning of leachate control system
Verify that the amount of liquids removed from each leak detection system is
record at least once a week during the active life and closure period
HW 170 TSDFs that treat
F020, F021, F022, F023, F026,
and/or F027 in permitted waste
piles are required to follow
specific operating procedures
(40 CFR 264 259)
Determine if the TSDF treats F020-F023, F026, or F027
Verify that these wastes are kept in enclosed piles unless the owner/operator has
a management plan approved by the Regional Administrator
HW 171 TSDFs that operate
permitted waste piles must
follow specific requirements
for closure and post-closure
care (40 CFR 264 258)
Verify that at the time of closure all waste residues, contaminated containment
system components, subsoils, and structures and equipment contaminated with
hazardous waste have been removed or decontaminated.
Verify that if all contaminated subsoils cannot be removed or decontaminated
practicably the site is closed and managed according to closure and post-closure
care requirements for a landfill
Verify that if the TSDF has a waste pile that does not comply with the liner
requirement, and is not exempted from this requirement, they comply with the
following
- The written closure plan addresses the removal of all contaminated substances
and a contingency plan if all contamination cannot be removed from the pile
- A contingency post-closure plan is prepared for the waste pile and be
submitted to the appropriate agency within 90 days after determining the
waste pile must be closed
Land Treatment Units
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 172 TSDFs with
permitted hazardous waste land
treatment units must meet
certain standards (40 CFR
264 270 through 264 273(f))
Determine if the TSDF operates a land treatment facility
Verify that the following standards are met at each permitted hazardous waste
land treatment unit
- The treatment zone is no more than 1 5 m (5 ft) from the initial soil surface
- The treatment zone is more than 1 m (3 ft) above the seasonal high water table
- Only wastes with hazardous constituents that can be degraded, transformed, or
immobilized are placed in the treatment zone
- Runon control systems are operated to prevent flow onto the treatment zone
during peak discharge from at least a 25 year storm
- Tanks and basins associated with the runon and runoff control systems are
emptied or otherwise managed after storms
- Wind dispersal is controlled
(NOTE The Regional Administrator will specify in a permit the exact elements
of the treatment program )
HW 173 TSDFs must conduct
inspections while land
treatment facilities are in
operation (40 CFR
264 273(g))
Verify that the land treatment system is inspected weekly and after storms to
detect evidence of
- Deterioration, malfunctions, or improper operation of runon and runoff
control systems
- Improper functioning of wind dispersal control measures
HW 174 TSDFs with food
chain crops grown in or on the
treatment zone are required to
meet specific operational
standards (40 CFR 264 276)
Determine if food chain crops are grown in or on the treatment zone
Verify that if food chain crops are grown, only those specified in the permit by
the Regional Administrator are being grown
Verify that if cadmium containing wastes are applied to food chain crops in or on
treatment zones, the following are met
- The pH of the waste and soil mixture is 6 5 or greater at the time of
application except in cases where the waste contains cadmium at
concentrations of 2 mg/kg or less
- The annual application of cadmium from waste does not exceed 0 5 kg/ha on
land used for production of tobacco, leafy vegetables, or root crops grown for
human consumption For other food chain crops the annual cadmium does not
exceed 0 5 kg/ha
- The cumulative application of cadmium from waste does not exceed 5 kg/ha if
the waste and soil mixture has a pH less than 6 5
- If the waste and soil mixture has a pH of 6 5 or greater or is maintained at a
pH of 6 5 or greater during crop growth and one of the following is met
- The cumulative application of cadmium from waste does not exceed 5 kg/ ha
if soil cation exchange capacity is less than 5 meq/IOOg
- The cumulative application of cadmium from waste does not exceed 10 kg/ ha
if soil cation exchange capacity is 5 to 15 meq/100 g
- The cumulative application of cadmium from waste does not exceed 20 kg/ ha
if soil cation exchange capacity is greater than 15 meq/100 g
- Animal feed is the only food chain crop produced
Phase 1 - Section 4
Hazardous Waste Management
4-97
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 175 Permitted land
treatment units must have an
unsaturated zone monitoring
program (40 CFR 264 278).
Verify that the unsaturated zone monitoring program meets the following
- The soil and soil-pore liquid are monitored to determine if hazardous
constituents migrate out of the treatment zone
- A system is installed that includes soil monitoring using soil cores and soil-
pore liquid monitoring using devices such as lysimeters
- A background value has been established for each hazardous constituent to be
monitored (see permit)
- The soil monitoring and soil-pore liquid monitoring is done immediately
below the treatment zone
- Consistent sampling and monitoring procedures are used
Verify that the contaminants listed in the permit are being monitored
Verify that when it is found that there is a statistically significant increase of
hazardous constituents below the treatment zone the following steps are taken
- The Regional Administrator is notified within seven days in writing
- Within 90 days a permit application is submitted to the Regional
Administrator for a permit modification to modify the operating practices
HW 176 Land treatment
facilities must keep an
operating record that includes
dates and rates of application
(40 CFR 265 279).
Verify that the operating record contains the dates and rates of applications
Phase 1 - Section 4
Hazardous Waste Management
4-98
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 177 All land treatment
facilities are required to meet
specific closure and post-
closure plans (40 CFR
264 280)
Verify That during the closure period the following requirements are met
- All operations are continued as necessary to maximize degradation,
transformation, or immobilization of hazardous constituents in the treatment
zone
- Runoff is minimized
- Runon and runoff management systems are maintained
- Wind dispersal of hazardous waste is controlled
- Compliance with food chain crop prohibitions is continued
- Unsaturated zone monitoring is continued except that soil-pore liquid
monitoring may be terminated 90 days after the last application of waste to the
treatment zone
- A vegetative cover is established on the portion of the land treatment facility
being closed when the cover will not substantially impede degradation,
transformation, or immobilization of hazardous constituents
Verify that when closure is completed, certification by an independent qualified
soil scientist or independent registered professional engineer was submitted to
the Regional Administrator that the facility has been closed according to the
specifications of an approved closure plan
Verily that during the post-closure period
- Operations are continued to enhance degradation, transformation, and sustain
immobilization of hazardous constituents in the treatment zone
- A vegetative cover is maintained
- Runon control systems are maintained
- Runoff management systems are maintained
- Wind dispersal of hazardous waste is controlled
- Food chain crop prohibitions are met
- Unsaturated zone monitoring is continued except that soil-pore liquid
monitoring may be terminated 90 days after the last application of waste to the
treatment zone
(NOTE The TSDF may not be required to establish a vegetative cover or meet
post-closure requirements if the Regional Administrator finds that the level of
hazardous waste constituents in the treatment soil zone does not exceed the
background value of those constituents by an amount that is statistically
significant)
HW 178 Hazardous wastes
F020 through F023, F026, and
F027 must not be placed in a
land treatment facility unless it
is done according to an
approved management plan for
these wastes (40 CFR
264 283)
Verify that these wastes are only place in a land treatment unit according to the
requirements of the approved waste management plan
Phase 1 - Section 4
Hazardous Waste Management
4-99
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
Hazardous Waste Landfills
HW 179. Permitted hazardous
waste landfills are required to
have a liner and a leachate
collection and removal system
(40 CFR 264.301(a) through
264 301(b))
Determine if the TSDF disposes of hazardous wastes in an onsite landfill
Verify that the landfill liner is-
- Designed, constructed, and installed to prevent any migration of waste out of
the landfill
- Placed on a properly supported base or foundation
- Installed to cover all surrounding earth likely to be in contact with the waste
Verify that the leachate collection and removal system is immediately above the
liner and will operate to remove leachate from the landfill
Verify that collected leachage is tested to determine correct disposal
methodology.
(NOTE The permit will contain specific design and operating conditions)
Phase 1 - Section 4
Hazardous Waste Management
4-100
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Compliance Category;
Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 180. New landfills on
which construction started after
29 January 1992, lateral
expansions which started
construction after 29 July
1992, and each replacement of
an existing landfill that will
start reuse after 29 July 1992
are required meet specific
design and operating standards
(40 CFR264 19, 264 301(c)
through 264.301(f), 264 302,
264 304)
Determine if the TSDF has any landfills meeting the stated criteria
Verify that the landfill has two or more liners and a leachate collection and
removal system above and between the liners or a waiver of double liner
requirement has been obtained from the EPA Regional Administrator
Verify that the TSDF has a CQA program to ensure that constructed units meet
or exceed all design criteria and specifications in the permit
Verify that the designated CQA officer is a registered professional engineer
Verify that the TSDF has a written CQA plan that addresses the following
- Identification of applicable units and a description of how they will be
constructed
- Identification of key personnel
- A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator
Verify that the pumpable liquids in the leak detection system sumps are collected
and removed to minimize the head on the bottom liner
Verify that surface impoundments subject to these requirements meet the action
leakage rate set by the Regional Administrator
Verify that the TSDF has an approved response action plan before the receipt of
waste.
Verify that if the flow rate into the leak detection system exceeds the action
leakage rate for any sump*
- The Regional Administrator is notified within seven days
- A written notification is submitted within 14 days
- To the extent practicable, the location, size and cause of any leak is
determined
- A determination is made as to whether waste receipt should be stopped or
restricted
- The Regional Administrator is notified of actions taken and actions to be
taken within 30 days after discovery
- A monthly report is submitted to the Regional Administrator as long as the
flow rate in the leak detection systems exceeds the action leakage rate
(NOTE These restrictions do not apply if the existing unit was constructed in
accordance with the design standards of section 3004(o)(l)(A)(i) and (o)(5) of
RCRA and there is no reason to believe that the liner is not functioning as
designed )
Phase 1 - Section 4
Hazardous Waste Management
4-101
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Compliance Category:
Hazardous Wast* Management
Regulatory Requirements:
Reviewer Checks:
HW 181. Hazardous waste
landfills are required to be
inspected (40 CFR 264 303)
Verify that liners were inspected during construction for overall integrity
Verify that immediately after construction was completed, the following
inspections were performed-
- Synthetic liners and covers to ensure tight seams and joints and absence of
tears
- Soil-based and admixed liners for imperfections that may increase
impermeability (e.g, cracks and root-holes)
Verify that while a landfill is in operation it is inspected weekly and after storms
to detect evidence of the following
- Deterioration, malfunctions, or improper operations of runon and runoff
control systems
- Proper functioning of wind dispersal control systems where present
- The presence of leachate in and proper functioning of the leachate collection
system
Verify that the amount of liquid removed from each leak detection sump is
recorded at least once a week during the active life of the landfill and closure
period
Verify that after a final cover is installed, the amount of liquids removed from
each leak detection system sump is recorded at least monthly or
- If the liquid level in the sump stays below the pump operating level for two
consecutive months, the liquid amounts are recorded quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, the liquid amounts are recorded semi-annually
HW 182 TSDFs with
permitted hazardous waste
landfills are required to meet
specific standards for
hazardous wastes F020, F021,
F022, F023, F026, and F027
(40 CFR 264 317)
Determine whether or not these wastes are landfilled at the TSDF
Verify that if they are landfilled, the TSDF has a management plan for their
disposal that is approved by the Regional Administrator.
Incinerators
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 183 TSDFs with
permitted hazardous waste
incinerators must comply with
certain operating requirements
(40 CFR 264 340 (a) through
264 340(c) and 264 341
through 264 344(a), 264 345,
264 346)
Determine if the TSDF incinerates hazardous waste
Determine if specific wastes (Principal Organic Hazardous Constituents (POHC))
are specified in the permit
Verify that only the wastes listed in the permit are burned, and only under the
operating conditions set forth in the permit
Verify that sufficient waste analyses are conducted throughout normal operations
to ensure that waste feed is within the limits specified in the permit
Verify that for each waste specified in the permit, the incinerator achieves a
Destruction and Removal Efficiency (DRE) of 99 99 percent
Verify that the DRE for all wastes incinerated is determined by the following
equation
(W,„- Woul)
DRE = * 100 percent
W,„ = mass feed rate of one POHC in the waste stream feeding the incinerator
W^, = mass emissions rate of the same POHC present in the exhaust emissions )
Verify that when EPA Hazardous Waste Numbers F020 through F023, F026, or
F027 are incinerated a DRE of 99 9999 percent is achieved and the Regional
Administrator is notified of the intent to burn
HW 184 Permitted hazardous
waste incinerators are required
to meet specific emission
standards (40 CFR 264 343(b)
and 264.343(c))
Determine if the incinerator produces stack emissions of hydrogen chloride
(HCL)
Verify that if HCL emissions exceed 1 8 kg/hr (4 Ib/h), the emissions are
controlled so that the rate of emission is no greater than the larger of either 1 8
kg/hr (4 lb/h) or 1 percent HCL in the stack gas prior to entering any pollution
control equipment
Verify that particulate matter no greater than 180 mg/dscm is emitted
HW. 185. Operators of
incinerators must conduct
monitoring while incinerating
hazardous waste (40 CFR
264 347)
Verify that the operator monitors, at a minimum, the following at the indicated
intervals.
- Waste feed rate, combustion temperature, combustion gas velocity, CO (prior
to release) continuously
- The incinerator and associated equipment for leaks, spills etc daily
- The emergency waste feed cutoff system and associated emergency cutoff
alarms- weekly
Verify that monitoring and inspection data is recorded and the records placed in
the operating log
Phase 1 - Section 4
Hazardous Waste Management
4-103
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 186 When permitted
hazardous waste incinerators
are closed all hazardous waste
and hazardous waste residues
must be removed (40 CFR
264 351)
Verify that all hazardous wastes and hazardous waste residues, including ash,
scrubber waters, and scrubber sludges, are removed from the incinerator site.
Miscellaneous Units
(NOTE The Open Burning/Open Detonation (OB/OD) of waste explosives at permitted TSDFs is done under the
classification of miscellaneous unit. This is also sometimes referred to as a Subpart X Permit)
HW 187 TSDFs that treat,
store, or dispose of hazardous
wastes in permitted
miscellaneous units must
comply with specific
environmental performance
standard requirements (40 CFR
264 601)
Determine whether the TSDF treats, stores, or disposes of any hazardous waste in
miscellaneous units
Verify that miscellaneous units are located, designed, constructed, operated, maintained, and
closed in a manner that will ensure protection of human health and the environment,
including
• Prevention of any release due to migration in the surface water, wetlands, or the soil
surface, taking in to consideration
— volume and physical and chemical characteristics of the waste in the unit
— the effectiveness of containing, confining, and collection systems and structures in
preventing migration
-- the hydrologic characteristics of the unit and surrounding area, including the
topography of the land around the unit
~ regional patterns of precipitation
-- existing quality, auantity, and direction of groundwater flow
— the proximity of the unit to surface waters
~ the current and potential uses of nearby surface waters and any water quality standards
established for those surface waters
~ the existing quality of surface waters and surface soils including other sources of
contamination and their cumulative impact
— regional pattern of land use
-- potential health risks caused by human exposure to the waste
•• potential for damage from exposure to domestic animals, wildlife, crops, vegetation,
and physical structures
- Prevention of any release that may have adverse affects on human health or the
environment due to migration of waste constituents in the groundwater or subsurface
environment, taking in to consideration
— volume, physical, and chemical characteristics of waste including its potential for
migration tnrough soil, liners, or other containing structures
~ the hydrological and geological characteristics of the unit and surrounding area
— existing quality of groundwater including other sources of contamination and their
cumulative impact on the groundwater
— the quantity and direction of groundwater flow
— proximity to and withdrawal rates of current and potential groundwater users
-- regional pattern of land use
-- potential for deposition or migration of waste into subsurface physical structures, and
the root zone of food-chain crops and other vegetation
-- potential health risks caused by human exposure to the waste
— potential for damage from exposure to domestic animals, wildlife, crops, vegetation,
and physical structures
Verify that miscellaneous units are designed and operated according to their permit
restrictions
Phase 1 - Section 4
Hazardous Waste Management
4-104
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 188. TSDFs that treat,
store, or dispose of hazardous
wastes in permitted
miscellaneous units must
comply with monitoring,
analysis, inspection, responses,
reporting, and corrective action
regulations (40 CFR 264 602)
Determine if the TSDF
- Follows the general inspection requirements of 40 CFR 264 15
- Tests and maintains equipment in compliance with 40 CFR 264 33
- Prepares a biennial report as specified in 40 CFR 264 75
- Prepares unmanifested waste reports and additional reports, if applicable, as
reauired in 40 CFR 264.76 through 264 77
- Takes corrective action to prevent releases as defined in 40 CFR 264 101
HW 189 A permitted
miscellaneous unit that is a
disposal unit must be
maintained according to the
permit requirements during the
post-closure period (40 CFR
264 603)
Determine if the TSDF has a closed miscellaneous unit
Verify that the post-closure requirements specified in the permit are being carried
out
Additional Requirements for Interim Status TSDFs
General
HW 190 Interim status TSDFs
are allowed to conduct OB/OD
of waste explosives under
specific conditions (40 CFR
265 382)
Determine if the TSDF is conducting OB/OD activities
Verify that the OB/OD occurs at the distance from an adjoining property line
indicated in the following chart
Lbs of Waste Explosive Minimum distance from OB/OD
or propellants activity to the proDertv of others
0 to 100 204 m (670 ft)
101 to 1000 380 m (1250 ft)
1001 to 10,000 530 m (1730 ft)
10,000 to 30,000 690 m (2260 ft)
HW 191 TSDFs operating
surface impoundments,
landfills, or land treatment
facilities are required to have a
groundwater monitoring
program that can determine the
impact of these activities on
the uppermost aquifer (40 CFR
265 90(a) through 265 90(c)
and 265 90(e))
Verify that unless the TSDF has demonstrated in writing there is a low potential
for water migration or received a waiver, the TSDF has a groundwater monitoring
program
Verify that the monitoring program is carried out throughout the active life of the
activity and also during post-closure for disposal facilities
Phase 1 - Section 4
Hazardous Waste Management
4-1 OS
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 192 Groundwater
monitoring systems are
required to meet specific
standards (40 CFR 265 91).
Verify that the groundwater monitoring system is capable of yielding groundwater
samples for analysis
Verify that groundwater monitoring systems consist of the following
Monitoring wells, at least three, installed hydraulically downgradient at the
limit of the waste management area
Monitoring wells, at least one, installed hydraulically upgradient from the
limit of the waste management area
An alternate hydraulically downgradient monitoring well location that has
been demonstrated in writing to be sufficient
(NOTE Separate monitoring systems are not required for each component of a
waste management system if the upgradient and downgradient sampling will detect
any discharge from the waste management area )
HW 193 The TSDF must
gather and analyze samples
from the groundwater
monitoring system according
to a groundwater sampling and
analysis plan (40 CFR 265 92).
Verify that the plan includes procedures and techniques for the following
Sample collection
Sample preservation and shipment
Analytical procedures
Chain of custody control
Verify that the TSDF established initial back groundwater quality
Verify that the concentrations and/or values are determined for the following
parameters and samples collected as indicated
Parameters characterizing the suitability of groundwater as drinking water as
found in Appendix III of 40 CFR 265
Parameters of chloride, iron, manganese, phenols, sodium, sulfate, annually
Parameters for pH, specific conductance, total organic carbon, total organic
halogen semi-annually
Verify that the elevation of the groundwater surface is determined each time a
sample is obtained
HW 194 Facilities with
interim status TSDFs must
have an outline of a more
extensive groundwater quality
assessment program (40 CFR
265 93(a))
Determine if a groundwater quality assessment program outline has been
developed
Verify that the program is capable of determining
Whether or not hazardous waste or hazardous waste constituents have
entered the groundwater
The rate ana extent of migration of hazardous waste or hazardous waste
constituents in the groundwater
The concentrations of hazardous waste or hazardous waste constituents in the
groundwater
HW 195 When there is a
significant increase for pH,
specific conductance, total
organic carbon, or total organic
halogen (or pH decrease) in the
downgradient wells the TSDF
must perform specific actions
(40 CFR 265 93(c)(2), and
265.93(d)(1) through
265 93(d)(4))
Verify that additional samples are taken from the wells showing a significant
change
Verify that if a significant increase (or pH decrease) is confirmed, written notice is
issued to the Regional Administrator within seven days of the confirmation
Verify that within 15 days after the notification was submitted, the TSDF submits a
groundwater quality assessment program
Verify that the program is implemented
Phase 1 - Section 4
Hazardous Waste Management
4-106
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
Reviewer Checks:
HW 196 If a TSDF is required
to have a groundwater
assessment program, specific
reports must be submitted and
actions taken depending on the
results of the program (40 CFR
265 93(d)(5) through
265 93(d)(7))
Verify that the program was implemented as soon as possible and a written report
containing an assessment of the water was sent to the Regional Administrator
(NOTE If the results of the first determinations under the program show that no
hazardous waste or hazardous waste constituents have entered the groundwater, the
TSDF can return to its usual practices of monitoring )
HW 197 Unless the
groundwater is being
monitored to satisfy a
groundwater assessment
program, the TSDF is required
to meet specific reporting and
record keeping requirements
(40 CFR 265 94(a))
Verify that records on analyses and groundwater elevations are kept throughout
the life of the site, and for disposal facilities, through post-closure
Verify that during the first year of groundwater monitoring the results of parameter
monitoring are submitted to the Regional Administrator within 15 days after
completing each quarterly analysis
Verify that after the first year, concentrations and values for monitored parameters
are reported annually
HW 198 When the
groundwater is being
monitored to satisfy a
groundwater assessment
program, records have to be
maintained of the analyses and
annual reported submitted (40
CFR 265 94(b))
Verify that records of analyses and evaluations specified in the plan are maintained
throughout the active life of the site, and for disposal facilities throughout post-
closure
Verify that the results of the program are submitted annually to the Regional
Administrator by 1 March of each calendar year
Surface Impoundments
Phase 1 - Section 4
Hazardous Waste Management
4-107
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements;
&6V&W& Cbttfctt
HW 199 New surface
impoundments that started
construction after 29 January
1992, lateral expansions of
surface impoundments which
started construction after 29
July 1992, and replacements of
existing surface impoundments
where reuse started after 29
July 1992 are required to meet
specific design and operating
criteria (40 CFR 265 19,
265 221(a) through
265 221(e), 265 221(h),
265 222, 265 223)
Verify that the listed surface impoundments have two liners and a leachate
collection and removal system between the liners unless a waiver has been granted
by the Regional Administrator
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit
Verify that the designated CQA officer is a registered professional engineer
Verify that the TSDF has a written CQA plan that addresses the following-
Identification of applicable units and a description of how they will be
constructed
Identification of key personnel
A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator.
Verify that the Regional Administrator is notified 60 days prior to the receipt of
wastes.
Verify that a TSDF submitting notice files a Part B application within six months
of the receipt of notice.
Verify that the TSDF is complying with the action leakage rate established by the
Regional Administrator and if the rate is exceeded by flow into any sump:
The Regional Administrator is notified within 7 days
A written notification is submitted within 14 days
The location, size and cause of any leak is determined to the extent
practicable
A determination is made as to whether waste receipt should be stopped or
restricted
The Regional Administrator is notified of actions taken and actions to be
taken within 30 days after discovery of a leak
A monthly report is submitted to the Regional Administrator as long as the
flow rate in the leak detection system exceeds the action leakage rate
Verify that the TSDF has an approved response action plan
(NOTE As of 18 February 1993, surface impoundments that are newly subject to
hazardous waste requirements because of new additions or characteristics for the
identification of hazardous waste are required to meet the standards outlined above
concerning having two or more liners and a leachate collection system )
Phase 1 - Section 4
Hazardous Waste Management
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Compliant Category;
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 200 Interim status surface
impoundments are required to
meet specific operating and
containment standards (40
CFR 265.221(0, 265 221(g),
265 223, 265 225, 265 226)
Verify that there is enough freeboard to prevent any overtopping of the dike by
overfilling, wave actions, or a storm
Verify that there is a freeboard of 60 cm (2 ft) unless written certification states
that a lesser freeboard is acceptable
Verify that all earthen dikes have a protective cover such as grass, shale, or rock
to minimize wind and water erosion and preserve integrity
Verify that the freeboard is inspected at least once each day
Verify that the surface impoundment is inspected at least once a week for signs of
deterioration, leaks, or failure.
Verify that the amount of liquids removed from each leak detection system sump
is recorded at least
- Once a week during the active life and closure period
- Monthly after the final cover is installed or
-- if the liquid level in the sump stays below the pump operating level of two
consecutive months, quarterly
- if the liquid level in the sump stays below the pump operating level for two
consecutive quarters, semi-annually
HW 201 In specific
circumstances additional waste
analyses must be done (40
CFR 265.225)
Verify that additional waste analyses are done whenever
- The surface impoundment is used to treat a substantially different hazardous
waste from what was previously treated
- A substantially different process is used to treat the waste
HW 202 Specific procedures
must be followed during the
closure and post-closure
periods for an interim status
surface impoundment (40 CFR
265 228)
Verify that at closure all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated
with waste and leashate are removed or decontaminated
Verify that post-closure care includes care equivalent to that for interim status
landfills and 40 CFR 265 310, including
- Elimination of free liquids
- Stabilization of wastes to a bearing capacity sufficient to support the final
cover
- Covering of surface impoundment
- Maintenance and monitoring of leak detection system
Verify that if wastes, waste residues, or contaminated materials remain after
closure
- The integrity of the final cover is maintained
- A groundwater monitoring system is maintained that meets the requirements of
40 CFR 265 90 through 265 94
- Runon and runoff are prevented from damaging or eroding the final cover
Waste Piles
Phase 1 - Section 4
Hazardous Waste Management
4-109
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW.203. Interim status waste
piles are required to meet
specific standards for wind
protection, waste analysis, and
containment (40 CFR 265 250,
265 251,265 253)
Determine if the TSDF operates an interim waste pile
Verify that interim status waste piles are covered or otherwise managed to prevent
dispersal of the pile contents by the wind
Verify that if the leachate or runoff from a pile is a hazardous waste, one of the
following is done
- Option one
~ place the pile on an impermeable base that is compatible with the waste
-- design, construct, operate, and maintain a runon control system capable of
preventing flow onto the active portion of the pile during peak discharge
from at least a 25 year storm
-- design, construct, operate, and maintain a runoff management system to
collect and control at least the water volume resulting for a 24 hour, 25 year
storm
-- empty and manage collection and holding facilities for the runon and runoff
systems
- Option two
~ protect the pile from precipitation and runon
~ no liquids or wastes containing liquids are placed in the pile
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 204 New interim status
piles which start construction
after 29 January 1992, lateral
expansions of a waste pile unit
which started after 29 July
1992, and each such
replacement of an existing
waste pile unit for which reuse
started after 29 July 1992 must
meet specific design and
operating standards (40CFR
265.19,265 255,265 259, and
265 260)
Determine if the TSDF operates an interim status waste pile meeting the listed
description
Verify that the waste pile has two or more liners and a leachate collection and
removal system
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit
Verify that the TSDF has a written CQA plan that addresses the following
- Identification of applicable units and a description of how they will be
constructed
- Identification of key personnel
- A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator
Verify that waste piles subject to these requirements meet the action leakage rate
set by the Regional Administrator
Verify that the TSDF has an approved response action plan before receipt of
waste
Verify that if the flow rate into the leak detection system exceeds the action
leakage rate for any sump1
- The Regional Administrator is notified within seven days
- A written notification is submitted within 14 days
- The location, size and cause of any leak is determined to the extent practicable
- A determination is made as to whether waste receipt should be stopped or
restricted
- The Regional Administrator is notified of actions to be taken within 30 days
after discovery of a leak
- a monthly report is submitted to the Regional Administrator as long as the flow
rate in the leak detection system exceeds the action leakage rate
Verify that the amount of liquids removed from each leak detection sump is
recorded at least one a week during the active life and closure period
HW 205 Except in specific
instances, TSDFs are required
to analyze a representative
sample from each incoming
waste before adding the waste
to an existing pile (40 CFR
265 252).
Verify that an analysis is performed unless one of the following occurs
- The only wastes that the TSDF receives for piling are compatible
- The waste received is compatible with the pile in which it is to be placed
HW.206 Interim status waste
piles must meet specific
closure and post closure
requirements (40 CFR
265 258).
Verify that at closure all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated
with waste and leachate are removed or decontaminated
Verify that if all residues cannot be removed, the waste pile is closed and post-
closure care is carried out as for a landfill
Land Treatment Units
Phase 1 - Section 4
Hazardous Waste Management
4-1II
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW.207. Interim status land
treatment units are required to
be operated according to
specific standards (40 CFR
265.270, 265.272, 265 273,
and 265 279)
Determine if the TSDF operates an interim status land treatment unit.
Verify that the following standards are met at the land treatment unit
- Hazardous wastes are not placed in or on a land treatment facility unless it can
be made less hazardous or nonhazardous by degradation, transformation, or
immobilization processes occurring in or on the soil
- Runon control systems are operated to prevent flow onto the treatment zone
duringpeak discharge from at least a 25 year storm
- Runoff management systems are capable of controlling and collecting a water
volume at least equivalent to a 24 hour, 25 year storm
- Tanks and basins associated with the runon and runoff control systems are
emptied or otherwise managed after storms
- Wind dispersal is controlled
Verify that in addition to required waste analysis, prior to placing a hazardous
waste in or on a land treatment facility the owner or operator
- Determines the concentrations in the waste of any substance which equaled or
exceeded the maximum concentrations contained in Table 1 of 264 21
- Determines the concentration of any substance which caused the waste to be
listed as hazardous
• Determines the concentrations of arsenic, cadmium, lead, and mercury if food
chain crops are grown unless there is documentation present to prove that none
of these constituents exist
Verify that hazardous waste application dates and rates are included in the
operating record
HW 208. TSDFs are required
to operate interim status land
treatment facilities where food
chain crops are grown
according to specific standards
(40 CFR 265 276)
Determine if the TSDF grows food chain crops on their land treatment facilities
Verify that the TSDF notified the Regional Administrator that food chain crops
were being grown
Verify that food chain crops are not grown on the land treatment facility unless
there is proof that the crop will not be contaminated by arsenic, lead, mercury, or
other harmful constituents
Verify that if the TSDF accepts waste that is contaminated with cadmium, the
handling practices outlined in 50 CFR 265 276(c) are followed
HW 209 TSDFs with interim
status land treatment facilities
are required to have an
unsaturated zone monitoring
plan (40 CFR 265 278)
Verify that the TSDF has an unsaturated zone monitoring plan that includes
- Soil monitoring using soil cores
- Soil-pore water monitoring using devices such as lysimeters
- Depth and number of samples to be taken.
Verify that the TSDF is following the plan
Phase 1 • Section 4
Hazardous Waste Management
4-112
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Compliance Category:
Hazardous Waste Management
Tteplafc&ry Requirements:
Reviewer Qieckr.
HW 2 f 0 TSDFs with interim
status land treatment facilities
are required to meet specific
requirements concerning
closure and post-closure (40
CFR 265 280)
Verify that in the closure plan, the TSDF has addressed the following issues for
intenm status land treatment facilities
- Control of migration of wastes
- Control of the release of contaminated runoff into surface water
- Control of the release of airborne particulates
- Compliance with food chain crop restrictions.
Verify that during closure
- Unsaturated zone monitoring is continued
- The runon control system is maintained
- The runoff management system is maintained
- There is continued control of wind dispersal of particulate matter.
Verify that when closure was completed, the TSDF notified the Regional
Administrator.
Verify that during post-closure the following is done
- Soil-core monitoring is continued as specified in the post closure plan
- Access to the unit is restricted as appropriate
- Growth of food chain crops complies with restrictions
- Wind dispersal of hazardous wastes is controlled
Hazardous Waste Landfills
Phase I - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 211 New interim status
landfill units which started
construction after 29 January
1992, each lateral expansion of
a landfill unit that started
construction after 29 July
1992, and each replacement of
an existing landfill that will
begin reuse after 29 July 1992
is required to meet specific
design and operating standards
(40CFR 265 19, 265 301(a)
through 65 301(e) and
265 302 through 265 304)
Determine if the TSDF has any interim status landfills meeting the stated criteria
Verify that the landfill has two or more liners and a leachate collection system
above and between the liners or a waiver of the double liner requirement has been
obtained from the EPA Regional Administrator
Verify that the TSDF has a CQA program to ensure that constructed units meet or
exceed all design criteria and specifications in the permit
Verify that the designated CQA officer is a registered professional engineer
Verify that the TSDF has a written CQA plan that addresses the following
- Identification of applicable units and a description of how they will be
constructed
- Identification of key personnel
- A description of sampling and inspection activities
Verify that waste is not received in a unit until an approved CQA plan has been
submitted to the Regional Administrator
Verify that the TSDF notifies the Regional Administrator at least 60 days prior to
receiving waste and files a Part B application within six months of the receipt of
notice
Verify that landfills subject to these requirements meet the action leakage rate set
by the Regional Administrator
Verify that the TSDF has an approved response action plan before the receipt of
waste
Verify that if the flow rate into the leak detection system exceed the action
leakage rate for any sump
- The Regional Administrator is notified within seven days
- A written notification is submitted within 14 days
- To the extent practicable, the location, size and cause of any leak is determined
- A determination is made as to whether waste receipt should be stopped or
restricted
- The Regional Administrator is notified of actions taken and actions to be taken
within 30 days after discovery
- A monthly report is submitted to the Regional Administrator as long as the
flow rate is the leak detection system exceeds the action leakage rate
HW.211 (continued)
Verify that after a final cover is installed, the amount of liquids removed from
each leak detection system sump is recorded at least monthly or'
- If the liquid level in the sump stays below the pump operating level for two
consecutive months, quarterly
- If the liquid level in the sump stays below the pump operating level for two
consecutive quarters, semiannually
Incinerators
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW212 TSDFs with interim
status that use incinerators for
hazardous waste must
sufficiently analyze all wastes
burned (40 CFR 265 340 and
40 CFR 265 341)
Determine if the TSDF incinerates hazardous wastes
Determine if the results of each waste analysis are kept on file in the operating
record
Verify that for each waste not previously burned at the site, the results of the
waste analysis establish
- Steady state (normal) operating conditions including
— waste fuel feed
-- auxiliary fuel feed
— air flow
-- type of pollutants that might be emitted
-- heating value
-- halogen content
-- sulfur content
-- lead concentration level
-- mercury concentration level
(NOTE TSDFs with interim status may be exempt from all the requirements for
hazardous waste incinerators (except closure) under certain conditions
- The TSDF has written documentation that the wastes they incinerate do not
contain any hazardous constituents listed in Appendix 4-4
- The documentation is retained at the TSDF
- The wastes are listed as hazardous solely because of their ignitable (Hazard
Code I) or corrosive (Hazard Code C) properties, or both as listed and
determined in 40 CFR 261, part C or D
- The wastes are listed as reactive (Hazard Code R) for characteristics other than
those listed in 40 CFR 261,23(a)(1), (2), (3), (6), (7), or (8) and will not be
burned when other hazardous wastes are present in the combustion zone)
HW2I3 TSDFs with interim
status may bum F020 through
F023, F026, F027 if they have
proper certification (40 CFR
265 352)
Determine if the TSDF burns EPA hazardous waste numbers F020 through F023,
F026, or F027
Verify that the TSDF has received certification from the Assistant Administrator
for Solid Waste and Emergency Response if such wastes are burned at the site
HW 214 TSDFs with interim
status that incinerate hazardous
waste must not feed hazardous
waste unless theincinerator is
at a steady state (40 CFR
265 345)
Verify that the waste is not fed until steady state conditions are reached by
observing the incinerator during startup and shutdown
i
Phase 1 - Section 4
Hazardous Waste Management
4-115
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Compliant Category:
Hazardous: Waste Management
Begulstory Requirements:
Reviewer Checks:
HW 215. An interim status
TSDF that incinerates
hazardous waste must conduct
monitoring and inspections (40
CFR 265 347)
Verify that the following monitoring and inspection procedures are followed
- Existing instruments related to combustion and emission are monitored every
15 min including the instruments that control'
-- waste feed
-- auxiliary fuel feed
-- air flow
-- incinerator temperature
-- scrubber flow
-- scrubber pH
- The complete incinerator and associated equipment are monitored at least daily
for leaks, spills, and fugitive emissions, including
-- pumps
-- valves
-- conveyors
— pipes
-- emergency shutdown controls
-- system alarms
HW.216. At closure of an
interim status incinerator all
hazardous waste and hazardous
waste residues must be
removed (40 CFR 265 351)
Verify that when an interim status hazardous waste incinerator is closed, the
wastes and residues are removed.
Thermal Treatment
HW.217 TSDFs with interim
status thermal treatment
facilities must meet specific
requirements (40 CFR
265.370, 265 373, 265 375,
265 381, and 265 383)
Determine if the TSDF operates an interim status thermal treatment facility (other
than enclosed devices using controlled flame combustion)
Verify that the following requirements are met
- The thermal treatment process is operating at steady state (normal) conditions,
including temperature, before adding hazardous waste (unless the process is a
noncontinuous (batch) process that requires a complete thermal cycle to treat
the waste)
- Waste analysis is performed on waste not previously treated at the thermal
treatment facility that includes
- establishing steady state (normal) operating condition
- types of pollutants which might be emitted
-- heating value
-- halogen and sulfur content
- concentrations of lead and mercury.
(NOTE The open burning of hazardous waste is prohibited except for the open
burning and detonation of waste explosives)
Verify that if open burning or detonation of waste explosives is conducted, the
following standards are met
- Pounds of waste explosives or propellants determines the minimum distance
from open burning or detonation to property of others as shown below
-- 0-100 204m (670 ft)
- 101-1000 380m (1250 ft)
- 1001-10,000 530m (1730 ft)
-- 10,001-30,000 690m (2260 ft)
Verify that at closure all wastes and residues are removed
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer CShecksj
HW218 Interim status
thermal treatment facilities
must be certified, it they treat
certain wastes (40 CFR
265 383)
Determine if the TSDF thermally treats EPA waste numbers F020 through F023,
F026, or F027.
Verify that the TSDF has received certification from the Assistant Administrator
for Solid Waste and Emergency Response to burn such wastes
HW219 Operators of interim
status thermal treatment
facilities must conduct
monitoring and inspections
while thermally treating
hazardous waste (40 CFR
265 377)
Determine if the operator conducts at a minimum the following monitoring while
thermally treating hazardous wastes
- Every 15 mm, the following instrumentation for temperature and emission
controls are monitored and appropriate corrections are made immediately
— waste feed rate
-- auxiliary fuel rate
— treatment process temperature
-- relevant process flow and level controls
-- every hour, stack emissions are visually checked for normal appearance
(color and opacity)
- Every day, the complete thermal treatment process and associated equipment
are checked including
-- pumps, valves, conveyors, pipes, etc inspected for leaks, spills, and fugitive
emissions
-- emergency shutdown controls and systems alarms are checked for proper
operation
Chemical/Physical/Biological Treatment
HW 220 TSDFs with interim
status chemical, physical, and
biological treatment facilities
must meet certain requirements
(40 CFR 265 400 through
265 402, 265 404)
Determine if the TSDF operates a chemical, physical, or biological treatment
facility to treat hazardous wastes
(NOTE These requirements do not apply to TSDFs which treat hazardous wastes
by chemical, physical, biological methods in other than tanks, surface
impoundments, and land treatment units )
Verify that the following criteria are met
- Wastes or treatment reagents are not placed in treatment process or equipment
if they could cause ruptures, leaks, corrosion or other failures
- In addition to the analyses required by 40 CFR 265 13, continuously fed
systems are equipped with waste feed cutoff or bypass system
- Waste analyses and treatment tests (e g , bench scale or pilot plant tests) are
performed, or written, documented information is obtained whenever a
substantially different waste is treated or a substantially different treatment
process is used
Verify that at closure all wastes and residues are removed
HW 221 TSDFs with
chemical, physical, and
biological treatment facilities
must conduct regular
inspections (40 CFR 265 403)
Determine if the chemical, physical, and biological treatment facility is inspected
in accordance with the following
- At least daily, discharge control and safety equipment (e g , waste feed cutoff
system, bypass system, drainage systems, ana pressure relief systems) to ensure
good working order
- At least daily, data from monitoring equipment is checked to ensure process is
operated in accordance with its design
- At least weekly, construction materials of the treatment process or equipment is
inspected to detect corrosion, leaks, etc
- At least weekly, construction materials of and the area surrounding dikes or
other discharge confinement structures are inspected to detect erosion or signs
of leakage (dead vegetation, wet spots, etc).
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste MaBagemeat
Regulatory Requirements:
Reviewer Checks:
HW.222 TSDFs with interim
status may not place ignitable,
reactive, or incompatible waste
in a treatment process or
equipment unless certain
requirements are met (40 CFR
265 405 through 265 406)
Determine whether the TSDF treats any of these wastes
Verify that any ignitable or reactive waste is treated or mixed in such a way before
or immediately after placement in the process so that the resultant material no
longer meets the definition for ignitable or reactive wastes and is treated in such a
way that it is not exposed to conditions that may cause it to react or ignite
Verify that incompatible wastes are not placed in the same treatment process,
equipment, or in unwashed equipment that previously held incompatible waste
Export/Import of Hazardous Waste
HW.223 Determine if HW are
exported/ imported, if
exported/imported, then
facilities that export hazardous
waste outside the united States
must comply with specific
notification requirements (40
CFR 262 53(a) and 262 53(b)).
Determine if the facility imports/exports hazardous waste
Verify that 60 days prior to the initial shipment of hazardous waste to each
country in each calendar year, the facility has notified the EPA (in writing) of the
following
- Name, mailing address, telephone number, and EPA identification number of
the primary exporter
- By consignee, for each hazardous waste type:
- identification of the hazardous waste shipped by EPA identification number
- DOT shipping name, hazard class, and importer for the waste
-- estimated frequency/rate at which such wastes(s) is to be exported
- estimated total quantity (in units)
- all points of entry to and departure from each foreign country the waste will
pass through
- a description of the approximate length of time the waste will remain in
each country, and how it will be handled there
- the mode of transportation used to transport the waste
- type(s) of containers used
- description of the treatment, storage, or disposal method to be used in the
receiving country
-- name and address of the foreign consignee
HW 224 When shipping
hazardous waste outside the
United States, the facility is
required to have an EPA
aclaiowledgment of consent
that confirms the consent of the
foreign country to receive the
waste (40 CFR 262.52(c) and
262 53(f))
Verify that a copy of the EPA acknowledgment of consent is on file by checking
the records
HW.225. Primary exporters of
hazardous waste must require
confirmation of the delivery of
the hazardous waste and a
description of any significant
discrepancies (40 CFR
262.54(f))
Verify that the facility has been receiving confirmation of delivery by reviewing
the manifest files.
Determine if there are any notations of discrepancies
Phase 1 - Section 4
Hazardous Waste Management
4-118
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Compliancy Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 226 Primary exporters of
hazardous waste outside the
United States are required to
use manifests with special
additions (40 CFR 262 54(a)
through 262 54(e) and
262 54(i))
Verify that the manifest copies comply with the general manifest requirements of
40 CFR 262 20 through 262 23
Determine if the following exceptions and additions are noted by reviewing the
manifest copies
- The name and address of the foreign consignee is put in the place of the
designated facility's name, address, and EPA number
- The point of departure through which the waste must travel in the United States
before entering the foreign country is indicated
- This statement "and conform to the terms of the attached EPA
Acknowledgment of Consent" is added to the end of the first sentence of the
certification in Item 16
Verify that a copy of the manifest is provided for delivery to the U.S. Customs
official at the U.S. point of departure.
(NOTE: The primary exporter's state may require the use of its manifest.)
HW.227 Primary exporters of
hazardous waste outside the
United States are required to
file an exception report under
certain conditions (40 CFR
262 55)
Verify that an exception report was filed if
- A signed copy of the manifest from the transporter containing the following
information was not received within 45 days from the day it was accepted by
the initial transporter:
- date of departure of the waste from the United States
- place of departure of the waste from the United States
-- within 90 clays from the date the waste was accepted by the initial
transporter, the facility has not received a written confirmation from the
foreign consignee stating that the hazardous waste was received
~ the waste is returned to the United States.
HW.228. Primary exporters of
hazardous waste are required to
follow specific procedures
when a shipment cannot be
delivered to the designated or
alternate consignee (40 CFR
262 54(g)).
Verify that when a shipment cannot be delivered, the facility does one of the
following-
- Renotifies the EPA of a change in the conditions of the original notification to
allow shipment to a new consignee and obtains an EPA Acknowledgment of
Consent prior to delivery
- Instructs the transporter to return the waste to the primary exporter in the
United States or designates another facility within the United States
Verify that the facility instructs the transporter to revise the manifest to reflect
changes made.
Phase 1 - Section 4
Hazardous Waste Management
4-119
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Compliance Category;
Hazardous Waste M&nagemeM
Regulatory Requirements:
Reviewer Checks;
HW.229 An annual report
must be files with the Regional
Administrator by 1 March of
each year by the primary
exporter (40 FR 262 56)
Verify that an annual report has been submitted by 1 March of every calendar year
by checking the records.
Determine if the Annual Reports contain the following information for all
hazardous waste exported during the previous year by checking a random sample*
- Type, EPA hazardous waste number, DOT hazard class and name for each
hazardous waste(s) exported
- EPA identification number for each transporter (where applicable)
- Quantity of hazardous waste(s) exported
- Frequency (dates) of hazardous waste(s) exported
- Ultimate destination for all hazardous waste(s) exported
- Efforts used to reduce the volume and toxicity of the waste (and the changes
achieved during the year in comparison to previous years)
- A certification signed by the primary exporter that states
"I certify under penalty of law that I have personally examined and
am familiar with the information submitted in this and all attached
documents, and that based on my inquiry of those individuals
immediately responsible for obtaining the information, I believe that
the submitted information is true, accurate, and complete I am aware
that there are significant penalties for submitting false information
including the possibility of fine and imprisonment"
HW 230. Primary exporters of
hazardous wastes must
maintain additional records
that relate to their export
activities (40 CFR 262 57)
Verify that copies of the following are kept for at least three years-
- Notification of intent to export
- EPA Acknowledgment of Consent
- Confirmation of delivery (signed manifests) of the waste
- Annual reports.
(NOTE: Periods of retention are automatically extended during the course of any
unresolved enforcement action )
Used Oil
General
HW 231 Depending on the
constituents of the used oil,
(see Appendix 4-12), facilities
are required to handle used oil
as a hazardous waste or
according to specific used oil
requirements (40 CFR 279.10)
Determine which types of the used oils listed in Appendix 4-12 are generated at
the facility
Verify that used oil is handled according to its classification as one of the
following (see flow chart)
- A hazardous waste
- Used oil that falls under the requirements of 40 CFR 279
- Used oil that is not subject to the requirements of the 40 CFR 279 and neither
is it a hazardous waste unless testing indicates it does contain hazardous
constituents.
Used Oil Generators
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
(NOTE The requirements for used oil generators do not apply to the following'
Household DIY used oil generators
Vessels at sea or at port (in these cases generation occurs when it is transported ashore)
Mixtures of used oil and diesel fuel mixed by the generators for use in the generators own vehicles
Fanners who generate an average of 25 gal/mo (94 64 L/mo) or less of used oil from vehicles or machinery used
on the farm in a calendar year)
(NOTE- In relation to used oil coming ashore from vessels, the owner or operator of the vessel and the person
removing or accepting used oil from the vessel are co-generators of the used oil and are both responsible for
managing the waste as used oil once it is ashore)
HW 232 Used oil generators
that detect a release (other than
a UST release) after the
effective date of the authorized
used oil program for the state
in which the release is located
must meet specific
requirements (40 CFR 279 22
(d»
Verify that when a release is detected the following is done
- The release is stopped
- The released usea oil is contained
- The released used oil is cleaned up and properly managed
- And leaking used oil storage containers or tanks are repaired or replaced prior
to returning them to service
HW 233 Generator are
allowed to bum used oil in
used oil-fire space heaters if
specific parameters are met (40
CFR 279 23)
Determine if the facility operates any used oil-fire space heaters
Verify that the following parameters are met
- The heater burns only used oil that the facility generates or used oil received
from household DIY used oil generators
- The heater is designed to have a maximum capacity of not more than 0 5
MBtu/h (0 15 W/h)
- The combustion gases from the heater are vented to the ambient air
HW 234 Except in specific
circumstances, used oil
generators must ensure that
their used oil is transported
only by transporters who have
an EPA identification number
(40 CFR 279 24)
Determine if the facility is transporting used oil or contracting the transportation
of used oil
Verify that the transporter has an EPA identification number except when
- The generator does not transport more than 55 gal (208 20L) at any time, the
vehicle used is owned by the generator or an employee of the generator, and
the used oil is going to a used oil collection center tnat is permitted
- The generator is transporting the used oil to an aggregation point owned and/or
operated by the same generator in a vehicle owned by the generator or an
employee and no more than 55 gal (208 20L) is transported
- The used oil is reclaimed under a contractual agreement and the reclaimed oil
is returned to the generator for use as lubricant, cutting oil, or coolant and the
contract (or tolling agreement) contains the following.
-- the type of used oil and frequency of shipments
— verification that the vehicle used for transportation is owned by the used oil
processor/refiner
— verification that reclaimed oil will be returned to the generator
HW 235 Used oil generators
are not allowed to mix
hazardous waste with used oil
unless specific parameters are
met (40 CFR 279 21(a))
Verify that the facility does not mix hazardous waste with used oil unless
- The resulting mixture does not exhibit any characteristics of hazardous waste
- The waste is hazardous solely because it exhibits the characteristic of
igmtability and is not a listed hazardous waste
Phase 1 - Section 4
Hazardous Waste Management
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 236 Containers used to
store used oil at used oil
generators must be in good
condition and not leaking (40
CFR 279.22(b))
Verify that containers are not leaking, bulging, rusting, damaged, or dented
Verify that used oil is transferred to a new container or managed in another
appropriate manner when necessary
HW 237 The words "USED
OIL" must be clearly marked
on containers used to store
used oil and fill pipes used to
transfer used oil into
underground storage facilities
(40 CFR 279.22(c))
Verify that containers and fill pipes used to transfer used oil are clearly marked
with the words "USED OIL"
HW.238. Containers of used
oil at used oil generator's
facilities should be managed in
accordance with good
management practices (MP)
Verify the following by inspecting containers and storage areas
- Containers are not stored more than two high and have pallets between them
- At least 3 ft (0 91 m) of aisle space is provided between rows of containers
Used Oil Collection Centers and Aggregation Points
HW.239 Do-It-Yourselfers
(DIY) used oil collection
centers are required to meet the
same standards as used oil
generators (40 CFR 279 30)
Verify that DIY used oil collection centers such as the auto hobby shop meet the
requirements outlined in the section titled USED OIL GENERATORS
HW 240 Used oil collection
centers are required t be
licensed/permitted and
operated according to specific
standards (40 CFR 279 31)
Determine if the facility operates a used oil collection center.
Verify that the collection center meets the requirements for used oil generators
outlined in the section titled USED OIL GENERATORS.
Verify that the collection center is registered/licensed/permitted/recognized by a
state/country/municipal government to manage used on
HW241 Used oil aggregation
points are required to be
operated according to the
standards for used oil
generators (40 CFR 279 32)
Verify that the used oil aggregation point is operated according to the standards
outlined in the section titled USED OIL GENERATORS
Used Oil Transportation
(NOTE These requirements concerning transportation and transfer of used oil do not apply to the following
Onsite transportation
Generators who self-transport shipments of used oil totaling 55 gal (208 20L) or less from the generator to a
used oil collection center
Generators who self-transport shipments of used oil totaling 55 gal (208 20L) or less from the generator to a
used oil aggregation point owned by the generator
Transportation of used oil generated by household DIYs from the initial generator to a regulated generator,
collection center, aggregation point, processor/refiner, or burner.)
Phase 1 - Section 4
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks;
HW 242 Transporters who put
used oil in a truck that has
previously transported
hazardous waste without
emptying and cleaning the
truck are required to transport
and handle tne used oil as a
hazardous waste (40 CFR
279 40(b) through 279 40(c))
Verify that if used oil is contaminated with hazardous waste, it is transported as a
hazardous waste according to the standards in the Hazardous Waste Management
section
(NOTE Facilities that transport used oil imported from abroad or exported
outside of the United States must met these requirements while in the boundaries
of the United States)
HW 243 Used oil transporters
can consolidate or aggregate
loads of used oil (40 CFR
279 41)
Verify that transporters conduct only incidental processing operations such as
settling and water separation unless they also comply with the requirements for
processors and refiners
HW 244 Used oil transporters
are required to have an EPA
identification number (40 CFR
279 42)
Verify that if the facility is transporting used oil, it has an EPA identification
number
HW 245 Transporters must
meet specific requirements for
deliveries and shipments of
used oil (40 CFR 279 43(a)
through 279 43(b))
Verify that all used oil is delivered to
- Another used oil transporter if the transporter has an EPA identification
number
- A used oil processing/re-refining facility with an EPA identification number
- An off-specification used oil burner facility with an EPA identification number
- An on-specification used oil burner facility
Verify that DOT labeling, packaging, and placarding requirements are met
HW 246 Transporters are
required to take specific
actions if there is a discharge
of used oil during
transportation (40 CFR
279 43(c))
Verify that if there is a discharge the following are done
- Notification of authorities (the NRC)
- Containment of the discharge
- Submit a written report to the DOT
- Cleanup
HW 247 Transporters are
required to determine if the
total halogen content of used
oil being transported or stored
at a transfer facility is above or
below 1000 ppm (40 CFR
279 44)
Verify that the transporter determines the total halogen content of the used oil by
one of the following methods-
- Testing the used oil
- Applying knowledge of halogen content of the used oil in light of the materials
or processes used
Verify that records of analyses are kept for three years
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 248. Used oil transporters
are required to keep records for
used oil shipments and
deliveries (40 CFR 279 46)
Verify that the following records are kept for each shipment accepted for
transport
- Name and address of the generator, transporter, or processor/re-refiner who
provided the used oil for transport
- EPA identification number
- The auantity of oil accepted
- The day of acceptance
- Signature of receipt
Verify that the following records are kept for each delivery to another used oil
transporter or to a used oil burner, processor/re-refiner, or disposal facility and for
export/import activities.
- The name and address of the receiving facility or transporter
- The EPA identification number of the receiving facility or transporter
- The auantity of used oil delivered
- The date of delivery
- The signature, dated upon receipt of the used oil, of a representative of the
receiving facility or transporter
Verify that records are maintained for three years
HW 249 Transfer facilities are
required to store used oil in
tanks and containers that meet
specific requirements (40 CFR
279 45(b) through 279 45(g))
Verify that the tanks and containers at transfer facilities meet the requirements
outlined in the section titled USED OIL GENERATORS.
Verify that containers and ASTs used to store used oil have secondary
containment that meets that following minimum requirements:
- Dikes, berms, or retaining walls
- A floor that covers the entire area within the dikes, berms, or retaining walls
- The system is impervious
Verify that containers and aboveground tanks are labeled with the words "USED
OIL"
Verify that fill pipes used to transfer used oil into underground storage tanks at
transfer facilities are labeled with the words "USED OIL".
HW 250 Specific steps must
be followed in response to a
release of used oil to the
environment (40 CFR
279 45(h))
Verify that the following steps are taken
- The release is stopped
- The release is contained
- The release is cleaned up and properly managed
- Necessary repairs and replacements are done
Used Oil Burners
Phase 1 - Section 4
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Heviewer Checks:
HW251 Off-specification
used oil fuel may be burned for
energy recovery in industrial
furnaces and boilers (40 CFR
279 12(c), 279 60(a), and
279 61(a))
Determine if the facility burns used oil fuel for the purpose of energy recovery
Verify that off-speculation used oil fuel is only burned for energy recovery in one
of the following-
- An industrial furnace
- A boiler that is identified as one of the following-
- industrial boilers that are located on the site of a facility engaged in a
manufacturing process where substances are transformed into new products
by mechanical or chemical processes
-- utility boilers used to produce electric power steam, heated or cooled air, or
other gases or fluids for sale
~ used oil-fired space heaters
- Hazardous waste incinerators
(NOTE The following are exempt from meeting these requirements
- The burning of used oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-refiner for purposes of processing)
HW 252 Used oil burners are
required to have an EPA
identification number (40 CFR
279 60(a) and 279 62)
Verify that the facility has an EPA identification number
(NOTE The following are exempt from meeting these requirements
- The burning of used oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-refiner for purposes of processing )
HW 253 Used oil burners are
required to determine if used
oil is a hazardous waste (40
CFR 279 60(a) and 279 63)
Verify that the used oil is either tested or the used oil burner applies their
knowledge of the halogen content of the used oil in light of the materials or
processes used, or using information from another source
Verify that copies of analyses are maintained for three years
HW 254 Used oil burners are
required to store used oil in
containers that meet specific
requirement (40 CFR
279 60(a), 279 64(a) through
279 64(0)
Verify that the containers at used oil burners meet the requirements outlined in the
section titled USED OIL GENERATORS
Verify that containers used to store used oil have secondary containment that
meets the following minimum requirements
- Dikes, berms, or retaining walls
- A floor that covers the entire area within the dikes, berms, or retaining walls
- The system is impervious
Verify that containers are labeled with the words "USED OIL".
(NOTE The following are exempt from meeting these requirements
- The burning of used oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-reflner for purposes of processing )
HW 255 Specific steps must
be followed in response to a
release at a used oil burner (40
CFR 279 60(a) and 279 64(g))
Verify that the following steps are taken
- The release is stopped
- The release is contained
- The release is cleaned up and properly managed
- Necessary repairs replacements are done
(NOTE The following are exempt from meeting these requirements
- The burning of used oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-reflner for purposes of processing)
Phase 1 - Section 4
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4-12S
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW.256 Used oil burners are
required to keep a record of
each used oil shipment
accepted for burning (40 CFR
279 60(a) and 279.65)
Verify that some form of records are kept that documents the following
- The name and address of the transporter who delivered the used oil
- The name and address of the generator or processor or re-refiner from whom
the used oil was sent to the burner
- The EPA identification numbers of the transporter or, if applicable, the
generator, processor/re-refiner
- The Quantity of used oil accepted
- The date of acceptance
Verify that records are maintained for at least three years.
(NOTE: The following are exempt from meeting these requirements
- The burning of used oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-refiner for purposes of processing )
HW.257. Before a burner can
accept the first shipment of off-
specification used oil fuel from
a generator, transporter, or
processor/re-refiner, the burner
must provide a one-time
written notice (40 CFR
279 60(a) and 279 66)
Verify that the burner issued a notice to the EPA stating the location and
description of the activity and certifying that the used oil will only be burned in an
industrial furnace or boiler.
Verify that the certification is maintained for three years from the date of the last
shipment received.
(NOTE: The following are exempt from meeting these requirements:
- The burning of usea oil by a generator in an onsite space heater
- The burning of used oil by a processor/re-refiner for purposes of processing.)
Used Oil Marketing
HW.258. Used oil fuel
marketers may only initiate a
shipment of off-specification
used oil to a used oil burner
who has an EPA identification
number and burns the used oil
in an industrial furnace or
boiler (40 CFR 279 70(b) and
279.71).
Determine if the facility is marketing off-specification used fuel oil.
Verify that it is going to an appropriate used oil burner.
(NOTE: These requirements do not apply to the following
- Persons who direct shipments of on-specification usecfoil and who are not the
first person to claim the oil is on-specification
- Usea oil generators and transporters who transport used oil received only from
generators, unless the generator or transporter directs a shipment of off-
specification used oil from their facility to a used oil burner.)
HW.259. Generators,
transporters, processor/re-
refiners, or burners must
determine if the fuel oil is off
or on-specification (40 CFR
279 70(b) and 279.72)
Verify that a determination as to whether the used oil fuel is off or on-
specification is made by analyses or obtaining copies of other analyses.
Verify that records of analyses are maintained for three years
(NOTE1 These requirements do not apply to the following-
- Persons who direct shipments of on-specification usea oil and who are not the
first person to claim the oil is on-specification
- Used oil generators and transporters who transport used oil received only from
generators, unless the generator or transporter directs a shipment of off-
specification used oil from their facility to a used oil burner.)
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 260 Used oil fuel
marketers are required to have
a EPA identification number
(40 CFR 279 70(b) and
279 73)
Verify that the facility has a EPA identification number
(NOTE These requirements do not apply to the following-
- Persons who direct shipments of on-speciflcation used oil and who are not the
first person to claim the oil is on-specification
- Used oil generators and transporters who transport used oil received only from
generators, unless the generator or transporter directs a shipment of off-
specification used oil from their facility to a used oil burner)
HW261 Any used oil
marketer that directs a
shipment of used oil to a
burner is required to keep
specific records (40 CFR
279 70(b) and 279 74)
Verify that records containing the following information are kept of each
shipment of off-specification oil
- The name and address of the transporter who delivers the used oil to the burner
- The name and address of the burner who will receive the used oil
- The EPA identification number of the burner
- The quantity of used oil shipped
- The date of shipment
(NOTE These requirements do not apply to the following
- Persons who direct shipments of on-specification used oil and who are not the
first person to claim the oil is on-specification
- Used oil generators and transporters who transport used oil received only from
generators, unless the generator or transporter directs a shipment of off-
specification used oil from their facility to a used oil burner)
HW 262 Before a used oil
generator, transporter,
processor/re-refiner directs the
first shipment of off-
specification used oil to a
burner, they must obtain a one-
time written and signed notice
from the burner (40 CFR
279 70(b) and 279 75)
Verify that notice from the burner has been received that indicates the burner
notified the EPA of the location and used oil management activities and that the
burner will only bum off-specification oil in approved furnaces and boilers
Verify that a copy of the notice is kept for three years from the date the last
shipment of off-specification used oil is shipped to the burner
HW 263 Used oil cannot be
used for dust suppression
unless allowed by the state (40
CFR 279 82)
Verify that used oil is not used for dust suppression at the facility
If used oil is used for dust suppression, verify that this activity is allowed by the
state regulatory agency
Waste Minimization/Pollution Prevention
Phase 1 - Section 4
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Compliance Category:
Hazardous Waste Management
Regulatory Requirements:
Reviewer Checks:
HW 264. The generator should
have in place a waste
minimization program to
reduce the volume and toxicity
of hazardous wastes generated
The generator is required to
sign the Generator's
Certification statement on each
manifest, attesting to its waste
minimization program.
Executive Order 12856,
Federal Compliance with
Right-to-Know Laws and
Pollution Prevention
Requirements, signed into law
in August 1993, requires each
Federal agency to develop a
pollution prevention strategy
and submit it to the EPA
Administrator by August 3,
1994 and reauires Federal
facilities to develop a written
pollution prevention plan by
December 1995.
Review the generator's waste minimization program to determine if the program
includes practical methods for reducing the volume of hazardous wastes
generated Determine whether any or all of the following methods suggested by
EPA are incorporated into the program
- The generator retains information which documents waste minimization
activities
- The program includes
-- provisions for top management assurance that waste minimization is a
company-wide effort
-- characterization of waste generation and waste management costs
-- periodic waste minimization assessments
-- a cost allocation system
-- encourages technology transfer
-- includes program implementation and evaluation
- waste minimization employee awareness plans
- adequate funding
- clearly delineated roles both within DOE and among each contractor
generating waste
- Conclude if facility actions are resulting in the reduction of hazardous wastes
(NOTE Refer to Interim Final Guidance to Hazardous Waste Generators on the
Elements of a Waste Minimization Program, 58 FR 31114, May 28, 1993. This
document is intended to provide nonbinding, and nonenforceable guidance to
generators of regulated hazardous wastes )
Phase I - Section 4
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Phase 1
Section 5
CERCLA/SARA
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Phase 1
Section 5
Table of Contents
CERCLA/SARA
A. Applicability 5-1
B. Federal Legislation 5-1
C. State/Local Regulations 5-1
D. Key Compliance Requirements 5-1
E. Key Compliance Definitions 5-5
F Records to Review 5-9
G. Physical Features to Inspect 5-10
Appendices
A5-1 Consolidated List of Chemicals Covered in Title III of SARA A5-1
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A. Applicability
This section addresses facilities where hazardous substances were released or pose a
substantial threat of a release. This section focuses on two main areas:
1. Property transfer considerations for property that may have stored or released hazardous
substances; and
2 Spill and release reporting.
Assessors are required to review agency, Federal, state, and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
of 1980
This Act, Public Law (PL) 96-510 (42 U.S. Code (USC) 9601 et seq), as amended by the
Superfund Amendments and Reauthorization Act (SARA) of 1986 (PL 99-499) provides for
liability, compensation, cleanup, and emergency response for hazardous substances released
into the environment and cleanup of inactive hazardous waste disposal sites. CERCLA,
commonly known as "Superfund," establishes a fund which is financed by hazardous substance
generators and is used to financially support cleanup and response actions of abandoned
hazardous waste sites when no financially responsible party(ies) can be found. Parties
responsible for the contamination of hazardous waste sites are liable for all costs incurred in
the cleanup and remediation process. The EPA has generated and periodically updates a list of
sites requiring cleanup under CERCLA, known as the National Priorities List (NPL).
Although Federal agency hazardous waste sites may be listed on the NPL, no Federal facilities
are eligible to receive financial assistance from the Superfund program.
C. State/Local Regulations
State and local municipalities may establish release reporting requirements that are more
stringent than those under CERCLA.
D. Key Compliance Requirements
1. Hazardous Substance Release Reporting
Under CERCLA Section 103, facilities are required to notify the National Response
Center (NRC) immediately if they release hazardous substances in excess of or equal to
Phase 1 - Section 5
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reportable quantities. Facilities with continuous and stable releases have limited notification
requirements (40 CFR 302.1 through 302.6, and 302.8).
2. National Contingency Flan (NCP)
Section 104(a) of CERCLA requires that whenever there is a release or the substantial
threat of a release of any pollutant or contaminant to the environment or which may present an
imminent and substantial danger to the public health or welfare, the President is authorized to
respond in a manner consistent with the National Contingency Plan (NCP). The NCP outlines
procedures and standards for the cleanup of releases and hazardous waste sites and establishes
the framework for site evaluations, remedial investigations/feasibility studies, remedial
selection and design, removal actions, community relations, and administrative records. The
NCP requires that the cleanup is to be conducted by the "lead agency" (the definition of which
is under 40 CFR 300.5). Under the NCP, the lead agency is responsible for conducting the
following activities as they apply to the hazardous waste site's situation.
3. Site Evaluation
If a release has or may have occurred, the first step required is a site evaluation, the goal
of which is to collect data and evaluate releases of hazardous substances, pollutants, or
contaminants to determine the extent of the release and the release's impact to public health
and the environment 40 CFR 300.420 promulgates the regulations which outline the
requirements for a site evaluation. A site evaluation is required to consist of the following
three components:
• A Preliminary Assessment (PA) which is a review of existing site information and an off-
site reconnaissance, if appropriate, to determine if a release may require further
investigations or removal actions;
• A Site Inspection (SI) which is an on-site investigation to determine whether a release has
occurred, to identify the preliminary public health and environmental threats associated
with the release, and it includes, as appropriate, both on- and off-site field sampling and
analysis; and
• A review to determine if the site should be included on the NPL.
If it is determined that the site will need remediation actions, then the lead agency is
required to institute ? remedial investigation/feasibility study, unless the release "may present
an imminent and substantial danger to public health, welfare or the environment," in which
case the facility must conduct an immediate removal action.
4. Remedial Investigation/Feasibility Study (RI/FS)
If the site is required to institute remediation actions, then the first required step is a
Remedial Investigation/Feasibility Study (RI/FS) intended to assess site conditions and
evaluate remedial alternatives to the extent necessary to select a site remedy. The regulations
Phase 1 - Section S
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5-2
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promulgated under CERCLA that apply to RI/FSs are in 40 CFR 300.430(a)-(e) and require
that an RI/FS consist of the following four steps.
• Project Scoping which is a plan developed by the facility for conducting an RI/FS such
that the detail of analysis is appropriate to the complexity of the release site problems
being addressed;
• A Remedial Investigation which is the collection of the necessary field data to adequately
characterize the release site in order to assist in developing and evaluating remedial
alternatives;
• A Risk Assessment which, as a component of the RI, should characterize the current and
potential threats to human health and the environment that may be posed by contact to
environmental media; and
• A Feasibility Study which is a study done to ensure that appropriate remedial alternatives
are developed and evaluated.
Following the completion of the RI/FS, a report must be issued and given a period for
public comment (to be discussed further in 'Community Relations') and then the lead agency
must enter in to the remedy selection and design process.
5. Remedial Selection and Design
The regulations related to the selection and design of a remedy are promulgated in 40
CFR 300.430(f) and describe the required process. The lead agency must select, in
conjunction with the lead regulatory agency, a preferred proposed alternative for remediation
which can be presented to the public (and state) for their review and comment. The public
comments must be considered before the lead agency can issue a final Remedial
Design/Remedial Action (RD/RA). Upon receiving new information from the public or
regulatory agencies, the lead agency should reassess its initial remedial alternative
determination The public comments may prompt the lead agency to modify aspects of their
preferred alternative or cause the lead agency to select a different alternative. The lead agency
and the lead regulatory agency will make the final remedy selection decision and they will
document that decision in the Record of Decision (ROD).
6. Removal Actions
If at any point during the remediation process, a determination has been made that there is
a imminent threat to public health welfare, or the environment, the lead agency is required by
CERCLA to take an appropriate removal action to abate, prevent, minimize, stabilize,
mitigate, or eliminate the release or threat of release. The promulgation of this rule in 40 CFR
300.410 requires that when the determination that a removal action is appropriate has been
made, the following steps should be undertaken as promptly as possible.
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• A removal preliminary assessment which includes the collection or review of readily
available information such as site management practices, information from waste
generator, document review, and facility interviews;
• A removal site inspection, if necessary, to gather information that was not obtained during
the removal preliminary assessment; and
• A removal action which is performed in response to a specific release.
The individual facilities will have the latitude to respond as necessary to ensure the
minimization of harm to public health, welfare, or the environment.
7. Community Relations
Section 117 of CERCLA requires (through 40 CFR 300 430 and 300.435) that the lead
agency conduct various Community Relations (CR) activities throughout the inactive waste site
evaluation process. The intention is to promote active communication between communities
affected by the release site and the facility's response for implementing remedial actions. CR
activities must be undertaken in the RI/FS, RD/RA, and removal actions processes and must
include interviewing community interest groups, developing a Community Relations Plan
(CRP), and completing various regulatory notification requirements. The CRP is designed to
ensure that the public has been provided the appropriate opportunity to become involved in
site-related decision making; to identify the appropriate activities for ensuring such public
involvement; and to provide the appropriate opportunity for the community to learn about the
release site.
8. Administrative Record
Section 133(k) of CERCLA requires the establishment and maintenance of an
administrative record which contains all documents containing information used to select
response actions, information on the RI/FS and RD/RA processes, the Record of Decision
(ROD) and all public comments received. There are specific requirements in CERCLA that are
promulgated in 40 CFR 300.800-300.805 which require the administrative record to be
maintained at a central location near the release site and that it must be easily accessible to
community interest groups.
9. Property Transfer
Under section 120(h) of CERCLA, whenever an agency for the United States enters into
contracts for the sale or other transfer of real estate which is owned by the United States, on
which hazardous substances were stored for one year or more, known to have been released,
or disposed of during the time the property was owned by the United States, the contract must
include notice of the type and quantity of such hazardous substance and the time at which such
activities took place. These rules are promulgated in 40 CFR 373 and the notifications are
required for property transfers that occurred after October 16, 1990. The hazardous substance
storage requirement only applies when quantities are or have been stored greater than or equal
to 1,000 kilograms or the CERCLA reportable quantity, whichever is greater. Hazardous
Phase 1 - Section 5
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substances that are listed as acutely hazardous wastes (40 CFR 261 30), and that are stored for
one year or more, are subject to the contract notice requirement when stored in quantities
greater than or equal to one kilogram. The release of hazardous substances applies only when
quantities greater than or equal to the substance's CERCLA reportable quantity exist.
E. Key Compliance Definitions
1. CERCLIS
The abbreviation of the CERCLA Information System, EPA's comprehensive data base
and management system that inventories and tracks releases addressed or needing to be
addressed by the Superfund program. CERCLIS contains the official inventory of CERCLA
sites and supports EPA's site planning and tracking functions Sites that EPA decides do not
warrant moving further in the site evaluation process are given a "No Further Response Action
Planned" (NFRAP) designation in CERCLIS This means that no additional Federal steps
under CERCLA will be taken at the site unless future information so warrants. Sites are not
removed from the data base after completion of evaluations in order to document that these
evaluations took place and to preclude the possibility that they be needlessly repeated.
Inclusion of a specific site or area in CERCLIS data base does not represent a determination of
any party's liability, nor does it represent a finding that any response action is necessary.
Sites that are deleted from the NPL are not designated NFRAP sites. Deleted sites are listed
in a separate category in the CERCLIS data base (40 CFR 300.5)
2. Community Relations Coordinator
Lead agency staff who work with the On-Scene Coordinations/Remedial Project Manager
(OSC/RPM) to involve and inform the public about the Superftmd process and response
actions in accordance with the interactive community relations requirements set forth in the
NCP (40 CFR 300 5).
3. Environment
As defined by section 101(8) of CERCLA, environment means the navigable waters, the
waters of the contiguous zone, and the ocean waters of which the natural resources are under
the exclusive management authority of the United States under the Magnuson Fishery
Conservation and Management Act; and any other surface water, ground water, drinking water
supply, land surface or subsurface strata, or ambient air within the United States or under the
jurisdiction of the United States (40 CFR 300.5)
4. Facility
As defined by section 101(9) of CERCLA, facility means any building, structure,
installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly owned
treatment works), well, pit, pond, lagoon, impoundment, ditch, landfill, storage container,
motor vehicle, rolling stock, or aircraft, or any site or area, where a hazardous substance has
been deposited, stored, disposed of, or placed, or otherwise come to be located; but does not
include any consumer product in consumer use or any vessel (40 CFR 300.5).
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5. Feasibility Study (FS)
A study undertaken by the lead agency to develop and evaluate options for remedial
action. The FS emphasizes data analysis and is generally performed concurrently and in an
interactive fashion with the RI, using data gathered during the RI. The RI data are used to
define the objectives of the response action, to develop remedial action alternatives, and to
undertake an initial screening and detailed analysis of the alternatives. The term also refers to
a report that describes the results of the study (40 CFR 300.5)
6. Hazard Ranking System (HRS)
The method used by EPA to evaluate the relative potential of hazardous substance releases
to cause health or safety problems, or ecological or environmental damage (40 CFR 300.5).
7. Hazardous Substance
As defined by section 101(4) of CERCLA, hazardous substance means: Any substance
designated pursuant to section 311(b)(2)(A) of the CWA; any element, compound mixture,
solution, or substance designated pursuant to section 102 of CERCLA; any hazardous waste
having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste
Disposal Act (but not including any waste the regulation of which under the Solid Waste
Disposal Act has been suspended by Act of Congress); any toxic pollutant listed under, section
307(a) of the CWA; any hazardous air pollutant listed under section 112 of the Clean Air Act;
and any imminently hazardous chemical substance or mixture with respect to which the EPA
Administrator has taken action pursuant to section 7 of the Toxic Substances Control Act. The
term does not include petroleum, including crude oil or any fraction thereof which is not
otherwise specifically listed or designated as a hazardous substance in the first sentence of this
paragraph, and the term does not include natural gas, natural gas liquids, liquefied natural gas,
or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas (40 CFR
300.5).
8. Lead Agency
The agency that provides the OSC/RPM to plan and implement response action under the
NCP, EPA, the United States Coast Guard (USCG), another Federal agency, or a state (or
political subdivision of a state) operating pursuant to a contract or cooperative agreement
executed pursuant to section 104(d)(1) of CERCLA, or designated pursuant to a Superfund
Memorandum of Agreement (SMOA) entered into pursuant to subpart F of the NCP or other
agreements may be the lead agency for a response action. In the case of a release of a
hazardous substance, pollutant, or contaminant, where the release is on, or the sole source of
the release is from, any facility or vessel under the jurisdiction, custody, or control of
Department of Defense (DOD) or Department of Energy (DOE), then DOD or DOE will be
the lead agency. Where the release is on, or the sole source of the release is from, any facility
or vessel under the jurisdiction, custody, or control of a Federal agency other than EPA, the
USCG, DOD, or DOE, then that agency will be the lead agency for remedial actions and
removal actions other than emergencies The Federal agency maintains its lead agency
responsibilities whether the remedy is selected by the Federal agency for non-NPL sites or by
EPA and the Federal agency or by EPA alone under CERCLA section 120 The lead agency
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will consult with the support agency, if one exists, throughout the response process (40 CFR
300.5).
9. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
10. National Priorities List (NPL)
The list, compiled by EPA pursuant to CERCLA section 105, of uncontrolled hazardous
substance releases in the United States that are priorities for long-term remedial evaluation and
response (40 CFR 300.5).
11. Person
An individual, firm, corporation, association, partnership, consortium, joint venture,
commercial entity, United States government, state municipality, commission, political
subdivision of a state, or any interstate body (40 CFR 300.5 and 302.3).
12. Pollutant or Contaminant
As defined by section 101(33) or CERCLA, pollutant or contaminant includes, but not be
limited to, any element, substance, compound, or mixture, including disease-causing agents,
which after release into the environment and upon exposure, ingestion, inhalation, or
assimilation into any organism, either directly from the environment or indirectly by ingestion
through food chains, will or may reasonably be anticipated to cause death, disease, behavioral
abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in
reproduction) or physical deformations, in such organisms or their offspring. The term does
not include petroleum, including crude oil or any fraction thereof which is not otherwise
specifically listed or designated as a hazardous substance under section 101(4)(A) through (F)
of CERCLA, nor does it include natural gas of pipeline quality (or mixtures of natural gas and
such synthetic gas). For purposes of the NCP, the term pollutant or contaminant means any
pollutant or contaminant that may present an imminent and substantial danger to public health
or welfare (40 CFR 300 5)
13. Preliminary Assessment (PA)
Review of existing information and an off-site reconnaissance, if appropriate, to determine
if a release may require additional investigation or action A PA may include an on-site
reconnaissance, if appropriate (40 CFR 300.5).
14. Release
As defined by section 101(22) of CERCLA, release means any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing
into the environment (including the abandonment or discarding of barrels, containers, and
other closed receptacles containing any hazardous substance or pollutant or contaminant), but
excludes: Any release which results in exposure to persons solely within a workplace, with
respect to a claim which such persons may assert against the employer of such persons;
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emissions from the engine exhaust of a motor vehicle, rolling stock, aircraft, vessel, or
pipeline pumping station engine; release of source byproduct, or special nuclear material from
a nuclear incident, as those terms are defined in the Atomic Energy Act of 1954, if such
release is subject to requirements with respect to financial protection established by the
Nuclear Regulatory Commission under section 170 of such Act, or, for the purposes of section
104 of CERCLA or any other response action, any release of source, byproduct, or special
nuclear materials from any processing site designated under section 102(a)(1) or 302(a) of the
Uranium Mill Tailings Radiation Control Act of 1978; and the normal application of fertilizer.
For purposes of the NCP, release also means threat of release (40 CFR 300.5 and 302.3).
15. Relevant and Appropriate Requirements
Those cleanup standards, standards of control, and other substantive requirements,
criteria, or limitations promulgated under Federal environmental or state environmental or
facility citing laws that, while not "applicable" to a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance at a CERCLA site, address
problems or situations sufficiently similar to those encountered at the CERCLA site that their
use is well suited to the particular site. Only those state standards that are identified in a
timely manner and are more stringent than Federal requirements may be relevant and
appropriate (40 CFR 300.5).
16. Remedial Design (RD)
The technical analysis and procedures which follow the selection of remedy for a site and
result in a detailed set of plans and specifications for implementation of the remedial actions
(40 CFR 300.5).
17. Remedial Investigation (RI)
A process undertaken by the lead agency to determine the nature and extent of the
problem presented by the release. The RI emphasizes data collection and site characterization
and is generally performed concurrently and in an interactive fashion with the feasibility study.
The RI includes sampling and monitoring, as necessary, and includes the gathering of
sufficient information to determine the necessity for remedial action and to support the
evaluation of remedial alternatives (40 CFR 300.5).
18. Remedy or Remedial Action (RA)
Those actions consistent with permanent remedy taken instead of, or in addition to,
removal action in the event of a release or threatened release of a hazardous substance into the
environment, to prevent or minimize the release of hazardous substances so that they do not
migrate to cause substantial danger to present or future public health or welfare or the
environment. The term includes, but is not limited to, such actions at the location of the
release as storage, confinement, perimeter protection suing dikes, trenches, or ditches, clay
cover, neutralization, cleanup of released hazardous substances and associated contaminated
materials, recycling or reuse diversion, destruction, segregation of reactive wastes, dredging
or excavations, repair or replacement of leaking containers, collection of leachate and run-off,
on-site treatment or incineration, provision of alternative water supplies, any monitoring
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reasonably required to assure that such actions protect the public health and welfare and the
environment and, where appropriate, post-removal site control activities. The term includes
the costs of permanent relocation of residents and businesses and community facilities
(including the cost of providing "alternative land of equivalent value" to an Indian tribe
pursuant to CERCLA section 126(b)) where EPA determines that, alone or in combination
with other measures, such relocation is more cost-effective than, and environmentally
preferable to, the transportation, storage, treatment, destruction, or secure disposition off-site
of such hazardous substances, or may otherwise be necessary to protect the public health or
welfare; the term includes off-site transport and off-site storage, treatment, destruction, or
secure disposition of hazardous substances and associated contaminated materials. For the
purpose of the NCP, the term also includes enforcement activities related thereto (40 CFR
300.5).
19. Remove or Removal
As defined by section 311(a)(8) of the CWA, refers to removal of oil or hazardous
substances from the water and shorelines or the taking of such other actions as may be
necessary to minimize or mitigate damage to the public health or welfare or to the
environment. As defined by section 101(23) of CERCLA, removal of released hazardous
substances from the environment, such actions as may be necessary taken in the event of the
threat of release of hazardous substances into the environment; such actions as may be
necessary to monitor, assess, and evaluate the release or threat of release of hazardous
substances, the disposal of removed material; or the taking of such other actions as may be
necessary to prevent, minimize, or mitigate damage to the public health or welfare or the
environment, which may otherwise result from a release or threat of release. The term
includes, in addition, without being limited to, security fencing or other measures to limit
access, provision of alternative water supplies, temporary evacuation and housing of
threatened individuals not otherwise provided for, action taken under section 104(b) of
CERCLA, post-removal site control, where appropriate, and any emergency assistance which
may be provided under the Disaster Relief Act of 1974. For the purpose of the NCP, the term
also includes enforcement activities related thereto (40 CFR 300.5).
20. Reportable Quantity
That quantity, as set forth in 40 CFR 302, the release of which requires notification
pursuant to 40 CFR 302 (40 CFR 302.3).
21. Site Inspection (SI)
An on-site investigation to determine whether there is a release or potential release and the
nature of the associated threats. The purpose is to augment the data collected in the
preliminary assessment and to generate, if necessary, sampling and other field data to
determine if further action or investigation is appropriate (40 CFR 300.5).
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5-9
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F. Records to Review
• Spill/release records
• Hazardous substance inventory records.
G. Physical Features to Inspect
• Cleanup sites.
H. Guidance for Checklist Users
Heifer To
page Numbers
All Facilities
C 1 through C 3
5-11
Release Discovery and Notification
C.4
C.5 through C.6
C.7
5-11
5-12
5-13
Site Evaluation
C 8
C 9
5-14
5-15
Remedial Investigation and Feasibility
Study
C 10
5-16
Remedial Selection and Design
C 11
5-19
Removal Action
C.12
5-20
Community Relations
C 13
5-22
Administrative Record
C.14
5-23
Property Transfer
C 15
5-24
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Compliance Category:
CERCLA/SARA
Regulatory Eeqairemeots;
Reviewer CfcectaK
All Facilities
C 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation.)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements,or equivalent state enforcement actions.
For those open items, indicate what corrective action is planned and milestones
established to correct problems
Determine how many dockets, if any, your facility has
C.2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist.
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding.)
Determine if any new regulations have been issued since the finalization of the guide.
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued
regulations.
C 3 Facilities are required to
abide by state and local
regulations concerning
hazardous materials (EO 12088,
Section 1-1)
Verify that the facility is abiding by state and local requirements.
Verify that the facility is operating according to permits issued by the state or local
agencies.
(NOTE. Issues typically regulated by state and local agencies include.
- Transportation of hazardous materials
- Notification requirements
• Response plan requirements
- Spill response requirements.)
Release Discovery and Notification
C 4 Facilities that are
determined 1) to own or
operate, or 2) who at the time
owned or operated, or 3) who
accepted hazardous substances
for transport and selected a
facility at which hazardous
substances are or have been
stored, treated, or disposed of,
are required to notify the EPA
Verify that the facility has procedures in place to identify areas where hazardous
substances are or may have been stored, treated, or released at the facility
Confirm that the facility maintains an inventory of potential inactive waste sites and
determine whether the inventory contains the following information for each site
- The site location.
- The site history (1 e , types of waste or hazardous substance that may have been
released)
- Facility responses to environmental problems
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Compliance Category:
CERCLA/SARA
Regulatory Requirements:
Reviewer decks;
C 5 Facilities were required to
notify EPA of the existence of
hazardous waste sites
(CERCLAs 103,40 CFR
300 405(b), 300 1350),
300 120(b)).
Confirm through interviewing facility personnel and reviewing facility release
reporting procedures that the facility has performed the following
- If any hazardous substances are found to have been stored, treated, or disposed of at
the facility, the EPA is notified of the existence of the site(s) unless the site(s) has
been issued a valid RCRA permit
- Notified the EPA if the facility accepted hazardous substances for transport and
selected a facility where hazardous substances are or have been stored, treated, or
disposed of without a valid RCRA permit
- Notified the National Response Center (NRC) when a hazardous substance release
exceeded a CERCLA Reportable Quantity
- Promptly notified trustees for natural resources of hazardous substance releases that
are injuring or may injure natural resources under their jurisdiction
C 6 Releases in excess or equal
to reportable quantities of
hazardous substances shall be
reported to the NRC
immediately (40 CFR 302 1
through 302 6)
Verify that spills in excess of the reportable quantities listed in Appendix 5-1 have
been reported
Verify that a procedure is in place for the notification of the NRC immediately after
becoming aware of the release
Verify that if mixtures or solutions of hazardous substances are released, except for
radionuclides, it is reported when either of the following occur:
- The quantity of all hazardous constituents of the mixture or solution is known and a
reportable quantity or more of any hazardous constituent is released
- The quantity of one or more of the hazardous constituents of the mixture or solution
is unknown and the total amount of the mixture or solution released equals or
exceeds the reportable quantity for the hazardous constituent with the lowest
reportable quantity
(NOTE Notification requirements for radionuclide releases are not included in this
guide)
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Compliance Category:
CERCLA/SARA
Regulatory fitequirmettts;
Reviewer Cbeett&
C 7 Facilities with releases
that are continuous and stable in
quantity and rate are required to
meet limited notification
requirements (40 CFR 302 8).
Determine if the facility has any releases that are continuous and stable in quantity
and rate
Verify that the following notifications have been given
- Initial telephone notification
- Initial written notification within 30 days of the initial telephone notification
- Follow-up notification within 30 days of the first anniversary date of the initial
written notification
- Notification of changes in
- The composition or source of the release
- Information submitted in the initial written notification
- The follow-up notification required on the first anniversary date of the initial
written
- Notification of when there is an increase in the quantity of the hazardous substances
in any 24-hour period that represents a statistically significant increase
(NOTE Instead of the initial written report or follow-up report, the facility may
submit a copy of the Toxic Release Inventory (TRJ) form submitted under SARA
Title III section 313 for the previous 1 July provided that conditions are met as
described in 40 CFR 302.80).)
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Compliance Category:
CERCLA/SARA
Regulatory Requirements;
Reviewer Cbectei
Site Evaluation
C 8. When a facility
Verify that for all potential inactive waste sites a preliminary assessment (PA) is
experiences a hazardous
conducted that contains at least the following
substance release to the
- A review of existing information about the release such as
environment, an evaluation of
- Information on the pathways of exposure,
the release site must be
- Exposure targets, and
performed to determine the
- Source and nature of release
extent of the release and the
- On-site reconnaissance
release's impact to public health
- Off-site reconnaissance
and the environment. A site
evaluation typically contains the
When the facility performs a remedial PA, confirm that the facility completes the
following three components (40
EPA Preliminary Assessment form or its equivalent and that it includes the following
CFR 300 420)
information:
- A description of the release
a A Preliminary Assessment
- A description of the probable nature of the release
(PA) which is a review of
- A recommendation on whether further action is warranted, which lead agency
existing site information and
should conduct further action, and whether a Site Investigation (SI) or removal
an off-site reconnaissance, if
action, or both, should be undertaken
appropriate, to determine if a
release may require further
Where the facility has received an interim or final RCRA facility permit, determine
investigations or removal
whether the facility has completed a RCRA Facility Assessment (RFA)
actions Typically, when
performing a PA, facility
For facility, Sis verify that prior to conducting any field sampling, the facility has
documents are reviewed and
developed sampling and analysis plans which consist of the following
field sampling is not
- A field sampling plan
conducted
- A Quality Assurance Project Plan (QAPP)
b A Site Inspection (SI) which
Determine whether the facility has included the following information when
is an on-site investigation to
preparing an SI
determine whether a release
- A description/history/nature of waste handling
has occurred and to identify
- A description of known contaminants
the preliminary public health
- A description of pathways of migration of contaminants
and environmental threats
- An identification and description of human and environmental targets
associated with the release
- A recommendation on whether further action is warranted.
The SI typically builds upon
the information collected
Determine if the facility determined whether a removal action is appropriate based
during the PA Furthermore,
upon the information collected during the PA/SI If so, confirm that the facility
the SI involves, as
initiated a removal PA pursuant to C 12.
appropriate, both on- and off-
site field sampling and
analysis
c A review to determine if the
site should be included on the
National Priorities List
(NPL)
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Compliance Category:
CERCLA/SARA
Regulatory Requirements:
Reviewer decks:
C 9 Sites that meet a certain
criteria may be eligible for
placement on the National
Priorities List (NPL) (40 CFR
300 425(c), (d))
Confirm that the facility has assisted Federal and state agencies in evaluating whether
release sites have met one of the following criteria
- The release scores sufficiently high pursuant to the Hazard Ranking System
(NOTE The Hazard Ranking System is the method used by EPA to evaluate the
relative potential of hazardous substance releases to cause health or safety problems,
ecological, or environmental damage )
- The state has designated a release as its highest priority (a state may have only one
highest priority)
- The release satisfies all of the following criteria
-- The Agency for Toxic Substances and Disease Registry has issued a health
advisory that recommends dissociation of individuals from the release,
- EPA determines that the release poses a significant threat to public health, and
-- EPA anticipates that it will be more cost-effective to use its remedial authority
than to use removal authority to respond to the release
(NOTE The lead agency is responsible for submitting NPL candidates to the EPA by
scoring the release site using the Hazard Ranking Scoring (HRS) model The EPA is
responsible for reviewing the lead agencies' HRS scoping package and revising them
as appropriate Finally, the EPA will propose release sites to the NPL after ensuring
appropriate public involvement (40 CFR 300 425(d)))
If the facility determines that a release is eligible for placement on the NPL, verify
that the facility has submitted the release score (using HRS model) and has provided
the appropriate backup documentation
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Compliance Category;
CERCLA/SARA
Regulatory Requiremeata;
Reviewer Checks
Remedial Investigation and Feasibility Study
C 10 The purpose of the RJ/FS
is to assess site conditions and
evaluate remedial alternatives to
the extent necessary to select a
site remedy Developing and
implementing an RI/FS
generally includes the following
(40 CFR 300 430).
a Project Scoping - The facility
should have developed a plan
for conducting an RI/FS such
that the detail of analysis is
appropriate to the complexity
of the release site problems
being addressed
b Remedial Investigation - The
purpose of an RJ is to collect
the necessary field data to
adequately characterize the
release site in order to assist
in developing and evaluating
remedial alternatives Site
characterization may be
conducted in one or more
phases to focus sampling
efforts and to better define
the potential threat to human
health or the environment
Determine whether the facility has initiated coordination with regulatory agencies to
ensure that both parties have discussed and identified the appropriate sequence
actions necessary to address the release site problems
Verify that the facility has conducted project scoping to identify the optimal set and
sequence of actions necessary to address the release site problems Specifically, the
following should be incorporated into the project scope
- The assembly and evaluation of existing data for the release site, including the
results of any removal actions and PA/SI data
- The identification of likely response scenarios, potentially applicable technologies,
and operable units that may address site problems
- The identification of the type, quality, and quantity of the data that will be collected
during the RI/FS.
- The preparation of site-specific health and safety plans that specify, at a minimum,
employee training and protective equipment, medical surveillance requirements,
standard operating procedures, and contingency plan that conforms with 29 CFR
1910 120(l)(l)and (1)(2)
- The development of a sampling and analysis plan that meets the requirements
outlined in C 8
- The identification of potential Federal and state Applicable or Relevant and
Appropriate Requirements (ARARs)
Determine whether the facility has assessed the following factors when conducting an
R1
- The physical characteristics of the site (i e , soils, sediments, geology,
hydrogeology, meteorology, and ecology)
- Characteristics of air, surface water, and ground water
- The general characteristics of the waste, including quantities, physical state,
concentration, toxicity, ability to bioaccumulate, and mobility
- The extent to which the source can be adequately identified and characterized (i e.,
evaluation of the vertical and horizontal extent of contamination)
- Actual and potential exposure routes (i.e., inhalation through air transport and
ingestion through groundwater or bioaccumulation)
- Actual and potential exposure pathways through environmental media
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Compliance Category:
CERCLA/SARA
Regulatory Requirements;
Reviewer Checks:
C 10 continued
c Risk Assessment - As a
component of the RJ, the risk
assessment should
characterize the current and
potential threats to human
health and the environment
that may be posed by contact
to environmental media
Typically, the risk
assessment results will assist
in establishing acceptable
exposure levels for use in
developing remedial
alternatives in the FS
d Feasibility Study - The
purpose of the FS is to ensure
that appropriate remedial
alternatives are developed
and evaluated The
development and evaluation
of alternatives should reflect
the scope and complexity of
the remedial action under
consideration and the release
site problems being
addressed
Verify that the facility in conjunction with regulatory agencies have identified the
potential ARARs for the release site
For each release site undergoing an RI, confirm that the facility has conducted a
baseline risk assessment which contains the following
- A characterization of the current and potential threats to human health and the
environment that may be posed by site contaminants migrating through
environmental media
- The establishment of acceptable exposure levels for use in developing remedial
alternatives
Where the facility has received an interim or final RCRA facility permit, determine
whether the facility has completed the following
- A RCRA Facility Investigation (RF1) to evaluate whether releases of hazardous
substances may have occurred from Solid Waste Management Units (SWMUs)
Verify that as a part of the FS, the facility has established remedial action objectives
(1 e , acceptable exposure levels that are protective of human health and the
environment) which have been developed by using the following
- Applicable or relevant and appropriate requirements (ARARs) under Federal or
state environmental laws
- Maximum Contaminant Level Goals (MCLGs), established under the Safe Drinking
Water Act, or if it the MCLG is determined not to be relevant, the corresponding
Maximum Contaminant Level (MCL)
- Water quality criteria established under sections 303 or 304 of the Clean Water Act
- An Alternative Concentration Limit (ACL) established according to CERCLA
section 121(d)(2)(B)(n)
For source control actions, confirm that the facility has developed alternatives tailored
to the release site conditions that employ the following, as appropriate
- Treatment techniques that reduce toxicity, mobility, or volume of the release site to
the maximum extent feasible, eliminating or minimizing the need for long-term
management
- One or more alternatives that involve little or no treatment, but provide protection
of human health and the environment primarily by preventing or controlling
exposure to the release site
- For groundwater response actions, remedial alternatives which attain site-specific
remediation levels within different time periods and using one or more different
technologies.
Phase 1 - Section 5
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Compliancy Category:
CBJ*CLA/SA»A
ftegafetory Rttjuirctottitsi
Reviewer Cfcetksi
C.10 continued
Confirm that as a part of an FS, the facility has developed the following'
- One or more innovative treatment technologies for further consideration
- A no-action alternative or a no further action alternative, if some removal or
remedial action has already occurred at the release site
Verify that, to the extent possible, the facility has considered the short- and long-term
aspects of the following criteria to guide the development and screening of remedial
alternatives.
- Effectiveness (i.e, minimization of residual risks and short-term impacts, long-term
protection, quickness of protection).
• Implementability (i.e., technical feasibility and availability).
- Cost (i.e., construction, operation, and maintenance).
Determine whether the facility has performed an analysis of a limited number of
remedial alternatives, which have been considered a viable approach to remedial
action, based on the following:
- Overall protection of human health and the environment
- Compliance with ARARs.
- Long-term effectiveness and permanence.
- Reduction of toxicity, mobility, or volume.
- Short-term effectiveness.
- Implementability.
- Cost.
- State acceptance.
- Community acceptance.
(NOTE- Where the facility has received an interim or final RCRA facility permit,
Federal and state authorities will request that a Corrective Measures Study (CMS) be
performed as part of a Corrective Action Order (CERCLA Section 3008(h)) or
corrective action requirement outlined in a permit application and/or permit
(CERCLA Section 3004(u) and (v)).)
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Compliance Category:
CERCLA/SARA
Regulatory Requiremeeta;
| Reviewer Ctectett-
Remedial Selection and Design
C 11 Upon the completion of
the RI/FS, the facility must
select in conjunction with the
regulatory agency a preferred
proposed alternative for
remediation which can be
presented to the public (and
state) for their review and
comment The public comments
must be considered before the
facility can issue a final
remedial design/remedial action
(RD/RA) Upon receiving new
information from the public or
regulatory agencies, the facility
should reassess its initial
remedial alternative
determination The public
comments may prompt the
facility to modify aspects of
their preferred alternative or
cause the facility to select a
different alternative The facility
and the lead regulatory agency
will make the final remedy
selection decision and they will
document that decision in the
Record of Decision (ROD) (40
CFR 300 430(0, 300 435(b),
(c), (f))
When the facility has, in conjunction with the regulatory agency, identified a
preferred proposed remedial action alternative, verify that the proposed plan has been
presented to the public for comment
Determine whether the proposed plan presented to the public contains the following
- A brief summary of the alternatives.
- The rationale used to develop the preferred alternative
- A summary of comments received from regulatory agencies
- A summary of any proposed waiver from an ARAR
Verify that the facility conducts the following community relation activities to
support the selection of the remedy
- Publishes a notice of availability and a brief analysis of the proposed plan in a
major local newspaper.
- Makes the proposed plan and supporting information available in the
Administrative Record
- Provides for a public comment period of not less than 30 days.
- Provides for a public meeting at or near the facility during the public comment
period.
- Keeps a transcript of the meetin| and makes the transcript available to the public
- Prepares a written summary of significant comments and new information received
during the public comment period
If any new information is made available which significantly changes the proposed
remedy, confirm that the facility
- Seeks additional public comment on the revised changes (if the changes could not
reasonably have been anticipated by the public)
- Includes a discussion in the ROD of the changes and the reasons
- Issues a revised proposed plan which includes a discussion of the significant
changes and reasons.
Determine whether, after a review of the regulatory agency and public comments, the
facility, in conjunction with the regulatory agency, has selected a final remedy and
documented this remedy in a ROD that contains the following information
- How the selected remedy is protective of human health.
- A description of ARARs that will be met
- A description of ARARs that will not be met and applicable waivers
- How the remedy is cost-effective
- How the remedy uses permanent solutions and alternative treatment technologies to
the maximum extent
Whether preferences for remedies employing treatment which permanently and
significantly reduces the toxicity, mobility, or volume as a principal element is or is
not satisfied and, if not, why not
- If the remedy is selected with pollution prevention technologies in mind
- The remediation levels the remedy is expected to achieve
- A discussion of significant changes made to the proposed plan and a response to
public comments
- Whether contamination will remain at the site such that a review will have to be
made no less often than every five years
Phase 1 - Section 5
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Compliance Category:
CERCLA/SARA
Regulatory ftequlrcmeata;
' Reviewer Cheeks?
C 11. continued
Verily that the facility has developed an RD/RA that is consistent with the selected
and implemented remedy as set forth in the ROD
Determine whether the facility has ensured that all Federal and state requirements that
are identified in the ROD (i e, ARARs) have been met during the RD/RA
Determine whether the facility has reviewed the community relations plan prior to
initiating the RD to identify if the plan should be revised to address additional or new
public involvement activities during the RD/RA process.
Confirm that Operations and Maintenance (O&M) measures have been initiated after
the remedial action objectives/goals outlined in the ROD have been achieved.
Removal Action
C 12 At any release site,
regardless if the site has been
included on the NPL, where the
facility has made the
determination that there is a
threat to public health, welfare,
or the environment, the facility
may take an appropriate
removal action to abate,
prevent, minimize, stabilize,
mitigate, or eliminate the release
or threat of release When the
facility has determined that a
removal action is appropriate,
the facility should undertaken
the action as promptly as
possible The action typically
consists of the following three
stages (40 CFR 300 410,
300.415)
a A removal preliminary
assessment which includes
the collection or review of
readily available information
such as site management
practices, information from
waste generator, document
review, and facility
interviews.
b. A removal site inspection, if
necessary, to gather
information that was not
obtained during the removal
preliminary assessment
c. A removal action which is
performed in response to a
specific release.
Confirm that the following information has been considered by the facility when
performing a removal preliminaiy assessment-
- Identification of the source and nature of the release or threat of release
- Evaluation by the Agency for Toxic Substances and Disease Registry or by other
sources (e g, state public health agencies) of the threat to public health
- Evaluation of the magnitude of the threat
- Evaluation of factors necessary to make the determination of whether a removal is
necessary
Determine whether a removal site inspection has been performed.
Verify that the facility has documented the results obtained from a removal site
evaluation.
Verify that the facility evaluated the following factors prior to initiating a removal
action to determine whether or not the action was appropriate
- Actual or potential exposure of contaminants to nearby human populations,
animals, or the food chain
- Actual or potential contamination of drinking water supplies or sensitive
ecosystems.
- Hazardous substances or contaminants stored at the facility that may pose a threat
of release.
- High levels of hazardous substances or contaminants m surface soils that may
migrate.
- Weather conditions that may cause hazardous substances or contaminants to be
released.
- Threat of fire or explosion.
- The availability of appropriate release response mechanisms
Phase 1 - Section 5
CERCLA/SARA
5-20
-------
Compliance Category:
CERCLA/SARA
Regulatory Requirements:
Reviewer Checks?
C 12 Continued
If the removal action requires a planning period of greater than six months, verify that
the facility has developed the following
- An Engineering Evaluation/Cost Analysis (EE/CA) on the removal alternatives for
the site
- A sampling and analysis plan that has been reviewed and approved by the EPA
If removal actions have been implemented, determine whether the selected action, to
the extent practicable, has contributed to the anticipated long-term remedial action for
the release site
(NOTE 40 CFR 300 415(d) provides several removal action examples )
Confirm that the facility has performed the following community relations activities
when initiating a removal action
- A spokesperson has been selected to inform the community of actions taken, to
respond to inquiries, and to provide information concerning the release
- For actions in which less than six months exist before on-site removal activity
begin, the facility
-- Publishes a notice of availability of the Administrative Record file in a major
newspaper within 60 days of initiating the on-site removal activity,
-- Provides a public comment period of not less than 30 days from the time the
Administrative Record was made available to the public, and
- Prepares a written response to significant public comments
- For removal actions where on-site activity is expected to extend beyond 120 days
from the initiation of those activities, determine whether the facility conducted the
following before the end of the 120-day period
-- Conducted community interviews,
- Prepared a community relations plan based upon the community interviews and
other relevant information, and
- Established an information repository and Administrative Record, available to
the public, at or near the facility
- For planning periods of at least six months prior to initiating an on-site removal
activity, determine whether the facility has completed the following
-- Complied with the requirements of c above prior to completing the EE/CA
(except that the information repository and Administrative Record must be
established no later than when the EE/CA Approval Memorandum is signed),
- Published a notice of availability and brief description of the EE/CA in a major
local newspaper,
-- Provided a public comment period on the EE/CA of not less than 30 days, and
- Prepared a written response to significant public comments
Phase 1 - Section S
CERCLA/SARA
5-21
-------
Compliance Category:
CERCLA/SARA
Regulatory Requirements;
Reviewer C6eck»
Community Relations
C 13 The facility is required to
conduct various Community
Relations (CR) activities
throughout the inactive waste
site evaluation process The
community relations
requirements are intended to
promote active communication
between communities affected
by the release site and the
facility response for
implementing remedial actions
Specifically, the facility will be
required to initiate CR activities
during the RI/FS, removal
action, and enforcement action
stages Examples of CR
activities will include
interviewing community interest
groups, developing a
Community Relations Plan
(CRP), and completing various
regulatory notification
requirements The purpose of
the CRP is to ensure that the
public has been provided the
appropriate opportunity to
become involved in site-related
decision making, to identify the
appropriate activities for
ensuring such public
involvement, and to provide the
appropriate opportunity for the
community to learn about the
release site (40 CFR 300 430(c),
(0)
Verify that prior to commencing fieldwork for the RI, the facility has completed the
following
- Conducted interviews with community interest groups
- Developed a Community Relations Plan (CRP) that is based on the community
interviews and other relevant information.
- Established and informed the public of the establishment of a information
repository at or near the location of the response action
Confirm that the facility prior to initiating their remedial design reviewed the CRP to
determine whether it should be revised to describe further public involvement
activities during the RD/RA phase that were not already addressed or provided for in
the CRP
Ensure that if the facility (with assistance from regulatory agencies) enters into an
enforcement agreement with de minimis parties, a notice of the proposed agreement
has been published in the Federal Register at least 30 days before the agreement
becomes final
Verify that if an enforcement agreement is embodied in a consent decree, that public
notice and opportunity for public comment are provided
If a change in the remedial or enforcement action has occurred, confirm that the
facility has issued a notice in a major local newspaper stating that the ROD has
undergone a revision
Verify that after the ROD has been signed, the facility has made it available for public
inspection and has published a notice of the ROD's availability in a major local
newspaper
Phase 1 - Section 5
CERCLA/SARA
5-22
-------
Compliancy C&tegory:
CmCUJSA&A
Regulatory ttequirefttettts;
Hevjewer Cltcksr
Administrative Record
C 14 It is required that the
facility develop and maintain an
administrative record that
contains the documents that
form the basis for the selection
of a response action The
administrative record is required
to be maintained at a central
location near the release site and
the record should be easily
accessible to community interest
groups (40 CFR 300 800,
300 805,300 810, 300 815,
300 820)
Confirm that the facility has established a docket at an office of the facility or other
central location for which documents included in the administrative record are located
and a copy of the documents in the AR have also been made available for public
inspection at or near the release site.
When documents have not been placed in a file at or near the release site, verify that
the facility has added such documents to the file upon request
Verify that copies of the following documents have been submitted to the EPA
- The administrative record index
- RI/FS work plans
- RJ/FS reports released for public comment
- Proposed remedial action plan
- Public comments on the RJ/FS and proposed plan
- Any documents specifically requested by the EPA
Review the administrative record to ensure that it contains the following documents
- Data that has been used to form the basis for the selection of a response action
(specific examples are noted in 40 CFR 300 810(a)(1))
- Guidance documents, technical literature, and site-specific policies that may form
the basis for the selection of a response action (specific examples are noted in 40
CFR 300 810(a)(2))
- Documents received, published, or made available to the public for remedial or
removal actions (specific examples are noted in 40 CFR 300 810(a)(3))
- Decision documents (e g, ROD, action memorandum)
- Enforcement orders
- Document index
For removal actions that have a planning period of at least six months prior to
initiating on-site activities, verify the following
- The administrative record has been made available for public inspection at or near
the site when the Engineering Evaluation/Cost Analysis (EE/CA) has been made
available for public comment
- A public participation process and public comment period has been provided as
outlined in C 12
For removal actions that are not subjected to C 14, verify the following
- Documents included in the administrative record were made available for public
inspection no later than 60 days after initiation of on-site removal activity
- A notice of availability was published in a major local newspaper when the
administrative documents were made available for public inspection
- A public comment period of not less than 30 days was provided
For remedial investigation actions, ensure that the facility completed the following
- The administrative record file used for selecting a remedial action was made
available for public inspection when the remedial investigation phase begins
- A public comment period was provided as outlined in Step C 14
- The public participation process was completed as outlined in Step C 14
Property Transfer
Phase I - Section 5
CERCLA/SARA
5-23
-------
Compliance Category:
C&RCLA/SARA
Regulatory Requirements;
Reviewer Checks;
C 15 Facilities are required to
identify in contracts for the sale
or other transfer of real estate
which is owned by the United
States that hazardous substances
were stored for one year or
more, known to have been
released, or disposed of during
the time the property was
owned by the United States
This notification is required for
property transfers that occurred
after October 16, 1990 The real
estate contract is required to
include, to the extent such
information is available, the
type and quantity of hazardous
substances, and the period at
which the storage, release, or
disposal took place The
hazardous substance storage
requirement only applies when
quantities are or have been
stored greater than or equal to
1,000 kilograms or the
CERCLA reportable quantity,
whichever is greater Hazardous
substances that are listed as
acutely hazardous wastes (40
CFR 261 30), and that are
stored for one year or more, are
subject to the contract notice
requirement when stored in
quantities greater than or equal
to one kilogram The release of
hazardous substances applies
only when quantities greater
than or equal to the substance's
CERCLA reportable quantity
exist (40 CFR 373)
Confirm that the facility has developed procedures to ensure that property which is
transferred to any entity has been evaluated to determine whether hazardous
substances are or were stored on-site or whether hazardous substance were released
Verify that the facility has completed the necessary contract notification requirements
when real estate, which has been owned by the facility, is sold or transferred after
October 16, 1990, and satisfies the following
- Hazardous substances are or have been stored in quantities greater than or equal to
1,000 kilograms or the CERCLA reportable quantity, whichever is greater
- Hazardous substances have been stored for one year or more
- Hazardous substances, which are listed as acutely hazardous waste (40 CFR
261 30), have been stored for one year or more, and in quantities greater than or
equal to one kilogram
- Hazardous substance releases in quantities greater than or equal to the substance's
CERCLA reportable quantity
Review real estate property sale and transfer contracts to confirm that they include the
following
- Notice of the following
-- Hazardous substance name,
- The Chemical Abstracts Services Registry Number (CASRN), where applicable,
- Hazardous substance regulatory synonym as listed in 40 CFR 302 4, where
applicable,
- The RCRA hazardous waste number specified in 40 CFR 261 30, where
applicable,
-- The quantity in kilograms and pounds of the hazardous substance that has been
stored for one year or more, or known to have been released or disposed of on
the property, and
-- The dates that such storage, release, or disposal occurred.
- The following statement has been prominently displayed- "The information
contained in this notice is required under the authority of regulations promulgated
under section 120(h) of the Comprehensive Environmental Response,
Compensation, and Liabilities Act (CERCLA or "Superfiind") 42 U S.C section
9620(h)"
Phase 1 - Section S
CERCLA/SARA
5-24
-------
Section 5
CERCLA/SARA
Appendix
-------
Appendix 5-1
Consolidated List of Chemicals Covered in Title HI of SARA
This consolidated chemical list includes chemicals subject to reporting requirements under Title
III of SARA. This consolidated chemical list does not contain all chemicals that are subject to
reporting requirements in Sections 311 and 312 of SARA Title III. These hazardous chemicals,
for which MSDS must be developed under the Occupational Safety and Health Act Hazard
Communication Standards, are identified by broad criteria, rather than enumeration. There are
over 50,000 such substances that meet the criteria. The consolidated list has been prepared to
help determine whether there is a need to submit reports under Section 304 or 313 of Title III
and, for a specific chemical, what reports need to be submitted.
The list includes chemicals under the four following Federal statutory provisions:
1. SARA Section 302 Extremely Hazardous Substances - The presence of which, in sufficient
quantities, requires certain emergency planning activities to be conducted. Releases of these
substances are also subject to reporting under Section 304 of Title III. The final rule listing
the extremely hazardous substances and their threshold planning quantities (TPQ), is found
in 40 CFR355.
2. CERCLA Hazardous Substances (RQ) Chemicals - Releases of which are subject to
reporting under the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA or Superfund) of 1980. Such releases are also subject to reporting under
Section 304 of Title III. CERCLA hazardous substances, and their reportable quantities
(RQ), are listed in 40 CFR Part 302, Table 302.4.
3. SARA Section 313 Toxic Chemicals - Emissions or releases of which must be reported
annually as part of SARA Title Ill's community right-to-know provisions. A list of these
toxic chemicals is found in 40 CFR 372.65.
4. RCRA Hazardous Wastes - from the "P" and "U" lists (40 CFR 261.33), of specific
chemicals. RCRA hazardous wastes from the "F" and "K" lists are not included here; such
waste streams are also CERCLA hazardous substances. This listing is provided as an
indicator that you may already have data on a specific chemical that can be used for Title III
reporting purposes.
There are four columns in the consolidated list corresponding to these four statutory provisions.
If a chemical is listed as an extremely hazardous substance under Section 302, its TPQ is given in
the extremely hazardous substance column. Similarly, the CERCLA RQ is given for those
chemicals that are listed as hazardous substances. A key to the symbols used in the Section 302
and CERCLA columns precedes the list. An "X" in the column for Section 313 indicates that the
chemical is subject to reporting under Section 313.
The letter-and-digit code in the column for 40 CFR 261.33 is the chemical's RCRA hazardous
waste code. A blank in any of these columns indicates that the chemical is not subject to the
corresponding statutory authorities.
The Chemical Abstract Service (CAS) registry number is provided for each chemical on the list.
A5-1
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Key to Symbols in the Consolidated Chemical List
* Indicates that the RQ is subject to change when an assessment of potential carcinogenicity
and/or chronic toxicity is completed; until then, the statutory RQ applies.
## Indicates that an adjusted RQ has been proposed, but a final judgment has not been made.
+ USEPA has proposed to adjust the RQ for radionuclides by establishing RQs in units of
curies; until then, the 1 lb RQ applies.
* Indicates that the chemical is proposed for deletion from the list of extremely hazardous
substances.
* * Indicates that no RQ is assigned to this generic or broad class.
A5-2
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Consolidated Chemical List
This is an alphabetical listing of the consolidated list of chemicals Numbered chemicals are
listed first.
Chemical Name
Extremely
Haz Sub 40
CFR355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
1 ,Amino-2-methyl-anthraquinone
X
82-28-0
1-Butan amine,N-butyl-N-nitroso-
10
X
U172
924-16-3
1 -Chloro-1,1 -difluoroethane (HCFC-
142(b)
X
75-68-3
1 -Chloro-1,1,2,2-tetrafluorocthane
(HCFC-124a)
X
354-25-6
1 -Methylbutadiene
100
U186
504-60-9
l-Naphthalamine
100
X
U167
134-32-7
1-Propan amine
5000
U194
107-10-8
l-Propanol,2,3-dibromo-phosphate (3 1)
10
X
U235
126-72-7
(1,1 '-Biphenyl)-4,4'dianiine,
3,3'dimethoxy-
100
X
U091
119-90-4
(1,1 '-Bipheny l)-4,4'diamine,
3,3'dimethyl-
10
X
U095
119-93-7
1,1 -Dichloro-1 -fluoroethane (HCFC-
141b)
X
1717-80-6
1,1 -Dichloro-1,2,2-trifluoroethane
(HCFC-123b)
X
812-04-4
1,1-Dichloroethane
1000
U076
75-34-3
1,1 -Dichloroethylene
100
X
U078
75-35-4
1,1,1,2-T etrachloroethane
X
630-20-6
1,2-Benzenedicarboxylic acid,[bis(2-
ethylhexyl)]ester
100
X
U028
117-81-7
1,2-Benzenedicarboxylic acid, diethyl
ester (diethyl phthlate)
1000
X
U088
84-66-2
1,2-Benzenediol,4-[ 1 -hydroxy-2-
(methylamino) ethyl]-
1000
P042
51-43-4
1,2-Benzisothiazolin-3(2H) one, 1,1-
dioxide
100
X
U202
81-07-2
A5-3
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
1,2-Benzphenanthrene
100
U050
218-01-9
1,2-Butylene oxide
X
106-88-7
1,2-Dibromo-3-chloropropane
1
X
U066
96-12-8
1,2-Dichloro-1,1,2-trifluoroethane
(HCFC-123a)
X
354-23-4
1,2-Dichloroethane
100
X
U077
107-06-2
1,2-Dichloroethylene
X
540-59-0
1,2-Dichloropropane
1000
X
U083
78-87-5
1,2-Dimethylhydrazine
1
U099
540-73-8
1,2-Dipheny lhydrazine
10
X
U109
122-66-7
1,2-Oxathiolane,2,2-dioxide
10
X
U193
1120-71-4
1,2-trans-Dichloroethy lene
1000
U079
156-60-5
1,3-Benzenediol
5000
U201
108-46-3
1,3-Benzodioxole, 5-propyl
10
U090
94-58-6
l,3-Benzodioxole,5-)l-l propenyl
100
X
U14I
120-58-1
1,3-Benzodioxole, 5-) 2,propenyl
100
X
U203
94-59-7
1,3-Butadiene
X
106-99-0
1,3-Dichloropropylene
100
X
U084
542-75-6
1,3-Isobenzofurandione
5000
X
U190
85-44-9
1,4-Dichloro-2-butene
X
764-41-0
1,4-Diethylene dioxide (1,4-Dioxane)
100
X
U108
123-91-1
1,4-Naphthalenedione
5000
U166
130-15-4
2-Acetylaminofluorene
1
X
U005
53-96-3
2-Aminoanthraquinone
X
117-79-3
2-Butanone peroxide
10
U160
1338-23-4
2-Butanone (Methyl ethyl ketone)
5000
X
U159
78-93-3
2-Butene, 1,4-dichloro-
1
U074
764-41-0
2-Chloro-l,l,2,2-
tetrafluoroethane(HCFC 124)
X
2837-89-0
2-Chloroacetophenone
X
532-27-4
A5-4
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
{pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
2-Chloroethyl vinyl ether
1000
U042
110-75-8
2-Chlorophenol
100
U048
95-57-8
2-Cyclohexl-4,6-dinitrophenoll
100
P034
131-89-5
2-Ethoxyethanol
100
x
110-80-5
2-Furancarboxaldehyde
5000
U125
98-01-1
2-Methoxyethanol
x
109-86-4
2-Methylpyndine
X
109-06-8
2-Naphthylamine
10
X
U168
91-59-8
2-Nitropropane
10
X
U171
79-46-9
2-Phenylphenol
X
90-43-7
2-Picoline
5000
U191
109-06-8
2,2-Dichloro-1,1,1 -tnfluoroethane
(HCFC-123)
X
306-83-2
2,2-Dichloropropionic acid
5000
75-99-0
2,3-Dichloropropene
100
X
78-88-6
2,3,4-T nchlorophenol
10
X
15950-66-0
2,3,5-T nchlorophenol
10
933-78-8
2,3,6-T nchlorophenol
10
933-75-5
2,3,7,8-Tetrachlorodibenzo p-dioxin
(TCDD)
1
1746-01-6
2,4-D acid
100
X
U240
94-75-7
2,4-D esters
100
94-11-1
2,4-D esters
100
94-79-1
2,4-D esters
100
94-80-4
2,4-D esters
100
1320-18-9
2,4-D esters
100
1928-38-7
2,4-D esters
100
2971-38-2
2,4-D esters
100
53467-11-1
2,4-D esters
100
1928-61-6
2,4-D esters
100
1929-73-3
A5-5
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
2,4-D esters
100
25168-26-7
2,4-Diaminoanisole sulfate
X
39156-41-7
2,4-Diaminosole
X
615-41-7
2,4-Diaminotoluene
10
U221
823-40-5
2,4-Dichlorophenol
100
X
U08I
120-83-2
2,4-Dimethylphenol
100
X
U10I
105-67-9
2,4-Dmitrophenol
10
X
P048
51-28-5
2,4,5-T esters
1000
25168-15-4
2,4,5-T salts
1000
13560-99-1
2,4,5-T amines
5000
1319-72-8
2,4,5-T amines
5000
3813-14-7
2,4,5-T amines
5000
6369-96-6
2,4,5-T amines
5000
6369-97-7
2,4,5-T amines
5000
2008-46-0
2,4,5-T esters
1000
93-79-8
2,4,5-T esters
1000
1928-47-8
2,4,5-T esters
1000
2545-59-7
2,4,5-T esters
1000
61792-07-2
2,4,5-T
1000
U232
93-76-5
2,4,5-TP acid esters
100
32534-95-5
2,5-Furandione
5000
X
U147
108-31-6
2,6-Dichlorophenol
100
1)082
87-65-0
2,6-Xylidine
X
87-62-7
3,3-Dichlorobenzidine
X
91-94-1
3,4-Diaminotoluene
10
X
U22I
95-80-7
3,4-Dimtrotoluene
10
610-39-9
3,4,5-Tnchlorophenol
10
609-19-8
3,5-Diehloro-N-{l, 1 -dimethyl-2-
propynyl) benzamide
5000
U192
23950-58-5
A5-6
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65M
Haz Mat
which are
RCRA
wastes
CAS No.
4-Aminoazobenzene
X
60-09-3
4-Aminobiphenyl
X
92-67-1
4-Chloro-m-cresol
5000
U039
59-50-7
4-Chlorophenyl phenyl ether
5000
7005-72-3
4-Nitrobiphenyl
X
92-93-3
4,4'-Diaminodiphenyl ether
X
101-80-4
4,4'-Isopropylidenediphenol
X
80-05-7
4,4'-Methylene bis(N,N-di-methyl)
benzen amine
X
101-61-1
4,4'-Methylenedianiline
X
101-77-9
4,4'-Thiodianiline 6-dinitrophenoll
X
139-65-1
5-Nitro-o-anisidine
X
99-59-2
5-Nitro-o-toluidine
X
99-55-6
Acenaphthene
100
83-32-9
Acenaphthylene
5000
208-96-8
Acetaldehyde
1000
X
U001
75-07-0
Acetaldehyde, tnchloro-
5000
U034
75-87-6
Acetamide
X
60-35-5
Acetamide-N-(4-ethoxyphenyl)-
100
U187
62-44-2
Acetamide,N-{aminothi-oxomethyl)-
1000
P002
591-08-2
Acetic acid
5000
64-19-7
Acetic acid, ethyl ester
5000
U112
141-78-6
Acetic acid, fluoro, sodium salt
10/10,000
10
P058
62-74-8
Acetic acid, lead(2+) salt
10
U144
301-04-2
Acetic acid, thallium(l+) salt
100
U214
563-68-8
Acetic anhydride
5000
108-24-7
Acetone
5000
X
U002
67-64-1
Acetone cyanohydnn
1000
10
P069
75-86-5
Acetone thiosemicarbazide
1000/10,000
1752-30-3
A5-7
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
foounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fai
Haz Mat
which are
RCRA
wastes
CAS No.
Acetonitrile
5000
X
U003
75-05-8
Acetophenone
5000
X
U004
98-86-2
Acetyl bromide
5000
506-96-7
Acetyl chloride
5000
U006
75-36-5
Acrolein
500
1
X
P003
107-02-8
Acrylamide
1000/10,000
5000
X
U007
79-06-1
Acrylic acid
5000
X
U008
79-10-7
Acrylonitrile
10,000
100
X
U009
107-13-1
Acrylyl chloride
100
814-68-6
Adipic acid
5000
124-04-09
Adipomtrile
1000
111-69-3
Aldicarb
100/10,000
1
P070
116-06-3
Aldrin
500/10,000
1
X
P004
309-00-2
Allyl alcohol
1000
100
X
P005
107-18-6
Allyl chlonde
1000
X
107-05-1
Allylamine
500
107-11-9
alpha,alpha-Dimethyl phenethylamine
5000
P046
122-09-8
alpha-Endosulfan
1
959-98-8
alpha-BHC
10
319-84-6
Aluminum (fume or dust)
X
7429-90-5
Aluminum oxide (fibrous forms)
X
1344-28-1
Aluminum phosphide
500
100
P006
20859-73-8
Aluminum sulfate
5000
10043-01-3
Aminoptenn
500/10,000
54-62-6
Amiton
500
78-53-5
Anuton oxalate
100/10,000
3734-97-2
Amitrole
10
X
U011
61-82-5
Ammonia
500
100
X
7664-41-7
Ammonium acetate
5000
631-61-8
A5-8
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(bounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(h)
Haz Mat
which are
RCRA
wastes
CAS No.
Ammonium benzoate
5000
1863-63-4
Ammonium bicarbonate
5000
1066-33-7
Ammonium bichromate
10
7789-09-5
Ammonium bifluoride
100
1341-49-7
Ammonium bisulfite
5000
10192-30-0
Ammonium carbamate
5000
1111-78-0
Ammonium carbonate
5000
506-87-6
Ammonium chloride
5000
12125-02-9
Ammonium chromate
10
7788-98-9
Ammonium citrate,dibasic
5000
3012-65-5
Ammonium fluoborate
5000
13826-83-0
Ammonium fluoride
100
12125-01-8
Ammonium hydroxide
1000
336-21-6
Ammonium nitrate (solution)
x
6484-52-2
Ammonium oxalate
5000
5972-73-6
Ammonium oxalate
5000
6009-70-7
Ammonium oxalate
5000
14258-49-2
Ammonium picrate
10
P009
131-74-8
Ammonium silicofluonde
1000
16919-19-0
Ammonium sulfamate
5000
7773-06-0
Ammonium sulfate (solution)
X
7783-20-2
Ammonium sulfide
100
12135-76-1
Ammonium sulfite
5000
10196-04-0
Ammonium tartrate
5000
14307-43-8
Ammonium tartrate
5000
3164-29-2
Ammonium thiocyanate
5000
1762-95-4
Ammonium vanadate
1000
PI 19
7803-55-6
Amphetamine
1000
300-62-9
Amyl acetate
5000
628-63-7
A5-9
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
HazSub40
CFR355
(bounds^
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372j6S(&)
Haz Mat
which are
RCRA
wastes
CAS No.
Analine, 2,4,6- tnmethyl-
500
88-05-1
Amline
1000
5000
X
U012
62-53-3
Anthracene
5000
X
120-12-7
Antimony
5000
X
7440-36-0
Antimony pentachlondc
1000
7647-18-9
Antimony pentafluonde
500
7783-70-2
Antimony potassium tartrate
100
28300-74-5
Antimony tribromide
1000
7789-61-9
Antimony trichloride
1000
10025-91-9
Antimony trifluoride
1000
7783-56-4
Antimony tnoxide
1000
1309-64-4
Antimycin A
1000/10,000
1397-94-0
Antu
500/10,000
86-88-4
Aroclor 1016
1
12674-11-2
Aroclor 1221
I
11104-28-2
Aroclor 1232
1
11141-16-5
Aroclor 1242
1
53469-21-9
Aroclor 1248
1
12672-29-6
Aroclor 1254
1
11097-69-1
Aroclor 1260
1
11096-82-5
Arsenic
1
X
7440-38-2
Arsenic acid
1
P010
1327-52-2
Arsenic acid
1
P010
7778-39-4
Arsenic disulfide
1
1303-32-8
Arsenic pentoxide
100/10,000
1
P011
1303-28-2
Arsenic trisulflde
1
1303-33-9
Arsenic trioxide
100/10,000
1
P012
1327-53-3
Arsenous trichloride
500
I
7784-34-1
Arsine
100
7784-42-1
A5-I0
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Eitremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Arsine, diethyl-
1
P038
692-42-2
Asbestos
1
X
1332-21-4
Azaserine
1
U015
115-02-6
Azinophos-ethyl
100/10,000
2642-71-9
Azinophos-methyl
10/10,000
86-50-0
Barium and compounds
X
7440-39-3
Barium cyanide
10
P013
542-62-1
Benzal chloride
500
5000
X
U017
98-87-3
Benzamide
X
55-21-0
Benz[a]anthracene
10
U018
56-55-3
Benzanthracene,7,12-dimethyl-
1
U094
57-97-6
Benz[c]acridine
100
U016
225-51-4
Benzenamine,2-methyl 5-nitro-
100
U181
99-55-8
Benzenamine,2-methyl, hydrochloride
100
X
U222
636-21-5
Benzenamine,3-(tnfluoro-methyl)-
500
98-16-8
Benzenamine-4-chloro
1000
P024
106-47-8
Benzenamine,4-chloro-2-methyl-
hydrochlonde
100
U049
3165-93-3
Benzenenamine, 4-methyl
100
U353
106-49-0
Benzen amine,4-nitro-
5000
P077
100-01-6
Benzenamine 4,4'-methylenebis-2-chloro
10
X
U158
101-14-4
Benzenamine,NN-dimethyl-4-phenylazo
10
X
U093
60-11-7
Benzene
10
X
U019
71-43-2
Benzene, 1 -bromo-4-phenoxy-
100
U030
101-55-3
Benzene, 1 -{chloromethy l)-4-mtro-
500/10,000
100-14-1
Benzene, 1 -methy 1-2,4-dinitro-
10
X
U105
121-14-2
Benzene, 1-methylethyl- (Cumene)
5000
X
U055
98-82-8
Benzene, 1,2-dichloro
100
X
U070
95-50-1
Benzene, 1,2,4,5-tetrachloro-
5000
U207
95-94-3
A5-11
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
bounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Benzene, 1,3-dichloro
100
X
U071
541-73-1
Benzene, 1,3-dnsocy-anatomethy 1
100
X
U223
26471-62-5
Benzene, 1,3,5-trinitro-
10
U234
99-35-4
Benzene, 1,4-dichloro
100
X
U072
106-46-7
Benzene, 2-methyl-l,3-dinitro-
100
X
U106
606-20-2
Benzene, chloro-
100
X
U037
108-90-7
Benzene, dimethyl-
1000
X
U239
1330-20-7
Benzene, hexachloro-
10
X
U127
118-74-1
Benzene, hexahydro- (cyclohexane)
1000
X
U056
110-82-7
Benzene, m-dimethyl-
1000
X
108-38-3
Benzene, methyl-{toulene)
1000
X
U220
108-88-3
Benzene, o-dimethyl-
1000
X
95-47-6
Benzene, p-dimethyl-
1000
X
106-42-3
Benzene, pentachloro-
10
U183
608-93-5
Benzene, pentachloronitro-
100
X
U185
82-68-8
Benzenearsomc acid
10/10,000
98-05-5
Benzenesulfonyl chloride
100
U020
98-09-9
Benzidine
1
X
U021
92-87-5
Benzimidazole,4,5-dichloro-2-
(trifluoromethyl)
500/10,000
36J5-2I-2
Benz[)]aceanthrylene, 1,2-dihydro-3-
methyl-
10
UI57
56-49-5
Benzoic acid
5000
65-85-0
Benzo[a]pyrene
1
U022
50-32-8
Benzo[b]fluoranthene
1
205-99-2
Benzo[ghi]perylene
5000
191-24-2
Benzoic acid
5000
65-85-0
Benzo|jk]fluorene
100
U120
206-44-0
Benzo[k]fluoranthene
5000
207-08-9
Benzonitrile
5000
100-47-0
AS-12
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Eitremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Benzo trichloride
500
10
X
U023
98-07-7
Benzoyl chloride
1000
X
98-88-4
Benzoyl peroxide
X
94-36-0
Benzyl chloride
500
100
X
P028
100-44-7
Benzyl cyanide
500
140-29-4
Beryllium chloride
1
7787-47-5
Beryllium fluoride
1
7787-49-7
Beryllium nitrate
1
13597-99-4
Beryllium nitrate
1
7787-55-5
Beryllium powder
10
X
P015
7440-41-7
beta-Endosyulfan
1
33213-65-9
beta-BHC
1
319-85-7
beta-Chloronaphthalene
5000
U047
91-58-7
Bicyclo[2 2 l]heptane-2-carbonitr\le, 5-
chloro-6-(methyla)
500/10,000
15271-41-7
Biphenyl
X
92-52-4
Bis(2-chloroethoxy) methane
1000
X
U024
111-91-1
Bis(2-chloroisopropyl) ether
1000
X
U027
108-60-1
Bis(2-ethylhexyl)adipate
X
103-23-1
Bis(chloromethyl)ketone
10/10,000
534-07-6
Bitoscariate
500/10,000
4044-65-9
Boron trichloride
500
10294-34-5
Boron tnfluoride compound with methyl
ether (1 1)
1000
353-42-4
Boron trifluoride
500
7637-07-2
Bromadiolone
100/10,000
18772-56-7
Bromine
500
7726-95-6
Bromoacetone
1000
P017
598-31-2
Bromochlorodifluoromethan (Halon
1211)
X
353-59-3
A5-13
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
HazSub40
CFR355
fDOundat
HazSubRQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
Haz Mat
which are
RCRA
wastes
CAS No.
Bromoform
100
X
U225
75-25-2
Bromotrifluorometh-ane (Halon 1311)
X
75-63-8
Brucine
100
P018
357-57-3
Butanoic acid,4-[bis(2-
chloroethyl)amino] benzene-
10
U035
305-03-3
Butyl benzyl Phthalate
100
X
85-68-7
Butyl acetate
5000
123-86-4
Butyl acrylate
X
141-32-2
Butylamine
1000
109-73-9
Butyraldehyde
X
123-72-8
Butyric acid
5000
107-92-6
CI Acid Green 3
X
4680-78-8
CI Basic Green 4
X
569-64-2
CI Basic Red 1
X
989-38-8
CI Direct Black 38
X
1937-37-7
CI Direct Blue 6
X
2602-46-2
CI Direct Brown 95
X
16071-86-6
CI Disperse Yellow 3
X
2832-40-8
CI Food Red 15
X
81-88-9
CI Food Red 5
X
3761-53-3
CI Solvent Orange 7
X
3118-97-6
CI Solvent Yellow 14
X
824-07-0
CI Solvent Yellow 34 (Auramine)
100
X
U014
492-80-8
CI Solvent Yellow 3
X
97-56-3
CI Vat Yellow 4
X
128-66-5
Cacodylic acid
1
U136
75-60-5
Cadmium
10
X
7440-43-9
Cadmium acetate
10
543-90-8
Cadmium bromide
10
7789-42-6
A5-14
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Cadmium chloride
10
10108-64-2
Cadmium oxide
100/10,000
1306-19-0
Cadmium stearate
1000/10,000
2223-93-0
Calcium arsenate
500/10,000
1
7778-44-1
Calcium arsemte
1
52740-16-6
Calcium carbide
10
75-20-7
Calcium chromate
10
U032
13765-19-0
Calcium cyan amide
X
156-62-7
Calcium cyamde
10
P021
592-01-8
Calcium dodecylbenzene sulfonate
1000
26264-06-2
Calcium hypochlorite
10
7778-54-3
Canthandin
100/10,000
56-25-7
Captan
10
X
133-06-2
Carbachol chlonde
500/10,000
51-83-2
Carbamic acid, ethyl ester
100
X
U238
51-79-6
Carbamic acid, methyl- mtroso-,ethyl
ester
1
U178
615-53-2
Carbamic acid, methyl-o- (((2,4-
dimethyl-1,3 dithiolan-2-y
100/10,000
26419-73-8
Carbamic chloride, dimethyl-
1
X
U097
79-44-7
Carbaryl
100
X
63-25-2
Carbofuran
10/10,000
10
1563-66-2
Carbon disulfide
10,000
100
X
P022
75-15-0
Carbon oxyfluonde
1000
U033
353-50-4
Carbon tetrachloride
10
X
U211
56-23-5
Carbonyl sulfide
X
463-58-1
Carbophenothion
500
786-19-6
Catechol
X
120-80-9
Chloramben
X
133-90-4
Chlordane
1000
1
X
U036
57-74-9
A5-15
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(Doundst
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Chlorfenvinfos
500
470-90-6
Chlorinated fluorocarbon(Freon 113)
X
76-13-1
Chlorine
100
10
X
7782-50-5
Chlorine cyanide
10
P033
506-77-4
Chlorine dioxide
X
10049-04-4
Chlormephos
500
24934-91-6
Chlormequat chloride
100/10,000
999-81-5
Chlornaphazine
100
U026
494-03-1
Chloroacetaldehyde
1000
P023
107-20-0
Chloroacetic acid
100/10,000
X
79-11-8
Chlorobenzilate
10
X
U038
510-15-6
Chlorodibromomethane
100
124-48-1
Chlorodifluoromethane (HCFC-22)
X
75-45-6
Chloroethane
100
X
75-00-3
Chloroethanol
500
107-07-3
Chloroethyl chloroformate
1000
627-11-2
Chloroform
10,000
10
X
U044
67-66-3
Chloromethyl methyl ether
100
10
X
U046
107-30-2
Chlorophacinone
100/10,000
3691-35-8
Chloroprene
X
126-99-8
Chlorotetrafluoroethane
X
63938-10-3
Chlorothaloml
X
1897-45-6
Chloroxuron
500/10,000
1982-47-4
Chlorpynfos
1
2921-88-2
Chlorsulfonic acid
1000
7790-94-5
Chlorthiophos
500
21923-23-9
Chromic acetate
1000
1066-30-4
Chromic acid
10
11115-74-5
Chromic acid
10
7738-94-5
A5-16
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Chromic chloride
1/10,000
10025-73-7
Chromic sulfate
1000
10101-53-8
Chromium
5000
X
7440-47-3
Chromous chloride
1000
10049-05-5
Cobalt
X
7440-50-8
Cobalt,((2,2'-1,2- ethanediylbis (ni-
trilomethylidyne))bis(6)
100/10,000
62207-76-5
Cobalt carbonyl
10/10,000
10210-68-1
Cobaltous bromide
1000
7789-43-7
Cobaltous formate
1000
544-18-3
Cobaltous sulfamate
1000
14017-41-5
Colchicine
10/10,000
64-86-8
Copper
5000
X
7440-50-8
Copper cyanide
10
P029
544-92-3
Coumaphos
100/10,000
10
56-72-4
Coumatetralyl
500/10,000
5836-29-3
Cresol(s) (mixed isomers)
1000
X
U052
1319-77-3
Cresol.o-
1000/10,000
1000
X
U052
95-48-7
Creosote
1
X
U051
8001-58-9
Cnmidine
100/10,000
535-89-7
Crotonaldehyde,(E)-
1000
100
U053
123-73-9
Crotonaldehyde
1000
100
U053
4170-30-3
Cumene hyroperoxide
X
80-15-9
Cupferron
X
135-20-6
Cupric acetate
100
142-71-2
Cupnc chloride
10
7447-39-4
Cupric nitrate
100
3251-23-8
Cupnc oxalate
100
5893-66-3
Cupric sulfate
10
7758-98-7
A5-17
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Tonic
Chemicals 40
CFR
372.65(b)
Haz Mat
which are
RCRA
wastes
CAS No.
Cupnc sulfate ammomated
100
10380-29-7
Cupric tartrate
100
815-82-7
Cyanides (soluble cyanide salts
10
P030
57-12-5
Cyanogen
100
P031
460-19-5
Cyanogen bromide
500/10,000
1000
U246
506-68-3
Cyanogen iodide
1000/10,000
506-78-5
Cyanophos
1000
2636-26-2
Cyanunc fluoride
100
675-14-9
Cyclohexanone
5000
U057
108-94-1
Cycloheximide
100/10,000
66-81-9
Cyclohexylamine
10,000
108-91-8
Cyclophosphamide
10
U058
50-18-0
D-Glucopyranose,2-deoxy-2-(3-methyl-
3-ni-trosoureido)-
1
U206
18883-66-4
Daunomycin
10
U059
20830-81-3
DDD
1
U060
72-54-8
DDE
1
72-55-9
DDT
1
U061
50-29-3
Decaborane(14)
500/10,000
17702-41-9
Decabromodiphenyl oxide
X
1163-19-5
Delta-BHC
1
319-86-8
Demeton
500
8065-48-3
Demeton-S-methyl
500
919-86-8
Di-(2-ethylhexyl)phthlate (DEHP)
X
177-81-7
Di-n-octyl phthalate
5000
X
U107
117-84-0
Di-n-propylmtrosamine(N-Nitrosodi-n-
propyl amine)
10
X
Ulll
621-64-7
Dialifor
100/10,000
10311-84-9
Dial late
100
X
U062
2303-16-4
Diaminotoluene (mixed isomers)
10
X
U221
25376-45-8
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
HazSub40
CFR355
bounds)
HazSubRQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa1
Haz Mat
which are
RCRA
wastes
CAS No.
Diaminotoluene(mixed isomers)
10
496-72-0
Diazinon
I
333-41-5
Diazomethane
X
334-88-3
Dibenz(a)lpyrene
10
U064
189-55-9
Dibenz[a,h] anthracene
1
U063
53-70-3
Dibenzofuran
X
132-64-9
Diborane
100
19287-45-7
Dibromotetrafluor- ethane (Halon 2402
X
124-73-2
Dibutyl phthalate
10
X
U069
84-74-2
Dicamba
1000
1918-00-9
Dichlone
1
117-80-6
Dichloro-1,1,2-trifluoroethane
X
90454-18-5
Dichlorobenzene (mixed isomers)
100
X
25321-22-6
Dichlorobromomethane
5000
X
75-27-4
Dichlorodifluoromethane(CFC-12)
5000
X
U075
75-71-8
Dichloroethyl ether
10,000
10
X
U025
111-44-4
Dichloromethyl ether
100
10
X
P016
542-88-1
Dichloromethyl- phenylsilane
1000
149-74-6
Dichloropropane
1000
26638-19-7
Dichloropropane-
100
8003-19-8
Dichloropropene
100
26952-23-8
Dichlorotetrafluoro-ethane (CFC-114)
X
76-14-2
Dichlorotrifluoroethane
X
34077-87-7
Dichlorvos
1000
10
X
62-73-7
Dicholobenil
100
1194-65-6
Dicofol
X
115-32-2
Dicrotophos
100
141-66-2
Dieldnn
1
P037
60-57-1
Diepoxybutane
500
10
X
U085
1464-53-5
A5-19
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Diethanolamine
X
111-42-2
Diethyl chlorophosphate
500
814-49-3
Diethyl-p-nitrophenylphosphate
100
P041
311-45-5
Diethyl sulfate
X
64-67-5
Diethylamine
100
109-89-7
Diethylcarbamazine citrate
100/10,000
1642-54-2
Diethylstilbestrol
1
U089
56-53-1
Digitoxin
100/10,000
71-63-6
Diglycidyl ether
1000
2238-07-5
Digoxm
10/10,000
20830-75-5
Dihydrosafrole
x
94-58-6
Dnsopropylfluorophosphate
100
100
P043
55-91-4
Dimefox
500
115-26-4
Dimethoate
500/10,000
10
P044
60-51-5
Dimethyl-p-phenyl-enediamine
10/10,000
99-98-9
Dimethyl phosphoro- chlondothioate
500
2524-03-0
Dimethyl phthalate
5000
X
U102
131-11-3
Dimethyl sulfate
500
100
X
U103
77-78-1
Dimethylamine
1000
U092
124-40-3
Dimethyldichlorosilane
500
75-78-5
Dimethylhydrazine
1000
10
X
U098
57-14-7
Dimetilan
500/10,000
644-64-4
Dinitrobenzene (mixed)
100
25154-54-5
Dimtrophenol
10
25550-58-7
Dimtrotoulene
10/10,000
10
X
P047
534-52-1
Dinitrotoluene (mixed isomers)
10
X
25321-14-6
Dinoseb
100/10,000
1000
P020
88-85-7
Dinoterb
500/10,000
1420-07-1
Dioxathion
500
78-34-2
A5-20
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Diphacinone
10/10,000
82-66-6
Diphosphoramide, octamethyl-
100
100
P085
152-16-9
Dipropylamine
5000
U110
142-84-7
Diquat
1000
85-00-7
Diquat
1000
2764-72-9
Disulfoton
500
1
P039
298-04-4
Dithiazimne iodide
500/10,000
514-73-8
Dithiobiuret
100/10,000
100
P049
541-53-7
Diuron
100
330-54-1
Dodecylbenzenesulfonic acid
1000
27176-87-0
Emetine,dihyrochloride
1/10,000
316-42-7
Endosulfan
10/10,000
1
P050
115-29-7
Endosulfan sulfate
1
1031-07-8
Endothall
1000
P088
145-73-3
Endothion
500/10,000
2778-04-3
Endnn
500/10,000
1
P051
72-20-8
Endrin aldehyde
1
7421-93-4
Epichlorohydrin
1000
100
X
U041
106-89-8
EPN
100/10,000
2104-64-5
Ergocalciferol
1000/10,000
50-14-6
Ergotamine tartrate
500/10,000
379-79-3
Ethan amine,N-ethyl-N-nitroso-
1
X
U174
55-18-5
Ethane,l,l'-oxybis-
100
U117
60-29-7
Ethane,l,2-dibromo-
1
X
U067
106-93-4
Ethane, 1,1,2-trichloro
100
X
U227
79-00-5
Ethane, 1,1,1,2-tetrachloro-
100
U208
630-20-6
Ethanc, 1,1,2,2-tetrachloro-
100
X
U209
79-34-5
Ethane, hexachloro
100
X
U131
67-72-1
Ethanesulfonyl chlonde, 2-chloro-
500
1622-32-8
A5-21
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Ethanethioamide
10
X
U218
62-55-5
Ethanol, 1,2-dichloro-acetate
1000
10140-87-1
Ethanol,2,2'-{nitroso imino) bis-
1
U173
1116-54-7
Ethene, tetrachloro
100
X
U210
127-18-4
Ethene, chloro-
1
X
U043
75-01-4
Ethion
1000
10
563-12-2
Ethoprophos
1000
13194-48-4
Ethyl acrylate
1000
X
U113
140-88-5
Ethyl chloroformate
X
541-41-3
Ethyl methacrylate
1000
U118
97-63-2
Ethyl methanesulfonate
1
U119
62-50-0
Ethylbenzene
1000
X
100-41-4
Ethylbis(2-chloroethyl)amine
500
538-07-8
Ethylene
X
74-85-1
Ethylene glycol
X
107-21-1
Ethylene oxide
1000
10
X
U115
75-21-8
Ethylene thiourea
10
X
U116
96-45-7
Ethylenebisdithiocarbamic- acid, salts &
esters
5000
U114
111-54-6
Ethylenediamine
10,000
5000
107-15-3
Ethylenediamine tetra-acetic acid
(EDTA)
5000
60-00-4
Ethyleneimine
500
1
X
P054
151-56-4
Ethylenethiocyanate
10,000
542-90-5
Ethylidene dichloride
X
75-34-3
Famphur
1000
P097
52-85-7
Fenamiphos
10/10,000
22224-92-6
Fenitrothion
500
122-14-5
Fensulfothion
500
115-90-2
Ferric ammonium citrate
1000
1185-57-5
A5-22
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Feme ammonium oxalate
1000
2944-67-4
Ferric ammonium oxalate
1000
55488-87-4
Feme chloride
1000
7705-08-0
Ferric fluoride
100
7783-50-8
Feme nitrate
1000
10421-48-4
Ferric sulfate
1000
10028-22-5
Ferrous ammonium sulfate
1000
10045-89-3
Ferrous chloride
100
7758-94-3
Ferrous sulfate
1000
7720-78-7
Ferrous sulfate
1000
7782-63-0
Florouracil
500/10,000
51-21-8
Fluenetil
100/10,000
4301-50-2
Fluometuron
X
2164-17-2
Fluorene
5000
86-73-7
Fluorine
500
10
P056
7782-41-4
Fluoroacelamide
100/10,000
100
P057
640-19-7
Fluoroacettc acid
10/10,000
144-49-0
Fluoroacetyl chloride
10
359-06-8
Fonofos
500
944-22-9
Formaldehyde
500
100
X
U122
50-00-0
Formaldehyde cyanohydrin
1000
107-16-4
Formetanate hydrochloride
500/10,000
23422-53-9
Formic acid
5000
X
U123
64-18-6
Formothion
100
2540-82-1
Formparanate
100/10,000
17702-57-7
Fosthietan
500
21548-32-3
Fuberidazole
100/10,000
3878-19-1
Fulminic acid, mercury(Il) salt
10
P065
628-86-4
Fumanc acid
5000
110-17-8
A5-23
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a1
Haz Mat
which are
RCRA
wastes
CAS No.
Furan
500
100
U124
110-00-9
Furan, tetrahydro-
1000
U213
109-99-9
Gallium trichloride
500/10,000
13450-90-3
Glycidylaldehyde
10
U126
765-33-4
Guanidine,N-nitroso-N methyl-N'-nitro
10
U163
70-25-7
Heptachlor
1
X
P059
76-44-8
Heptachlor epoxide
1
1024-57-3
Hexachloro-1,3-butadiene
1
X
U128
87-68-3
Hexachlorocyclopentadiene
100
10
X
U130
77-47-4
Hexachloronaphthalene
X
1335-87-1
Hexachlorophene
100
X
U132
70-30-4
Hexachloropropene
1000
U234
1888-71-7
Hexaethyl tetraphosphate
100
P062
757-58-4
Hexamethylenediamine, N,N'-dibutyl-
500
4835-11-4
Hexamethylphosphoramide
X
680-31-9
Hydrazine
1000
1
X
U133
302-01-2
Hydrazine sulfate
X
10034-93-2
Hydrochloric acid (Hydro-gen chloride
(gas only))***
500
5000
X
7647-01-0
Hydrocyanic acid
100
10
X
P063
74-90-8
Hydrogen fluoride
100
100
X
U134
7664-39-3
Hydrogen penoxide (cone > 52%)
1000
7722-84-1
Hydrogen selenide
10
7783-07-5
Hydrogen sulfide
500
100
X
U135
7783-06-4
Hydroquinone
500/10,000
x
123-31-9
Indeno(l,2,3-cd)pyrene
100
U137
193-39-5
Iron, pentacarbonyl-
100
13463-40-06
iso-Amyl acetate
5000
123-92-2
iso-Butyl acetate
5000
110-19-0
A5-24
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
bounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa1
Haz Mat
which are
RCRA
wastes
CAS No.
iso-Butylamine
1000
78-81-9
iso-Butyric acid
5000
79-31-2
Isobenzan
100/10,000
297-78-9
Isobutyl alcohol
5000
U140
78-83-1
Isobutyraldehyde
X
78-84-2
Isobutyromtrile
1000
78-82-0
Isocyanic acid,3,4-dichlorophenyl ester
500/10,000
102-36-3
Isodnn
100/10,000
1
P060
465-73-6
Isophorone
5000
78-59-1
Isophorone diisocyanate
100
4098-71-9
Isoprene
100
78-79-5
Isopropanolamine dode-cyclbenzene
sulfonate
1000
42504-46-1
Isopropyl alcohol (mfg- strong acid
processes)
X
67-63-0
Isopropyl chloroformate
1000
108-23-6
Isopropylmethylpyrazolyl
dimethylcarbamate
500
119-38-0
Kepone
1
U142
143-50-0
Lactonitrile
1000
78-97-7
Lasiocarpine
10
U143
303-34-4
Lead
10
X
7439-92-1
Lead arsenate
1
10102-48-4
Lead arsenate
1
7645-25-2
Lead arsenate
1
7784-40-9
Lead chloride
10
7758-95-4
Lead fluoborate
10
13814-96-5
Lead fluoride
10
7783-46-2
Lead iodide
10
10101-63-0
Lead nitrate
10
10099-74-8
A 5-25
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title EQ of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
{pounds')
Haz Sub RQ
40 CFR 342.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Lead phosphate
10
U145
7446-27-7
Lead stearate
10
1072-35-1
Lead stearate
10
52652-59-2
Lead stearate
10
7428-48-0
Lead stearate
10
56189-09-4
Lead subacetate
10
U146
1335-32-6
Lead sulfate
10
15739-80-7
Lead sulfate
10
7446-14-2
Lead sulfide
10
1314-87-0
Lead thiocyanate
10
592-87-0
Leptophos
500/10,000
21609-90-5
Lewisite
10
541-25-3
Lindane
1000/10,000
1
X
U129
58-89-9
Lithium chromate
10
14307-35-8
Lithium hydride
100
7580-67-8
m-Cresol
1000
X
U052
108-39-4
m-Nitrophenol
100
554-84-7
m-Nitrotoluene
1000
99-08-1
Malathion
100
121-75-5
Maleic acid
5000
110-16-7
Maleic, hydrazide
5000
U148
123-33-1
Malonomtnle
500/10,000
1000
X
U149
109-77-3
Maneb
X
12427-38-2
Manganese
X
7439-96-5
Manganese, tricarbonyl
methylcyclopentadienyl
100
12108-13-3
Mechloreth amine
10
X
51-75-2
Melphalan
1
U150
148-82-3
Mephosfolan
500
950-10-7
A5-26
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
foounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Mercuric acetate
500/10,000
1600-27-7
Mercuric chloride
500/10,000
7487-94-7
Mercuric cyanide
1
592-04-1
Mercuric nitrate
10
10045-94-0
Mercuric oxide
500/10,000
21908-53-2
Mercuric sulfate
10
7783-35-9
Mercuric thiocyanate
10
592-85-8
Mercurous nitrate
10
7782-86-7
Mercurous nitrate
10
10415-75-5
Mercury
1
X
U151
7439-97-6
Methacrolein diacetate
1000
10476-95-6
Methacrylic anhydride
500
760-93-0
Methacryloyl chloride
100
920-46-7
Methacryloyloxyethyl isocyanate
100
30674-80-7
Methacrylonitrile
500
1000
X
U152
126-98-7
Methamidophos
100/10,000
10265-92-6
Methane, chloro
100
X
U045
74-87-3
Methane, dibromo-
1000
X
U068
74-95-3
Methane, dichloro-
1000
X
U080
75-09-2
Methane, lodide-
100
X
U138
74-88-4
Methane, tnchlorofluoro- (CFC-11)
5000
U121
75-69-4
Methanesulfanyl chloride, trichloro
500
100
PI 18
594-42-3
Methanesulfonyl fluoride
1000
558-25-8
Methanol
5000
X
U154
67-56-1
Methapyrilene
5000
U155
91-80-5
Methidathion
500/10,000
950-37-8
Methiocarb
500/10,000
10
2032-65-7
Methomyl
500/10,000
100
P066
16752-77-5
Methoxychlor
1
X
72-43-5
A5-27
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Methoxyethylmercuricacetate
500/10,000
151-38-2
Methyl 2-chloroacrylate
500
80-63-7
Methyl acrylate
X
96-33-3
Methyl bromide
1000
1000
X
U029
74-83-9
Methyl chlorocarbonate
X
79-22-1
Methyl
chloroformate(Methylchlorocarbonate)
500
1000
U156
79-22-1
Methyl chloroform
1000
X
U226
71-55-6
Methyl hydrazine
10
X
P068
60-34-4
Methyl isobutyl ketone
5000
X
U161
108-10-1
Methyl isocyanate
500
10
X
P064
624-83-9
Methyl isothiocyanate
500
556-61-1
Methyl mercaptan
500
100
X
U153
74-93-1
Methyl methacrylate
1000
X
U162
80-62-6
Methyl phenkapton
500
3735-23-7
Methyl phosphonic dichlonde
100
676-97-1
Methyl tert-butyl ether
X
1634-04-4
Methyl thiocyanate
10,000
556-64-9
Methyl vinyl ketone
10
78-94-4
Methylene-bis-(phenyliso-cyanate)(MBI)
X
101-68-8
Methylmercunc dicy-anamide
500/10,000
502-39-6
Methylthiouracil
10
U164
56-04-2
Methyltrichlorosilane
500
75-79-6
Metolcarb
100/10,000
1129-41-5
Mevinphos
500
10
7786-34-7
Mexacarbate
500/10,000
1000
315-18-4
Michler's ketone
X
90-94-8
Mitomycin C
500/10,000
10
U010
50-07-7
Molybdenum trioxide
X
1313-27-5
A5-28
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
foounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Moncrotophos
10/10,000
6923-22-4
(Mono)chloropenta- fluoroethane (CFC
115)
X
76-15-3
Monoethylamine
100
75-04-7
Monomethylamine
100
74-89-5
Muscimol
500/10,000
1000
P007
2763-96-4
Mustard gas
500
X
505-60-2
n-Butyl alcohol
X
71-36-3
N.N'-Dimethylaniline
X
121-69-7
N,N'-Diethylhydrazine
10
U086
1615-80-1
N-Nitroso-N-ethylurea
1
X
759-73-9
N-Nitroso-N-methylurea
1
X
684-93-5
N-Nitrosodiphenylamine
100
X
86-30-6
N-Nitrosomethylvinylamine
10
X
4549-40-0
N-Niirosomorpholine
X
59-89-2
N-Nitrosonornicotine
X
16543-55-8
N-Nitrosopiperidine
10
X
U179
100-75-4
N-Nitrosopyrrolidine
1
U180
930-55-2
Naled
10
300-76-5
Naphthalene
100
X
U165
91-20-3
Naphthenic acid
100
1338-24-5
Nickel
100
X
7440-02-0
Nickel ammonium sulfate
100
15699-18-0
Nickel carbonyl
1
10
P073
13463-39-3
Nickel chloride
100
37211-05-5
Nickel chloride
100
7718-54-9
Nickel cyanide
10
P074
557-19-7
Nickel hydroxide
10
12054-48-7
Nickel nitrate
100
14216-75-2
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title ID of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Nickel sulfate
100
7786-81-4
Nicotine
100
100
P075
54-11-5
Nicotine sulfate
100/10,000
65-30-5
Nitric acid
1000
1000
x
7697-37-2
Nitric oxide
100
10
P076
10102-43-9
Nitrilotnacetic acid
x
139-13-9
Nitrobenzene
10,000
1000
X
U169
98-95-3
Nitrocyclohexane
500
1122-60-7
Nitrogen
x
1836-75-5
Nitrogen dioxide
100
10
P078
10102-44-0
Nitrogen dioxide
10
P078
10544-72-6
Nitroglycerine
10
X
P081
55-63-0
Nitrophenol (mixed)
100
25154-55-6
Nitrosodimethylamine
1000
10
X
P082
62-75-9
Nitrotoluene
1000
1321-12-6
Norbormide
100/10,000
991-42-4
0,0-Diethyl S-methyl dithiophosphate
5000
U087
3288-58-2
o-Anisidine hydrochloride
X
134-29-2
o-Anisidine
X
90-04-0
o-Dinitrobenzene
100
X
528-29-0
o-Nitrophenol
100
X
88-75-5
o-Nitrotoluene
1000
88-72-2
o-Toluidine
100
X
U328
95-53-4
Octachloronaphthalene
X
2234-13-1
Osmium tetroxide
1000
X
P087
20816-12-0
Ouabain
100/10,000
630-60-4
Oxamyl
100/10,000
23135-22-0
Oxetane,3,3- bis(chloromethyl)-
500
78-71-7
Oxydisulfoton
500
2497-07-6
A5-30
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Ozone
100
10028-15-6
p-Anisidine
X
104-94-9
p-Benzoquinone
10
X
U197
106-51-4
p-Cresidine
X
120-71-8
p-Cresol
1000
X
U052
106-44-5
p-Dinitrobenzene
100
X
100-25-4
p-Nitrophenol
100
X
UI70
100-02-7
p-Nitrosodiphenylamine
X
156-10-5
p-Nitrotoluene
1000
99-99-0
p-Phenylenediamine
X
106-50-3
Paraformaldehyde
1000
30525-89-4
Paraldehyde
1000
X
123-63-7
Paraquat
10/10,000
1910-42-5
Paraquat methosulfate
10/10,000
2074-50-2
Parathion
100
10
X
P089
56-38-2
Parathion, methyl
100/10,000
100
P071
298-00-0
Paris green (Cupne acetoarsenite)
500/10,000
1
12002-03-8
Pentaborane
500
19624-22-7
Pentachloroethane
10
X
U184
76-01-7
Pentachlorophenol
10
X
U242
87-86-5
Pentadecyclamine
100/10,000
2570-26-5
Peracetic acid
500
X
79-121-0
Phenanthrene
5000
85-01-8
Phenol
500/10,000
1000
X
U188
108-95-2
Phenol,2,2'-thio bis (4-chloro-6-methy!
100/10,000
4418-66-0
Phenol,2,3,4,6-tetrachloro
10
U212
58-90-2
Phenol,2,4,5-tnchloro
10
X
U230
95-95-4
Phenol,2,4,6-tnchloro
10
X
U231
88-06-2
A5-31
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Phenol, 3-( 1 -methy lethy 1),
methylcarbamate
500/10,000
64-00-6
Phenoxarsine, 10,1O'-oxydi-
500/10,000
58-36-6
Phenyl dichloroarsine
500
1
P036
696-28-6
Phenylhydrazme hydrochloride
1000/10,000
59-88-1
Phenyl mercury acetate
500/10,000
100
P092
62-38-4
Phenylsilatrane
100/10,000
2097-19-0
Phenylthiourea
100/10,000
100
P093
103-85-5
Phorate
10
10
P094
298-02-2
Phosacetim
100/10,000
4104-14-7
Phosfolan
100/10,000
947-02-4
Phosgene
10
10
X
P095
75-44-5
Phosmet
10/10,000
732-11-6
Phosphamidon
100
13171-21-6
Phosphine
500
100
P096
7803-51-2
Phosphonothioic acidmethyl-0-(4-
nitrophenyl)0-phenyl ester
500
2665-30-7
Phosphonothioic acid, methyl-O-ethyl-
0-(4-{niethylthio)phenyk Ester
500
2703-13-1
Phosphonothioic acid, methyl-,s-(2-
(bis(l -methylethyl)amino Ethyl o-Ethyl
Ester
100
50782-69-9
Phosphoric acid
5000
X
7664-38-2
Phosphonc acid, dimethyl 4-
(methylthio)phenyl ester
500
3254-63-5
Phosphorothioc acid, 0,0-diethyl, 0-
pyrazinyl ester
500
100
P040
297-97-2
Phosphorothioic acid, 0,0-dimethyl-S-
(2-methylthio)ethyl est
500
2587-90-8
Phosphorus
100
1
X
7723-14-0
Phosphorus oxychlonde
500
1000
10025-87-3
Phosphorus pentachloride
500
10026-13-8
A5-32
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Doundsl
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Phosphorus pentasulfide
100
U189
1314-80-3
Phosphorus pentoxide
10
1314-56-3
Phosphorus trichloride
1000
1000
7719-12-2
Physostigmine
100/10,000
57-47-6
Physostigmine, sali-cylate(l 1)
100/10,000
57-64-7
Picric acid
X
88-89-1
Picrotoxin
500/10,000
124-87-8
Pipendine
1000
110-89-4
Pirimifos-ethyl
1000
23505-41-1
Polychlonnated biphenyls
1
X
1336-36-3
Potassium arsenate
1
7784-41-0
Potassium arsenite
500/10,000
1
10124-50-2
Potassium bichromate
10
7778-50-9
Potassium chromate
10
7789-00-6
Potassium cyanide
100
10
P098
151-50-8
Potassium hydroxide
1000
1310-58-3
Potassium permanganate
100
7722-64-7
Potassium silver cyanide
500
1
P099
506-61-6
Promecarb
500/10,000
2631-37-0
Pronamide
X
23950-58-5
Propargite
10
2312-35-8
Propargyl alcohol
1000
P102
107-19-7
Propargyl bromide
10
106-96-7
Propiolactone.beta-
500
X
57-57-8
Propionaldehyde
X
123-38-6
Propionic acid
5000
79-09-4
Propionic acid,2-(2,4,5-
trichlorophenoxy)-
100
U233
93-72-1
Propionic anhydride
5000
123-62-6
A 5-33
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
bounds)
Haz Sub RQ
.40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Propiophenone,4'-amino-
100/10,000
70-69-9
Propenenitnle
500
10
P10I
107-12-0
Propenenitnle,3-chloro-
1000
1000
P027
542-76-7
Propoxur
X
114-26-1
Propyl chloroformate
500
109-61-5
Propylene (Propene)
X
115-07-1
Propylene oxide
10,000
100
X
75-56-9
Propyleneimine
10,000
1
X
P067
75-55-8
Prothoate
100/10,000
2275-18-5
Pyrene
1000/10,000
5000
129-00-0
Pyrethnns
1
121-21-1
Pyrethnns
1
121-29-9
Pyrethnns
1
8003-34-7
Pyridine
1000
X
U196
110-86-1
Pyridine,2-methyl-5-vinyl-
500
140-76-1
Pyndine,4-amino-
500/10,000
1000
P008
504-24-5
Pyndine,4-nitro-1 -oxide
500/10,000
1124-33-0
Pynminil
100/10,000
53558-25-1
Quinoline
5000
X
91-22-5
Reserpine
5000
U200
50-55-5
Salcomine
500/10,000
14167-18-1
Sann
10
107-44-8
sec-Amyl acetate
5000
626-38-0
sec-Butyl acetate
5000
105-46-4
sec-Butyl alcohol
X
78-92-2
sec-Butylamine
1000
13952-84-6
sec-Butylamine
1000
513-49-5
Selenium
100
X
7782-49-2
Selenium dioxide
10
U204
7446-08-4
A 5-34
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title HI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Selenium disulfide
10
U205
7448-56-4
Selenium oxychlonde
500
7791-23-3
Selenious acid
1000/10,000
10
U204
7783-00-8
Selenouree
1000
PI03
630-10-4
Semicarbazide hydrochloride
1000/10,000
563-41-7
Silane,(4-aminobutyl) diethoxymethyl-
1000
3037-72-7
Silver
1000
X
7440-22-4
Silver cyanide
1
P104
506-64-9
Silver nitrate
1
7761-88-8
Sodium
10
7440-23-5
Sodium arsenate
1000/10,000
1
7631-89-2
Sodium arsenite
500/10,000
1
7784-46-5
Sodium azide (Na(N3))
500
1000
P105
26628-22-8
Sodium bichromate
10
10588-01-9
Sodium bifluonde
100
1333-83-1
Sodium bisulfite
5000
7631-90-5
Sodium cacodylate
100/10,000
124-65-2
Sodium chromate
10
7775-11-3
Sodium cyanide (Na(CN))
100
10
PI 06
143-33-9
Sodium dodecylbenzene sulfonate
1000
25155-30-0
Sodium fluoride
1000
7681-49-4
Sodium fluoroacetate
10/10,000
10
P058
62-74-8
Sodium hydrosulfide
5000
16721-80-5
Sodium hydroxide
1000
1310-73-2
Sodium hypochlorite
100
10022-70-5
Sodium hypochlorite
100
7681-52-9
Sodium methylate
1000
124-41-4
Sodium nitrite
100
7632-00-0
Sodium phosphate,dibasic
5000
10039-32-4
A5-35
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Sodium phosphate,dibasic
5000
10140-65-5
Sodium phosphate,dibasic
5000
7558-79-4
Sodium phosphate, tnbasic
5000
10101-89-0
Sodium phosphate,tnbasic
5000
10124-56-8
Sodium phosphate,tnbasic
5000
10361-89-4
Sodium phosphate,tnbasic
5000
7601-54-9
Sodium phosphate,tnbasic
5000
7758-29-4
Sodium phosphate,tnbasic
5000
7785-84-4
Sodium selenate
100/10,000
13410-01-0
Sodium selemte
100/10,000
100
10102-18-8
Sodium selemte
100
7782-82-3
Sodium tellurite
500/10,000
10102-20-2
Strannane.acetoxy-triphenyl-
500/10,000
900-95-8
Strontium chromate
10
7789-06-2
Strychnine
100/10,000
10
P108
57-24-9
Strychnine, sulfate
100/10,000
60-41-3
Styrene
1000
X
100-42-5
Styrene oxide
x
96-09-3
Sulfotep
500
100
P109
3689-24-5
Sulfoxide,3-chloropropyl octyl
500
3569-57-1
Sulfur dioxide
500
7446-09-5
Sulfur monochlonde
1000
12771-08-3
Sulfur tetrafluoride
100
7783-60-0
Sulfur tnoxide
100
7446-11-9
Sulfuric acid
1000
1000
X
7664-93-9
Sulfuric acid
1000
8014-95-7
Tabun
10
77-81-6
Tellurium
500/10,000
13494-80-9
Tellurium hexafluonde
100
7783-80-4
A5-36
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a}
Haz Mat
which are
RCRA
wastes
CAS No.
Tetraethyldithiopyr phosphate
100
10
Pill
107-49-3
Terbufos
100
13071-79-9
tert-Amyl acetate
5000
625-16-1
tert-Butyl acetate
5000
540-88-5
tert-Butyl alcohol
X
75-65-0
tert-Butylamine
1000
75-64-9
Tetrachlorvinphos
X
961-11-5
Tetraethyllead
100
10
PI 10
78-00-2
Tetraethyltin
100
597-64-8
Tetramethyl Lead
100
75-74-1
Tetranitromethane
500
10
PI 12
509-14-8
Thallic oxide
100
PI 13
1314-32-5
Thallium
1000
X
7440-28-0
Thallium(l) carbonate
100/10,000
100
U215
6533-73-9
Thallium (I)sulfate
100/10,000
100
PI 15
10031-59-1
Thalhum(I)nitrate
100
U217
10102-45-1
Thallium(I)selenide
1000
PI 14
12039-52-0
Thallous chloride
100/10,000
100
U216
7791-73-9
Thallous malonate
100/10,000
2757-18-8
Thallous sulfate
100/10,000
100
PI 15
7446-18-6
Thiocarbazide
1000/10,000
2231-57-4
Thiofanox
100/10,000
100
P045
39196-18-4
Thiram
10
X
U244
137-26-8
Thiophenol
500
100
P014
108-98-5
Thiosemicarbazide
100/10,000
100
PI 16
79-19-6
Thiourea
10
X
62-56-6
Thiourea,(2-chlorophenyl)-
100/10,000
100
P026
5344-82-1
Thiourea, (2- methylphenyl)-
500/10,000
614-78-8
Thonum dioxide
X
1314-20-1
A 5-37
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Titanium dioxide
X
13463-67-7
Titanium tetrachloride
100
X
7550-45-0
Toluene2,4-dusocyanate
500
100
X
584-84-9
Toluene2,6-dnsocyanate
100
100
X
91-08-7
T oxaphene(Campheclor)
1
X
P123
8001-35-2
Trans 1,1-dichlorobutene
500
110-57-6
Triamiphos
500/10,000
1031-47-6
Triaziquone
X
68-76-8
Triazofos
500
24017-47-8
Tnchloroacetyl chloride
500
76-02-8
Tnchloro(chloromethyl) silane
100
1558-25-4
Trichloro(dichlorophenyl) silane
500
27137-85-5
Trichloroethylene
100
X
U228
79-01-6
Tnchloroethylsilane
500
115-21-9
Tnchlorofon
100
X
52-68-6
Trichloronate
500
327-98-0
Tnchlorophenol
10
25167-82-2
Tnchlorophenylsilane
500
98-13-5
Triethanolamine dode-cylbenzene
sulfonate
1000
27323-41-7
Triethoxysilane
500
998-30-1
Triethylamine
5000
121-44-8
Trifluralm
X
1582-09-8
Tnmethylamine
100
75-50-3
Trimethylchlorosilane
1000
75-77-4
Trimethylolpropane phosphite
100/10,000
824-11-3
Trimethyltin chloride
500/10,000
1066-45-1
Tnphenyltin chloride
500/10,000
639-58-7
Tris(2-chloroethyl) amine
100
555-77-1
A5-38
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372^5ra)
Haz Mat
which are
RCRA
wastes
CAS No.
Trypan blue
10
X
U236
72-57-1
Uracil, 5-[bis(2-chloroethyl)amino]-
10
U237
66-75-1
Uranyl acetate
100
541-09-3
Uranyl nitrate
100
10102-06-4
Uranyl nitrate
100
36478-76-9
Valinomycin
1000/10,000
2001-95-8
Vanadium(fume or dust)
X
7440-62-2
Vanadium pentoxide
100/10,000
1000
P120
1314-62-1
Vanadyl sulfate
1000
27774-13-6
Vinyl acetater
1000
5000
X
108-05-4
Vinyl bromide
X
593-60-2
Warfarin
500/10,000
100
P001
81-81-2
Warfarin sodium
100/10,000
129-06-6
Xylenol
1000
1300-71-6
Xylylene dichlonde
100/10,000
28347-13-9
Zinc
1000
X
7440-66-6
Zinc acetate
1000
557-34-6
Zinc ammonium chloride
1000
52628-25-8
Zinc ammonium chlonde
1000
14639-97-5
Zinc ammonium chlonde
1000
14639-98-6
Zinc borate
1000
1332-07-6
Zinc bromide
1000
7699-45-8
Zinc carbonate
1000
3486-35-9
Zinc chlonde
1000
7646-85-7
Zinc cyanide
10
P121
557-21-1
Zinc, dichloro(4,4-dimethyl-
5(((methylamino) carbnyl)oxy)imino)
Pentane-nitnle)-,(T-4)
100/10,000
58270-08-9
Zinc fluonde
1000
7783-49-5
Zinc formate
1000
557-41-5
A5-39
-------
Appendix 5-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
fooundsl
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(al
Haz Mat
which are
RCRA
wastes
CAS No.
Zinc hydrosulfite
1000
7779-86-4
Zinc nitrate
1000
7779-88-6
Zinc phenolsulfonate
5000
127-82-2
Zinc phosphide
500
100
P122
1314-84-7
Zinc silicofluonde
5000
16871-71-9
Zinc sulfate
1000
7733-02-0
Zineb ,
X
12122-67-7
Zirconium nitrate
5000
13746-89-9
Zirconium potassium fluoride
1000
.
16923-95-8
Zirconium sulfate
5000
14644-61-2
Zirconium tetrachloride
5000
10026-11-6
A5-40
-------
Phase 1
Section 6
Spill Control and Response
-------
Phase 1
Section 6
Table of Contents
Spill Control and Response
A. Applicability 6-1
B. Federal Legislation 6-1
C. State/Local Regulations 6-1
D Key Compliance Requirements 6-2
E. Key Compliance Definitions 6-3
F. Records to Review 6-6
G. Physical Features to Inspect 6-6
H. Guidance for Checklist Users 6-7
Appendices
A6-1.
Facility Response Plans
A6-1
-------
A. Applicability
This section applies to facilities that store oil in tanks or containers above or below the
ground. Specifically, this section addresses oil spill response plans, facility response plans,
and oil transfer activities.
Assessors are required to review agency, Federal, state and local regulations to perform a
comprehensive assessment.
B. Federal Legislation
1. Water Pollution Control Act of 1972
This law was the primary Federal law governing the discharge of oil into navigable
waters. The Federal Water Pollution Control Act (FWPCA) of 1972 was amended by the
Clean Water Act (CWA) of 1977. Section 311 of the CWA describes a policy that no
discharges of oil or hazardous substances into navigable waters should occur Regulations
found in 40 CFR 110 and 112 establish requirements for oil spill reporting and preparation of
oil spill plans for facilities exceeding the threshold quantities of stored oil. 40 CFR 110
prohibits the discharge of harmful quantities of oil into navigable waters. 40 CFR 110 also
defines harmful quantities as those discharges that will cause a sheen or discoloration of the
surface of the water or a sludge or emulsion to be deposited beneath the surface of the water
2. The Oil Pollution Act (OPA) of 1990
This law, Public Law (PL) 301-308; 33 U.S. Code (USC) 2701-2761, as amended,
requires the prevention of oil pollution into navigable waters by tank vessels. Additionally,
this act applies to the storage of flammable and combustible liquids.
C. State/Local Regulations
Many states (e.g., New Jersey, California) and some major metropolitan and regional
planning agencies have developed legislation and implemented regulations that closely parallel
the Federal regulations. Some, however, may differ in important ways, and the evaluator
should obtain copies of the state or local requirements for the Oil and Hazardous Substances
Pollution Contingency (OHSPC) and the Spill Prevention, Control, and Countermeasures
(SPCC) plans, where appropriate, and review them for those differences before conducting the
evaluations.
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D. Key Compliance Requirements
1. The SPCC Plan
Facilities that store, transport, or dispense petroleum products are required to prepare an
SPCC Plan, unless certain criteria are met. The SPCC Plan is required to contain general
information about the facility, the name and title of the designated coordinator, and an
inventory of all storage, handling, and transfer facilities. Each SPCC Plan must be reviewed at
least once every three years, unless it is an exempted facility. The SPCC plan must be
reviewed and/or amended when there is a material change in facility design, construction,
operation, or maintenance that alters the potential for an oil spill. Each SPCC Plan and any
amendments must be certified by a professional engineer, and the plan and each amendment
must be prepared according to sound engineering practices. A copy of the SPCC Plan is
required to be available at sites that are normally attended at least eight hours/day where there
is a potential for a discharge. All facility personnel involved with the management and
handling of oil must receive training (40 CFR 112.3, 112.5, and 112.7(e)(10)).
2. Facility Response Plan
Recent revisions to 40 CFR 112 require nontransportation related onshore facilities that,
because of location, could reasonably be expected to cause substantial harm to the environment
by discharging oil into or on the navigable waters or adjoining shoreline to prepare facility
response plans for responding to a worst case discharge of oil and to a substantial threat of
such discharge (40 CFR 112.20).
A facility could, because of its location, reasonably be expected to cause substantial harm if it
meets any of the following criteria:
• The facility transfers oil over water to or from vessels and has a total oil storage capacity
greater than or equal to 42,000 gallons.
• The facility's total oil storage capacity is greater than or equal to 1 million gallons, and
one of the following is true:
- the facility does not have secondary containment for each above-ground area
sufficiently large to contain the capacity of the largest AST within each storage area
plus sufficient freeboard to allow for precipitation;
-- the facility is located at a distance such that discharge from the facility could cause
injury to fish and wildlife and sensitive environment;
- the facility is located at a distance such that a discharge from the facility would shut
down a public drinking water intake; and
~ the facility has had a reportable oil spill in an amount greater than or equal to 10,000
gallons within the last five years.
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6-2
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3. Discharges/Spills
A discharge of oil into navigable waters of the United States, adjoining shorelines, or
areas that may affect natural resources belonging to or under the exclusive management
authority of the United States must be reported to the National Response Center (NRC).
Facilities are not allowed to add dispersants or emulsifiers to oils that are discharged (40 CFR
110.2 through 110.10).
4. Discharge Prevention/Cleanup
Facilities are required to have appropriate containment and/or diversionary structures and
cleanup equipment readily available to prevent discharged petroleum products from reaching
navigable water courses (40 CFR 112.7(c)). According to legal counsel and private sector
lawyers, the "shoulds" in 40 CFR 112 are "musts". This decision is based on the clause 40
CFR 112.7(e) requiring "conformance with the following applicable guidelines, other effective
spill prevention and containment procedures (or, if more stringent), with state rules,
regulations, or guidelines". According to the opinions we received, the word "or" implies
required compliance with either the Federal guidelines or the state rules, whichever is more
strict.
5. Piping Systems
Buried piping at facility transfer operations, pumping activities and in-plant processing is
required to have a protective wrapping and/or coating and be cathodically protected if soil
conditions warrant (40 CFR 112.7(e)(3)(i) and 112.7(e)(3)(iv)).
6. Loading and Unloading Racks
Onshore tank car and tank truck loading/unloading racks are required to have containment
and a method of preventing vehicles from leaving before transfer lines have been disconnected
Personnel at these sites are required to survey drains and outlets of vehicles prior to their
departure to ensure that there is no leakage (40 CFR 112 7(e)(4)).
E. Key Compliance Definitions
1. Container
Any portable device in which materials are stored, transported, treated, disposed of, or
otherwise handled (40 CFR 279.1).
2. Contiguous Zone
The entire zone established or to be established by the United States under article 24 of
the Convention on the Territorial Sea and Contiguous Zone (40 CFR 110.1).
Phase 1 - Section 6
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6-3
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3. Continuous Discharge
A discharge occurring without interruption throughout the operating hours of the facility,
except for infrequent shutdowns for maintenance, process changes, or other similar activities
(40CFR 123.3).
4. Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24 hour period that
reasonably represents the calendar day for purposes of sampling (40 CFR 122.2).
5. Direct Discharge
The discharge of a pollutant (40 CFR 122.2).
6. Discharge
When used in relation to section 311 of the Act, includes, but is not limited to, any
spilling, leaking, pumping, pouring, emitting, emptying, or dumping, but excludes (40 CFR
110.1):
• Discharges in compliance with a permit;
• Discharges resulting from circumstances identified and reviewed and made a part of the
public record with respect to an issued permit and subject to a condition in the permit; and
• Continuous or anticipated intermittent discharges from a point source, identified in a
permit application, that are caused by events occurring within the scope of relevant
operating or treatment systems.
7. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
8. Navigable Waters
The waters of the United States, including the territorial seas. Navigable waters do not
include prior converted cropland. The terms includes (40 CFR 100 2):
• All waters that are currently used, were used in the past, or may be susceptible to use in
interstate or foreign commerce, including all waters that are subject to the ebb and flow of
the tide;
• Interstate waters, including interstate wetlands;
Phase 1 - Section 6
Spill Control and Response
6-4
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• All other waters such as intrastate lakes, rivers, streams (including intermittent streams),
mudflats, sandflats, and wetlands, the use, degradation, or destruction of which would
affect or could affect interstate or foreign commerce including any such waters-
- That are or could be used by interstate or foreign travelers for recreational or other
purposes;
-- From which fish or shellfish are or could be taken and sold in interstate or foreign
commerce; and
-- That are used or could be used for industrial purposes by industries in interstate
commerce.
• All impoundments of waters otherwise defined as navigable waters under this section;
• Tributaries of waters identified above, including adjacent wetlands; and
• Wetlands adjacent to waters identified above.
9. Offshore Facility
Any facility of any kind located in, on, or under any of the navigable waters of the United
States, and any facility or any kind that is subject to the jurisdiction of the United States and is
located in, on, or under any other waters, other than a vessel or a public vessel (40 CFR 110.2
and 33 CFR 153.103).
10. Oil
When used in relation to Section 311 of the Act, means oil of any kind or in any form,
including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes
other than dredged spoil (40 CFR 110.2 and 33 CFR 153.103).
11. Public Vessel
A vessel owned or bare boat chartered and operated by the United States, or by a state or
political subdivision thereof, or by a foreign nation, except when such vessel is engaged in
commerce (40 CFR 110.2 and 33 CFR 153.103).
12. Sheen
An iridescent appearance on the surface of the water (40 CFR 110.2).
13. Sludge
An aggregate of oil or oil and other matter of any kind in any form other than dredged
spoil, having a combined specific gravity equivalent to or greater than water (40 CFR 110.2).
Phase 1 - Section 6
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6-5
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14. Spill Event
A discharge of oil into or upon the navigable waters of the United States or adjoining
shorelines in harmful quantities (40 CFR 112.3).
15. Spill Prevention, Control, and Countermeasure (SPCC) Plan
The SPCC plan is a carefully thought-out plan prepared in accordance with good
engineering practices, which has the full approval of management at a level with authority to
commit the necessary resources (40 CFR 112.3).
16. Vessel
Every description of watercraft or other artificial contrivance used, or capable of being
used, as a means of transportation on water other than a public vessel (40 CFR 110.2).
17. Wetlands
Those areas that are inundated or saturated by surface or groundwater at a frequency or
duration sufficient to support (and that under normal circumstances do support) a prevalence of
vegetation typically adapted for life in saturated soil conditions. Wetlands generally include
playa lakes, swamps, marshes, bogs, and similar areas such as sloughs, prairie potholes, wet
meadows, prairie river overflows, mudflats, and natural ponds (40 CFR 110.2).
F. Records to Review
• Records of all spills, leaks, and associated site assessment/cleanup activities (for three
years)
• Official correspondence with state implementing agency
• SPCC Plan
• Facility response plan, if required by OPA
• Records of spill response training programs and employee training
• Tank inspection/integrity testing records.
G. Physical Features to Inspect
• Refueling facilities, including:
Above- and below-ground storage tanks and dikes
Venting
Fill pipes
Gauges
• Washrack areas
• Vehicle maintenance areas
• Oil separators
• Sites where oil is stored in containers other than tanks
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Spill Control and Response
6-6
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• Fire training pits
• Grease racks
• Loading/unloading racks
H. Guidance for Checklist Users
R«fer To
Checklist items
Page Numbers
All Facilities
S 1 through S 3
6-8
Spill Plans
S 4
6-9
S 5 through S 7
6-10
S.8 through S 10
6-11
Discharges/Spills
S.ll
6-11
S 12
6-12
Storage Areas
S.13 through S.14
6-12
S-15
6-13
Transfer Terminals
S.16 through S.17
6-13
Loading and Unloading
S.18
6-13
S 19
6-14
Facility Response Plans
S 20
6-14
Phase 1 - Section 6
Spill Control and Response
6-7
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Compliance Category:
Spill Control antf Response
Regulator? Requirements:
Reviewer Chertuc
All Facilities
S 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, interagency
agreements, or equivalent state enforcement actions
If actions have not been taken, indicate what, if any, corrective action plan has been
developed and timetable for completion
S 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding)
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities that are regulated but not addressed
in this checklist
Annotate the checklist to include new standards, and verify that the facility is in
compliance with all applicable and newly issued regulations
S 3 Facilities are required to
abide by state and local
regulations concerning spill
management (EO 12088, Sect
1-1)
Annotate the protocol to include state/local standards and verify that the facility is
abiding with state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
- Spill management
- Reporting and recordkeeping
- Containment)
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Spill Control and Response
6-8
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Compliance Category:
Spill Omtrol and Response
Regulatory Require ent$;
Reviewer Checks;
Spill Plans
S 4 Facilities that store,
transport, or dispense petroleum
products are required to prepare
aSPCC Plan (40 CFR 112 3)
Verify that the facility has a SPCC Plan
(NOTE Facilities are exempt from the requirements outlined in 40 CFR 112 if
- The facility, equipment, or operation is not subject to the jurisdiction of the EPA as
follows
~ onshore and offshore sites which, due to their location, could not be reasonably
expected to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines
— equipment or operations of vessels or transportation related onshore and
offshore sites that are subject to the authority of the DOT
- Both of the following criteria are met
-- the underground buried storage capacity of the facility is 42,000 gal (15,987 30
L) or less of oil
- the aggregate storage capacity which is not buried at the facility is 1,320 gal
(4,996 74 L) of oil or less with no single container exceeding a capacity of 660
gal (2,498 37 L) (40 CFR 112 1(d)(2))
(NOTE This applies to onshore and offshore sites including onshore and offshore
mobile or portable facilities, such as onshore drilling or workover rigs, barge-mounted
offshore drilling or workover rigs, and portable fueling facilities)
Phase 1 - Section 6
Spill Control and Response
6-9
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Compliance Category:
SpUl Cwrtrot aad Response
Regulatory Requirements:
Reviewer CbecJw
S 5 The SPCC plan is required
to contain specific information
(40 CFR 112 7)
Determine if the SPCC plan includes the following key items
- Senior management approval
- Spill reporting procedures
- Prespill planning for major potential spill areas
- Spill containment and cleanup equipment/facilities
- Oil spill contingency plan
- Training procedures
- Spill response exercises
- Plan review and update procedures
- Security measures
- Inspection procedures
- Tank integrity testing procedures
Verify that the SPCC Plan contains.
- General information about the facility including
— name
-- type of function
— location of facility drainage patterns
— location maps
- Name and title of designated spill coordinator
- Inventory of all storage, handling, and transfer facilities that could produce
significant spills, including.
— predictions of direction and rate of flow
-- total quantities of oil that could be spilled as a result of major failure
S 6 Each SPCC plan must be
reviewed at least once every 3
years (40 CFR 112 5(b))
Verify that the SPCC plan has been reviewed at least once every three years
S 7 The SPCC must be
reviewed and/or amended under
specific circumstances (40 CFR
112 4 and 112.5(a))
Verify that the plan was amended within six months if there was a material change in
the facility design, construction, operations, or maintenance that alters the potential
for an oil spill
Verify that the plan was sent to the EPA for review if the facility:
- Discharged oil of more than 1,000 gal (3,785 41 L) into navigable waters in a single
spill event
- Discharged oil in harmful quantities into navigable waters in two reportable spill
events within any 12-month period
Phase 1 - Section 6
Spill Control and Response
6-10
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Compliance Category;
Spill Control a»4 Response
Regulatory Reqalrefltenls;
Reviewer Cbecfcs
S 8 Each SPCC Plan and any
amendments must be certified
by a professional engineer and
the plan and each amendment
must be prepared according to
sound engineering practices (40
CFR 112 3(d) and 112 5(c))
Verify that the SPCC Plan has been certified by a registered professional engineer
S 9 A copy of the SPCC plan
is required to be available at
sites that are normally attended
at least 8 hours/day where there
is a potential for a discharge (40
CFR 112 3(e))
Verify that a copy of the SPCC is available at sites that have personnel onsite at least
eight hours a day
(NOTE. If personnel are not onsite for eight hours/day, the plan may be kept at the
nearest field office and the plan should be made available to the Regional
Administrator.)
S 10 All facility personnel
involved with the management
and handling of oil must take
part in periodic training in spill
prevention and response (40
CFR 112 7(e)(10))
Verify that training has been conducted by reviewing training records and
interviewing the staff
Verify that spill training addresses the procedures to follow when a spill occurs, such
as.
- Emergency response
- Notification
- Containment
- Safety practices
- Remediation
Discharges/Spills
S 11 Discharges of oil into or
upon the navigable waters of
the United States or adjoining
shorelines or into or upon the
waters of the contiguous zone
or into areas that may affect
natural resources belonging to,
or under the exclusive
management authority of the
United States, must be reported
(40 CFR 110 2 through 110 10)
Interview staff and review spill records to determine if the facility has had any
discharges of oils
(NOTE' Discharges of oil are defined as those that violate applicable water quality
standards or cause a film or a sheen upon or discoloration of the surface of the water
or adjoining shoreline or cause a sludge or emulsion to be deposited beneath the
surface of the water or upon adjoining shores)
Verify that the NRC was notified as soon as possible after discovery of a discharge as
defined in the above NOTE
(NOTE If direct reporting to the NRC is not practicable, reports may be made to the
Coast Guard or EPA pre-designated OSC )
(NOTE Discharges of oil from a properly functioning vessel engine are not
considered harmful, but discharges of oil from a vessel's bilge are not allowed )
Phase 1 - Section 6
Spill Control and Response
6-11
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Compliance Category:
Spill Control and Response
Regulatory RequSretoenfs:
Reviewer Checks:
S.12. Facilities are not allowed
to add dispersants or emulsifiers
to oils that are discharged (40
CFR 110.8)
Verify that facilities do not add dispersants or emulsifiers to discharges.
Storage Areas
S.13 Appropriate containment
and/or diversionary structures
and cleanup equipment to
prevent discharged petroleum
products from reaching
navigable wateT course are
required to be readily available
at the facility (40 CFR
112 7(c)).
(NOTE: Water is of special concern during fueling of vessels on the water and repair,
maintenance, and replacement of powerhouse and water control structures)
Determine that at onshore facilities one of the following prevention systems or an
equivalent is used-
- Absorbent material
- Dikes, berms, or retaining walls sufficiently impervious to contain spilled oil
- Curbing devices
- Culverting gutters or other drainage systems
- Weirs, booms, or other barriers
• Spill diversion ponds
- Retention ponds
Verify that at offshore facilities (see definitions), one of the following or an
equivalent is available.
- Curbing
- Drip pans
- Sumps
- Collection systems
Determine the following for spill equipment in each oil storage area:
- Adequacy of material types and quantity
- Accessibility of storage locations
- Condition of equipment
S.14. Drainage of rainwater
from diked areas must be
controlled by a valve that is
closed when not in active use
(40 CFR 112 7(e)(1) and
112 7(e)(2)(iii)).
When plant drainage drains
directly into water courses and
not into wastewater treatment
plants, retained stormwater
should be inspected (40 CFR
112 7(e)(l)(ii)).
Verify that valves are closed when not in use by inspecting drainage valves at diked
areas.
Verify that drainage valves are attended that opened to drain the diked/bermed area by
interviewing personnel
Determine if operating personnel understand the meaning of a harmful discharge as
described in 40 CFR 110.6
Inspect records for any drainage water which was inspected to determine if it would
represent a harmful discharge
Phase 1 - Section 6
Spill Control and Response
6-12
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CompfiaiHie Category:
Spm Control aad Response
Regulatory
¦Reviewer Checks:
S. 15 Drainage water that is
determined to contain
petroleum products in harmful
quantities must be treated prior
to discharge to meet applicable
water quality standards (40
CFR 112.7(e)(2))
Determine if discharges containing harmful quantities of petroleum products were
properly treated, recovered, or disposed and reported by interviewing onsite
personnel.
Transfer Terminals
S 16 Buried piping at a transfer
facility, pumping station, or in-
plant processing facility is
required to have a protective
wrapping and coating and is
required to be cathodically
protected if soil conditions
warrant (40 CFR
112.7(e)(3)(i))
Determine whether soil conditions warrant cathodic protection Verify that buried fuel
piping is properly protected from corrosion by examining records and interviewing
personnel
Verify that methods are appropriate and correctly applied if cathodic protection is
used
Verify that detected leaks and failures are being reported
S 17 All above-and below-
ground fuel piping systems at
transfer facilities, pumping
stations, and m-plant processing
facilities must be regularly
examined and any suspected
leaks investigated immediately
(40 CFR 112.7(e)(3)(iv))
Verify that regular inspections have been conducted by examining records and
interviewing personnel
Verify that general condition of items, such as flange joints, valve glands and bodies,
catch pans, pipeline supports, locking of valves, and metal surfaces have been
assessed
Verify that confirmed leaks have been reported and that leaking pipes are repaired or
replaced through a review of records.
Loading and Unloading
S. 18 Onshore tank car and tank
truck loading/unloading racks
are required to meet specific
structural standards (40 CFR
112 7(e)(4)(ii) and 40 CFR
112.7(e)(4)(iii))
Verify that where rack drainage does not flow into a catchment basin or treatment
facility designed to handle spills, a quick drainage system is used
Verify that any containment system is designed to hold at least the maximum capacity
of any single compartment of a tank car or tank truck loaded or unloaded at the site
Verify that an interlocked warning light or physical barrier system, or warning signs
are provided in loading/unloading areas to prevent vehicular departure before
complete disconnect of flexible or fixed transfer lines.
Phase 1 - Section 6
Spill Control and Response
6-13
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Compliance Category:
$pHl Control and Response
Regulatory Requirements:
Reviewer Checks:
S 19 Specific operational
procedures are required to be
performed at facility tank car
and tank truck
loading/unloading sites (40
CFR 112 7(e)(iv))
Verify that before filling and departure of any tank car or tank truck, the lower-most
drain and all outlets of the vehicle are closely examined for leakage and, if necessary,
tightened, adjusted, or replaced to prevent leakage while in transit
Facility Response Plans
(NOTE The facility response plan requirements are effective 30 August 1994 )
(NOTE. See Appendix 6-1 for facility criteria in determining whether a facility response plan is required.)
S 20 Certain facilities, because
of their location and the
potential to cause substantial
harm to the environment by
discharging oil into or on the
navigable waters or adjoining
shorelines, are required to
prepare facility response plans.
(40 CFR 112 20)
By reviewing the volume of oil stored on site and assessing the facility location with
regard to the potential to cause substantial harm to the environment, determine if the
facility is required to prepare a facility response plan (see Appendix 6-1)
If a plan is required
- Determine the date of preparation and verify that the plan has been submitted to the
EPA Regional Administrator by the required deadline
(NOTE The deadlines differ depending upon the date the facility commenced
operation See 40 CFR 112 20 for dates by which facility response must be
submitted.)
- Review the plan against the model facility-specific response plan in 40 CFR 112
Appendix F for conformance with criteria and inclusion of appropriate information,
including, but not limited to*
-- emergency response action plan
- facility information
-- information about emergency response
- hazard evaluation
- response planning levels
- discharge detection systems
-- plan implementation
-- self-inspection, drills/exercises, and response training
- diagrams
-- security systems
- response plan cover sheet
Through interviews, determine the frequency with which the facility reviews/plans to
review its facility response plan and complete the following.
- Review facility construction diagrams, files, and other capital project information
and interview key personnel to determine if there have been any facility changes
that materially affected the facility response to a worst case discharge If so,
confirm that.
-- the plan has been appropriately revised; and
- the revised portions of the plan were resubmitted to the EPA Regional
Administrator within 60 days of each facility change.
- Verify that the facility at least periodically reviews and updates the plan to reflect
changes at the facility and submits these revised portions to the EPA Regional
Administrator
Phase 1 - Section 6
Spill Control and Response
6-14
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Compliance Category:
SpUl Control and Response
Regulatory Requirements:
Reviewer Checks:
S 20 Continued
Determine if a copy of the facility response plan has been provided to the local
emergency planning committee or state emergency planning commission, if so
requested
Confirm that the facility response has been coordinated with the local emergency
planning committee, regardless of whether the plan was submitted to them
If the facility is required to prepare a facility response plan, review the training
program it developed to implement the response plan and train facility personnel in
response procedures By reviewing the program and interviewing the training
manager and key response personnel, verify that the following is included in the
training program
(NOTE The training program is to be described in the facility response plan (40 CFR
112 20(h)(8)))
- Training is functional in nature according to job tasks
- Specific lesson plans on relevant subject areas have been developed and
communicated to oil spill response and cleanup personnel
- Response drills/exercises are included in the training program, as well as
procedures to evaluate the effectiveness of the drills/exercises (Appendix E to 40
CFR 112 provides guidance for the determination and evaluation of required
response resources for facility response plans )
If the facility has determined that, because of its location, it could not reasonably be
expected to cause substantial harm to the environment by discharging oil into or on
the navigable waters of adjoining shorelines, review the facility rationale and note
your opinion Also confirm that the facility has completed and maintained at the
facility the certification form (contained in 40 CFR 112 Appendix C) and any other
supporting documentation
If the facility does not meet the criteria for a facility response plan, by interviewing
the facility manager and other key environmental response personnel and reviewing
documentation, determine if the facility has received notice from EPA requiring the
facility to prepare such response plans If so, review the facility documentation to
verify that it prepared a facility response plan and submitted it to EPA within six
months of EPA's request
Phase 1 - Section 6
Spill Control and Response
6-15
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Section 6
Spill Control and Response
Appendix
-------
Appendix 6-1
Facility Response Plans
Facilities required to prepare and submit facility response plans:
The following facilities, because of their location and the potential to cause substantial harm to the
environment by discharging oil into or on the navigable waters or adjoining shorelines, are required to
prepare facility response plans (40 CFR 112.20(f)(1))
• The facility transfers oil over water to or from vessels and has a total oil storage capacity greater
than or equal to 42,000 gallons, or
• The facility's total oil storage capacity is greater than or equal to 1 million gallons, and one or
more of the following is true.
The facility does not have secondary containment for each above-ground storage area
sufficiently large to contain the capacity of the largest above-ground storage tank within
each storage area plus sufficient freeboard to allow for precipitation,
The facility is located at a distance such that a discharge from the facility could cause injury
to fish and wildlife and sensitive environments,
The facility is located at a distance such that a discharge from the facility would shut down
operations at a public drinking water intake; or
The facility has had a reportable spill greater than or equal to 10,000 gallons within the last
five years.
To determine whether a facility could, because of its location, reasonably be expected to cause
substantial harm to the environment by discharging oil into or on the navigable waters or adjoining
shorelines, the EPA Regional Administrator will consider the following factors (40 CFR 112.20(f)(2)).
• Type of transfer operation,
• Oil storage capacity;
• Lack of secondary containment,
• Proximity to fish and wildlife and sensitive environments and other areas determined by the EPA
Regional Administrator to possess ecological value;
• Proximity to drinking water intakes;
• Spill history, and
• Other site-specific characteristics and environmental factors that the EPA Regional Administrator
determines to be relevant to protecting the environment from harm by discharges of oil into or on
navigable waters or adjoining shorelines
A6-1
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Appendix 6-1 (continued)
Facility Response Plans
To determine whether a facility could, because of its location, reasonably be expected to cause
significant and substantial harm to the environment by discharging oil into or on the navigable waters
or adjoining shorelines, the EPA Regional Administrator may also consider the following factors (40
CFR 112 20(f)(3))
• Frequency of past spills;
• Proximity to navigable waters;
• Age of oil storage tanks; and
• Other facility-specific and region-specific information, including local impacts on public health.
A6-2
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Phase 1
Section 7
Management of Environmental Impacts
-------
Phase 1
Section 7
Table of Contents
Management of Environmental Impacts
A. Applicability 7-1
B Federal Legislation 7-1
C State/Local Regulations 7-11
D Key Compliance Requirement 7-11
E. Key Compliance Definitions 7-21
F. Records to Review 7-25
G Physical Features to Inspect 7-26
H Guidance for Checklist Users 7-27
Appendices
A7-1 Noxious Weeds A7-2
A7-2 Management of Environmental Impacts Facility Tour Checklist . A7-8
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A. Applicability
This section, which applies to all Federal facilities and Federal actions, integrates the
requirements of diverse laws and regulations pertaining to the assessment, documentation,
management, avoidance, minimization, monitoring, and mitigation of environmental impacts
resulting from the actions and policies of Federal agencies and the construction and operations
of Federal facilities. The collective intent of these laws and regulations is the protection of
human health and the environment, including the protection and management of natural
resources such as the physical media (air, soil, water) and biological components of
ecosystems; protected habitats (e.g., wetlands); endangered and threatened species;
agricultural resources; and commercial and recreational fisheries This section integrates the
environmental impact assessment and prevention elements of Federal requirements that
normally will apply to any facility potentially affecting human health and/or the natural and
built environment.
The primary focus of this section is on policy formulation and facility construction impacts
of Federal agencies, as regulated by laws such as the National Environmental Policy Act
(NEPA), the Endangered Species Act (ESA), and Section 404 of the Clean Water Act (CWA).
More specific regulatory requirements for the prevention, management, and monitoring of
facility operational impacts to physical environmental media (e.g., air, soil, and water), which
supplement the environmental management provisions of NEPA, ESA, CWA and other laws,
are addressed in greater detail elsewhere in other checklists. Management of agency/facility
impacts to cultural and historic resources, such as archaeological, paleontological, and historic
sites and materials, which must be evaluated concurrently with impacts to ecological
resources, is addressed separately.
To perform a comprehensive assessment, assessors also are required to review agency,
Federal, state, and local regulations pertaining to the management of facility impacts to natural
resources.
B. Federal Legislation
1. The National Environmental Policy Act (NEPA)
The purpose of this Act (42 US Code (USC) 4321-4370c), as last amended in November
1990, is to declare and implement a national policy to prevent or eliminate damage to the
environment and biosphere and to stimulate the health and welfare of humans (42 USC 4321).
Its underlying intent is to encourage productive and enjoyable harmony between humans and
their environment. Under NEPA, the continuing policy of the Federal government is to use
all practicable planning, policy, and regulatory means and measures in a manner calculated to
foster and promote the general welfare; to create and maintain conditions under which humans
and nature can exist in productive harmony; and to fulfill the social, economic, and other
needs of present and future generations of Americans (42 USC 4331(a)). Under NEPA and
related laws, it is the continuing responsibility of the Federal government to manage, monitor,
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and preserve the important historic, cultural, and natural aspects of our national heritage (42
USC 4331(b)(4))
2. Executive Order (EO) 11514, Protection and Enhancement of Environmental Quality
This EO, issued on 5 March 1970 and amended by EO 11991 (which was issued on 24
May 1977), is a Presidential order which implements NEPA. Under this EO, the Federal
government must provide leadership in protecting and enhancing the quality of the nation's
environment to sustain and enrich human life. Federal agencies must direct their policies,
plans, and programs so as to meet national environmental goals.
3. The Endangered Species Act (ESA) of 1973
The purpose of this Act (16 USC 1531-1547 et al., last amended in October 1988) is to
provide a means whereby the ecosystems upon which endangered species and threatened
species depend may be conserved; to provide a program for the conservation of such
endangered species and threatened species; and to take such steps as may be appropriate to
achieve the purposes of the treaties and conventions for protection of endangered species (16
USC 1531(b)). Under ESA, the policy of Congress is that all Federal departments and
agencies must seek to conserve endangered species and threatened species and must use their
authorities in furtherance of the purposes of this Act. In addition, Federal agencies must
cooperate with state and local agencies to resolve water resource issues in concert with
conservation of endangered species (16 USC 1531(c)).
4. The Fish and Wildlife Coordination Act of 1946
This Act, last amended in July 1965 (16 USC 666(c)), is the Federal legislation that
coordinates programs and activities regarding the conservation and rehabilitation of fish and
wildlife in the United States. A key element linking this statute to assessments of
environmental impacts conducted under NEPA is the requirement for interagency consultations
by the lead NEPA review agency, with appropriate Federal agencies responsible for the
protection and management of fish and wildlife resources throughout the NEPA review
process.
For example, whenever the waters of any stream or other body of water are proposed or
authorized to be impounded, diverted, the channel deepened, or otherwise controlled or
modified for any purpose, including navigation and drainage, by any department or agency of
the United States, or by any public or private agency under Federal permit or license, such
department or agency first must consult with the US Fish and Wildlife Service, Department of
the Interior (DOI), and with the head of the agency exercising administration over the wildlife
resources of the particular state where the impoundment, diversion, or other control facility is
to be constructed, with a view to the conservation of wildlife resources by preventing loss of
and damage to such resources as well as providing for the development and improvement
thereof in connection with such water resource development (16 USC 662(a)).
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5. The Fish and Wildlife Conservation Act of 1980
This Act (Public Law 96-366; 16 USC 2901 et seq.) promotes state programs for the
purpose of conserving, restoring, or otherwise benefiting nongame fish and wildlife, their
habitats, and their uses.
6. The Migratory Bird Treaty Act of 1918
This Act, last amended in December 1989 (16 USC 703-711), is a Federal law that
enforces international conventions for the protection of migratory birds and game animals to
which the United States is a party. Unless permitted by regulations, it is unlawful at any time,
by any means or in any manner, to pursue, hunt, take, capture, kill, attempt to take, capture,
or kill, possess, offer for sale, sell, offer to barter, offer to purchase, deliver for shipment,
ship, export, import, cause to be shipped, exported, or imported, deliver for transportation,
transport or cause to be transported, carry or cause to be carried, or receive for shipment,
transportation, carriage, or export, any migratory bird; any part, nest, or egg of any such bird;
or any product, whether or not manufactured, which consists, or is composed in whole or in
part, of any such bird or any part, nest, or egg thereof, included in the terms of the
conventions for the protection and conservation of migratory birds and game mammals
between the United States and the USSR, the United States and Mexico, and the United States
and Japan (16 USC 703). It is also unlawful to ship, transport, or carry, by any means
whatever, from one state, territory, or district to or through another state, territory, or district,
or to or through a foreign country, any bird, or any part, nest, or egg thereof, captured,
killed, taken, shipped, transported, or carried at any time contrary to the laws of the state,
territory, or district in which it was captured, killed, or taken, or from which it was shipped,
transported, or carried (16 USC 705).
7. Section 10 of the Rivers and Harbors Act of 1899 (RHA)
Section 10 of this Act (33 USC 403) requires issuance of a permit by the Corps of
Engineers for maintenance dredging in navigable waters of the United States Permit
applications under Section 10 are typically made jointly with Section 404 permit applications
under CWA for discharge of dredge and fill material into "waters of the United States."
8. Sections 404 and 401 of the Clean Water Act (CWA)
Section 404 of this Act (33 USC 1344) requires that all discharges of dredge and fill
material into "waters of the United States," including vegetated wetlands, must meet the
requirements of EPA's 404(b)(1) guidelines (40 CFR 230). All dredge and fill projects
permitted individually or jointly under Section 10 (RHA) and Section 404 (CWA) also must
obtain a Section 401 water quality certification from the state (33 USC 1341), unless
specifically exempted by Congress under Section 404(r) of CWA
9. Highly Erodible Land and Wetland Conservation
These United States Department of Agriculture (USDA) regulations (7 CFR 12),
administered by the USDA Agricultural Stabilization and Conservation Service (ASCS), set
forth the "terms and conditions under which a person who produces an agricultural commodity
on highly erodible land or designates such land for conservation use, plants an agricultural
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commodity on a converted wetland, or converts a wetland shall be determined to be ineligible
for certain benefits provided by the United States Department of Agriculture and agencies and
instruments of the Department" (7 CFR 12.1(a)). The environmental impact mitigation
purposes of these economic disincentives for unsound agricultural practices are to reduce soil
erosion, reduce sedimentation and improve water quality, and promote wetland conservation.
10. Executive Order 11988, Floodplain Management
This EO, dated 24 May 1977 and amended by EO 12148, on 20 July 1979, implements
NEPA, the National Flood Insurance Act of 1968, and the Flood Disaster Protection Act of
1973. Each agency must provide leadership and take action to reduce the risk of flood loss;
minimize the impact of floods on human safety, health and welfare; and restore and preserve
the natural and beneficial values served by floodplains. Each agency must evaluate the
potential effects of any actions it may take in a floodplain; ensure that its planning programs
and budget requests reflect consideration of flood hazards and floodplain management; and
prescribe procedures to implement the policies and requirements of this Order. Each agency
must take floodplain management into account when formulating or evaluating any water and
land use plans and must require land and water resources use appropriate to the degree of
hazard involved. Agencies must include adequate provision for the evaluation and
consideration of flood hazards in the regulations and operating procedures for the license,
permits, loan, or grants-in-aid programs that they administer (Section 2(c)).
11. Executive Order 11990, the Protection of Wetlands
This EO, dated 24 May 1977 and amended by EO 12608 (dated 9 September 1987),
requires all Federal agencies to issue procedures for ensuring that wetlands protection issues
are considered in all decision-making activities. Existing procedures such as those established
to implement NEPA must be modified to include wetlands protection and management. Under
this EO, each Federal agency must provide leadership and take action to minimize the
destruction, loss, or degradation of wetlands and to preserve and enhance the natural and
beneficial values of wetlands. Each agency, to the extent permitted by law, must avoid
undertaking or providing assistance for new construction located in wetlands, unless the head
of the agency finds that:
• There is no practical alternative to such construction, and
• The proposed action includes all practical measures to minimize harm to wetlands that may
result from such use. In making this finding the head of the agency may take into account
economic, environmental, and other pertinent factors (Section 2(a)).
Each agency must also provide opportunity for early public review of any plans or
proposals for new construction in wetlands (Section 2(b)).
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12. The Convention on Wetlands of International Importance Especially as Waterfowl
Habitat (Ramsar Convention)
This Convention was created on 2 February 1971, in Ramsar, amended by the Paris
Protocol of 12 March 1982, and entered into force for the United States on 18 December
1986. Each country must promote the conservation of wetlands and waterfowl by establishing
nature reserves on wetlands and providing adequately for their wardening (Article 4, para. 1)
The signatory nations (Contracting Parties) must promote the training of personnel competent
in the fields of wetland research, management, and wardening (Article 4, para. 4).
Contracting Parties agreed:
• Wetlands constitute a resource of great economic, cultural, scientific, and recreational
value, the loss of which would be irreparable,
• The progressive encroachment on and loss of wetlands now and in the future should be
stemmed;
• Waterfowl in their seasonal migration should be regarded as an international resource, and
• Conservation of wetlands and their flora and fauna can be ensured by combining
far-sighted national policies with coordinated international action
13. Sikes Act of 1960
This Act (16 USC 670a-670o, last amended in November 1989) authorizes the Secretary of
Defense to carry out a program of planning, development, maintenance, and coordination of
wildlife, fish, and game conservation and rehabilitation in military reservations in accordance
with a cooperative plan mutually agreed upon by the Secretary of Defense, the Secretary of the
Interior (SOI), and the appropriate state agency designated by the state in which the
reservation is located (16 USC 670a(a)). This Act also requires the Secretary of each military
department to:
• Manage the natural resources of each military reservation within the United States that is
under his/her jurisdiction so as to:
-- provide sustained multipurpose uses of those resources; and
-- provide the public access that is necessary or appropriate for those uses, to the extent
that those uses and that access are not inconsistent with the military mission of the
reservation (16 USC 670a-l(a)).
• Ensure, to the extent feasible, that the services necessary for the development,
implementation, and enforcement of fish and wildlife management on each military
reservation within the United States under his/her jurisdiction are provided by DOD
personnel who have professional training in those services (16 USC 670a-l(b)).
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14. Public Law (PL) 86-337
This Law (10 USC 2671) requires that all hunting, fishing, and trapping on DoD facilities
be in accordance with the fish and game laws of the state in which the facilities are located and
that appropriate state licenses for these activities on the DoD facility be obtained. PL 86-717
requires that projects be developed and maintained to encourage, promote, and assure adequate
and dependable future resources, including supplies of forest products. The forest lands will
be administered to increase the value of project lands for recreation and wildlife and to
promote ecological conditions by following accepted conservation practices.
15. The Coastal Zone Management Act (CZMA) of 1972
This Act, lasted amended in November 1990 (16 USC 1451-1464), is the state-
administered, Federal legislation that governs the preservation and onshore and offshore
management of coastal zones in the nation. The national policy for these coastal zones is to:
• Preserve, protect, develop, and where possible, restore or enhance, the resources of the
nation's coastal zones for this and succeeding generations;
• Encourage and assist states to exercise effectively their responsibilities in the coastal zone
through the development and implementation of management programs to achieve wise use
of the land and water resources of the coastal zone, giving full consideration to ecological,
cultural, historic, and aesthetic values, as well as the needs for compatible economic
development,
• Encourage the preparation of special area management plans that provide for increased
specificity in protecting significant natural resources; reasonable coastal-dependent
economic growth; improved protection of life and property in hazardous areas, including
those areas likely to be affected by land subsidence, sea level rise, storm events, or
fluctuating water levels of the Great Lakes; and improved predictability in governmental
decision making;
• Encourage the participation and cooperation of the public, state and local governments;
interstate and other regional agencies; and Federal agencies having programs affecting the
coastal zones, in carrying out the purposes of this Act;
• Encourage coordination and cooperation with and among the appropriate Federal, state,
and local agencies and international organizations, where appropriate, in collection,
analysis, synthesis, and dissemination of coastal management information; research results;
and technical assistance to support state and Federal regulation of land-use practices
affecting the coastal land ocean resources of the United States; and
• Respond to changing circumstances affecting the coastal environment and coastal resource
management by encouraging states to consider such issues as ocean uses potentially
affecting coastal zones (16 USC 145).
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16. The Marine Mammal Protection Act (MMPA)
This Act (PL 95-522; 16 USC 1361) prohibits the illegal taking of marine mammals,
regardless of whether or not they are protected under the Endangered Species Act. Although
the taking issue may not be directly applicable to normal Federal facility activities, the
environmental monitoring plans of coastal facilities should ensure that facility effects on
marine mammals are monitored and mitigated to the fullest extent practicable.
17. Marine Protection, Research, and Sanctuaries Act of 1972 (MPRSA)
This Act (PL 92-532, 33 USC 1401 and 1431) implements the provisions of international
conventions on ocean dumping and marine pollution to which the United States is a signatory.
Title I of the MPRSA prohibits ocean dumping of solid, hazardous, medical, and radioactive
wastes without a permit. Title III of the MPRSA provides for the establishment of national
marine sanctuaries that are afforded special protection and management programs.
18. Wild and Scenic Rivers Act of 1986
This Act (16 USC 1271-1287, last amended in May 1991) outlines the policy of the United
States that certain selected rivers of the nation which, because of their immediate
environments, possess outstandingly remarkable scenic, recreational, geologic, fish and
wildlife, historic, cultural, or other similar values, must be preserved in free-flowing
condition, further, they and their immediate environments must be protected for the benefit
and enjoyment of present and future generations. The Congress declares that the established
national policy of dam and other construction at appropriate sections of the rivers of the
United States needs to be complemented by a policy that would preserve other selected rivers
or sections thereof in their free-flowing condition to protect the water quality of such rivers
and fulfill other vital national conservation purposes (16 USC 1271). The purpose of this Act
is to implement the declared policy of Congress by instituting a national wild and scenic rivers
system, designing the initial components of that system, and prescribing the methods by which
and standards to which additional components may be added to the system from time to time
(16 USC 1272).
19. Farmland Protection Policy Act of 1981
The purpose of this Act (7 USC 4201-4209, last amended in December 1991) is to
minimize the extent to which Federal programs contribute to the unnecessary and irreversible
conversion of farmland to nonagricultural uses and to assure that Federal programs are
administered in a manner that, to the extent practicable, will be compatible with state, unit,
and private programs and policies to protect farmland (7 USC 4201(b))
20. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
of 1980
As amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (42
USC 9601-11050, 10 USC 2701-2810 et. seq.), CERCLA/SARA regulates the prevention,
control, characterization of, and compensation for impacts and risks to human health and the
environment, including damages to natural resources, caused by environmental contamination
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resulting from releases of oil, chemicals, and other hazardous materials. Where applicable,
the site-specific CERCLA/SARA requirements of Federal agencies and facilities may include:
• The comprehensive characterization of the on-site/off-site nature, extent, and
fate/migration of contamination in physical and/or biological media (Remedial
Investigation (RI));
• Assessments of the contamination exposure risks to human populations (Human Health
Risk Assessment (HHRA)) and ecological receptors (Ecological Risk Assessment (ERA));
• Natural Resource Damage Assessment (NRDA) and notification of Federal and state
natural resource trustees regarding damages to trustee resources (e.g., habitats and
species);
• The evaluation of other human health and/or environmental consequences of contaminant
releases;
• A Feasibility Study (FS) of alternative strategies and methods for site cleanup and
restoration; and
• The design (Remedial Design (RD)) and implementation (Remedial Action (RA)) of site-
specific remediation plans.
21. Criteria for Classification of Solid Waste Disposal Facilities and Practices
40 CFR 257 regulates the disposal of sludge by application to land used for production of
food chain crops. It also sets forth criteria for waste disposal by soil injection and prohibits
solid waste disposal facilities or practices from adversely affecting floodplains and endangered
species.
22. Oil Pollution Prevention Act
Regulations promulgated under this Act (40 CFR 112) require that surface water receptors be
protected from facility releases of oils by implementation of Spill Prevention Control and
Countermeasures (SPCC) plans that address each potential source.
23. The Pollution Prevention Act of 1990
This Act (PL 101-508, as amended by PL 102-389) encourages examination of waste more
broadly with a view toward reducing pollution. All pollutants are to be minimized and waste
creation is to be controlled not just during the production process, but also in the design of
products that will have less impact on the environment during use and after disposal.
24. EO 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to
comply with applicable Federal, state, and local pollution control standards. It makes the head
of each executive agency responsible for ensuring that the agencies, facilities, programs, and
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activities the agency funds meet applicable Federal, state, and local environmental
requirements for correcting situations that are not in compliance with such requirements. In
addition, the EO requires that each agency ensure that sufficient funds for environmental
compliance are included in the agency budget.
25. EO 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements
This EO, dated 3 August 1993, details the requirements to be met to ensure that Federal
agencies conduct their facility management and acquisition activities so that, to the maximum
extent practicable, the quantity of toxic chemicals entering any waste stream is reduced as
expeditiously as possible. The EO required each Federal agency to submit a pollution
prevention strategy to the EPA Administrator by 3 August 1994 Among the specific
requirements of this EO are a 50 percent reduction of total releases of pollutants and off-site
transfers of toxic chemicals per agency by 1999 and the formulation of facility-specific
pollution prevention plans.
26. Radiation Protection of the Public and the Environment
Department of Energy (DOE) regulations 10 CFR 834 codify the environmental
surveillance requirements of DOE facilities for physical media and biota, including endangered
species and terrestrial/aquatic foodstuffs. These DOE regulations provide valuable guidance
for other Federal agencies/facilities that lack comparable regulations and are recommended as
Best Management Practices (BMPs) for the monitoring and assessment of impacts from
facility-derived radionuclides (and chemical contaminants).
27. The Noise Control Act of 1972
This Act, PL 92-574 (42 USC 4901-4918), as amended:
• Establishes a means for effective coordination of Federal research and activities in noise
control,
• Authorizes the establishment of Federal noise emission standards for products distributed
in commerce; and
• Provides information to the public regarding the noise emission and noise reduction
characteristics of such products.
Four categories of noise-generating products are covered:
• Construction equipment,
• Transportation equipment (including recreational vehicles and related equipment);
• Any motor or engine (including any equipment of which an engine or motor is an integral
part); and
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• Electrical or electronic equipment.
The following are not covered by the Act (42 USC 4902(3)):
• Any aircraft, aircraft engine, propeller, or appliance;
• Any military weapons or equipment designed for combat use;
• Any rockets or equipment designed for research or experimental or developmental work to
be performed by the National Aeronautics and Space Administration (NASA); and
• Any other machinery or equipment designed for use in experimental work done by or for
the Federal government.
28. Aviation Safety and Noise Abatement Act of 1979
This Act (PL 96-193; 49 USC Appendix 2103, 2104), as amended, complements the Noise
Control Act by regulating airport noise. Any airport operator may submit to the Secretary of
Transportation a noise exposure map. Such map shall set forth the noncompatible uses in each
area of the map, a description of the projected aircraft operations at such airport, and the ways
in which such operations will affect receptor populations and thus require revisions of the map
(49 USC 2103) Any airport operator who has submitted a noise exposure map and related
information may submit to the Secretary of Transportation a noise compatibility program.
This program shall include measures that the operator has taken or proposes for the reduction
of existing noncompatible uses and the prevention of the introduction of noncompatible uses
within the area covered by the noise exposure map submitted (49 USC Appendix 2104).
29. Executive Order 11987, Exotic Organisms
This EO requires executive agencies to restrict the introduction of exotic species into
natural ecosystems which they own or lease and encourage the states to prevent such
introductions.
30. Executive Order 11989, Use of Off-Road Vehicles (ORVs) on the Public Lands
This EO specifies that ORVs may not be used without special use and location designation.
31. The Federal Noxious Weed Act of 1970
This Act, last amended in September 1988 (7 USC 2803 and 2809), states that no person is
permitted to move any noxious weed identified in a regulation into or through the United
States or interstate, unless such movement is:
• From Canada, or authorized under general or specific permit from the Secretary of
Agriculture; and
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• Made in accordance with such conditions as the Secretary may prescribe in a permit and in
regulations to prevent the dissemination into the United States, or interstate, of such
noxious weed (42 USC 2803).
A listing of aquatic, parasitic, and terrestrial plant species that are federally designated as
noxious weeds (7 CFR 360.200) appears in Appendix 7-1.
32. Draft United Nations Convention on Biodiversity
This draft treaty, presented in June 1992 at the United Nations Conference on the
Environment and Development in Rio de Janeiro, Brazil, promotes the conservation of
biological diversity, restoration of damaged ecosystems, recovery of threatened and
endangered species, and sustainable use of biological resources. The United States is a
signatory to the Convention
C. State/Local Regulations
Many states have laws and regulations comparable to Federal laws such as NEPA, ESA,
and Section 404 of the CWA, which are equally or more stringent than these Federal laws
Under such state laws, additional or overlapping requirements may pertain to actions of
Federal agencies and facilities potentially affecting ecological resources such as physical
media, wetlands, protected species and their habitats, and other categories of flora and fauna.
Such examples of state requirements include, but are not limited to-
• Lists of protected plant and animal species, considered rare, threatened, or endangered at
the state level, even if they are not listed as federally protected species under ESA,
• Regulations and Management Practices (MPs) for the protection of surface waters, coastal
zones, wetlands, and the prevention of nonpoint source pollution; and
• Regulations governing hunting and fishing activities.
D. Key Compliance Requirements
1. Agricultural Resources
Other than the Farmland Protection Policy Act of 1981 (7 CFR 658), which minimizes the
extent to which Federal programs may contribute to the unnecessary conversion of farmland to
nonagricultural use, agricultural resources are afforded minimal direct protection under
Federal, state, and local regulations.
Solid waste disposal regulations (40 CFR 257) provide some protection for agricultural
resources, however, because agricultural and livestock production lands are protected from
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contaminants that could potentially come from the sewage wastes that are used as fertilizer and
soil conditioners.
Federal environmental reviews conducted under NEPA also may offer some protection for
agricultural resources, if the impacts of a new Federal facility or agency action on local
agriculture are specified as impact issues to be addressed during the public scoping sessions
for a NEPA review. Agency-specific policies and regulations also may offer some protection,
such as those of DOE that mandate the routine environmental surveillance of agricultural soils
and foodstuffs, to detect DOE facility-derived chemical contaminants and radionuclides within
a 16 km radius of DOE facilities.
State-level environmental review requirements, similar to those of NEPA, also may
address facility impacts to agricultural resources and/or promote the preservation of
agricultural land.
2. Aquatic Biota
Federal and state laws protect aquatic biota, both directly for trustee resources such as
anadromous fish, commercial shellfish, endangered species, and marine mammals, and/or
indirectly by protecting aquatic or wetland habitats and regulating facility impacts to the
chemical and radiological quality of the sediments and surface waters found within these
habitats. Reporting requirements for spills of oil and hazardous materials into surface waters,
for example, include notification of trustees of many of these aquatic biological resources.
Prevention and minimization of impacts to aquatic biota from effluent discharges, including
storm water, is accomplished primarily through the National Pollutant Discharge Elimination
System (NPDES) permits program under the CWA (40 CFR 122). To be effective, NPDES
permits must set facility/site-specific effluent standards, that reflect the capacity of the
receiving water body to assimilate and dilute the contaminant levels of the effluent to nontoxic
concentrations. To preclude or minimize adverse effects on aquatic biota, NPDES permits
should be conditioned to prevent exceedances of surface water quality standards within the
surface waters receiving the effluent. To achieve this, the effluent limits should be based on
the ambient water quality criteria developed by EPA (1976, 1986, 1987, and 1992). Ambient
Water Quality Criteria (AWQC), developed for fresh and marine surface waters by EPA under
Section 304(a)(1) of the CWA, are periodically updated and are based on acute and chronic
toxicity data for aquatic biota. Because they are designed to protect entire communities of
aquatic flora and fauna, these AWQC are the most useful regulatory standards for the
protection of fresh water and marine organisms within the context of the Clean Water Act.
The National Oceanic and Atmospheric Administration (NOAA) also has published
sediment guidelines that can be applied to marine and freshwater ecosystems to assess
ecological risks to benthic invertebrate biota from exposures to sediment contamination. As
indicated above for agricultural foodstuffs, other agency-specific regulations, such as those of
DOE, may also require monitoring of the levels of facility-derived chemicals and radionuclides
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in the surface water, sediments, and biota of aquatic ecosystems that are potentially affected by
facility operations.
3. Coastal Zone Resource Management
The Coastal Zone Management Act of 1972 (CZMA, 16 USC 1451-1464) establishes
national policy pertaining to the coordinated Federal, state, and local management of natural
resources of the coastal zones of the United States, including surface waters, wetlands,
floodplains, fish and wildlife, and their habitats. Federal agency policies and facility
development activities in the coastal zone, boundaries of which are defined in each state's
CZMA Plan, must be consistent with state-administered Coastal Zone Management Plans
established pursuant to CZMA. Each facility within the coastal zone must obtain a Certificate
of Consistency with the state's CZMA Plan.
Ecological resources found within the coastal zone also may be protected under other
Federal and/or state laws, such as those pertaining to wetlands (CWA), floodplains,
commercial fish and shellfish resources, migratory birds (MBTA), and marine mammals
(MMPA). Estuarine and open ocean ecosystems also may be protected from dumping of solid,
hazardous, medical, and radioactive wastes (without a permit), as marine sanctuaries, under
the Marine Protection, Research, and Sanctuaries Act of 1972 (MPRSA; P.L. 92-532, 33
USC 1401 and 1431). Provisions of the CWA and CERCLA also afford protection to certain
"trustee resources" of the coastal zone, such as anadromous fish, commercial fish and
shellfish, migratory birds, marine mammals, and wetlands, from spills or releases of oil and
hazardous materials.
4. Dredge and Fill Permits
Dredge and fill activities conducted within both navigable and nonnavigable "waters of the
United States" are regulated by the United States Army Corps of Engineers (COE) pursuant
to:
• Section 10 of the Rivers and Harbors Act of 1899 (RHA; 33 USC 403), and
• Section 404 of the Clean Water Act (CWA; 33 USC 1344).
Application under both statutes is made jointly to the COE for the discharge of dredge
spoil/water and/or fill into "waters of the United States," which include all surface water
bodies and vegetated wetlands such as swamps and marshes. As part of the Sections 10/404
review process, the COE must determine if the project will comply with EPA's 404(b)(1)
guidelines (40 CFR 230) that were established as a guide to evaluating discharges of dredged
or fill material into the waters of the United States. As part of the Sections 10/404 public
interest review process (33 CFR 320.4(a)), the COE also must consider project-specific and
cumulative impacts to aesthetics; economics; land use; recreation; shore erosion; water
quality; and wetland, fish, and wildlife resources.
As part of the interagency review process mandated by the National Environmental Policy
Act (NEPA; see 40 CFR 6.302) and the Fish and Wildlife Coordination Act (16 USC 661-
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667e; see 33 CFR 230.25), the COE must obtain application review commentary from the
U.S. Environmental Protection Agency (EPA), the National Marine Fisheries Service
(NMFS), and the U.S. Fish and Wildlife Service (USFWS), before deciding whether an
Environmental Impact Statement (EIS) is required under NEPA, and before issuing a Section
404 permit.
In compliance with Section 401 of the Clean Water Act (33 CFR 325.2(b)(1)), and as a
requirement of the Section 404 permitting process, a Water Quality Certification (WQC) also
must be obtained for the project from the state In some states, the COE may hold joint public
hearings on Sections 10/404, Section 401, and related permit applications under other state
laws (e.g., wetland protection laws). To obtain the Section 401 WQC from the state, the
proposed project must be shown to comply with the state's surface water quality criteria,
which must be at least as stringent as EPA's ambient water quality criteria (AWQC) for the
protection of aquatic life.
Section 404(c) empowers EPA to veto Section 404 permits issued by the COE.
5. Ecological Risk Assessment (ERA)
An ERA is the assessment of qualitative and/or quantitative risks posed to communities,
populations, or individual species of ecological receptors (flora and fauna) from the exposure
to chemicals or radionuclides in the physical and biological media of their environment. ERAs
are often required as part of or concurrently with remedial investigations at CERCLA and/or
RCRA sites and may form the basis for natural resource damage assessments and the
development of ecological risk-based site cleanup decisions, goals, and remedial actions. An
ERA may be based on direct exposures (e g., contact, ingestion, inhalation) or indirect
exposures (e g., food chain contamination) to environmental contaminants.
6. Endangered and Threatened Species
Pursuant to both NEPA (40 CFR 6.108 and 6.302) and the Endangered Species Act (16
USC 1531 et seq.; 33 CFR 230.25), Federal agencies and facilities must consider their
potential impacts to Federal and state-listed endangered/threatened plant or animal species, and
their habitats. Such evaluations, which may include a Baseline Assessment of Endangered
Species (BATES), are best conducted during NEPA reviews prior to deciding if an EIS is
required and/or issuing Federal permits (e.g., Sections 10/404 dredge and fill permits).
Although many states have Natural Heritage Programs or other programs to maintain lists of
both Federal- and state-listed endangered/threatened species, not all of these also have
endangered species laws.
Facilities with Federal- and/or state-listed endangered and threatened species are required
to implement habitat protection and management programs designed to ensure their
conservation. A baseline survey is required to determine if the facility has any such species
and to inventory such populations as a basis for devising protection and management measures
needed to maintain them. Such surveys are typically required within the context of NEPA or
comparable state-level environmental reviews, and/or as part of the permitting process for
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agency/facility actions or policies affecting wetlands and/or associated surface waters, under
Section 404 of the CWA and similar state laws/regulations.
Protected species management programs should be developed in consultation with
appropriate Federal and state agencies, and annual consultations with these agencies should be
used to report on the species status and to obtain updates on possible on-site occurrences of
previously unreported protected species. All facilities must review proposed actions and
activities to ensure that they are not likely to jeopardize the continued existence of a federally-
listed species or to destroy or adversely modify its critical habitat (40 CFR 1500; 50 CFR
402.01(a), 402.10,402.12).
7. Environmental Assessment and Monitoring
NEPA is the primary law mandating the assessment of environmental impacts, in concert
with other laws designed to protect the quality of physical media (air, soil, ground and surface
water), such as the Clean Air Act, Clean Water Act, and Safe Drinking Water Act Federal
agency/facility commitments made in NEPA documents, moreover, may include long-term
monitoring and assessment of a facility's environmental impacts. Facility-specific permit
requirements governing air and water emissions and waste disposal activities also are likely to
include environmental monitoring requirements and perhaps ecological effects measurements
that must be conducted during the initial construction and/or long-term operation of the
facility.
The assessor should, therefore, evaluate the adequacy and accuracy of facility-specific
NEPA documents as a basis for long-term monitoring and assessment of facility operational
impacts and then coordinate a compliance review of specific monitoring requirements for
physical media with the appropriate assessors charged with evaluating medium-specific permit
compliance.
This collaboration is critical, because it will provide the impact assessment specialists with
necessary data on the types, locations, and concentrations of contaminants released by the
facility to assess the facility's impacts on the physical and biological components of local
ecosystems.
8. Environmental Noise
NEPA requirements for impact assessment and mitigation include noise effects on humans
and the environment. Other Federal laws regulating the management and mitigation of noise
impacts are the Noise Control Act of 1972 (NCA) and the Aviation Safety and Noise
Abatement Act of 1979 (ASANAA). Noise effects on wildlife and, in particular, on animal
species protected under the ESA, MBTA, and MMPA, also are critical elements of any NEPA
review or document.
9. Floodplain Management
This includes proactive land use planning to avoid or minimize human activities within
and/or alterations of natural floodplains along rivers and other water bodies where the
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statistical frequency of flooding (e.g., 10-year and 100-year floodplains) is sufficiently high as
to pose significant risk to human life and property. Floodplain management and regulation is
mandated by EO 11988 and may also be required by state laws protecting floodplain habitats
associated with wetland and surface water resources.
10. Ground Water Protection
Facility operations must be conducted to prevent or minimize, assess, monitor, and
mitigate adverse impacts to ground water resources, whether or not the affected aquifers are
used as a drinking water source for human consumption. Applicable Federal ground water
protection regulations and quality standards are set forth under CERCLA, the CWA, the Safe
Drinking Water Act (SDWA), and RCRA. These assessment, monitoring, and ground water
protection requirements are addressed in greater detail in other checklists. Many states also
have ground water and drinking water standards, and soil standards that are designed to
protect ground water resources.
11. Human Health Risk Assessment (HHRA)
HHRA is the assessment, usually quantitative, of incremental, noncancer and cancer risks
posed to human receptors from the exposure to chemicals and/or radionuclides occurring in the
physical and/or biological media (e.g., food) of their environment. As with ERAs, HHRAs
are typically required as part of or concurrently with remedial investigations at CERCLA
and/or RCRA sites, they often form the basis for health risk-based remedial planning
decisions, media-specific site cleanup standards, and remedial action plans. HHRAs generally
integrate a combination of direct (e.g., contact, ingestion, inhalation) and indirect (e.g.,
contaminated foods) exposures to site-derived environmental contaminants.
12. Natural Resources Damage Assessment (NRDA)
NRDAs may be required to assess the impacts on natural resources resulting from
operations and contaminant releases at hazardous waste facilities/sites (CERCLA) or from
environmental releases of oil and other hazardous materials into waters of the United States
(CWA). CERCLA regulations also require that lead Federal agencies reporting releases
and/or performing NRDAs coordinate with other state and Federal Natural Resource Trustees
when a facility release or discharge may injure natural resources. These assessment,
monitoring, and reporting requirements for releases of oil and hazardous materials are
addressed in greater detail in other checklists.
13. NEPA Reviews and Documentation
Prior to undertaking any action having a potentially significant environmental impact, the
Federal agency proposing such action must conduct an environmental review, pursuant to the
Council on Environmental Quality (CEQ) NEPA regulations (40 CFR 1500-1508) and its
agency-specific, NEPA implementing regulations, which were promulgated as required in
these CEQ NEPA regulations. The level and extent of NEPA review required is determined
on a case-by-case basis, and the documentation requirements will vary as a function of the
nature, complexity, scale, and environmental consequences of the action, as indicated below.
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• Environmental Assessment (EA) - At a minimum, every NEPA review requires preparation
of an EA before any contract for action is entered into or action is begun The purpose of
an EA is to support a decision regarding the need for a more comprehensive
Environmental Impact Statement (EIS) If the lead agency determines that the expected
environmental impacts are not sufficient to warrant preparation of an EIS, it will issue a
Finding Of No Significant Impact (FONSI) and thus terminate the NEPA review process
• Finding of No Significant Impact (FONSI) - When a FONSI is issued on the basis of an
EA, the FONSI must meet certain requirements, such as the name of the action, a brief
description of the action, a discussion of environmental effects, the conclusions that have
led to the FONSI, the date of approval, and the appropriate signature (40 CFR 1502.4,
1502.10 through 1502 13, 1503.4(i), 1508.9, and 1508.13).
• Environmental Impact Statement (EIS) - An agency or facility must produce an EIS if, at
any time during preparation of the EA, it becomes apparent that a proposed action is likely
to significantly degrade environmental quality, pose a threat to public health or safety,
and/or result in adverse cultural, socioeconomic, physical, biogeochemical, and/or
ecological impacts. The scope and content of the EIS must be determined on the basis of
Federal interagency consultations and inputs from state agencies and other concerned
private and public entities, as part of a public scoping process
Both the EA and EIS must include an evaluation of project (e.g., project siting or design)
or policy alternatives; an assessment of adverse and beneficial impacts; identification of
strategies and measures to avoid, minimize, or mitigate adverse impacts; and documentation of
any residual, adverse impacts that cannot be fully mitigated
14. No Net Loss Policy for Wetlands
The Federal "no net loss policy" for wetlands, as set forth in a Memorandum of
Agreement between the EPA and the COE, effective 31 January 1990, states that destruction
of wetlands should be avoided wherever possible, especially in cases where less damaging
alternatives to destructive projects/actions are available (40 CFR 230.10(a)). This policy
incorporates guidance from the CEQ, which defines avoidance of impacts as the top priority
for mitigation, with minimization of impacts as a secondary option, and mitigation of wetland
impacts/losses as a third, last resort option for those cases in which no less damaging
alternatives exist and wetland impacts prove unavoidable. The policy requires that the COE
"strive to avoid adverse impacts...to existing aquatic resources, and for wetlands, will strive to
achieve a goal of no overall net loss of values and functions."
15. Pollution Control and Prevention
Pollution control and prevention requirements for air, soil, surface water, and ground
water should be addressed cooperatively with the assessors of these physical media, only as
needed to assess a facility's impacts resulting from human and ecological exposures to these
media. One example is adverse effects on the aquatic biota of receiving waters resulting from
exceedances of facility-specific effluent discharge permit limitations (NPDES) that cause local
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exceedances of Ambient Water Quality Criteria (AWQC) established by the EPA for the
protection of aquatic life
16. Pollution Prevention Plan
A pollution prevention plan is a facility-specific plan for the control, prevention, and
reduction of pollution releases and off-site transfers of toxic chemicals, as required of all
Federal agencies by EO 12088, EO 12856, the Pollution Prevention Act, and related Federal
laws/regulations. EO 12856, for example, requires all Federal agencies to submit a pollution
strategy to the EPA Administrator by 3 August 1994, and to develop facility-specific pollution
prevention plans by 1995.
17. Remedial Investigation (RI)
Where applicable, Federal facilities may be required to conduct an RI and related studies
of potentially contaminated sites. Examples include a Department of Defense Installation
Restoration Program and/or compliance with CERCLA/SARA and/or RCRA regulations.
18. Soil and Sediment Quality
Federal remediation guidelines for soil and/or sediment contamination are mostly
associated with CERCLA/SARA and RCRA regulations and may vary among sites based on
the results of RI/FS studies and site-specific risks posed to human and ecological receptors.
Petroleum and other chemical contamination of soils and sediments are of particular
importance in areas of releases from hazardous material transport vehicles. Guidelines set by
EPA or state regulators and site-specific Applicable or Relevant and Appropriate Regulations
(ARARS) developed during CERCLA remedial activities may be useful to consider while
auditing sites with soil contamination.
Guidelines on permissible radioactivity levels in solid materials and liquid waste streams
disposed of or discharged to soil or sediment are addressed in some agency-specific policies
and regulations, in particular those of DOE (e.g., 10 CFR 834). In addition, standards used
for remedial action on residual radioactive material from inactive uranium processing sites
(40 CFR 192) could be applied to any sites where such material is present in soil or sediments
above background levels.
a. Soils. Common sources of soil contamination at facilities are:
• Chemical and radiological effluent discharges
• Use, disposal, storage, and management of hazardous and radiological materials and/or
waste
• Spills/discharges during the handling, transport, or use of hazardous and radiological
materials and/or wastes
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In addition, gaseous and particulate contaminants in air, such as sulfurous and nitrous
oxides and radioactive particle emissions from stacks of production facilities, may settle on
soil surfaces far from their source. Local soil contamination can also result from landfills
containing municipal solid waste, which invariably contains discarded pesticides, cleaning
agents, and chemicals.
Toxic Substances Control Act (TSCA) regulations for PCBs denote the level of cleanup
required after a PCB spill incident (40 CFR 761.125). Guidelines available from RCRA
include restrictions on disposal of solid or sewage wastes on or below agricultural lands.
Although there are no federally mandated criteria to define an acceptable level of Total
Petroleum Hydrocarbon (TPH) in soils, several states have or are developing risk-based and/or
ground water protective soil standards for TPH, related petrochemicals, pesticides, metals, and
other chemicals
b. Sediments. Because sediments may originate as soil, any contaminant, especially on
the surface, can be washed into water bodies where it may settle out of suspension
Consequently, regulations and guidelines applicable to soils could also serve for sediments and
vice versa. To a lesser extent, contaminated plants and animals, including aquatic organisms,
could also contribute to sediment contamination as a result of biomass decomposition and
organic particulate deposition.
Chemical and radiological contamination of sediments may have adverse environmental
effects, for some of the following reasons:
• Contaminated sediments may be in equilibrium with pore water and thus could contaminate
aquatic life, particularly benthic invertebrates and their predators, such as fish;
• Dredging of sediments in wetlands and surface waters can generate large volumes of
excavated sediments which, because of possible unacceptable levels of contaminants, may
pose problems in handling and disposal; and
• Contaminated sediments can be disturbed, resuspended, and/or redeposited on land
surfaces by boating, shipping, flood events, dredging, and underwater construction.
Bottom sediments of water bodies generate the potential for continued environmental
degradation, even when water-column contaminant levels comply with established water
quality criteria, because the sediments can first act as a sink for contaminants and then as a
source during resuspension
Although there are no federally mandated sediment quality criteria that define acceptable
levels of chemical sediment contamination, potential ecological impacts can be assessed using
sediment ecotoxicological guidelines published by NOAA (Long and Morgan, 1990, 1991)
These bioassay-based sediment guidelines can be applied to assess potential impacts and risks
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to benthic invertebrate biota of marine and freshwater ecosystems from exposures to specific
sediment contaminants.
19. Surface Water Protection
Facility operations must be conducted to prevent or minimize, assess, monitor, and
mitigate adverse impacts to surface water resources, whether or not the affected water bodies
are used as a drinking water source for human consumption. Applicable Federal surface water
protection regulations are set forth by the EPA under Section 304(a)(1) of the CWA, as
Ambient Water Quality Criteria (AWQC) designed both for the protection of aquatic life and
as standards for the human consumption of surface water and/or fish. These surface water
assessment, monitoring, and protection requirements are addressed in greater detail in the
Water Pollution Control checklist. Many states also have surface water standards, that must
be approved by the EPA and must be as stringent or more stringent than EPA's AWQC.
20. Vegetation Management
Vegetation management refers to efforts to establish and maintain beneficial vegetative
cover types and communities and to control and/or eliminate noxious weeds that have the
ability to disrupt and degrade native plant and animal communities, cause economic damages
to property and agricultural crops, and/or cause health problems to humans and/or agricultural
animals (livestock). Federal and state regulations governing the use of herbicides, the
destruction and transport of noxious weeds, and the alteration of vegetated wetlands and other
protected habitats, collectively, must be considered in the development of facility-specific
vegetation management plans.
21. Water Quality Certification
See Dredge and Fill Permits (Sections 401 and 404 of the CWA) and Surface Water
Protection (Section 304(a)(1) of the CWA).
22. Wetlands Protection
Protection of "waters of the United States," including vegetated wetlands, is federally
mandated under Section 404 of the CWA, EO 11990, Protection of Wetlands, and the Federal
"no net loss policy" for wetlands as set forth in a Memorandum of Agreement between the
EPA and the Corps of Engineers (effective as of 31 January 1990).
23. Wild and Scenic Rivers
The Wild and Scenic Rivers Act of 1968 (30 CFR 297) prohibits the use of Federal Hinds
for activities that would have an adverse effect on those characteristics that caused a river to be
classified as wild, scenic, or recreational. Protection of officially designated wild and scenic
rivers from construction and/or operation of Federal facilities is also provided by various other
laws that protect the physical media, upland (bank) habitats, wetlands, floodplains, vegetation,
and resident and migratory fauna that are associated with the riverine and riparian ecosystems
of these wild and scenic river corridors.
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Protection of the aesthetic, cultural, and historical values of these federally listed rivers is
also addressed in the Cultural and Historic Resources checklist.
24. Wildlife Protection and Management
Resident, migratory, terrestrial, and wetlands wildlife individuals and populations (aquatic
biota are addressed separately) may be affected by the construction and/or operation of Federal
facilities, either:
• Directly, through direct impacts (e.g., suffocation from earth moving activities), loss of
habitat, displacement, and/or exposure to site-derived contaminants; and/or
• Indirectly, as a result of the loss or contamination of their food resources caused by the
exposure of these plant or animal food species to site-derived radionuclides and/or
chemical contaminants.
Except for legally protected Federal and state trustee resources such as endangered species
(ESA), marine mammals (MMPA), and migratory birds (MBTA), little direct Federal or state
protection is afforded to aquatic, wetland, and terrestrial wildlife. Thus NEPA provides the
primary tool for the regulation of impacts to wildlife species that are not legally protected, in
and of themselves, under Federal or state statutes. NEPA reviews and documentation,
including interagency consultations mandated by the Fish and Wildlife Coordination Act are
the primary means of protecting wildlife populations and their habitats.
Other Federal laws mandating the characterization and remediation of site contamination
(e.g., CERCLA/SARA and RCRA), however, can also mandate assessments of impacts/risks
to wildlife species in the form of an ecological risk assessment (ERA), which, in turn, may be
used to set site remediation goals and chemical-specific cleanup standards for soil, sediment,
and surface water. Wildlife management is also promoted by Federal laws such as the Sikes
Act, which allows Federal facilities to charge fees for hunting and fishing permits. These
funds then must be used for on-site fish and wildlife conservation programs.
E. Key Compliance Definitions
1. Action
All activities or programs of any kind authorized, funded, or carried out, in whole or in
part, by Federal agencies in the United States or upon the high seas. Examples include, but
are not limited to (50 CFR 402.02):
• Actions intended to conserve listed species or their habitat;
• The promulgation of regulations;
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• The granting of licenses, contracts, leases, easements, rights-of-way, permits, or
grants-in-aid, and
• Actions directly or indirectly causing modifications to the air, landscape, soil, sediment,
ground water, surface water, and/or the biota (including humans) and ecosystems affected
by impacts to the quality of physical environmental media.
2. Action Area
All areas to be affected directly or indirectly by the Federal action and not merely the
immediate area involved in the action (50 CFR 402.02).
3. Anadromous Fish
Species of finfish that spend much of their adult life or nonreproductive seasons thereof in
the marine environment but migrate inland to freshwater habitats during their respective
spawning seasons, where eggs are released/fertilized, embryos develop, and juvenile fish
spend up to several years maturing before migrating downstream to marine waters. Protection
and management of anadromous fish species (e.g., salmon, shad) are the responsibilities of
Federal agencies such as the United States Fish and Wildlife Service (DOI USFWS) and the
National Oceanic and Atmospheric Administration (NOAA). States may also have laws and
regulations designed to protect, manage, and regulate the sport and commercial harvesting of
such fish populations.
4. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe or
environmentally sound operating procedures.
5. Candidate Species
Any plant or animal species being considered by the Secretary of Interior (SOI) for Federal
listing as a rare, threatened, or endangered species under the ESA (50 CFR 404.02). This
term may also apply to candidates for state-listing under comparable state laws.
6. CERCLIS
The acronym for EPA's CERCLA information system, a comprehensive database and
management system that inventories and tracks releases addressed or needing to be addressed
by the Superfund program (40 CFR 300.5).
7. Compensatory Wetland Replication
A wetland impact mitigation method increasingly used at the Federal and state levels to
compensate for unavoidable losses of wetland habitats, wherein a new wetland as similar in
hydrology, soils, and vegetation to that lost is created, preferably within the same hydrologic
reach as the lost wetland. It should be noted, however, that this is a last resort when
avoidance of impacts is not possible, since wetland creation has proven effective and
successful, in most cases, only where relatively simple, herbaceous wetland plant communities
such as wet meadows, marshes, and shrub swamps are being created.
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8. Critical Habitat
Specific areas within the geographic area commonly occupied by a species that contain
features essential to the survival, reproductive success, and effective conservation of the
species and that may require special management considerations or protection. Specific areas
outside the currently occupied range of a rare, threatened, or endangered species may be
determined by the SOI as areas essential for the conservation of the species (50 CFR 424.02).
This term also may apply to critical habitat for state-listed species under comparable state
laws.
9. Decibel (dB)
A quantitative measure for sound. The zero on the decibel scale is based on the lowest
sound level that a healthy, unimpaired human ear can hear. Decibels are not linear but are
representative points on a sharply rising (exponential) curve
10. dBA
A scale for measuring sound levels in decibels, using the A-weighting network of a sound
level meter.
11. dBC
A scale for measuring sound levels in decibels, using the C-weighting network of a sound
level meter
12. Destruction or Adverse Modification
A direct or indirect alteration that appreciably diminishes the value of critical habitat for
both the survival and recovery of a listed species. Such alterations include, but are not limited
to, alterations adversely modifying any of those physical or biological features that were the
basis for determining the habitat to be critical (50 CFR 402.02).
13. Endangered Species
Any plant or animal species that is in danger of extinction throughout all or a significant
portion of its range (other than noxious weeds or a species of the Class Insecta determined to
constitute a pest). Federally listed endangered species are officially designated by the DOI (50
CFR 81.1). This term also may apply to state-listed species under comparable state laws.
14. Environmental Remediation
The active cleanup of environmental contamination in physical media, followed by
restoration of the damaged landscape, including its physical and/or biological components.
Remediation is planned/implemented on the basis of a comprehensive Remedial Investigation
(RI) and Feasibility Study (FS), conducted as under the requirements of CERCLA and/or
RCRA.
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15. Feasibility Study (FS)
A study undertaken by the lead agency, on the basis of data gathered during an RI and
related studies (e.g., ERA and HHRA), to develop and evaluate options for remedial action at
a contaminated site (40 CFR 300.5).
16. Finding of No Significant Impact (FONSI)
A NEPA document issued by the Federal agency leading a NEPA review that is based on
the results of an EA and that briefly presents the reasons why an action, not otherwise
excluded from an EIS under NEPA, does not require preparation of an EIS (40 CFR 1508.13).
17. Jeopardize the Continued Existence of
To engage in an action that reasonably would be expected, directly or indirectly, to reduce
appreciably the likelihood of both the survival and recovery of a listed species in the wild by
reducing the reproduction, numbers, or distribution of that species (50 CFR 402.02).
18. No Net Loss of Wetlands
The Federal goal and policy of preventing any net loss of wetland acreage, functions, or
values in the United States, in part, by avoiding or minimizing wetland impacts to the
maximum extent possible and choosing to mitigate wetland losses through compensatory
replication or creation of wetlands, as a last resort only when wetland impacts or losses are
unavoidable.
19. Notice of Intent (NOI)
A published notice from a Federal agency leading a NEPA review that an EIS will be
prepared. It must be published in the Federal Register and should contain (40 CFR 1508.22):
• A description of the proposed action and possible alternatives;
• The proposed public EIS scoping process and schedule; and
• The name and address of the person who can give more information.
20. Preliminary Assessment (PA)
A review of existing information, and an on-site and/or off-site reconnaissance if
appropriate, to determine if an environmental release of a contaminant may require additional
investigation or action. A PA may include an on-site reconnaissance if appropriate (40 CFR
300.5).
21. Remedial Design (RD)
Technical analysis and procedures following selection of a cleanup method for a
contaminated site, which results in a detailed set of plans and specifications for the remedial
action (e.g , at a CERCLA or RCRA site)(40 CFR 300.5).
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22. Remedial Investigation (RI)
A process undertaken by the lead agency to determine the nature and extent of the site's
environmental contamination problem presented by the release of a hazardous substance (40
CFR 300 5).
23. Threatened Species
Any species likely to become an endangered species within the foreseeable future
throughout all or a significant portion of its geographic distributional range. Federally listed
threatened species are officially designated by the DOI (50 CFR 81.21). This term also may
apply to state-listed species under comparable state laws.
F. Records to Review
• Administrative Records (CERCLA)
• Aerial site photographs
• Agricultural and Grazing Lease Contracts
• Coastal Zone Management Plans
• Dredging permits (Section 10 RHA)
• Ecological Risk Assessments (ERA)
• Endangered Species Management Plan
• Environmental Impact Documentation (e.g., NEPA documents)
• Federal/state lists of protected plant and animal species
• Fish and Wildlife Cooperative Agreements
• Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRM) to
identify the 100-year floodplain
• Forest and Vegetation Management Plans
• Grounds Maintenance Contracts
• Human Health Risk Assessments (HHRA)
• Land and surface water resource management plans
• Land use and site development master plans
• Memoranda of Agreement (MOA)
• National Wetlands Inventory (NWI) maps
• Natural Resource Damage Assessments (NRDA)
• Natural Resources Managemetn Plan (Facility)
• Natural Resources Heritage Programs to get listing of Endangered/Threatened species for
facility area (GIS maps with above data plotted for facility)
• NEPA Documents: EA, FONSI, EIS, Supplemental EIS
• Notices of Violations (NOVs) for'air/water emissions
• NPDES permit effluent limitations and effluent monitoring data
• Outdoor Recreation Cooperative Agreement
• Pollution Prevention Plans
• Remedial Investigation/Feasibility Study (RI/FS) reports
• Surface water quality monitoring results (compare to Federal/state AWQC)
• US Geological Survey (USGS) topographic maps
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• Wetland permits (Section 404 CWA and state permits)
• Heavy equipment/vehicle lay-down yards/parking lots.
G. Physical Features to Inspect
• Agricultural areas: croplands, livestock pens, and grazing pastures/lease areas (condition
and management)
• Construction, dredging, and excavation sites (landscaping and control of erosion, runoff,
and sedimentation)
• Critical habitats for protected species of flora/fauna
• Devices to prevent wildlife contact with hazardous materials
• Equipment that could damage wildlife, its habitat, or land and water resources (use and
control)
• Exposed soils and steep slopes (condition and erosion)
• Facilities constructed since passage of the CWA (spatial relationship to floodplains and
wetlands)
• Floodplains, associated rivers, dams, and levees
• Forest management areas (condition and management)
• Grounds maintenance areas (beautification and condition)
• Heavy equipment/vehicle lay-down yards/parking lots
• Pipeline, powerline, and sewerage corridors and facilities
• Pesticide application areas (impacts to nontarget species)
• Shorelines, coastal storm surge areas, and velocity zones
• Sites undergoing remedial action (impacts of remediation)
• Stormwater drainage areas and management systems (condition)
• Surface water bodies, water intakes, and pumping stations
• Terrestrial wildlife habitats (condition and management)
• Training (e.g., firefighting and spill response) sites
• Vegetated wetland ecosystems
• Vegetation control areas (impacts to nontarget species)
• Waste disposal, transfer, and/or storage facilities
• Wastewater biological treatment facilities (including wetlands)
• Wildlife containment areas (condition and management)
• Wildlife hunting areas, preserves, and sanctuaries.
Phase 1 - Section 7
Management of Environmental Impacts
7-26
-------
H. Guidance for Checklist Users
Refer To
Checklist items
Page Nvntbers
All Facilities
IMP.l through IMP 3
7-29
Noise
IMP 4
7-29
IMP 5 through IMP 6
7-30
Pollution Prevention
IMP 7 through IMP 8
7-30
Exotic Organisms
IMP.9
7-30
Off-Road Vehicles
IMP 10
7-31
NEPA Compliance
IMP 11 through IMP 13
7-31
IMP. 14 through IMP. 15
7-32
IMP 16 through IMP 17
7-33
IMP. 18 through IMP 20
7-34
IMP 21 through IMP 23
7-35
Ecological Assessment and Monitoring
IMP 24
7-35
IMP 25 through IMP 26
7-36
IMP 27
7-37
IMP 28
7-38
IMP.29 through IMP 30
7-39
IMP 31
7-40
Soil and Sediment
IMP 32
7-41
IMP 33
7-42
Phase 1 - Section 7
Management of Environmental Impacts
7-27
-------
Refer To
Checklist Items
; PageNumbm
Vegetation
IMP 34
IMP 35
7-42
7-43
Wildlife
IMP 36 through IMP.37
IMP 38 through IMP.40
7-44
7-45
Aquatic Biota
IMP.41 through IMP.43
7-46
Endangered Species
IMP 44
IMP.45 through IMP 46
7-47
7-48
Floodplains and Wetlands
IMP 47
IMP 48 through IMP 49
IMP 50 through IMP.52
7-49
7-50
7-51
Agricultural Resources
IMP.53
IMP 54 through IMP.56
7-51
7-52
Coastal Resources
IMP.57
IMP 58 through IMP 59
7-52
7-53
Wild and Scenic Rivers
IMP 60
7-53
Phase 1 - Section 7
Management of Environmental Impacts
7-28
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CotoiMlMws Category:
Management of Environmental Impacts
Regulatory Requirements:
Reviewer Checks*.
All Facilities
IMP 1 Review the current
status of any ongoing or
unresolved Consent Orders,
Compliance Agreements,
Notices of Violation (NOV),
Interagency Agreements, or
equivalent state enforcement
actions. (A finding under this
checklist item will have the
enforcement action/identifying
information as the citation )
Determine if noncompliance issues, pertaining to any of the following compliance or
resource categories, have been resolved by reviewing a copy of the previous report,
Consent Orders, Compliance Agreements, NOVs, Interagency agreements or
equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
IMP 2 Facilities are required
to comply with all applicable
Federal regulatory requirements
not contained in this checklist.
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding, unless it is a best
management practice.)
Determine if any new regulations have been issued since the finalization of the guide.
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities that are federally regulated but not
addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations.
IMP.3. All facilities are
required to abide by state and
local regulations concerning
prevention of pollution impacts
to natural resources (EO 12088,
Sect 1-1,16 USC 1531(c)).
Verify that the facility is abiding by state and local requirements pertaining to the
natural resources addressed below under IMP 4 through IMP 12
Verify that the facility is operating according to impact prevention, mitigation, and
monitoring conditions of permits issued by state or local agencies
Noise
IMP.4 Facilities are required
to abide by Federal, state and
local regulations concerning
environmental noise (EO
12088, Sect 1-1, 42 USC
4901-4918)
Verify that the facility is abiding by Federal, state, and local noise control
requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE: Issues typically regulated by state and local agencies include'
Construction noise
Shooting/firing range noise
Motor vehicle noise )
Phase 1 - Section 7
Management of Environmental Impacts
7-29
-------
Compliance Category:
Management of Environmefetat Impacts
Regulatory Requirements;
Reviewer Chectt#
IMP 5 Airport facilities must
document and manage noise
impacts as required by the
Aviation Safety and Noise
Abatement Act (PL 96-193)
Verify that the facility has submitted a noise exposure map and noise compatibility
program to the Secretary of Transportation
Verify that the exposure map and compatibility program are revised and updated, as
needed, to keep pace with local land use changes.
IMP 6 A single facility Point
Of Contact (POC) should be
identified for noise complaints
(MP).
If the facility has activities that produce noise that would potentially disturb people
outside the property lines, verify that a POC has been identified and is accessible to
concerned parties
Verify that the POC keeps a log of complaints
Pollution Prevention
IMP.7. All Federal facilities
are required to abide by state
and local regulations
concerning pollution prevention
(EO 12088, Sect. 1-1)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies.
(NOTE. Issues typically regulated by state and local agencies include
Pollution prevention plans
Effluent and emissions monitoring
Hazardous material use reduction )
IMP 8. Facilities are required
to prepare Pollution Prevention
Plans by 31 December 1995
(EO 12856, Sect 3-302(d))
Verify that the facility is in the process of preparing a Pollution Prevention Plan that
outlines what the facility is going to do to minimize pollution.
(NOTE: Coordinate with the auditor assigned to the Emergency Planning and
Community Right-to-Know checklist.)
Exotic Organisms
IMP.9. Executive Order 11987,
Exotic Organisms, requires
executive agencies to restrict
the introduction of exotic
species into natural ecosystems
they own or lease and to
encourage the states to prevent
such introductions (EO 11987).
Determine whether the agency/facility has an active program to monitor and prevent
the introduction of exotic plant and animal species into natural ecosystems on Federal
lands
Verify that, if appropriate, the facility/agency cooperates with appropriate state/local
authorities to eradicate, as needed, and to prevent or minimize the further colonization
of unaffected ecosystems by exotic organisms found on Federal lands
Off-Road Vehicles
Phase 1 - Section 7
Management of Environmental Impacts
7-30
-------
Compliance Category:
Management of Enviro&meatat
Regulator Requiret&eetst
Hfivitwtr Cfeetfcit
IMP 10 Executive Order
11989, Use of Off-Road
Vehicles (ORVs) on the Public
Lands, specifies that ORVs may
not be used without special use
and location designation (EO
11989)
Verify that the facility has an appropriate program to control, manage, and issue
permits for the use of ORVs on Federal lands,that adequately identifies and protects
environmentally sensitive areas, ecosystems, habitats, and their resident biota
NEPA Compliance
IMP 11 The NEPA process
must be integrated into
planning for projects at the
facility as early as possible to
prevent delays in project
implementation (40 CFR
1501 1, 1501 2)
Verify that the NEPA process is routinely integrated as a part of new project planning
and development to assure that potentially significant impact issues are identified as
early as possible
Verify that early cooperative consultation among agencies is also a part of new project
development
Verify that the facility identifies environmental effects and values in adequate detail
for the comparison with economic benefits and other technical analyses
Verify that the facility develops and describes appropriate alternatives to
recommended actions in any proposal that involves unresolved conflicts concerning
alternative uses of available resources
IMP 12 An Environmental
Assessment (EA) must be
produced, under certain
circumstances, to determine if
an Environmental Impact
Statement (EIS) is necessary
(40 CFR 1501 1(b) and
1508 9)
Determine if an EA has been completed and submitted for review by the lead Federal
agency before any contract for action is entered into or action is begun unless
The action normally requires an EIS
Normally does not require either an EIS or a CX (a categorical exclusion)
Verify that the assessment was prepared according to agency policies
(NOTE 40 CFR 1501 3 requires Federal agencies to adopt procedures to indicate
when an EA is required to be done Review agency-specific NEPA implementing
regulations.)
IMP 13 A facility must
produce an EIS if certain
conditions exist due to a
proposed action (40 CFR
1501 4(a), 1501 4(c), and
1502 4)
Verify that the facility produces an EIS for any activity that normally required an EIS
including-
The adoption of new agency policies, programs, or regulations
Issuance of a Federal permit
Technological developments
Provision of Federal funding for a non-government project
Broad agency actions
Based on the EA, it is deemed necessary by the lead agency
(NOTE Federal Agencies are required to develop policies indicating what types of
actions require an EIS )
Phase 1 - Section 7
Management of Environmental Impacts
7-31
-------
CoaipiiaiH# Category:
jManagexuettf of Envirotttaebtal Impacts
Regulatory Rfajairaneate;
IMP. 14. If, because of the
results of an EA, an EIS is not
going to be prepared, a Finding
of No Significant Impact
(FONSI) must be prepared
according to specific
parameters (40 CFR 1501.4(e)
and 1508 13)
Verify that FONSIs include the following information
The name of the action
A brief description of the action (including any alternatives considered)
A short discussion of anticipated environmental effects
The conclusions that have led to the FONSI.
Verify that, in general, the FONSI is made available for public review
Verify that the FONSI is made available for public review for 30 days, prior to
making a final determination whether to prepare an EIS and before the action begins,
when-
The proposed action is, or is closely similar to, one which normally requires the
preparation of an EIS by the lead agency
The nature of the proposed action is without precedence
IMP 15 When two or more
Agencies propose or are
involved in the same action or
in a group of actions directly
related to each other because of
their functional
interdependences or
geographical proximity, a lead
agency will supervise the
preparation of the EIS (40 CFR
1501 5 and 1501.6)
If the facility is involved in an EIS that includes actions of agencies other than their
own, determine who the lead agency is.
(NOTE: Federal, state, or local agencies, including at least one Federal agency, may
act as joint lead agencies to prepare an EIS)
Verify that a letter or memorandum of agreement indicates which agency is the lead
Federal agency and which are the cooperating agencies
Verify that, if the facility is operated by the lead agency, it
Requests the participation of each cooperating agency in the NEPA process at the
earliest possible time
Uses the environmental analysis and proposals of cooperating agencies with
jurisdiction by law or special expertise to the maximum extent possible consistent
with its responsibility as lead agency
Meets with a cooperating agency at the cooperating agency's request
Phase 1 - Section 7
Management of Environmental Impacts
7-32
-------
Compliance Category:
Maoageraenf of Ettvir«»tn
-------
Compliance Category:
Management ofEttviroamental Impacts
Regulatory Requirements:
Reviewer Checks:
IMP 18 Public involvement is
a required part of the EIS
process (40 CFR 1506 6)
Verify that the facility (and/or lead agency) made a diligent effort to involve the
public including
Providing public notice of NEPA-related hearings, public meetings, and the
availability of environmental documentation such as
mailing of notices to those who have requested it on an individual action
notice in the Federal Register and mailings to national organizations
reasonably expected to be interested if the action is of national concern
notice to the state, local Indian tribes, local newspapers, and other local
media if the action is of local concern
Holding or sponsoring public meetings in response to
substantial environmental controversy or substantial interest in holding the
meeting
a request for a hearing by another agency with jurisdiction over the action
supported by reasons the hearing would be helpful
soliciting appropriate information from the public
explanations of where individuals can get information or status reports
IMP 19 After the preparation
of the draft EIS, the facility is
required to obtain and request
comments from specific
individuals (40 CFR 1502 19,
1503 1).
Verify that prior to preparing the final EIS, the facility obtained the comments of any
Federal agency with jurisdiction by law or special expertise with respect to any
environmental impact involved or that is authorized to develop and enforce
environmental standards
Verify that prior to preparing the final EIS, comments were requested from the
following
Appropriate state and local agencies that are authorized to develop and enforce
environmental standards
Indian tribes, when the effects may be on a reservation
Any agency that has requested statements on actions of the kind proposed
Verify that comments were requested from the applicant, if any
Verify that comments were requested from the public
IMP.20 When preparing the
final EIS, specific actions are
required (40 CFR 1503 4)
Verify that when preparing the final EIS, all comments are assessed, considered, and
responded to in one of the following ways
The alternatives are modified, including the proposed action
Alternatives not previously given serious consideration by the agency are
developed and evaluated
The analysis is supplemented, improved, or modified
An explanation is provided as to why the comments do not warrant further
agency response
Verify that all substantive comments received on the draft (or a summary of the
comments) are attached to the final statement whether or not the comments are
thought to merit individual discussion
Phase 1 - Section 7
Management of Environmental Impacts
7-34
-------
Compliance Category:
Mattagemetti aflttvirottme&tallrajxicta
Regulatory Requiraneot*:
Reviewer Ousels
IMP 21 Under certain
circumstances, supplements to
the draft or final EIS must be
prepared (40 CFR 1502 9(c)(1)
and 1502 9(c)(4))
Verify that a supplement is prepared if one of the following occurs
The facility makes substantial changes in the proposed action that are relevant to
environmental concern
There are significant new circumstances or information relevant to environmental
concerns and bearing on the proposed action or its impact
Verify that the supplement is prepared, circulated, and filed in the same way as a draft
and final statement unless alternate procedures have been approved by the CEQ
IMP 22 At the time of a
decision, facilities are required
to prepare a concise public
record of decision (ROD) (40
CFR 1505 2)
Verify that the ROD states what the decision was and
Identifies all alternatives considered in reaching the decision, specifying the
alternative or alternatives considered to be environmentally preferable
Includes a statement as to whether all practicable means to avoid or minimize
environmental harm from the alternative selected have been adopted and, if not,
why not
IMP 23 When implementing
the decision, the facility must
meet specific requirements (40
CFR 1505 3)
Verify that mitigation and other conditions established in the EIS or during its review
and committed to be the facility/agency as a part of the decision are implemented
Verify that appropriate conditions are included in grants, permits, or other approvals
Verify that funding is based on agreed-to implementation of mitigation
Verify that results of relevant impact monitoring are made available upon request.
Ecological Assessment and Monitoring
IMP 24 A remedial site
evaluation consists of a
remedial preliminary
assessment (PA) and a remedial
Site Inspection (SI) (40 CFR
300 420) (Seethe
CERCLA/SARA checklist)
Verify that the remedial PA includes the following
A review of existing information about potential impacts from a release, such as
information on the pathways of exposure, exposure targets, and source
On-site and off-site reconnaissance of environmental impacts and stress
symptoms, as appropriate.
Phase 1 - Section 7
Management of Environmental Impacts
7-35
-------
Compliance Category:
Maaagewetrt oflnviro&mefttai Impacts
Regulatory Requlrem^ats;
Reviewer Checks;
IMP 25. Environmental risk
assessments may be required as
part of a remedial investigation
(RJ) or other CERCLA
compliance activity. (See the
CERCLA/SARA checklist.)
Verify that if natural resources are or may be injured by the release of oil or another
hazardous material, state and Federal trustees of the property are notified, and the
need for an ecological risk assessment (ERA) and/or natural resource damage
assessment (NRDA) has been determined.
Verify that data on the extent of facility-derived chemical and radionuclide
contamination in physical and biological media, generated by facility environmental
surveillance programs, are incorporated into baseline assessments of environmental
risks to ecological receptors.
Prior to an RI/FS or Engineering Evaluation and Cost Analysis (EE/CA), verify that
the site has identified whether there will be impacts on natural resources and has also
notified the appropriate trustees of the potential natural resource impacts (Executive
Order 12580; CERCLA Sections 104(b) and 122(j»
Concurrent with notification of the resource trustees (pursuant to CERCLA and
CWA), verify that the site has sought to coordinate plans, NRDA studies, or cleanup
activities with the trustees
Determine if a baseline ERA was performed prior to remedial action and if any
subsequent remedial action that has been completed resulted in residual ecological
risk on- or off-site
IMP 26 As a management
practice (MP), the facility
should have in place an
environmental monitoring
program that includes
biological surveillance as well
as chemical and/or radiological
surveillance of physical and
biological media to document
facility impacts to the
environment (MP) (NOTE.
This Department of Energy
policy requirement (DOE
Orders 5400 1 and 5400.5) is
treated by DOE as if it were a
regulation At a minimum,
such monitoring should be
considered as an MP for all
agencies)
Confirm that the facility uses the baseline ecological resource inventories of facility-
specific NEPA documents and/or ERAs to design customized, facility-specific
programs for the monitoring, protection, and management of biological diversity and
natural ecosystems.
If there is soil erosion and/or contamination migration to natural waterways, confirm
that there is a system in place for sampling of media and analyzing the concentrations
of the contaminants in the soil, sediment, and/or surface waters of waterways and
associated wetlands
Phase 1 - Section 7
Management of Environmental Impacts
7-36
-------
Compliance Category:
Maoageraetrt of Environmental Impacts
Regulatory Requfrettieats;
Reviewer Chctbi
IMP 27 Facility-specific
Federal and/or state permits
may require integrated physical,
chemical, radiological, and
biological monitoring to
document ecological impacts of
facility emissions or effluent
(See the following checklists
Air Pollution Control, Water
Pollution Control,
CERCLA/SARA, Spill Control
and Response, and
Environmental Radiation)
Determine if biological monitoring programs are being conducted as required by any
state or local regulations or by an operating air emission or effluent discharge permit
(e.g, PSD or NPDES permit) for the operation of the facility
If aquatic biological monitoring is required by an NPDES or other permit, confer with
the Surface Water (SW) specialist to confirm that
The permit has been renewed as required
Monitoring report specifications and deadlines have been met (during the audit
period)
Biological monitoring parameters are changed only in accordance with the permit
specifications
All biological monitoring program changes approved by the permitting authority
have been implemented
Review facility aquatic biological monitoring records/reports, verify compliance with
permit conditions, and obtain input from the water pollution specialist regarding the
seasonal timing (breeding, season?), pollutant types, intensity, and duration of
thermal/chemical effluent exceedances during the audit period If exceedances have
occurred
Based on AWQC and ambient water quality monitoring results, determine if the
duration and intensity of emissions were potentially toxic and/or lethal for the
exposed aquatic species and, if so, if any correlative evidence of invertebrate,
shellfish, or fish stress/death in the potential impact areas was observed and
recorded
Determine if any habitat restoration measures were required and/or taken
following facility-induced death of fish/shellfish/invertebrates
Verify that biological monitoring requirements of CWA Section 401 (state water
quality certification) and CWA Section 404 (dredge and fill) permits under the Clean
Water Act are being met
Phase 1 - Section 7
Management of Environmental Impacts
7-37
-------
Compliance Category:
Management ofEnvjronmental Impacts
Regulatory Requirements;
Reviewer Checks:
IMP 28 Monitoring of
environmental impacts and risks
from radionuclide releases must
include considerations of
ecological, food chain, and
human health effects, including
contamination of agricultural
and aquatic foodstuffs (40 CFR
190 10, 10 CFR 834)
If liquid process waste streams containing radioactive material in the form of
settleable solids are being released into natural waterways from any of the site's
facilities, verify that the site routinely tests sediments and associated native aquatic
organisms for radioactive contamination
If soil, sediment, surface water, and/or biota surveillance programs are conducted for
exposure to low-level wastes and radioactive material which may be released to
physical media or to cultivated plant and animal foods eaten by humans, verify that
facility-derived radionuclides do not cause an individual human to receive an overall
dose that exceeds an effective dose equivalent of
25 Millirems to the whole body
75 Millirems to the thyroid
25 Millirems to any other organ of the body
Determine if migratory or resident game animals that could have been exposed to
radionuclides (either directly or through ingestion of contaminated foods) and that are
or could be hunted for human consumption are being tested or analyzed for levels of
radionuclides acceptable for human consumption
Phase 1 - Section 7
Management of Environmental Impacts
7-38
-------
Compliance Category:
Management ofEnvirottmentailrajmcts
Regulatory Requirements:
Reviewer Checks:
IMP 29 Facility-specific
environmental monitoring
programs should be
sophisticated enough to permit
reliable assessments of on-site
and downstream contaminant-
specific impacts/risks to human
populations and sensitive
ecological receptors (MP)
Determine if the facility's integrated monitoring program for effluent, ambient surface
water quality and aquatic biota
Is mandatory or voluntary
Includes all permit-specified water quality parameters and seasonal sampling
requirements
Applies standardized biological monitoring and stress detection protocols, using
field-compiled data sheets
Requires that documented exceedances of water quality thresholds be followed
up by inspections for fish kills and/or stress symptoms in local aquatic indicator
species
Includes routine sampling of surface water, sediments, and/or biota at coincident
points in time and space
If the answer to any of the above is no, document the reasons
Verify that sediment and surface water sampling locations and methods, analytical
methods, parameters, and detection limits are adequate to assess the ecotoxicological
effects of facility-derived contaminants on aquatic biota and food chains through
comparisons of ambient contaminant levels with ecologically protective, Federal and
state Ambient Water Quality Criteria (AWQC) and sediment quality guidelines (e.g ,
NOAA)
Confirm that the facility monitors the levels of site-derived inorganic and organic
compounds in surface waters against the state and Federal AWQC designed to protect
freshwater and marine, aquatic organisms, and humans that consume these aquatic
biota
Verify that the facility adequately monitors its impacts to protected biota and their
habitats, such as threatened and endangered species of flora and fauna, anadromous
fish, migratory birds, marine mammals, floodplains, wetlands, and marine sanctuaries
Obtain and review data from environmental monitoring programs and determine if
they are adequate for use in, and if the site performs, ecological impact and risk
assessments for accidental or other nonroutine releases of contaminants into air, soil,
sediment, and/or surface water
IMP 30 Commitments made in
NEPA documents may liidude
facility monitoring of actual
(versus predicted)
environmental impacts and/or
the effectiveness of agreed-to
impact mitigation measures
(MP)
Determine if impact assessment models and impact projections, presented in facility
NEPA documents, have been verified by monitoring data from receptor locations for
facility-related
Air pollutant dispersion patterns
Dry and wet atmospheric deposition patterns
Aqueous/thermal effluent dilution/mixing patterns
Impacts on air/water quality and biota/ecosystems
Phase 1 - Section 7
Management of Environmental Impacts
7-39
-------
Compliance Category:
Management of Environmental Impacts
Regulatory Requirements;
Reviewer Checks;
IMP.31 As an MP and/or
regulatory requirement, water-
dependent facilities/activities
and facilities potentially
affecting aquatic ecosystems
should proactively manage and
minimize effects on local fish
and shellfish resources (CWA,
CZMA, MPSRA) (MP)
Determine if the facility has a fisheries management and/or monitoring program and
if
It is voluntary or required by specific permit conditions
Start-up and seasonal, operational data exist on fish impingement for facility
water intakes
Fish impingement monitoring is required and/or conducted for surface water
intake structures
Monthly/seasonal fish impingement data are up to date If so, review them for
this audit period
The facility routinely monitors contaminant bioaccumulation in aquatic indicator
organisms, especially aquatic foodstuffs (10 CFR 834)
Prohibitions of fishing and shellfish harvesting are clearly posted in contaminated
and/or restricted areas
The facility records and adequately documents full compliance with these permit
conditions
Any biocides used, such as those for corrosion prevention, are discharged into
surface waters
Nonimpingement fish kills, either in or downstream of receiving waters, have
been observed, documented, and reported to appropriate authorities (e g,
trustees) during the audit period
Any prescribed fisheries mitigation plan/program has been implemented during
or since construction of the facility
All required fish diversionary structures were properly constructed and
maintained to satisfy mitigation commitments made in NEPA documents and/or
specific permit requirements for water-dependent facilities
Phase 1 - Section 7
Management of Environmental Impacts
7-40
-------
Compliance Category:
Management ^Environmental Impute
Regulatory Requiremeots:
Reviewer Checks:
Soil and Sediment
IMP 32 Soil and sediment
inventory and monitoring
activities are often based on the
requirements of NEPA, other
Federal statutes regulating spills
and disposal of radioactive
materials and toxic chemicals,
and environmental monitoring
and biological surveillance MPs
for soil and sediment resources
(MP)
Tour the facility and interview key personnel to
Verify that suitable erosion and sediment control practices are used on land
undergoing clearing, grading, or other development activities to ensure that these
activities will not adversely affect adjacent floodplains, wetlands, or surface
waters
Verify that a protective vegetative cover or other measures are used to conserve
soils, minimize dust-induced damages to air quality, prevent erosion-mediated
contaminant migration off site, and/or preclude siltation damages to aquatic
ecological receptors
Confirm that the use of soil columns to retain and attenuate radioactive
contaminants contained in facility effluent has been and/or is being discontinued,
in accordance with pertinent agency regulations and/or policies (e g , DOE Order
5400 5, 10CFR 834)
Observe and assure that the facility's environmental monitoring program includes soil
and sediment sampling locations in all areas potentially affected by atmospheric
deposition, discharges of contaminated ground water (seeps), and/or facility effluent
to surface water resources (NOTE Coordinate review with appropriate specialists)
Review disposal practices and interview personnel to verify that land-farming and/or
soil-injection methods used for disposal of sludges, pesticides, radionuclides, and
other wastes are conducted in compliance with applicable Federal and state
regulations (e g, 40 CFR 168 8 and 257)
Phase 1 - Section 7
Management of Environmental Impacts
7-41
-------
Compliance Category:
Mawgeraent oflnviroamental lwpa<*s
Regulatory Jtequirttttttste;
Reviewer Chectwt
IMP 33 Site remediation of
soil and/or sediment
contamination should conform
to Federal, state, and/or site-
specific risk-based cleanup
goals/standards for specific
contaminants (40 CFR 192 12,
40 CFR 257; 40 CFR 257 3-
257.5)
Review the cleanup criteria established for chemical and/or radiological contaminants
in soils and sediments to confirm that'
Applicable Federal and/or state cleanup goals are met
Where no regulatory criteria exist, site-specific cleanup goals are based on
contaminant-specific human health or ecological risks
Attainment of the selected cleanup goals will ensure that any residual soil or
sediment contamination following cleanup will pose no significant human health
or ecological risk
Verify that the facility conducts remedial actions to provide reasonable assurance that
the concentration of radium-226 in land averaged over any area of 100 square meters
does not exceed the background level by more than
5 pCi/g averaged over the first 15 cm of soil below the surface
15 pCi/g averaged over the first 15 cm thick layers of soil below the surface
Verify that the facility conducts remedial actions to ensure that any occupied or
habitable buildings are made
To have a radon decay product concentration (including background) not to
exceed 0 02 WL
To have gamma radiation levels below 20 microentgens per hour
In accordance with any state-specific cleanup criteria.
For areas with solid or sewage wastes deposited from 0-1 m depth, confirm that
testing of soil-waste mix indicated a pH greater than or equal to 6 5 and
concentrations of cadmium below 2 mg/kg (dry weight)
Determine, through interviews and documentation review, if soils are routinely
sampled and analyzed from those lands used for grazing by dairy animals on which
solid or sewage wastes are being disposed from 0-1 m depth
Vegetation
IMP 34 Noxious weeds, listed
in Appendix 7-1, must not be
moved through the United
States unless the movement is
allowed by a permit (7 CFR
360 100 through 360.300)
Verify that the facility is not moving noxious weeds without a permit
Phase 1 - Section 7
Management of Environmental Impacts
7-42
-------
Compliance Category:
ofBttvirotttnentai Impacts
Regulatory Requirements;
Jteviewer Checks:
IMP 35 As an MP, facility
activities should be conducted
so as to minimize and mitigate,
as needed, damages to
vegetation (MP)
If any obvious (visible) vegetative stresses or deaths, either on-site or
downwind/downstream of the facility, occurred since construction or during the
current audit period, determine if
It had been accurately predicted in the facility-specific NEPA documents (EA,
EIS)
Mitigation of such impacts was required and has been provided per commitments
made in NEPA documents
It can be attributed to normal atmospheric emissions or aqueous effluent from the
facility
It is spatially and temporally related to air emission and/or effluent discharge
(NPDES) permit exceedances (confer with air and water pollution specialists)
It was caused by accidents, process upsets, chemical spills, or other unintentional
or nonroutme releases
It occurred to nontargeted plant species, as a result of improper facility-related
herbicide applications to noxious weeds
Critical habitat of protected species or other protected plant communities (e g ,
wetlands) were adversely affected
Any obvious vegetative stress/death was documented by means of color
photographs, field notes, specimen collection, and recorded information in
working papers
If wetland vegetation is damaged, determine if its restoration is mandated by a Section
404 (CWA) dredge and fill permit, and/or state and local wetland permits, and verify
that all regulatory restoration requirements have been satisfied under such permits
If terrestrial reclamation/restoration is performed following facility-induced damages,
review the program and determine if
It is mandatory or voluntary (permit or policy)
Permits or agency policy specifies the ecological objectives and success criteria
for restoration
Past reclamation results indicate that the techniques used adequately restored
baseline biological communities and ecological functions
Native species are planted or simply allowed to recolonize areas by natural
processes
Seeded plant species of the restored community are similar to the composition
and dominance patterns of the original habitat
Several experimental reclamation methods were used in similar habitats and, if
so, which most successfully recreated the baseline floristic characteristics
Installed plantings have survived, are healthy, and are being properly watered/
maintained
Phase 1 - Section 7
Management of Environmental Impacts
7-43
-------
^ ^ A-
IibjUMts -
Wildlife
IMP.36 Individuals may not
take, possess, import, export,
transport, sell, purchase, barter,
or offer for sale, purchase, or
barter any migratory bird, or the
parts, nests, or eggs without a
permit (50 CFR 21 11 through
21 50)
Determine if the facility is located along a bird migratory route
Verily that prior to killing birds for any reason, it is determined if they are migratory
birds
Verify that if actions are taken that affect migratory birds, the facility has Federal
and/or state approvals/permits to do so
(NOTE Exemptions from the permit requirement are available for mallard ducks and
other migratory waterfowl species, if they have been captive-reared and are properly
marked)
Determine if adequate measures are taken to protect migratory birds and their habitats,
such as waterfowl using floodplain and wetland areas, from poisoning and/or hunting
on Federal property, pursuant to NEPA, FWCA, the Migratory Bird Treaty Act of
1918, and international treaties such as the Ramsar Convention of 1971
Confirm that the facilities have not destroyed any wildlife or bird habitat and/or
obstructed migratory routes, without providing compensatory mitigation (e g , habitat
replacement) for such impacts (33 CFR 230.15 and 50 CFR 1505 2-1505 3)
IMP 37 Although legal
protection is afforded mostly to
wildlife that qualify as Federal
and state trustee resources (e.g.,
endangered species, marine
mammals, and migratory birds),
as an MP, facilities should
proactively manage wildlife
populations and their habitat to
comply with the intent of laws
such as NEPA, FWCA, and the
Sikes Act (MP)
Confirm that land, water resource, vegetation, and pest management plans and
operations are consistent with modern conservation and land use principles, provide
measures for the conservation of biological diversity, and minimize adverse effects on
biota and ecosystems from the use of pesticides
Confirm that all pesticide use by the facility complies with Federal and state laws and
regulations (See the Pesticide Management checklist)
From interviews, verify that the facility carefully monitors on-site recreation, hunting,
trapping, and fishing in natural habitats in accordance with.
Regulations for recreation on public lands (43 CFR Subchapter H)
Rules implementing the Fish and Wildlife Conservation Act of 1980 (50 CFR 83)
Applicable state regulations
Also note whether such restrictions are posted in potential hunting/fishing areas
Phase 1 - Section 7
Management of Environmental Impacts
7-44
-------
Compliance Category:
Management aflnviro&meiatal Impacts
Regulatory Requirements:
Reviewer Checks;
IMP 38 Assessment and
mitigation of facility impacts to
wildlife populations, as
proposed in NEPA documents,
should be based on accurate
data on local occurrences of
resident and migratory wildlife
populations (33 CFR230 13
and 230 15; 50 CFR 1505 2-
1505 3)
Determine if preconstruction, baseline shorebird, waterfowl, and mammal migratory
behaviors, patterns, routes, and seasons were documented as part of a NEPA review or
other environmental impact analysis
Determine if any compensatory mitigation has been provided for loss of wildlife
habitat
Verify that the facility's presence and/or activities do not disrupt or inhibit any of the
following
Wildlife access to and use of critical habitat
Bird or mammal migration
Nesting and breeding of migratory birds
Breeding of terrestrial or marine mammals
Feeding behavior of birds and other wildlife
Verify that the facility has sufficient ecological documentation with which to answer
such questions about impacts to wildlife
IMP.39. As an MP, each
Federal facility located in a
rural setting and/or inhabited by
wildlife should have a wildlife
management program designed
on the basis of data contained in
NEPA or other facility-specific
environmental documents
Verify that the facility has a wildlife management program and, if so, that it
Protects rare/endangered wildlife species and their local habitat (50 CFR 450 and
424)
Includes and follows procedures to maintain up-to-date records for timely
reporting of wildlife losses due to facility operations and/or related vehicular
traffic (e g , road kills)
Ensures that legal and/or agency-specific policy restrictions on hunting are
advertised locally, posted on site, and enforced by facility security and/or
appropriate government authorities
Includes any required habitat creation/enhancement or wildlife restocking
programs
Verify that the facility's wildlife management program includes preventive measures
(e.g , physical enclosures, netting) to protect wildlife from exposure to hazardous
material releases, storage areas, and contaminated surface water impoundments
IMP.40 All damages to
wildlife from releases of and/or
exposures to oil and other
hazardous materials should be
documented and reported to
appropriate Federal/state/local
agencies and/or resource
trustees (BMP, CERCLA;
CWA)
Determine if there have been any hazardous material releases or incidents resulting in
obvious, direct damages to wildlife. (See the Water Pollution Control and
CERCLA/SARA checklists)
Determine if such incidents have been recorded, reported to pertinent authorities,
documented in an NRDA, and/or mitigated to compensate for on-site and/or off-site
damages to wildlife species and/or their habitats (43 CFR 11) (See the Water
Pollution Control and CERCLA/SARA checklists )
Phase 1 - Section 7
Management of Environmental Impacts
7-45
-------
Compliance Category:
Management of Environ mental Impacts
Regulatory Requirements:
Reviewer Cheeks
Aquatic Biota
IMP 41 Federal (e g, CWA,
CERCLA) and state laws may
protect aquatic biota, both
directly (e g, trustee resources)
and/or indirectly, by protecting
aquatic or wetland habitats and
regulating facility impacts to
the chemical and radiological
quality of the sediments and
surface waters found within
these habitats Protection of
aquatic biota includes
compliance with regulatory
requirements and/or adherence
to MPs (MP)
Determine if invertebrates, fish, and shellfish resources, as well as spawning and
nursery areas, in impact areas were mapped and inventoried as part of a baseline site
characterization in facility NEPA documents (40 CFR 6)
Determine if the operation and/or maintenance of the facility has resulted in any new
obstructions to natural fish movement and/or deposits of deleterious materials into fish
habitat (CWA) and if
Water circulation, maintenance, dredging, and/or soil erosion resulted in silt
deposits to finfish or shellfish habitat
Uncontrolled releases of pollutants into fish habitats have occurred via spills,
storm water, cooling water, or wastewater discharges from the facility or its
infrastructure
Fish kills have resulted from such releases
Water intake structures are equipped with fish exclusionary/bypass devices
Fish losses resulting from impingement on intake screening are routinely
recorded/reported to appropriate agencies
Appropriate regulatory authorities have been notified of any such releases in
compliance with NPDES facility permits
NRDA reports have been prepared to document damages to aquatic biota that are
trustee resources
Remedial/restorative measures been required, approved, and/or implemented for
such deposits into fish habitat
IMP 42 Sediment and water
quality monitoring programs
may be required by facility
permits to help assess impacts
to aquatic biota and ecosystems
(MP)
Confer with the water pollution control and environmental radiation specialists to
verify that surface water and sediment sampling and analytical methods, especially
sample detection limits, are adequate to provide useable data on facility impacts to
sediment and surface water quality
Verify that analytical detection limits are low enough to assess media- and
contaminant-specific effects on and risks to benthic and pelagic biota by comparing
ambient contaminant levels with sediment quality guidelines and Federal/state
AWQC
IMP.43 The Marine Mammal
Protection Act (MMPA)
prohibits the illegal taking of
marine mammals, deliberate or
incidental, irrespective of
whether or not they are
protected under the Endangered
Species Act (16 USC 1361)
Verify that facility/agency NEPA reviews and other activities, such as maintenance
dredging in coastal waters, have documented the local presence and status of marine
mammal populations and have evaluated potential impacts of such activities to them
Determine if facility operations in the marine environment may have caused any
adverse effects to marine mammals
Evaluate whether environmental monitoring programs of coastal facilities are
adequate to assess potential facility effects on marine mammal populations.
Assess the adequacy of marine mammal impact prevention and mitigation programs
conducted by coastal facilities to comply with the provisions of the MMPA.
Phase 1 - Section 7
Management of Environmental Impacts
7-46
-------
Compliancy Category:
Mawtgeweat of Bnvjro&weftM Iwpacts
Regulatory Requirements;
; Reviewer Cfcecto:
Endangered Species
IMP 44 Federal protection of
plant and animal species
officially listed as endangered,
threatened, or rare, is afforded
primarily by the Endangered
Species Act (ESA) and related
provisions of Federal statutes
such as NEPA and the Fish and
Wildlife Coordination Act
(FWCA) Some states also
have endangered species laws
and independent lists of
protected species, many of
which may not appear in the
Federal lists (MP)
Compare baseline wildlife inventory of NEPA documents and monitoring records
against species listed as protected under the Endangered Species Act (50 CFR 17), as
needed, to determine if protected species inhabit the facility or its surroundings
If applicable, verify that the facility performed a Baseline Assessment of Threatened
and Endangered Species (BATES) and/or NEPA review for activities that may affect
federally listed endangered or threatened species occurring on site (NEPA, ESA)
Verify that any BATES was conducted in consultation with appropriate Federal
(USFWS or NMFS) and/or state agencies (e g , Natural Heritage Program), pursuant
to NEPA, ESA, and FWCA
Verify that the site conducts approved programs for the protection and management of
the species and their critical habitat (ESA, FWCA, and NEPA)
Verify that the facility consults state and Federal agencies annually to
Report on the status of protected species found on site
Obtain updated reports of new listings and/or local sightings of Federal- and
state-listed endangered and threatened species of flora and fauna
Select appropriate protected species for inclusion in the facility's biological
surveillance programs
If any rare or endangered wildlife species or aquatic organisms are known to inhabit
or feed at either the site or off-site facility impact areas, determine if
Appropriate Federal and state authorities (trustees) have been promptly notified
of their presence
Potential facility operational and/or long-term expansion impacts on these species
and their habitat have been fully evaluated as a basis for impact mitigation
programs
A protection and habitat management program has been developed and
implemented for these species in collaboration with appropriate wildlife experts
and regulatory authorities
Signs are posted to indicate locations of nesting sites and sensitive habitat, and
these areas are identified on site maps and appropriate site personnel are aware of
them
Verify that the facility conducts educational programs for site personnel regarding the
locations and sensitivities of endangered biota so as to prevent or minimize
operational impacts to these organisms
Phase 1 - Section 7
Management of Environmental Impacts
7-47
-------
Compliance Category:
Management of Environmental impacts
Regulatory Requirements:
Reviewer Checks
IMP 45 Facilities with
federally designated endangered
and threatened species must
carry out programs for their
conservation (50 CFR
402 01(a), 402 10, 402 12)
Verify that a survey has been to determine if the facility has any threatened or
endangered species and if so, that the conducted results are reflected in management
plans
Verify that consultations have been held with the US Fish and Wildlife Service
(USFWS), National Marine Fisheries Service (NMFS), and the appropriate state
conservation agency.
Verify that measures have been initiated to maintain threatened and endangered
species by checking records of USFWS and/or NMFS consultations/opinions
received
Verify that action was taken to comply with USFWS and/or NMFS requirements, if a
jeopardy biological opinion has been given
IMP 46 All facilities must
review proposed actions and
activities to ensure that they are
not likely to jeopardize the
continued existence of a listed
species or to destroy or
adversely modify its critical
habitat (50 CFR 402 01 (a) and
40 CFR 1500)
Verify that the following documents are considered in the review process
40 CFR 1500 through 1508, Council on Environmental Quality
50 CFR 17, Endangered and Threatened Wildlife and Plants
50 CFR 402, Interagency Cooperation-Endangered Species Act 1973, as amended
50 CFR 450, Endangered Species Exemption Process General Provisions
50 CFR 451, Endangered Species Exemption Process Application Procedures
Phase 1 - Section 7
Management of Environmental Impacts
7-48
-------
Compliance Category:
Management of Environ mental impacts
Regulatory Requirements:
Reviewer Checks:
Floodplains and Wetlands
IMP 47 Floodplain
management and wetland
protection by all Federal
agencies are mandated,
respectively, by Executive
Orders 11988 and 11990
Confirm that facility programs for floodplain management and wetlands protection
required by these EOs have been developed, in formal documents and following the
guidelines established
In accordance with criteria for land management and use (44 CFR 60, Subpart A)
In accordance with agency-specific floodplain management and wetlands
protection regulations and Federal policy
Determine if the facility's floodplain management program
Requires consultation with the COE about project siting, planning, and design
within floodplains (33 CFR 320)
Includes measures and standards to ensure no net loss of natural flood storage
capacity on or offsite
Identifies, evaluates, preserves, enhances, and/or restores the natural ecological
functions and beneficial societal values provided by floodplains
Prevents, whenever possible, building construction and other projects within
floodplains, so as to reduce human health and safety hazards from flooding
Requires consideration of project siting and/or design alternatives that avoid,
minimize, or mitigate adverse impacts to floodplain ecological functions and
values
Appears to have effectively minimized actual impacts from floods on human
health, safety, property, and welfare
Verify that any necessary structures built in the floodplain are in accordance with
criteria set forth in regulations promulgated by the Federal Insurance Administration
pursuant to the National Flood Insurance Act of 1968, as amended (33 CFR 208)
Verify that the agency/facility avoids undertaking or providing assistance for new
construction located in wetlands, unless the head of the agency finds that
There is no practical alternative to such construction, and
The proposed action includes all practical measures to minimize harm to wetlands
that may result from such use
Phase 1 - Section 7
Management of Environmental Impacts
7-49
-------
Compliance Category:
Matmgenttttf of £t»viroomental impacts
ftegtitotory Requirements;
Reviewer Check#
1MP.48 Dredge and fill
activities within "waters of the
United States," which include
wetlands, are regulated by the
US Army Corps of Engineers
(COE) pursuant to Section 404
of the CWA (33 CFR 323 3(a)
and 323 3(b)) (NOTE Fill
material means any material
used for the primary purpose of
replacing an aquatic area with
dry land or of changing the
bottom elevation of a water
body The term does not
include any pollutant
discharged into the water
primarily to dispose of waste,
that activity is regulated under
section 402 of the Clean Water
Act)
Confirm that the facility consults with the COE on use of the appropriate Federal
Wetlands Delineation Manual (WES Technical Report Y-87-1, January 1987) for the
delineation of wetlands based on soils, hydrology, and vegetation (58 FR 4995 (19
January 1993))
Verify that Section 10/404 permits (CWA) have been obtained from the COE for all
dredging and Filling activities and other work in waters of the United States, including
wetlands (33 CFR 320)
Verify that biological monitoring requirements of the facility's Section 10/404 dredge
and fill permits have been satisfied, such as studies to verify successful restoration
and/or compensatory replication of functional wetland habitats (33 CFR 320)
Verify that a wetland functional assessment, conducted during NEPA and/or CWA
Section 404 reviews, addresses the functional values of wetlands identified in the
404(b)(1) guidelines of the CWA (40 CFR 230) and forms the basis for the facility's
wetland impact assessment, mitigation and monitoring programs
IMP 49 In conjunction with
these EOs and the CWA,
Federal laws such as NEPA and
CERCLA protect wetlands and
floodplains, m part, by
requiring that NEPA reviews
and documents address and
provide mitigation for impacts
to wetlands, and CERCLA-
mandated investigations and
site remediation assess/ mitigate
contamination related impacts
and risks to wetlands and their
biota
Verify that all on-site wetland resources have been mapped and their ecological
features/functions described in NEPA documents, as a basis for facility-specific,
wetland impact assessment, mitigation, monitoring, and protection programs
Confirm that baseline ecological data contained in facility-specific NEPA documents
are used to develop site-specific, floodplain, and wetland management programs
needed to ensure the implementation of long-term impact mitigation measures
originally proposed in these same NEPA documents
Confirm that ecological risk assessments and natural resource damage assessments,
conducted by the facility under CERCLA and/or the CWA, have adequately addressed
risks and/or damages to wetland and floodplain ecosystems and their biota (43 CFR
11)
Phase 1 - Section 7
Management of Environmental Impacts
7-50
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Compliance Category:
MatttgenitJtf of lavirottMitotal impacts
Regulatory Requirements;
Reviewer Check*;
IMP 50 All agencies must
adhere to the Federal "no net
loss policy" for wetlands, as set
forth in a 1990 Memorandum of
Agreement between the EPA
and the COE The policy
requires that the COE "strive to
avoid adverse impacts to
existing aquatic resources, and
for wetlands, will strive to
achieve a goal of no overall net
loss of values and functions "
Verify that the facility systematically identifies, preserves, and manages the fish and
wildlife habitat value and the other beneficial ecological functions of wetlands, as
outlined in EPA's Section 404(b)(1) guidelines (33 CFR 320, 44 CFR 60)
Verify that the facility/agency avoids impacts to or destruction of wetlands whenever
possible, especially in cases where less damaging alternatives to destructive
projects/actions are available (40 CFR 230 10(a))
Verify that the facility follows wetlands policy guidance from the CEQ by minimizing
and/or mitigating all impacts to wetlands, in those cases where no less damaging
alternatives exist and wetland impacts prove to be unavoidable
IMP 51 The Highly Erodible
Land and Wetland Conservation
Act (7 CFR 12), which is
administered by the US
Department of Agriculture's
Agricultural Stabilization and
Conservation Service (USDA
ASCS), allows for the denial of
USDA economic support to
those entities engaged in
unsound agricultural operations
or practices that result in
damages to or losses of
wetlands
Verify that the agency/facility does not permit the planting of crops on a converted
wetland or the conversion of wetlands to agricultural production
If wetland losses were caused by agricultural activity on Federal lands, determine if
the agency/facility has notified USDA ASCS of any such losses that might warrant
forfeiture of USDA support
IMP 52 State and local laws
also commonly protect the
habitats, ecological functions,
and societal values provided by
wetlands, floodplains, and
associated surface water
resources
Identify and ensure facility compliance with wetland impact mitigation and
monitoring requirements of state and local wetland laws, regulations, permits and
policies
Agricultural Resources
IMP 53 The Farmland
Protection Policy Act of 1981
(7 CFR 658) limits the extent to
which Federal programs may
contribute to the unnecessary
conversion of farmland to non-
agricultural use
Determine if the facility has a program to conserve agricultural lands on site and
comply with related requirements of this law
Phase 1 - Section 7
Management of Environmental Impacts
7-51
-------
Compliance Category:
Management of Environmental Impacts
Regulatory Requirements:
Reviewer Checks
IMP 54 The Highly Erodible
Land and Wetland Conservation
Act (7 CFR 12), which is
administered by the (USDA
ASCS) allows for the denial of
USDA economic support to
those entities engaged in
unsound agricultural operations
or practices that result in soil
erosion, sedimentation, and
water quality degradation
Verify that the agency/facility does not permit the conduct of unsound agricultural
practices on Federal lands that result in soil erosion, sedimentation, or water quality
degradation
If such soil losses or water quality impacts were caused by unsound agricultural
practices on Federal lands, determine if the agency/facility has notified USDA ASCS
of agricultural practices that might warrant the forfeiture of USDA economic support.
IMP 55 Land farming or other
waste disposal methods
conducted on agricultural lands
must comply with all pertinent
Federal, state, and local laws,
regulations, and policies (40
CFR 257,257 3-5)
Confirm that solid wastes or sewage wastes from DOE facilities are not disposed of on
or below lands used for crop production or livestock grazing
On solid/sewage waste disposal lands used for dairy animals, verify that testing has
demonstrated PCB concentrations of less than 1 5 mg/kg milk fat and 0 2 mg/kg
animal feed actual weight
IMP 56 Although agricultural
resources are afforded little
protection under other Federal,
state, and local regulations,
facilities should develop soil
conservation and other
programs to manage on-site
agricultural resources, as an
MP.
Verify that Federal land in agricultural use is properly managed, in accordance with
agency policies, state/local regulations, Federal lease agreements, and sound range
management practices
Coastal Resources
IMP 57. Coastal resources,
their habitats, and the associated
biota are protected under the
Federal Coastal Zone
Management Act (CZMA)
through state-admmistered
Coastal Zone Management
Plans (15 CFR 930.33(a)).
Confirm that the agency/facility has obtained a Certificate of Consistency with the
state's Coastal Zone Management Plan for all projects located in wetlands, floodplains,
or other coastal land areas subject to the CZMA.
Verify that the facility has determined which (if any) of its activities affects ecological
resources of the coastal zone in states with approved management programs
Phase 1 • Section 7
Management of Environmental Impacts
7-52
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Compliance Category:
Maaagewe&t of Invjro&tnefttal Impacts
RegaJaiory Jtequtemeate:
Reviewer Cfeeebst
IMP 58 In the event of
environmental damage from a
spill or other release of oil or
hazardous material, resultant
effects to coastal ecological
resources must be evaluated by
means of Natural Resource
Damage Assessments (NRDA,
43 CFR 11 33).
Confirm that NRDAs have been conducted by the responsible agency/facility to assess
damages to Federal and state trustee resources from specific oil or hazardous material
spill/release events in coastal and marine ecosystems
IMP 59. The Marine
Protection, Research, and
Sanctuaries Act of 1972
(MPRSA) regulates ocean
dumping and marine pollution
and provides for the
establishment of national
marine sanctuaries that are
afforded special protection and
management programs
Verify that the facility/agency does not dispose of solid, hazardous, medical, or
radioactive wastes in the ocean, except as approved through, and in compliance with,
the conditions of a valid permit
Determine if any facility or adjacent land is part of the National Marine Sanctuary
Program (NMSP) or is currently a candidate on the Site Evaluation List (SEL) to be
added to the NMSP.
Verify that any facility bordering or potentially affecting a marine sanctuary protected
under the NMSP adheres to the MPRSA regulations protecting these ecosystems (15
CFR 922-923)
Wild and Scenic Rivers
IMP 60. Wild and scenic rivers
registered under the Wild and
Scenic Rivers Act (WSRA) are
protected primarily within the
context of environmental
reviews and planning decisions
made by the lead agency during
the NEPA review process (36
CFR 297.6(a))
Verify that during NEPA reviews, the facility has determined which (if any) of its
activities affects or has the potential to affect any rivers registered under the WSRA
Confirm that EAs, EISs, FONSIs, and related studies made to satisfy NEPA
requirements adequately address the effects on rivers protected by the WSRA.
Phase 1 - Section 7
Management of Environmental Impacts
7-53
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Section 7
Other Environmental Impacts
Appendices
-------
Appendix 7-1
Noxious Weeds
(7 CFR 360.200)
Si'iriilil'ii' N;imr
CuinmiMi N;imK'
1. Aquatic weeds
Azolla pinnata
R Brown
mosquito fern, water velvet
Eichomia azurea
(Swartz) Kunth
anchored waterhyacinth, rooted
waterhyacinth
Hydrilla verticillata
(Linnaeus f) Royle
hydrilla
Hygrophila polysperma
T Anderson
Miramar weed
lpomoea aquatica
Forsskal
water-spinach, swamp morning-glory
Lagarostphon major
(Ridley) Moss
Limnophila sessiliflora (Vahl) Blume
ambulia
(Linnaeus) Solms-Laubach
Monochoria vaginalis
(Burman f) C Presl
Sagittana latifolia
Linnaeus
arrowhead
Salvinia aunculata
Aublet
giant salvinia
Salvinia biloba
Raddi
giant salvinia
Salvinia herzogu
de la Sola
giant salvinia
Salvinia molesta
D S Mitchell
giant salvinia
Sparganium erectum
Linnaeus
exotic burrweed
Srrariotes alotdes
Linnaeus
water-aloe
•mf S S S f f
^
Aeginetia
spp
Alectra
spp
Cuscuta
spp (dodders),
other than the following species
Cuscuta amertcana
Linnaeus
Cuscuta applanata
Engelmann
Cuscuta approximata
Babington
A7-1
-------
Si'K'iitii'ii'
Omnium Yiiiir
Cuscuta attenuata
Waterfall
Cuscuta boldinghu
Urban
Cuscuta brachycalyx
Yuncker
Cuscuta califomica
Hooker & Arnot
Cuscuta campestris
Yuncker
Cuscuta cassytiodes
Nees ex Engelmann
Cuscuta ceanothu
Behr
Cuscuta cephalanthii
Engelmann
Cuscuta compacta
Jussieu
Cuscuta corylu
Engelmann
Cuscuta cuspidata
Engelmann
Cuscuta decipiens
Yuncker
Cuscuta dentatasquamata
Yuncker
Cuscuta denticulata
Engelmann
Cuscuta eptlimum
Weihe
Cuscuta epithymum
(Linnaeus) Linnaeus
Cuscuta erosa
Yuncker
Cuscuta europaea
Linnaeus
Cuscuta exalta
Engelmann
Cuscuta fasciculata
Yuncker
Cuscuta glabrior
(Engelmann) Yuncker
Cuscuta globulosa
Bentham
Cuscuta glomerata
Choisy
Cuscuta gronovu
Willenow
Cuscuta harpen
Small
Cuscuta howelliana
Rubtzoff
Cuscuta indecora
Choisy
Cuscuta jepsomi
Yuncker
Cuscuta leptantha
Engelmann
Cuscuta mitriformis
Engelmann
A7-2
-------
Scii'iililii' iViiiic
1
C'oiiiniiin Niiiih'
Cuscuta nevadems
I M Johnston
Cuscuta obtusiflora
Humbolt, Bonpland, & Kunth
Cuscuta occidentals
Millspaugh, Mill & Nutall
Cuscuta odontolepis
Engelmann
Cuscuta pentagona
Engelmann
Cuscuta planiflora
Tenore
Cuscuta plattensis
A Nelson
Cuscuta potygonorum
Engelmann
Cuscuta rostrata
Shuttleworth & Engelmann
Cuscuta runyonu
Yuncker
Cuscuta salina
Engelmann
Cuscuta sandwichiana
Choisy
Cuscuta squamata
Engelmann
Cuscuta suaveolens
Seringe
Cuscuta suksdorfi
Yuncker
Cuscuta tuberculata
Brandegee
Cuscuta umbellata
Humbolt, Bonpland & Kunth
Cuscuta umbrosa
Bey rich & Hooker
Cuscuta vetchu
Brandegee
Cuscuta warneri
Yuncker
Orobanche
spp (broomrapes)
other than the following species
Orobanche bulbosa
(Gray) G Beck
Orobanche cahfornica
Schlechtendal & Chamisso
Orobanche coopen
(Gray) Heller
Orobanche corymbosa
(Rydberg) Ferris
Orobanche dugessi
(S Watson) Munz
Orobanche fasctculata
Nutall
Orobanche ludoviciana
Nutall
Orobanche multicaulis
Brandegee
Orobanche panshu
(Jepson) Heckard
A7-3
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Scientific Nmiiu'
Comimiii .Niniie
Orobanche pinorum
Greyer ex Hooker
Orobanche uniflora
Linnaeus
Orobanche valida
Jepson
Orobanche valltcola
(Jepson) Heckard
Striga
spp (witchweeds)
"
I.-:
Ageratina adenophora
(Sprengel) King & Robinson
crofton weed
Altemanthera senilis
(Linnaeus) R Brown ex de Candolle
sessile joyweed
Asphodelus fistulosus
Linnaeus
omonweed
A vena sterilis
Linnaeus
including A vena ludoviciana
Durieu
animated oat, wild oat
Borreria alata
(Aublet) de Candolle
Carthamus oxyacanlha M Bieberstem
wild safflower
Chrysopogon aciculatus
(Retzius) Trimus
pilipiliula
Commeltna benghaleruis
Linnaeus
Benghal dayflower
Crupina vulgaris
Cassini
common crupina
Digitaria scalarum
(Schweinfurth) Chiovenda
African couchgrass, fingergrass
Digitaria velutina
(Forsskal) Palisot de Beauvois
velvet fingergrass, annual conchgrass
Drymaria arenarioides
Humboldt & Bonpland ex Roemer &
Schultes
lightning weed
Emex australis
Steinhell
three-cornered jack
Emex spinosa
(Linnaeus) Campdera
devil's thorn
Euphorbia prunifoli
Jacquin
painted euphorbia
Galega officinalis
Linnaeus
goats rue
Heracleum mantegazzianum
Sommier & Levier
giant hogweed
Imperata brasiliensis
Trimus
Brazilian satintail
A7-4
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|Siii'iililii' N;inu"
Common iS'iimi'
Imperata cyhndnca
(Linnaeus) Raeuschel
cogongras
Ipomoea triloba
Linnaeus
little bell, aiea morning-glory
Ischaemum rugosum
Salisbury
murainograss
Leptochloa chmensis
(Linnaeus) Nees
Asian sprangletop
Lycium ferocissimum
Miers
African boxthorn
Melastoma malabathricum
Linnaeus
Mikania cordata
(Burman f) B L Robinson
mile-a-minute
Mikania micrantha
Humboldt, Bonpland, & Kunth
Mimosa invisa
Martius
giant sensitive plant
Mimosa pigra
Linnaeus var pigra
catclaw mimosa
Nassella trichotoma
(Nees) Hackel ex Arechavaleta
serrated tussock
Opuntia aurantiaca
Lindley
jointed prickly pear
Oryza longistaminata
A Chevalier & Roehrich
red rice
Oryza punctata
Kotschy ex Steudel
red rice
Oryza rufipogon
Griffith
red rice
Paspalum scrobiculattun
Linnaeus
Kodomillet
Pennisetum clandestinum
Hochstetter ex Chiovenda
kikuyugrass
Pennisetum macrourum
Trinius
African feathergrass
Pennisetum pedicellatum
Trinius
kyasumagrass
Pennisetum potystachion
(Linnaeus) Schultes
missiongrass, thin napiergrass
Prosopis alpataco
R A Phitippi
Prosopis argentina
Burkart
Prosopis articulata
S Watson
Prosopis burkartu
Munoz
A7-5
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Scientific N;mic
('oniiiinn Niunc
Prosopis caldenia
Burkart
Prosopis caluigastana
Burkart
Prosopis campestris
Gnseback
Prosopis castellanosu
Burkan
Prosopis denudans
Benlham
Prosopis elata
(Burkart) Burkart
Prosopis farcta
(Solander ex Russel) Macbride
Prosopis ferox
Grisebach
Prosopis fiebrigu
Harms
Prosopis hassleri
Harms
Prosopis humilts
Gilles ex Hooker & Arnott
Prosopis kuntzei
Harms
Prosopis pallida
(Humboldt, Bonpland ex Willdenow)
Humboldt, Bonpland, & Kunth
Prosopis palmeri
S Watson
Prosopis reptans
Bentham var reptans
Prosopis rojasiana
Burkart
Prosopis runlealti
Burkart
Prosopis ruscifolia
Grisebach
Prosopis sericantha
Gillies ex Hooker & Amott
Prosopis strombulifera
(Lamarck) Bentham
Prosopis lorquata
(Cavanilles ex Lagasca y Segura) de
Candolle
Rottboellia exaltata
Linnaeus
itchgrass, raoulgrass
Rubus fruttcosus
Linnaeus (complex)
wild blackberry
A7-6
-------
SiU'iiliric Njiih'
Common Niiiih'
Rubus moluccanus
Linnaeus
wild raspberry
Saccharum spomaneum
Linnaeus
wild sugarcane
Salsola vermiculata
Linnaeus
wormleaf salsola
Setaria pallide-fusca
(Schumacher) Stapf & Hubbard
cattail grass
Solatium torvum
Swartz
turkeyberry
Tridax procumbens
Linnaeus
coat buttons
Vrochloa panicoides
Beauvois
liverseed grass
A7-7
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Appendix 7-2
Management of Environmental Impacts Facility Tour Checklist
This checklist is provided as a reference for things to look for and take notes on during the "orientation
tour " The list is not all inclusive, it is meant to serve as an aid or tool to remind the auditor of the major
considerations during the tour Areas and specific compliance issues should be identified and targeted
during the tour for subsequent follow-up/return visits
Ecological Assessment and Monitoring
Locations of environmental monitoring/sampling stations, including biological surveillance
areas
Locations of air and water emission/effluent point sources
Soil and Sediment
Erosion and sediment control devices for land undergoing development activities
Vegetative cover to control dust and minimize soil erosion
Soil type(s)
Land farming or soil injection methods
pH of soils in areas where solid or sewage wastes are deposited on land
Backfill areas or tailings deposit areas
Evidence of spills or releases into soils or sediments
Evidence of ground water seeps and downgradient of contaminant sources
Vegetation
Symptoms of stress/damage, plant death, or changes in floristic composition
Relation of prevailing winds or water currents to vegetative death or distress
Areas of reclamation or restoration (check health of plantings)
Presence of and control efforts for noxious weeds
Wildlife
Visible evidence of the relative extent of biodiversity
Measures to protect migratory birds (e.g , nets over waste lagoons) and their habitats
Restrictions on hunting posted at the facility
Adverse effects on habitat resulting from vegetative death
Breeding habitat for birds and wildlife
Presence of pest species of wildlife
Presence of wildlife migratory corridors or well-worn trails
Signs of wildlife presence (e g , tracks, nests, scat (dung), etc )
Sightings of wildlife onsite, utilizing habitats
Presence of wildlife exclusionary devices in hazardous areas (e.g , fences)
A7-8
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Appendix 7-2 (continued)
Management of Environmental Impacts Facility Tour Checklist
Aquatic Biota
Water quality of aquatic habitat (extent of eutrophication/algal blooms)
Abundance of invertebrates, fish, and shellfish
Evidence of fish kills resulting from contaminant releases or impingement water intakes
Outfalls to fish habitats
Locations of commercial shellfish beds and fishing grounds
Evidence of silt deposits in or filling of surface waters
Endangered Species
Presence of endangered species onsite
Damages to endangered species habitats
Endangered species surveillance program
Signs warning of habitat sensitivity
Floodplalns and Wetlands
Presence/condition of dams, levees, and impoundments
Signs indicating flood hazard zone
Presence of fill material and/or construction in floodplains or within the wetlands boundary
Locations of dredge spoil disposal areas in wetlands or floodplains
Locations of wetland mitigation areas, such as compensatory replication for lost/damaged
wetland habitat
Measures to minimize the effects of flooding in wetlands
Erosion/silt controls between work areas and wetlands
Agricultural Resources
Types of crops/livestock raised on nearby farms
Presence of crop/pasture lands within 16 km of facility
Sewage/solid waste applied to agricultural grounds
Coastal Resources
Define areas within the Coastal Zone Management Area
Wild and Scenic Rivers
Features of wild and scenic rivers that have been or could be affected by facility
A7-9
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Phase 1
Section 8
Hazardous Materials Management
-------
Phase 1
Section 8
Table of Contents
Hazardous Materials Management
A. Applicability 8-1
B. Federal Legislation 8-1
C. State/Local Regulations 8-1
D. Key Compliance Requirements 8-2
E. Key Compliance Definitions 8-4
F. Records to Review 8-8
G Physical Features to Inspect 8-8
H. Guidance for Checklist Users 8-9
Appendices
A8-1. Maximum Allowable Capacity of Containers A8-1
A8-2. Storage in Inside Rooms A8-2
A8-3. Flammable/Combustible Materials A8-3
A8-4. Potentially Incompatible Hazardous Materials A8-7
A8-5. Placarding Guidelines A8-10
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A. Applicability
This section addresses the proper storage and handling of chemicals and the spill contingency
and response requirements related to hazardous materials. Oil, pesticides, and asbestos are
hazardous materials that require special management practices at facilities; they and are addressed
in separate sections. Radioactive substances and the general category of hazardous wastes are also
not included in this section This section does not focus on individual hazardous chemicals or
substances used but deals with the generic requirements and Management Practices (MPs)
associated with minimizing impacts on the environment resulting from spills or releases of
hazardous materials because of improper storage and handling.
Assessors are required to review agency, Federal, state, and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. The Occupational Safety and Health Act (OSHA)
This Act, last amended in November 1990 (29 U S. Code (USC) 651-678), is a Federal statute
that governs the issues related to occupational safety and health. The purpose and policy of this
Act are to assure every working man and woman in the nation safe and healthful working
conditions and to preserve our human resources by, among other things, providing for the
development and publication of occupational safety and health standards, an effective enforcement
program, and appropriate reporting procedures with respect to occupational safety and health
procedures that will help achieve the objectives of this Act and accurately describe the nature of
the occupational safety and health (29 USC 651 (b)(9)( 10)( 12)).
2. The Hazardous Materials Transportation Act of 1975
This Act, as last amended in November 1990 (49 USC 1801-1819, et al), is the Federal
legislation that governs the transportation of hazardous materials in the nation. The policy of
Congress is to improve the regulatory and enforcement authority of the Secretary of
Transportation to protect the nation adequately against the risks to life and property inherent in the
transportation of hazardous materials in commerce (49 USC 1801).
3. The National Fire Code, Flammable and Combustible Liquids Code NFPA 30
Prohibits the storage of Class I and Class II liquids in plastic containers in general-purpose
warehousing.
C. State/Local Regulations
Hazardous materials may be regulated on the state level as well as by local agencies
(county/city fire departments) which may require flammable/combustible materials to meet certain
storage requirements. Usually, these local ordinances will follow the National Fire Protection
Phase 1 - Section 8
Hazardous Materials Management
8-1
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Association (NFPA) Fire Protection Guide on Hazardous Materials (Pamphlets 325A, 325M, 49,
49IF, and 704M)
D. Key Compliance Requirements
1. Planning and Documentation
Facilities should maintain a master listing of hazardous materials storage sites. When the
facility requires outside fire protection help, it should tell the local fire department the types of
hazardous chemicals it uses, the areas where it uses them, what it uses them for, and the amounts it
uses. Facilities are required to have Material Safety Data Sheet (MSDS) files for each hazardous
chemical it stores and uses, not including such items as hazardous waste, tobacco, or drugs and
cosmetics meant for personal use (29 CFR 1910.1200(b) and 1910.1200(g)).
2. Personnel Training
Facilities are required to provide all employees with written information about the hazardous
chemicals to which they are exposed. Personnel who work with hazardous materials are required
to be trained in the use of and potential hazards of such materials. All employees and supervisors
working on sites exposed to hazardous materials or other hazards are required to be trained before
engaging in these activities (29 CFR 1910.1200).
3. Hazardous Materials Storage
Containers for hazardous chemicals are required to be labeled or tagged with the identity of
the substance and appropriate warning markings. Areas where hazardous materials are stored or
used around the facility are required to be kept free from accumulations of materials that create a
hazard, such as leaking containers or a placement of containers in a manner that would create
hazards such as tripping, fire, or pests Substances that together may create a fire hazard must
separated (29 CFR 1910.176(c), 1910.1200(b) and 1910.1200(f)).
4. Hazardous Materials in Laboratories
Facilities that use hazardous chemicals in laboratories are required to have a Chemical
Hygiene Plan, which is reviewed annually. Such facilities are also required to provide employees
with information and training about the hazardous chemicals in their work areas Records about
the exposure of employees are to be kept medical records (29 CFR 1910.1450(e), 1910.1450(f),
1910.1450(h), 1910.1450(j))
5. Storage of Flammable/Combustibles
In general, containers of flammable combustible liquids are to be stored and handled so as not
to damage the container or label, block exits, or create a fire hazard (29 CFR 1910.106(d)).
6. Flammable Combustible Storage Cabinets
Storage cabinets are to be fire resistant and labeled FLAMMABLE - KEEP FIRE AWAY.
No more than 60 gal (227.12 L) of Class I or Class II liquids and no more than 120 gal (454.23 L)
of Class III liquids can be stored in a cabinet (29 CFR 1910.106(d)(3)).
Phase 1 - Section 8
Hazardous Materials Management
8-2
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7. Flammable Combustible Storage Rooms
Storage rooms inside a building are to be fire resistant and have a raised sill or ramp to
prevent the flow of spilled material from exiting the room Ventilation and clear aisles must be
provided, and dispensing must be done by an approved pump or self-closing faucet (29 CFR
1910.106(d)(4)).
8. Flammable/Combustible Warehouses or Storage Buildings
These structures will have 3-ft (0.91 m) wide aisles for access to doors, windows, or standpipe
connections. Materials will be stacked using pallets or dunnage when needed for stabilization, and
fire protection must be provided (29 CFR 1910 106(d)(5)(iv)).
9. Outside Storage of Flammable Combustible Liquids
Containers of flammable/combustible liquids can be stored outside if no more than 1,100 gal
(4,163.95 L) of liquid are stored adjacent to a building More than 1,100 gal (4,163 95 L) can be
stored if there are 10 ft (3.05 m) or more between buildings and the nearest flammable container
The storage area must be graded or surrounded by a curb to divert spills (29 CFR 1910.106(d)(6)).
10. Storage of Flammable/Combustibles in Industrial Areas
Specific guidelines, requirements, or operating standards apply wherever
flammable/combustible materials are stored, dispensed, or used in industrial plants; are in
incidental storage, or in use in unit operations. This includes availability of portable fire
extinguishers, precautions being to prevent ignition, and use of maintenance and operating
practices to control leakage and prevent accidental escape of flammable/combustible liquids (29
CFR 1910 106(e)(2) through 1910.106(e)(9)).
11. Compressed Gases
Regardless of where the cylinders are stored, NO SMOKING signs should be posted and
actions taken to prevent fire. Compressed gases are required to be stored according to the
Compressed Gas Association Pamphlet P-l-1965 (29 CFR 1910.101).
12. Acid Storage
Bulk storage of acids should be in buildings that are one story in height with ventilation
Safety equipment and fire protection must be available The building is labeled NO SMOKING
and heated to prevent freezing (MP)
13. Hazardous Materials Transportation
The regulations in Title 49, Subchapter C of the CFR detail requirements for the
transportation of hazardous materials. 49 CFR 171.1(c) stipulates that these requirements apply
when materials are being transported in commerce According to a representative from the
Department of Transportation (DOT), commerce is defined in terms of making a profit in this
instance. Therefore, according to this representative, Subchapter C does not apply when
government personnel are transporting hazardous materials in government vehicles.
Phase 1 - Section 8
Hazardous Materials Management
8-3
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E. Key Compliance Definitions
1. Aerosol
A material is dispensed from its container as a mist, spray, or foam by a propellant under
pressure (29 CFR 1910.106(a)(1)).
2. Airborne Radioactivity Area
This includes (29 CFR 1910.96(e)(4)(i)):
• Any room, enclosure, or operating area in which airborne radioactive materials, composed
wholly or partly of radioactive material, exist in concentration in excess of the amounts
specified in column 1, Table 1, Appendix B, 10 CFR 20.
• Any room, enclosure, or operating area in which airborne radioactive materials exist in
concentrations that, averaged over the number of hours in any week during which individuals
are in the area, exceed 25 percent of the amounts specified in column 1, Table 1, Appendix B
to 10 CFR 20.
3. Approved
Listed or approved by Underwriters Laboratories, Inc., Factory Mutual Engineering
Corporation, The Bureau of Mines, National Institute of Occupational Safety and Health (NIOSH),
The American National Standards Institute (ANSI), NFPA, or other nationally recognized
agencies that list, approve, test, or develop specifications for equipment to meet fire protection,
health, or safety requirements (29 CFR 1910.106(a)(35)).
4. Barrel
A volume of 42 US gallons (29 CFR 1910.106(a)(33)).
5. Basement
A story of a building or structure having one-half or more of its height below ground level to
which access for fire fighting purposes is unduly restricted (29 CFR 1910.106(a)(4)).
6. Boiling Point
The temperature at which a liquid starts to boil when at atmospheric pressure (14.7 psia (760
mm)), as determined by ASTM test D-86-72 (29 CFR 1910.106(a)(5)).
7. Bulk Plant
That portion of the property where flammable or combustible liquids are received by tank
vessel, pipelines, tank car, or tank vehicle, and are stored or blended in bulk for the purpose of
distributing such liquids by tank vessel pipeline, car, tank vehicle, or container (29 CFR
1910.106(a)(7)).
Phase 1 - Section 8
Hazardous Materials Management
8-4
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8. Closed Container
A container so sealed with a lid or other closing device that neither liquid nor vapor will
escape from it at ordinary temperatures (29 CFR 1910.106(a)(9)).
9. Combustible Liquid
A liquid having a flashpoint at or above 100°F (37.8°C). Combustible liquids are categorized
as Class II or Class III liquids and are further subdivided as follows (29 CFR 1910 106(a)( 18)):
• Class II liquids are those having a flashpoint at or above 100°F (37.8°C) and below 140°F
(60°C), except any mixture having components with flashpoints of 200°F (93.3 °C) or higher,
the volume of which makes up 99 percent or more of the total volume of the mixture.
• Class IIIA liquids are those having flashpoints at or above 140°F (60°C) and below 200°F
(93 3°C), except any mixture having components with flashpoints of 200°F (93.3°C) or
higher, the total volume of which makes up 99 percent or more of the total volume of the
mixture.
• Class IIIB liquids are those having flashpoints at or above 200°F (93.3°C).
10. Fire Area
That portion of a building separated from the remainder by construction that has a rated fire
resistance of at least one hour and all communicating openings properly protected by an assembly
having a fire resistance rating of at least two hours (29 CFR 1910.106(a)( 12)).
11. Flammable Aerosol
An aerosol that is required to be labeled FLAMMABLE under the Federal Hazardous
Substance Labeling Act (15 USC 1261). These aerosols are considered Class IA liquids (29 CFR
1910.106(a)(l 9)).
12. Flammable Liquid
A liquid with a flashpoint below 100°F (37.8°C) except any mixture having components with
flashpoints of 100°F (37.8 °C) or higher, the total of which make up 99 percent or more of the total
volume of the mixture. Flammable liquids are categorized as Class I liquids, and are further
subdivided as follows (29 CFR 1910.106(a)( 19)).
• Class IA are those that have a flashpoint below 73 °F (22.8 °C) and a boiling point below
100°F (37.8°C).
• Class IB are those that have a flashpoint below 73 °F (22.8°C) and a boiling point at or above
100°F (37.8°C).
• Class IC are those that have flashpoints at or above 73°F (22.8°C) and below 100°F
(37.8°C).
Phase 1 - Section 8
Hazardous Materials Management
8-5
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13. Flashpoint
The minimum temperature at which a liquid gives off vapor in sufficient concentration to
form an ignitable mixture with air near the surface of the liquid. Flashpoints are established using
several standard closed-cup test methods (29 CFR 1910.106(a)( 14)).
14. Hazardous Chemical
In relationship to laboratories, a chemical for which there is statistically significant evidence
based on at least one study conducted in accordance with established scientific principles that
acute or chronic health effects may occur in exposed employees (29 CFR 1910.1450(b)).
15. High Radiation Area
Any area accessible to personnel in which there exists radiation at such levels that a major
portion of the body could receive in any one hour a dose in excess of 100 mrems (29 CFR
1910.96(d)(3)(iii)).
16. Institutional Occupancy
The occupancy or use of a building or structure or any portion thereof by persons harbored or
detained to receive medical, charitable, or other care or treatment or by persons involuntarily
detained (29 CFR 1910.106(a)(16)).
17. Laboratory
A facility where the laboratory use of hazardous chemicals occurs. It is a workplace where
relatively small quantities of hazardous chemicals are used on a nonproduction basis (29 CFR
1910.1450(b)).
18. Laboratory Scale
Work with substances in which the containers used for reactions, transfers, and other handling
of substances are designed to be easily and safely manipulated by one person (29 CFR
1910.1450(b)).
19. Laboratory Use of a Hazardous Chemical
Handling or use of such chemicals in which all of the following conditions are met (29 CFR
1910.106(a)(17)):
• Chemical manipulations are carried out on a laboratory scale;
• Multiple chemical procedures or chemicals are used;
• The procedures involved are not part of a production process, nor in any way simulate a
production process; and
• Protective laboratory practices and equipment are available and are in common use to
minimize the potential for employee exposure to hazardous chemicals.
Phase 1 - Section 8
Hazardous Materials Management
8-6
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20. Liquid
Any material with a fluidity greater than that of 300 penetration asphalt when tested in
accordance with ASTM Test D-5-73. When not otherwise identified, the term liquid will include
both flammable and combustible liquid (29 CFR 1910.106(a)( 17))
21. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
22. Material Safety Data Sheet (MSDS)
Written or printed material that contains information on hazardous chemicals such as common
name, physical hazards, and health hazards (29 CFR 1910.1200(c)).
23. Office Occupancy
The occupancy or use of a building or structure or any portion thereof for the transaction of
business, or the rendering or receiving of professional services (29 CFR 1910.106(a)(24)).
24. Protection for Exposure
Adequate fire protection for structures on property adjacent to tanks where there are
employees of the establishment are located (29 CFR 1910.106(a)(27)).
25. Radiation
Includes alpha rays, beta rays, gamma rays, X-rays, neutrons, high-speed electrons, high-
speed protons, and other atomic particles, but does not include sound or radio waves, visible light,
or infrared or ultraviolet (29 CFR 1910.96(a)(1)).
25. Radiation Area
Any area accessible to personnel in which there exists radiation, originating in whole or in
part with licensed material, at such levels that a major portion of the body could receive in any one
hour a dose in excess of five mrems, or in any five consecutive days a dose in excess of 100
mrems (29 CFR 1910.96(d)(3)(ii)).
26. Radioactive Material
Any material that emits, by spontaneous nuclear disintegration, corpuscular or
electromagnetic emanations (29 CFR 1910.96(a)(2)).
27. Safety Can
An approved flammable liquid container having a spring-closing lid, spout cover, and other
features designed to safely relieve internal pressure and to provide safe storage for the liquid (29
CFR 1910.106(a)(29)).
28. Select Carcinogens
Any substance that meets one of the following criteria (29 CFR 1910.1450(b)):
Phase 1 - Section 8
Hazardous Materials Management
8-7
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• It is regulated by OSHA as a carcinogen;
• It is listed under the category "known to be carcinogens" and in the Annual Report on
Carcinogens published by the National Toxicology Program (NTP);
• It is listed under Group 1 (carcinogenic to humans) by the International Agency for Research
on Cancer Monographs (IARC); or
• It is listed in either Group 2A or 2B by IARC or under the category "reasonably anticipated to
be carcinogens" by NTP, and causes statistically significant tumor incidences in experimental
animals under specific situations.
29. Vapor Pressure
The pressure, measured in psia, exerted by a volatile liquid (29 CFR 1910.106(a)(30)).
F. Records to Review
• Hazardous Substance Spill Control and Contingency Plan
• Spill records
• Emergency plan documents
• MSDSs
• Inventory records
• Hazardous substance release reports
• Shipping papers
• Training records
• Placarding of hazardous materials
• Used oil storage sites
• HAZCOM plan
G. Physical Features to Inspect
• Hazardous material storage areas
• Shop activities
• Shipping and receiving area.
Phase 1 - Section 8
Hazardous Materials Management
8-8
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H. Guidance for Checklist Users
Refer To
Checklist Items
Page Numbers
All facilities
HM 1 through HM.4
8-10
HM 5 through HM 6
8-11
HM.7
8-12
HM 8
8-13
Personnel Training
HM 9
8-13
HM 10
8-15
Hazardous Materials in Laboratories
HM 11
8-16
HM 12 through HM 14
8-17
Releases of Hazardous Materials
HM 15
8-18
Flammable/Combustible Liquids
General
HM 16
8-18
HM. 17 through HM.20
8-19
HM 21 through HM 22
8-20
HM.23 through HM 24
8-21
Industrial Areas
HM.25
8-22
HM 26
8-23
HM 27
8-24
Compressed Gas Storage
HM 28
8-24
Hazardous Materials Transportation
HM.29 through HM.30
8-24
HM 31 through HM 33
8-25
HM 34 through HM 35
8-26
HM 36
8-27
HM 37
8-28
HM.38 through HM.39
8-29
HM 40
8-30
Radioactive Materials
HM 41 through HM 42
8-30
HM.43 through HM 44
8-31
HM.45 through HM 46
8-32
Phase 1 - Section 8
Hazardous Materials Management
8-9
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Compliance Category:
Hazardous Materials Management
Rega tatojy rewettte:
| Jteytewsr Checks:
All Facilities
HM 1 The current status of
any ongoing or unresolved
Consent Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
HM 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding.)
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
HM 3 Facilities are required to
abide by state and
local regulations concerning
hazardous materials (EO 12088,
Section 1-1)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
transportation of hazardous materials
notification requirements
response plan requirements
spill response requirements)
HM 4 A master listing of all
hazardous materials storage
sites should be maintained at
the facility (MP)
Determine the locations of all hazardous materials storage areas on the facility by
interviewing staff
(NOTE Hazardous constituents of expired materials discovered during the inventory
process, or at any other time, should be identified prior to disposal, see appropriate
checklist item in the Hazardous Waste Management protocol)
Phase 1 - Section 8
Hazardous Materials Management
8-10
-------
Compliaace Category:
Hazardous Materials Management
Regata(o*ylle
-------
Compliance Category.
Hazardous Materials Management
Itegelafoyyfte^uirfeBiettte;
JUvtewer Checks:
HM .7 Containers of hazardous
chemicals in the workplace are
required to be labeled, tagged,
or marked with specific
information (29 CFR
1910.1200(b)(3)(i),
1910 1200(b)(4)(i),
1910 1200(b)(5),
1910.1200(f)(5) through
1910 1200(f)(7)).
Verify that all containers of hazardous chemicals in the workplace are labeled with the
following information:
Identity of the hazardous chemical
Appropriate hazard warnings
- Name and address of the manufacturer, importer, or other responsible party
Identity of the hazardous chemical
Appropriate hazard warnings
(NOTE.
- The facility may use signs, placards, process sheets, batch tickets, operating
procedures or other written materials instead of attached labels to identify
stationary process containers as long as the alternate method identifies the
containers to which it is applicable.
Portable containers into which hazardous chemicals are transferred from labeled
containers and which are intended only for the immediate use of the employee
who performs the transfer are not required to be marked.
These requirements do not apply to
-- any pesticide as such term is defined in FIFRA, when subject to the labeling
requirements of that Act and regulations issued under that Act
-- any chemical substance or mixture as defined by the Toxic Substances Control
Act (TSCA) when subject to the labeling requirements of TSCA
-- any food, food additive, color additive, drug, cosmetic, or medical or
veterinary device as defined in the Federal Food, Drug, and Cosmetic Act
-- any distilled spirits, wine, or malt beverage intended for nonindustrial use as
defined in the Federal Alcohol Administration Act
-- any consumer product or hazardous substance as defined in the Consumer
Product Safety Act and the Federal Hazardous Substances Act when subject to
a consumer product safety standard or labeling requirement under those Acts
-- agricultural or vegetable seed treated with pesticides and labeled in accordance
with the Federal Seed Act
These requirements do not apply to
— hazardous waste
-- tobacco or tobacco products
-- wood or wood products
-- articles which are defined as a manufactured item other than a fluid or particle
which under normal conditions of use does not release more than very small
amounts of a hazardous chemical and does not pose a physical hazard or
health risk to personnel and that.
is formed to a specific shape or design during manufacture
has end use functions dependent in whole or in part upon its shape or
design during end use
- food or alcoholic beverages which are sold, used, or prepared in a retail
establishment and foods intended for consumption by personnel
- any drug as that term is defined in the Federal Food, Drug, and Cosmetic Act
when it is in its solid, final form for direct administration
— cosmetics which are packaged for sale or intended for personal use
-- any consumer product or hazardous substance as defined in the Consumer
Product Safety Act and the Federal Hazardous Substances Act where the
facility can demonstrate that it is used in the workplace in the same manner as
normal consumer use, and which use results in a duration and frequency of
exposure which is not greater then exposure experienced by consumers
-- ionizing and nonionizing radiation
-- biological hazards
This requirement also applies to laboratories It also applies to work operations
where employees only handle chemicals in sealed containers which are not
opened
Phase 1 - Section 8
Hazardous Materials Management
8-12
-------
Compliance Category;
Hazardous Materials Management
Regulatory Requirements;
Reviewer Checks:
HM 8 Specific housekeeping
requirements must be met in
areas where hazardous materials
are stored (29 CFR
1910 176(c))
Verify that areas where hazardous materials are stored and/or used around the facility
are free from accumulations of materials that create a hazard from tripping, fire,
explosion, or pest harborage
(NOTE The following are suggested housekeeping practices:
Drums/containers are not leaking and are tightly sealed
- Drip pans and/or absorbent material are placed under containers
Dispensing areas are located away from catch basins and storm drains )
Personnel Training
HM 9 Facilities are required to
have a written hazard
communication program that is
designed to provide all
employees with information
about the hazardous chemicals
to which they
are exposed (29 CFR
1910 1200(b)(6),
1910 1200(e)(1))
Verify that there is a written hazard communication program that contains or does the
following
How general training will be done to inform employees of issues such as MSDSs
and hazardous materials labels and other warning signs
A list of the hazardous chemicals known to be present (can be done for the entire
workplace or individual work areas)
How training will be done
The methods the facility will use to inform the employees of the hazards
associated with nonroutine tasks and the hazards associated with chemicals
contained in unlabeled pipes in their work areas
Provides the other employers onsite with access to MSDSs for each hazardous
chemical the other employer's employees may be exposed to while working
- Informs the other employers of the labeling system used in the workplace
Informs the other employers of any precautionary measures that need to be taken
to protect employees during the workplace's normal operating conditions and in
foreseeable emergencies
Verify that if the facility is operated such that employees from more than one
employer may be exposed (for example, employees of a construction contractor
working onsite), the hazard communication program also addresses what the facility
will do to
Provide the other employers onsite with access to MSDSs for each hazardous
chemical the other employer's employees may be exposed to while working
Inform the other employers of the labeling system used in the workplace
- Inform the other employers of any precautionary measures that need to be taken
to protect employees during the workplace's normal operating conditions and in
foreseeable emergencies
(NOTE This requirement also applies to laboratories and to work operations where
employees handle chemicals in sealed containers that are not opened under normal
conditions of use)
Phase 1 - Section 8
Hazardous Materials Management
8-13
-------
Compliance Category.
H&tardous Material* Mtmagetaejtrt
Regefatwy Re?wireiacBfs;
Reviewer Chetks:
HM 9 continued
(NOTE' These requirements do not apply to
Hazardous waste
Tobacco or tobacco products
Wood or wood products
- Articles that are defined as a manufactured item other than a fluid or particle
which, under normal conditions of use, does not release more than very small
amounts of a hazardous chemical and does not pose a physical hazard or health
risk to personnel and that:
~ is formed to a specific shape or design during manufacture
-- has end-use functions dependent in whole or in part upon its shape or design
during end use
Food or alcoholic beverages that are sold, used, or prepared in a retail
establishment and foods intended for consumption by personnel
- Any drug as that term is defined in the Federal Food, Drug, and Cosmetic Act
when it is in its solid, final form for direct administration
Cosmetics packaged for sale or intended for personal use
Any consumer product or hazardous substance as defined in the Consumer
Product Safety Act and the Federal Hazardous Substances Act where the facility
can demonstrate that it is used in the workplace in the same manner as normal
consumer use, and whose use results in a duration and frequency of exposure that
is not greater than exposure experienced by consumers
Ionizing and nonionizing radiation
Biological hazards)
Phase 1 - Section 8
Hazardous Materials Management
8-14
-------
Compliance Category!
Hazardous Materials Management
KtgatatoryRet^rcwetttj;
Checks:
HM. 10. Personnel working
with hazardous materials are
required to be trained in their
use and the potential hazards of
such materials (29 CFR
1910.1200(b)(3)(iii),
1910.1200(b)(4)(iii),
1910.1200(b)(6), and
1910 1200(h)).
Verify that employees are provided with information and are trained on hazardous
chemicals in their workplace at the time of initial assignment and whenever a new
hazard is introduced into the workplace
Verify that employees are informed of the following
Any operations in their work areas where hazardous chemicals are present
- The location and availability of the written hazard communication program,
including the required lists of hazardous chemicals and MSDSs
Verify that training includes
Methods and observations to use to detect a release
- The physical and health hazards of the chemicals in the work areas
Protective measures and procedures to use
- The details of the hazard communication program developed by the facility,
including an explanation of the labeling system, MSDSs, and how employees can
obtain and use the appropriate hazard information.
(NOTE- These requirements also apply to laboratories. They also apply, as necessary
for protection in event of a spill or leak, to work operations where employees only
handle chemicals in sealed containers that are not opened under normal conditions of
use.)
(NOTE: These requirements do not apply to
Hazardous waste
Tobacco or tobacco products
Wood or wood products
Articles defined as a manufactured item other than a fluid or particle which under
normal conditions of use does not release more than very small amounts of a
hazardous chemical and does not pose a physical hazard or health risk to
personnel and that
-- is formed to a specific shape or design during manufacture
- has end use functions dependent in whole or in part upon its shape or design
during end use
Food or alcoholic beverages that are sold, used, or prepared in a retail
establishment and foods intended for consumption by personnel
Any drug as that term is defined in the Federal Food, Drug, and Cosmetic Act
when it is in its solid, final form for direct administration
Cosmetics which are packaged for sale or intended for personal use
Any consumer product or hazardous substance as defined in the Consumer
Product Safety Act and the Federal Hazardous Substances Act where the facility
can demonstrate that it is used in the workplace in the same manner as normal
consumer use, and whose use results in a duration and frequency of exposure that
is not greater than exposure experienced by consumers
Ionizing and nonionizing radiation
Biological hazards)
Phase 1 - Section 8
Hazardous Materials Management
8-15
-------
Compliance Category.
Hazardous Materials Management
RfegatatoyyUe^atfewett^ f JUvtew €he«fc$
Hazardous Materials in Laboratories
(NOTE: The requirements for hazardous materials in laboratories do not apply to
- Uses of hazardous chemicals that do not meet the definition of laboratory use
- Laboratory uses of hazardous chemicals that provide no potential for exposure such as
commercially prepared kits, such as pregnancy tests, in which all the reagents needed to conduct the test are
contained in the kit
procedures using chemically impregnated test media, such as Dip and Read tests)
HM 11 Facilities engaged in
the laboratory use of hazardous
chemicals (see definitions) are
required to have a Chemical
Hygiene Plan (29 CFR
1910 1450(e))
Verify that a written Chemical Hygiene Plan exists and is:
- Capable of protecting employees from health hazards associated with hazardous
chemicals in the laboratory
Capable of keeping exposure to regulated substances below required limits
Verify that the plan is readily available to employees and employee representatives
Verify that the plan includes the following elements and indicates specific measures
to be taken when laboratory work involves the use of hazardous chemicals*
Standard operating procedures relevant to safety and health considerations to be
followed
- Criteria that will be used to determine and implement control measures to reduce
employee exposure to hazardous chemicals including the engineering controls,
the use of personal protective equipment, and hygiene practices
A requirement that fume hoods and other protective equipment are functioning
properly and specific measures are taken to ensure proper and adequate
performance of the equipment
Provisions for employee information and training
Circumstances and situations that require prior approval from a designated
individual
Provisions for medical consultations and medical exams
Designation of individuals responsible for the implementation of the plan
- Assignment of a Chemical Hygiene Officer and, if appropriate, establishment of a
Chemical Hygiene Committee
Provisions for additional employee protection when working with particularly
hazardous substances, including select carcinogens, reproductive toxins and
substances that have a high degree of acute toxicity Provisions might include:
-- establishment of a designated area
- use of containment devices such as fume hoods or glove boxes
— procedures for safe removal of contaminated waste
~ decontamination procedures
Verify that the plan is reviewed annually and updated as needed.
Phase 1 - Section 8
Hazardous Materials Management
8-16
-------
Compliance Category*
Hazardous Materials Management
Regulatory Requirements;
Reviewer Checks:
HM 12 Facilities engaged in
the laboratory use of hazardous
chemicals (see definitions) are
required to provide employees
with information and training
concerning the hazards of the
chemicals in their work areas
(29 CFR 1910 1450(0)
Verify that information about the hazards of the chemicals in the work area is
provided at the time of initial employment and prior to assignment involving new
exposure risks
(NOTE The frequency of refresher training is to be determined by the facility )
Verify that employees are informed of
- The requirements to be trained and informed
The location and availability of the Chemical Hygiene Plan
The permissible exposure limits for OSHA regulated substances or recommended
exposure levels for other hazardous chemicals where there is no OSHA limit
Signs and symptoms associated with exposure
The location and known availability of known reference material such as MSDSs
Verify that training includes
Methods and observations that may be used to detect the presence or release of a
hazardous chemical
The physical and health hazards of chemicals in the work area
The measures employees can take to protect themselves
Applicable details of the Chemical Hygiene Plan.
HM 13 Facilities engaged in
the laboratory use of hazardous
chemicals (see definitions) are
required to follow specific
handling and operating
procedures (29 CFR
1910 1450(h))
Verify that labels on incoming containers of hazardous chemicals are not removed or
defaced.
Verify that MSDSs are maintained and readily accessible to lab employees
Verify that if the facility is developing chemical substances, a determination is made
as to whether or not it is a hazardous chemical if the composition of the chemical is
known and the chemical is produced for use only by the laboratory
Verify that if the facility is developing a chemical substance as a byproduct and the
composition is not known, it is assumed to be hazardous
Verify that if the chemical substance is produced for another user outside of the lab,
the lab meets the standards outlined in 29 CFR 1910 1200 (see checklist items HM 6,
HM 7, HM.9, and HM.10)
HM 14 Facilities engaged in
the laboratory use of hazardous
chemicals (see definitions) are
required to maintain specific
records (29 CFR 1910 14500))
Verify that records of monitoring for employee exposure are maintained along with
any medical records or test results
Phase 1 - Section 8
Hazardous Materials Management
8-17
-------
Compliance Category*
Hazardous Materials Management
Regotaioty Reqajferoettts;j itevtew Checks:
Release of Hazardous Materials
HM 15 Absorbent materials
should be available for spill
and/or release cleanup in areas
where hazardous materials are
used or stored (MP)
Verify that absorbent materials are available for spill cleanup
Flammable/Combustible Liquids
(NOTE- The requirements pertaining to the handling, storage and use of flammable/combustible liquids with a flashpoint
below 200 °F (93.33 °C) outlined through 29 CFR 1910.106 (checklist items HM.17 through HM.27) do not apply to the
following
- Bulk transportation of flammable/combustible liquids
- Storage, handling, and use of fuel oil tanks and containers connected with oil burning equipment
- Storage of flammable and combustible liquids on farms
- Liquids without a flashpoint that may be flammable under some conditions, such as halogenated hydrocarbons and
mixtures containing halogenated hydrocarbons
- Mists, sprays, or foams, except in flammable aerosols
- The following facilities when they meet NFPA Standards
drycleaning plants
manufacture of organic coatings
solvent extraction plants
stationary combustion engines and gas turbines (29 CFR 1910.106(j))
General
HM 16 Specific management
practices should be considered
when storing and handling
flammable/combustible
materials (MP)
Verify that the following management practices are followed
Items are not stored against pipes or coils producing heat
Paint drums that are stored horizontally are rolled a half turn every 90 days
Containers of paint are pelletized prior to storage
Aerosol containers are stored in well-ventilated areas
Phase 1 - Section 8
Hazardous Materials Management
8-18
-------
Compliance Category:
Hazardous Materials Management
Regd la iory Requirements;
Reviewer Cbeci«:
HM 17 Drums and other
containers of less than 60 gal
(227 12 L) individual capacity
and portable tanks less than 660
gal (2,498 37 L) individual
capacity used to store
flammable or combustible
materials are required to meet
specific standards (29 CFR
1910 106(d)(1) and
1910 106(d)(2))
Verify that flammable and combustible liquid containers meet the constraints outlined
in Appendix 8-1 except that glass or plastic containers of no more than 1-gal (3 79-L)
capacity may be used for a Class 1A or IB flammable liquid if
The liquid would be rendered unfit for its intended use by contact with metal or
would excessively corrode a metal container
The user's process either would require more than 1 pt (0 47 L) of a Class IA
liquid or more than 1 qt (0 95 L) of a Class IB liquid of a single assay lot to be
used at one time, or would require the maintenance of an analytical standard
liquid of a quality that is not met by the specified standards of the liquids
available, and the quantity of the analytical standard liquid required to be used in
any one control process exceeds one-sixteenth of the capacity of the container
allowed under Appendix 8-1 for the class of liquid
Verify that each portable tank has one or more devices installed in the top with
sufficient emergency venting capacity to limit internal pressure under fire exposure
conditions to 10 psig or 30 percent of the bursting pressure of the tank, whichever is
greater
(NOTE These standards do not apply to
Storage of containers in service stations
Class I or Class II liquids in the fuel tanks of a motor vehicles, aircraft, boat, or
portable or stationary engine
Flammable or combustible paints, oils, varnishes, or similar mixtures used for
painting or maintenance when not kept for a period in excess of 30 days )
HM 18 Flammable or
combustible liquids shall not be
stored in ways that limit the use
of exits, stairways, or areas
normally used for the safe
egress of people (29 CFR
1910 106(d)(5)(0)
Verify that exits or common traffic routes are not blocked
(NOTE These standards do not apply to
Storage of containers in service stations
Class I or Class II liquids in the fuel tanks of a motor vehicles, aircraft, boat, or
portable or stationary engine
Flammable or combustible paints, oils, varnishes, or similar mixtures used for
painting or maintenance when not kept for a period in excess of 30 days )
HM 19 Storage cabinets used
for the storage of flammable/
combustible liquids must meet
specific requirements (29 CFR
1910 106(d)(3))
Verify that storage cabinets meet the following
No more than 60 gal (227 12 L) of Class 1 or Class II liquids nor any more than
120 gal (454 23 L) of Class 111 liquids are stored in the cabinet
The cabinets are fire resistant
Cabinets are constanily closed and are conspicuously labeled FLAMMABLE-
Keep Fire Away
HM 20 Slorage cabirets used
for the storage of flammable/
combustible liquids should meet
specific requirements (MP)
Verify that storage cabinets meet the following
Materials within the cabinet are segregated
There are no open containers within the cabinet
All containers in the cabinet are labeled
Phase 1 - Section 8
Hazardous Materials Management
8-19
-------
Compliance Category;
Hazardous Materials Management
Kegtrtotory Requirement*;
Reviewer Checks:
HM21 Flammable/
combustible storage rooms
inside of buildings must meet
certain specifications (29 CFR
1910 106(d)(4))
Verify that the facility's flammable/ combustible storage rooms meet the following
The walls meet fire resistance test N FPA 251-1969
A 4-in (10 16-cm) raised sill or ramp is provided to adjacent rooms or
buildings, or the floor of the storage area is 4 in. (10 16 cm) lower than the
surrounding floors
An open grated trench that drains into a safe area is in the building if a sill or
ramp is not present
Liquid tight wall/ floor joints exist
Self-closing fire doors exist (NFPA 80)
The electrical wiring and equipment meet NFPA 70 requirements
The storage in the rooms meet the requirements in Appendix 8-2
There is either gravity or mechanical exhaust ventilation system
The exhaust system provides for six changes of air in the room per hour
Mechanical exhaust systems are controlled by a switch outside the door and
have exhaust outlets on exterior walls
For gravity ventilation, the fresh air intake is on exterior walls
There is one clear aisle at least 3 ft (0 91 m) wide
Containers over 30-gal (113 56-L) capacity are not stacked one upon the other
Dispensing is done by an approved pump or self-closing faucet
HM 22 The storage of
flammable or combustible
liquids in warehouses or storage
buildings shall meet specific
requirements (29 CFR
1910.106(d)(5)(vi))
Verify that the following requirements are met
If the storage area is located 50 ft (15 24 m) or less from a building or line of
adjoining property that may be built upon, the exposing wall is a blank wall
having a fire-resistance rating of at least 2 hours
The storage arrangements outlined in Appendix 8-3 are met
Containers are separated by pallets or dunnage when necessary to provide
stability and prevent excess stress on container walls
Portable tanks stored over one tier high are designed to nest securely
No pile is closer than 3 ft (0 91 m) to the nearest beam, chord, girder, or other
obstruction
Piles are 3 ft (0 91 m) below sprinkler deflectors or discharge points of water
spray
All wood shelving is at least 1 in (2 54 cm) thick
Aisles are at least 3 ft (0 91 m) wide when necessary for access to doors,
windows, or standpipe connections
Phase 1 - Section 8
Hazardous Materials Management
8-20
-------
Compliance Category:
Hazardous Materials Management
Regolatory Requirements:
Reviewer Checks:
HM 23
Flammable/combustible
materials stored outside of
buildings must meet certain
storage and handling criteria
(29 CFR 1910 106(d)(6))
Verify that outdoor flammable/combustible storage meets the following
No more than 1,100 gal (4,163 95 L) of flammable/combustible liquids are
stored adjacent to buildings located on the same premises unless 10 ft (3 05 m)
or more exists between buildings and the nearest flammable container
The storage area is graded to divert spills or is surrounded by a curb at least 6 in
(15 24 cm) high
Drains terminate in a safe location
The storage area is protected against tampering and kept free of waste and other
combustible materials
All containers bear contents, labels, and hazard markings
Total quantity and arrangement of liquids outside a building complies with the
requirements in Appendix 8-3
(NOTE These standards do not apply to
Storage of containers in service stations
Class 1 or Class II liquids in the fuel tanks of a motor vehicles, aircraft, boat, or
portable or stationary engine
Flammable or combustible paints, oils, varnishes, or similar mixtures used for
painting or maintenance when not kept for a period in excess of 30 days )
HM 24 Areas where
flammable/ combustible
materials are stored must meet
certain fire protection standards
(29 CFR 1910 106(d)(7))
Verify that all flammable/combustible storage locations meet the following
There is at least one 12-B rated portable fire extinguisher located outside and
within 10 ft ((3 05 m) of a door opening into any room for storage
There is at least one 12-B rated portable fire extinguisher located within 10 to 25
ft (3 05 to 7 62 m) of any Class I or Class II liquid storage area outside of a
storage room, but inside a building
Fire extinguishing sprinklers or systems meet the standards in 29 CFR 1910 159
No smoking or open flame is permitted within 50 ft (15 24 m) and signs are
posted
Incompatible materials are not stored together (see Appendix 8-4)
No water reactive materials are stored in the same room with
flammable/combustible liquids
(NOTE These standards do not apply to
Storage of containers in service stations
Class I or Class II liquids in the fuel tanks of a motor vehicles, aircraft, boat, or
portable or stationary engine
Flammable or combustible paints, oils, varnishes, or similar mixtures used for
painting or maintenance when not kept for a period in excess of 30 days )
Phase 1 - Section 8
Hazardous Materials Management
8-21
-------
Compliance Category:
Hazardous Materials Management
Rego fatojy Requirements;
JUvtewtr Checks:
Industrial Areas
(NOTE Checklist items HM 25 through HM 27 pertain to industrial areas where the use of flammable or combustible
liquid is incidental to the principal business or where flammable or combustible liquids are handled or used only in unit
physical operations such as drying, evaporating, filtering, distillation, and similar operations which do not involve
chemical reactions)
HM.25. Areas where
flammable/combustible
materials are stored, dispensed,
or used in industrial plants shall
meet specific guidelines (29
CFR 1910.106(e)(4) through
1910.106(e)(9))
Verify that the following provisions are met
Portable fire extinguishers and fire control equipment are in place, in quantity,
and in type as needed for the hazards of operation and storage at the site
Adequate precautions are taken to prevent sources of ignition at the site
Class 1 liquids are not dispensed into containers unless nozzles and containers
are electrically interconnected
Operations such as welding and cutting for repairs to equipment are done under
the supervision of an individual in charge
Maintenance and operating practices control leakage and prevent the accidental
escape of flammable or combustible liquids
adequate aisles shall be maintained
combustible waste material and residues are kept to a minimum, stored in
covered metal containers, and disposed of daily
the grounds areas around the buildings and unit operating areas are kept
free of weeds, trash, or other unnecessary combustibles
Tank vehicle and tank car loading or unloading facilities are separated from
aboveground tanks, warehouses, and other plant buildings or nearest line of
adjoining property by a distance of 25 ft (7 62 m) for Class I liquids and 15 ft
(4 57 m) for Class 11 and III liquids
Phase 1 - Section 8
Hazardous Materials Management
8-22
-------
Compliance Category:
Hazardous Material Management
Regatatofy Ri$uiren»ett&:
Itevtew Checks:
HM 26. Incidental storage of
flammable/combustible liquids
in industrial areas must conform
to certain requirements (29 CFR
1910 106(e)(2))
Verify that flammable and combustible liquids are stored in closed containers
Verify that the storage areas meet the requirements outlined in 29 CFR
1910 106(d)(3) through 1910 106(d)(4) as listed in checklist items HM 19 and HM 21
except that
The quantity of liquid that is located outside of an mside storage room or storage
cabinet in a building or in any one fire area of a building does not exceed
25 gal (94 64 L) of Class IA liquids in containers
120 gal (454 25 L) of Class IB, IC, 11, or III liquids in containers
660 gal (2,498 37 L) of Class IB, IB, II, or III liquids in a single portable
tank
Where large quantities of flammable or combustible liquids are needed, storage
may be in tanks
Verify that areas where flammable/combustible liquids are transferred
from one container to another container are separated from other
operations in the building by an adequate distance ot by fire-resistant
construction
Verify that adequate drainage or other means is provided to contain
spills and adequate natural or mechanical ventilation is present
Verify that the following practices are observed at the point of final
use
Flammable liquids are kept in covered containers when not actually in use
Where flammable/combustible liquids are used or handled, means are provided
to dispose promptly and safely of spills and leaks
Class 1 liquids are used only where there are no open flames or other sources of
ignition
Flammable/combustible liquids are drawn from or transferred into vessels,
containers, or portable tanks within a building only through a closed piping
system, from safety cans by means of a device drawing through the top, or from
a container or portable tanks by gravity through an approved self closing valve.
(NOTE Transferring flammable/combustible liquids by means of air
pressure on the container or portable tank is prohibited)
Phase 1 - Section 8
Hazardous Materials Management
8-23
-------
CompHanee Category:
Hazardous Material JMtoiageasufctrt
Regulatory Re^wireraenfcK
Checks:
HM 27 Those areas where
flammable/ combustible liquids
are used in unit operations such
as mixing, drying, evaporating,
filtering, or distillation are
required to meet specific
operating standards (29 CFR
1910.106(e)(3)).
Verify that the following parameters are met
Areas are located so that each building or unit of equipment is accessible from at
least one side for fire fighting
Areas where unstable liquids are handled or small-scale unit chemical processes
are carried out shall be separated from the remainder of the area by a fire wall of
2 hours minimum fire-resistance rating
Emergency drainage systems direct leakage and fire protection water to a safe
location
Emergency drainage systems, if connected to public sewers or discharged into
public waterways, are equipped with traps or a separator
When Class I liquids are being used, ventilation is provided at a rate of not less
than 1 ftVm in/ft2 of solid floor area through either natural or mechanical means
Equipment is designed to limit flammable vapor-air mixtures
Compressed Gas Storage
HM 28. The in-plant storage,
handling, and utilization of all
compressed gases in cylinders,
portable tanks, rail tankers, or
motor vehicles must be done
according to the Compressed
Gas Association Pamphlet P-l-
1965 (29 CFR 1910.101).
Verify that compressed gas cylinders and tanks have safety relief devices
Hazardous Materials Transportation
(NOTE- The regulations found in Title 49, Subchapter C of the CFR detail requirements for the transportation of
hazardous materials 49 CFR 171.1 (c) stipulates that these requirements apply when materials are being transported in
commerce. According to a representative from the Department of Transportation, commerce is defined in this instance in
terms of making a profit, therefore, Subchapter C does not apply to Federal agencies when Government personnel are
transporting hazardous materials in Government vehicles However, the regulations do apply when transport is occurring
in non-Government vehicles)
HM 29 Shipping papers for
hazardous materials are
required to indicate the proper
shipping name, hazard class,
identification number, and
quantities of materials (49 CFR
172.202)
Verify that the proper information is displayed on the shipping papers for the
hazardous material.
HM 30 Each package or
container shall be marked in
accordance with specific
marking requirements (49 CFR
171 3)
Verify that the commodity description (proper shipping name) as well as the
following information is on the container
Exemption numbers for containers shipped under DOT exemptions
The name and address of consignee (or consignor) on the container.
Phase 1 - Section 8
Hazardous Materials Management
8-24
-------
Compliance Category:
Hazardous Materials Management
Regalafory Requirements;
Reviewer Cheeks:
HM31 The facility is
responsible for providing
proper placarding to vehicles
transporting hazardous
materials ofFthe facility (49
CFR 172 500)
Determine if facility vehicles are used to transport hazardous materials off the facility
Determine if proper DOT placards, as described in 49 CFR 172 504 through 172 558,
are affixed to vehicles being used to transport hazardous materials offsite
Determine if transportation has proper DOT placards for vehicles that are being used
for transport of hazardous materials
(NOTE Observe, if practical, the placarding of vehicles used to transport hazardous
materials)
(NOTE See Appendix 8-5 for sample wording of placards )
HM 32 The facility should
ensure that transportation of
hazardous materials between
buildings is accomplished in
accordance with good
management practices to help
ensure against spills, releases,
and accidents (MP)
Determine if procedures exist to manage movement of hazardous materials
throughout the facility
Determine if drivers are trained in spill control procedures
Determine if provisions have been made for securing hazardous materials in vehicles
when transporting
HM 33 A facility that offers
for transport, accepts for
transport, transfers, or otherwise
handles a hazardous material
must have emergency response
information available (49 CFR
172 600 through 172 604)
Verify that emergency response information includes
The description of the hazardous material required by 49 CFR 172 202-203
Immediate hazards to health
Risks of fire or explosion
Immediate precautions to take in the event of an accident or incident
Immediate methods for handling small or large fires
Immediate methods for handling spills or leaks in the absence of fire
Preliminary first aid measures
(NOTE Shipping papers must contain an emergency response telephone number for
the hazardous materials being shipped)
Verify that each carrier and facility operator maintains this emergency response
information
Phase 1 - Section 8
Hazardous Materials Management
8-25
-------
Compliance Category:
Hazardous Materials Management
RegatatoryRequireweats;
Revfew** Checks:
HM 34 Spills, leaks, and other
incidents occurring during
hazardous material
transportation require
immediate notification in
specific circumstances (49 CFR
171.15)
Verify that immediate notification is done for those incidents in which, as a direct
result of hazardous materials
A person is killed
A person is injured and requires hospitalization
Estimated carrier or other property damage exceeds $50,000
An evacuation of the general public occurs lasting 1 or more hours
One or more major transportation arteries or facilities are closed or shut down
for 1 or more hours
The operational flight pattern of an aircraft is altered
Fire, breakage, spillage, or suspected radioactive contamination occurs involving
shipment of radioactive materials
Fire, breakage, spillage, or suspected contamination occurs involving shipment
of etiologic agents
The carrier feels the situation merits reporting, even though it does not meet the
above requirements
Verify that the immediate notification is given to the DOT by telephone
(NOTE. If the notice involves etiologic agents, it may be given to the Centers for
Disease Control and Prevention(CDC))
HM 35 Written hazardous
materials incident reports are
required to be submitted to the
DOT of each hazardous
material incident within 30 days
of the incident (49 CFR
171 16)
Verify that Detailed Hazardous Materials Incident Reports (DHMIRs) are submitted
to the DOT within 30 days if.
Any of the circumstances of 49 CFR 171 15 are met
There has been an unintentional release of hazardous materials from a package
Any quantity of hazardous materials has been discharged during transportation
(NOTE Guidelines for assistance in completing a DHMIR may be obtained free of
charge from the Office of Hazardous Materials Transportation DHM-51, U S
Department of Transportation, Washington DC 20590 )
Verify that a copy of the report is retained onsite for 2 years (unless written
permission has been obtained from the DOT to maintain records elsewhere)
Phase 1 - Section 8
Hazardous Materials Management
8-26
-------
Compliance Category:
Hazardous Materials Management
Rego&tctfyRecjuirentents;
HM 36. Facilities are required
to train each of its employees
involved in the transportation of
hazardous materials according
to specific requirements (49
CFR 172.704(a), 172 704(b),
172 704(c)(3), 172.704(c)(4),
172.704(e), and 173 1(b))
(NOTE- Training conducted by facilities to comply with the hazard communication
programs required by OSHA, The Department of Labor (29 CFR 1910 120), or the
EPA (40 CFR 311.1) may be used to satisfy these requirements to the extent that the
training addresses the requirements)
(NOTE Relevant training received by the employee from a previous employer or
other source may be used to satisfy these requirements, provided a current record of
the training is obtained from the employee's previous employer)
Verify that each employee is provided with general awareness/familiarization training
designed to do the following
Provide familiarity with the requirements of 49 CFR 171 through 177
Enable each employee to recognize and identify hazardous materials consistent
with the hazard communication standards of 49 CFR 171 through 177
Verify that each employee is provided with function-specific training concerning
those requirements of 49 CFR 171 through 177 that are specifically applicable to the
functions the employee performs
(NOTE Training related to the requirements of the ICAO Technical Instructions and
the IMDG Code may be provided as an alternative to function-specific training on the
requirements of 49 CFR 171 through 177 to the extent such training addresses
functions authorized by 49 CFR 171 11 and 171 12)
Verify that each employee is provided with function-specific training concerning
exemptions issued under 49 CFR 106, 107, and 110 that are specifically applicable to
the functions the employee performs
Verify that each employee is provided with safety training concerning the following:
Emergency response information
Methods and procedures for avoiding accidents, such as the proper procedures
for handling packages containing hazardous materials
Measures to protect the employee from the hazards associated with hazardous
materials to which they may be exposed to in the workplace, including specific
measures the employer has implemented to protect employees from exposure
(NOTE This requirement does not apply to an employee who repairs, modifies,
reconditions, or tests packaging as qualified for use in the transportation of hazardous
materials, and who does not perform any other function subject to the requirements of
49 CFR 171 through 177)
Phase 1 - Section 8
Hazardous Materials Management
8-27
-------
Compliance Category*
Hazardous Materia)* Management
RegafstwyReguiremeofSi
Reviewer Checks:
HM 37. Facility employees that
operate motor vehicles
transporting hazardous
materials must be appropriately
trained (49 CFR 177 816(a) and
177 816(c))
(NOTE- This requirement may be met by compliance with the current requirements
for a Commercial Driver's License (CDL) with a tank vehicle or hazardous materials
endorsement)
Verify that the motor carrier does not transport (or cause to be transported) a
hazardous material unless each hazardous material employee who will operate a
motor vehicle has been trained in the following
The applicable requirements prescribed in 49 CFR 390 through 397
The procedures necessary for the safe operation of that vehicle
Verify that each driver receives driver training that includes the following subjects-
Pretrip safety inspection
Use of vehicle controls and equipment, including operation of emergency
equipment
Procedures for maneuvering tunnels, bridges, and railroad crossings
Requirements pertaining to attendance of vehicles, parking, smoking, routing,
and incident reports
Loading and unloading of materials, including load securement, package
handling methods, and compatibility and segregation of cargo in a mixed load
Operation of the vehicle, including turning, backing, braking, parking, and
handling
Vehicle characteristics, including those that affect vehicle stability, such as
effects of braking and curves
effects of speed on vehicle control
dangers associated with maneuvering through curves
dangers associated with weather or road conditions that a driver may
experience
high center of gravity
Phase 1 - Section 8
Hazardous Materials Management
8-28
-------
Compliance Category:
Hazardous Materials Management
Regalat&jyRfi^ttireiBeofe;
I&vfew Checks:
HM 38 Facility employees that
operate cargo tanks or vehicles
with portable tanks having a
capacity of 1,000 gal or more of
hazardous materials must be
appropriately trained (49 CFR
177.816(b) through
177 826(d)).
(NOTE This requirement may be met by compliance with the current requirements
for a COL with a tank vehicle or hazardous materials endorsements )
Verify that each hazardous material employee who operates a cargo tank or vehicle
with a portable tank with a capacity of 1000 gal or more receives training applicable
to the requirements of 49 CFR 171 through 177
Verify that each employee has the appropriate state-issued CDL
Verify that each employee receives specialized training that includes the following
subjects
Operation of emergency control features of the cargo tank and portable tank
Retest and inspection requirements for cargo tanks
Loading and unloading procedures
The properties and hazards of the materia) transported
Special vehicle handling characteristics, including the following'
high center of gravity
fluid load subject to surge
effects of fluid-load surge on braking
characteristic differences in stability among baffled, unbaffled, and multi-
compartmented tanks
effects of partial loads on vehicle stability.
HM 39. Facilities must meet
specific requirements regarding
training schedules (49 CFR
172 704(c)(1) through
172 704(c)(3)).
Verify that training for an employee hired on or before 2 July 1993 is completed prior
to 1 October 1993
Verify that training for an employee hired after 2 July 1993 is completed within 90
days after employment.
Verify that an employee who changes hazardous materials job functions completes
training in the new job function(s) within 90 days after the change.
(NOTE: An employee may perform new hazardous materials job functions prior to
the completion of training provided that the employee performs those functions under
the supervision of a properly trained and knowledgeable employee )
Verify that the employee receives the required training at least once every 2 years
Phase 1 - Section 8
Hazardous Materials Management
8-29
-------
Compliance Category*
Htttttrdous Materials Maa»gem«rt
Regafafojy
Review** Checks:
HM 40. Facilities are required
to maintain training records (49
CFR 172 704(d))
Verify that a record of current training, inclusive of the preceding two years, is
created and retained by the facility for each employee for as long as that employee is
employed by the facility as an employee and for 90 days thereafter
Verify that the record includes the following:
The employee's name
The most recent training completion date of the employee's training
A description, copy, or the location of the training materials used
The name and address of the person providing the training
Certification that the employee has been trained and tested.
Radioactive Materials
HM 41. Personnel working
around radioactive materials are
required to be notified of
specific information and then
trained (29 CFR 1910 96(i))
Verify that all individuals working in or frequenting any portion of a radiation area
are
Informed of the existence of radioactive materials
Instructed in the safety problems associated with exposure to such materials and
radiation, and in precautions or devices to minimize exposure
Advised of reports that must be made concerning exposure
Verify that the facility has conspicuously posted a current copy of its provisions and
operating procedures in locations where radioactive materials are found or keeps the
documents in a place where they are available upon request.
HM.42. Specific notification
requirements must be met for
radioactive material incidents
(29 CFR 1910 96(1) and
1910 96(m))
Verify that the facility notifies the Assistant Secretary of Labor (or the duly appointed
representative) by telephone or telegraph of any incident that may have caused or
threatened to cause
Exposure of the whole body or any individual to 25 rems or more of radiation
Exposure of the skin or the whole body of any individual to 150 rems or more of
radiation
Exposure of the feet, ankles, hands, or forearms of any individual to 375 rems or
more of radiation
Verify that the facility notifies the Assistant Secretary of Labor or his duly appointed
representative by telephone or telegraph of any incident that may have caused or
threatens to cause the release of radioactive material in concentrations which, if
averaged over a period of 24 hours, would exceed 5,000 times the limits specified m
Table II, Appendix B, 10 CFR 20
Verify that notification is made within 24 hours of-
Exposure of the whole body or any individual to 5 rems or more of radiation
Exposure of the skin or the whole body of any individual to 30 rems or more of
radiation
Exposure of the feet, ankles, hand, or forearms to 75 rems or more of radiation
Verify that a written report of overexposure is made within 30 days.
Phase 1 - Section 8
Hazardous Materials Management
8-30
-------
Compliance Category:
Hazardous Materials Management
KegttktofyRequirewetttfc
Checks:
HM 43 Specific signs are
required in radiation areas (29
CFR 1910 96(e)(1) through
1910 96(e)(3)(i), 1910 96(e)(4)
through 1910 96(e)(5), and
1910 96(g))
Verify that each radiation area is posted with a conspicuous sign or signs bearing the
radiation symbol and the words CAUTION, RADIATION AREA
Verify that each high-radiation area is posted with a conspicuous sign or signs bearing
the radiation symbol and the words CAUTION, HIGH-RADIATION AREA.
Verify that each airborne radioactive area is posted with a conspicuous sign or signs
bearing the radiation symbol and the words CAUTION, AIRBORNE
RADIOACTIVITY AREA
Verify that each area or room in which radioactive material is used or stored and
which contains any radioactive material (other than natural uranium or thorium) in
any amount exceeding 10 times the quantity of such material specified in Appendix C
of 10 CFR 20 is conspicuously posted with a sign or signs bearing the radiation
caution symbol and the words CAUTION, RADIOACTIVE MATERIALS
(NOTE. The following are exempted from sign posting requirements
A room or an area with a sealed source when the radiation level 12 in from the
surface of the source container or housing does not exceed 5 mrems/hour
Rooms or other areas containing radioactive material for periods of less than 8
hours if.
the materials are constantly attended during such periods by an individual
who takes appropriate precautions
the room is under the control of the facility.)
HM 44. Containers of
radioactive materials are
required to be labeled according
to specific standards (29 CFR
1910 96(e)(6) and 1910 96(h))
Verify that each container that is used to transport, store, or hold a quantity of
radioactive material (other than natural uranium or thorium) greater than the quantity
of the material specified in Appendix C, 10 CFR 20 bears a durable, clearly visible
label with the radiation caution symbol and the words CAUTION, RADIOACTIVE
MATERIAL.
(NOTE' A label is not required if:
The concentration of the material in the containers does not exceed that specified
in Appendix C, 10 CFR 20
The containers are laboratory containers such as beakers, flasks, and test tubes
used transiently in laboratory procedures, and the user is present.)
Verify that when containers are used for storage, the labels also state the quantities
and kinds of radioactive materials in the containers as well as the date of measurement
of the quantities
(NOTE Radioactive materials packaged and labeled according to DOT rules do not
have to be labeled according to these requirements if the inside containers are labeled
according to these requirements )
Phase 1 - Section 8
Hazardous Materials Management
8-31
-------
Compliance Category:
Hazardous Materials Management
RegafeMoty Rctfuirewe&tfc
Jfcvtewer Checks:
HM 45 High-radiation areas
are required to be equipped
with specific control devices
(29 CFR 1910 96(e)(3)(H))
Verify that each high-radiation area is equipped with a control device that either
causes the level of radiation to be reduced below the level at which an individual
might receive a dose of 100 mrems in 1 hour upon entry into the area or energizes a
conspicuous visible or audible alarm signal so that the individual entering and the
supervisor of the activity are aware of the entry
(NOTE This requirement does not apply to high radiation areas established for a
period of 30 days or less)
HM 46 Radioactive materials
stored in a nonradiation area
must be secured against
unauthorized removal from the
place of storage (29 CFR
1910 960))
Verify that radioactive materials are stored in a manner that they are secured against
unauthorized removal
Phase 1 - Section 8
Hazardous Materials Management
8-32
-------
Section 8
Hazardous Materials Management
Appendices
-------
Appendix 8-1
Maximum Allowable Capacity of Containers
and Portable Tanks
(29 CFR 1910.106(d)(2), Table H-12)
*
%pc
^ u - *
IC >
H 1
; m
Glass or approved plastic
1 pt (0 47 L)
1 qt (0 95 L)
1 gal (3 79 L)
1 gal (3 79 L)
1 gal (3 79 L)
Metal (other than DOT
drums)
1 gal (3 79 L)
5 gal (18 93 L)
5 gal (18 93 L)
5 gal (18 93 L)
5 gal (18 93 L)
Safety cans
2 gal (7 57 L)
5 gal (18 93 L)
5 gal (18 93 L)
5 gal (18 93 L)
5 gal (18 93 L)
Metal drums (DOT
specifications)
60 gal
(227 12 L)
60 gal
(227 12 L)
60 gal
(227 12 L)
60 gal
(227 12 L)
60 gal
(227 12 L)
Approved portable tanks
660 gal
(2498 37 L)
660 gal
(2498 37 L)
660 gal
(2498 37 L)
660 gal
(2498 37 L)
660 gal
(2498 37 L)
A8-1
-------
Appendix 8-2
Storage in Inside Rooms
(29 CFR 1910.106(d)(4), Table H-13)
"
'sW",:rT"1"""
Yes
2
500 ft2 (46 45 m2)
10(37.85 L)
No
2
500 ft2 (46.45 m2)
4(15.14 L)
Yes
1
150 ft2 (13.94 m2)
5 (18.93 L)
No
1
150 ft2 (13.94 m2)
2(7.57 L)
1 Fire protection system will be sprinkler, water spray, or other approved method.
2 If metric containers are being stored, use the nearest metric equivalent
A8-2
-------
Appendix 8-3
Flammable/Combustible Materials
(29 CFR 1910.106(d)(5) and 1910.106(d)(6), Tables H-14 through H-17)
Indoor Container Storage
*
Storage
..UttpotMad Storage
A
Ground and upper floors
Basement
2,750 gal (10,409 88 L)
(50)
Not permitted
600 gal (2,271.25 L)
(12)
Not permitted
B
Ground and upper floors
Basement
5,500 gal (20,819 77 L)
(100)
Not permitted
1,375 gal (5,204.94 L)
(25)
Not permitted
C
Ground and upper floors
Basement
16,500 gal (62,459 30 L) (300)
Not permitted
4,125 gal (15,614 82 L)
(25)
Not permitted
II
Ground and upper floors
Basement
16,500 gal (62,459 30 L) (300)
5,500 gal (20,819 77 L)
(100)
4,125 gal (15,614.82 L)
(75)
Not permitted
III
Ground and upper floors
Basement
55,000 gal (208,197.66 L)
(1,000)
8,250 gal (31,229 65 L)
(450)
13,750 gal (52,049 42 L) (250)
Not permitted
Numbers in parenthesis indicate corresponding number of 55-gal drums.
NOTE 1: When two or more classes of materials are stored in a single pile, the maximum gallonage permitted in
that pile will be the smallest of the two or more separate maximum gallonages
NOTE 2. Aisles will be provided so that no container is more than 12 ft (3 66 m) from an aisle. Main aisles will
be at least 8 ft (2.44 m) wide and side aisles at least 4 ft (1.22 m) wide
NOTE 3. Each pile shall be separated from the others by at least 4 ft (1 22 m).
A8-3
-------
Appendix 8-3 (continued)
Flammable/Combustible Materials
(29 CFR 1910.106(d)(5) and 1910.106(d)(6), Tables H-14 through H-17)
Outdoor Container Storage
: •*" <_ s v.
Class-"
MraifttttH) jwar pile
(ft) <»)
public my -
#t) m ,
IA
1100 (4163 95)
5 (1 52)
20 (6 10)
10 (3 05)
IB
2200(8327 91)
5(1.52)
20 (6 10)
10 (3.05)
tc
4400(44003.79)
5 (I 52)
20 (6 10)
10 (3.05)
II
8800 (33311.63)
5 (1 52)
10 (3.05)
5(1.52)
III
22,000 (83279.06)
5(1.52)
10 (3 05)
5(1.52)
NOTE 1: When two or more classes of materials are stored in a single pile, the maximum gallonage permitted in
that pile will be the smallest of the two or more separate gallonages
NOTE 2. Within 200 ft (60 96 m) of each container, there will be a 12-ft (3.66-m) wide access way to permit
approach of Fire control apparatus.
NOTE 3. The distances listed apply to properties that have protection for exposures as defined. If there are
exposures, and such protection for exposures does not exist, the distances in column 3 will be doubled.
NOTE 4: When total quantity stored does not exceed 50 percent of maximum per pile, the distance in columns 4
and 5 may be reduced 50 percent, but not less than 3 ft (0.91 m)
A 8-4
-------
Indoor Portable Tank Storage
r %
IA
Ground and upper floors
Basement
Not permitted
Not permitted
Not permitted
Not permitted
IB
Ground and upper floors
Basement
20,000 (75,708 24)
Not permitted
2000 (7,570 82)
Not permitted
IC
Ground and upper floors
Basement
40,000(151,420 48)
Not permitted
5500 (20,820.32)
Not permitted
II
Ground and upper floors
Basement
40,000(151,420.48)
20,000 (75,708.24)
5500 (20,820.32)
Not permitted
III
Ground and upper floors
Basement
60,000 (227,124 72)
20,000 (75,708.24)
22,000 (83,279.06)
Not permitted
NOTE 1 When one or more classes of materials are stored in a single pile, the maximum gallonage permitted in
that pile will be the smallest of the two or more separate maximum gallonages
NOTE 2- Aisles will be provided so that no container is more than 12 ft (3 66 m) from an aisle. Main aisles will
be at least 8 ft (2 44 m) wide and side aisles at least 4 ft (1.22 m) wide.
NOTE 3. All piles shall be separated from each other by at least 4 ft (1 22 m).
A8-5
-------
Outdoor Portable Tank Storage
rjflae
; v«h99
Masfewa® just
"J
¦fjmtom&i wtwsm;.. - -;
:¦
IA
2,200 (8,327.95)
5(1.52)
20(6.10)
10 (3.05)
IB
4,400 (44,003 79)
5 (1 52)
20 (6 10)
10 (3.05)
IC
8,800(33,311 63)
5 (1 52)
20 (6 10)
10 (3.05)
II
17,600 (66,623 25)
5 (1 52)
10 (3 05)
5(1.52)
III
44,000 (166,558 12)
5(1.52)
10(3.05)
5(1.52)
NOTE 1: When two or more classes of materials are stored in a single pile, the maximum gallonage permitted in
that pile will be the smallest of the two or more separate gallonages
NOTE 2. Within 200 ft (60 96 m) of each container, there will be a 12-ft (3 66-m) wide access way to permit
approach of fire control apparatus.
NOTE 3 The distances listed apply to properties that have protection for exposures as defined. If there are
exposures, and such protection for exposures does not exist, the distances in column 3 will be doubled.
NOTE 4: When total quantity stored does not exceed 50 percent of maximum per pile, the distance in columns 4
and 5 may be reduced 50 percent, but not less than 3 ft (0.91 m).
A8-6
-------
Appendix 8-4
Potentially Incompatible Hazardous Materials
{Law, Regulations, and Guidelines for Handling of Hazardous Waste, California Department of Health, February
1975 (40 CFR 264, Appendix V))
Below are examples of potentially incompatible materials, along with the harmful consequences that result from
mixing materials in one group with materials m another group. The list is intended as a guide to indicate the need
for special precautions when managing these potentially incompatible waste materials or components This list is
not intended to be exhaustive.
In the lists below, the mixing of a Group A material with a Group B material may have the potential consequences
as noted.
1 ^
Acetylene sludge
Acid sludge
Alkaline caustic liquids
Acid and water
Alkaline cleaner
Battery acid
Alkaline corrosive liquids
Chemical cleaners
Alkaline corrosive battery acid
Electrolyte, acid
Caustic wastewater
Etching acid liquid or solvent
Lime sludge and other corrosive alkalies
Pickling liquor and other corrosive acids
Lime wastewater
Spent acid
Lime and water
Spent mixed acid
Spent caustic
Spent sulfuric acid
Potential Consequences: Heat generation; violent reaction.
1:
Aluminum
Any waste in Group 1-A or 1-B
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder
Other reactive metals and metal hydrides
Potential Consequences: Fire or explosion; generation of flammable hydrogen gas.
A8-7
-------
Appendix 8-4 (continued)
Potentially Incompatible Hazardous Materials
&re«|>3»A ~°
Alcohols
Any concentrated waste in Groups 1-A or 1-B
Water
Calcium
Lithium
Metal hydrides
Potassium
S02, CI2, SOCI2, PCI3, CHj, S1CI3
Other water-reactive waste
Potential Consequences: Fire or explosion or heat generation; generation of flammable or toxic gases.
Alcohols
Concentrated Group 1-A or Group 1-B wastes
Aldehydes
Group 2-A wastes
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and solvents
Potential Consequences: Fire or explosion; violent reaction.
<5foaj>$«A - ^
. .. Gwupsa. ^
Spent cyanide and sulfide solutions
Group 1-B wastes
Potential Consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.
A 8-8
-------
Appendix 8-4 (continued)
Potentially Incompatible Hazardous Materials
"" <¦ " ^
- ""VT v;; % -
Chlorates
Acetic acid and other organic acids
Chlorine
Concentrated mineral acids
Chlorites
Group 2-A wastes
Chromic acid
Group 4-A wastes
Hypochlorites
Other flammable and combustible wastes
Nitrates
Nitric acid, fuming
Perchlorates
Permanganates
Perioxides
Other strong oxidizers
Potential Consequences: Fire, explosion; or violent reaction.
A8-9
-------
Appendix 8-5
Placarding Guidelines
The following table specifies placards that should be used for the transportation of ANY QUANTITY of the listed
hazardous material.
%'
s Materials <
v
J&Am
v., S -W
A AS
W s S ¦. V.V.'. SS f s W.s Ss ^ V s '
..•X s. % , % s
s s Vb «b ••
*• •*
'4 ,
% Iv
s
Class A Explosives
EXPLOSIVES A
Class B Explosives
EXPLOSIVES B
Poison A
POISON GAS
Flammable Solid
FLAMMABLE SOLID
(NOTE. Any of the above substances that are dangerous when wet should also have the placard- DANGEROUS
WHEN WET, in addition to their primary placard )
The following table specifies placards that should be used for the transportation of 1,000 lb or more of the listed
hazardous materials
s ^sv. ss s jf?n mm/* J.....A.':*.. " "" Vs<- s
s s s s I s s s *¦ %%. . i
N s ^s .. s ^<.V V s
d*
JPteeanfe "V -V
"• \w>
Class C Explosives
FLAMMABLE
Nonflammable Gas
NONFLAMMABLE GAS
Nonflammable Gas (Chlorine)
CHLORINE
Nonflammable Gas (Fluorme)
POISON
Nonflammable Gas (Oxygen, pressurized liquid)
OXYGEN
Flammable Gas
FLAMMABLE GAS
Combustible Liquid
COMBUSTIBLE
Flammable Liquid
FLAMMABLE
Flammable Solid
FLAMMABLE SOLID
Oxidizer
OXIDIZER
Organic Perioxide
ORGANIC PERIOXIDE
Posion B
POISON
Corrosive Material
CORROSIVE
Irritating Material
DANGEROUS
1. Placards should be affixed on both sides, rear and front, of the motor vehicle
2. Place placards clear of ladders, pipes, and tarps
3. Placards should be at least 3 in. away from advertising and markings
4. The DANGEROUS placards may be used when a motor vehicle contains two or more classes of hazardous
materials requiring different placards The DANGEROUS placard may be used in place of the separate
placards for each class.
5 Portable tanks having a rated capacity of 1000 gal or more must be placarded
6 Cargo tanks having any quantity of hazardous material must be placarded
A8-10
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Phase 1
Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
-------
Phase 1
Section 9
Table of Contents
Emergency Planning and Community Right-to-Know (EPCRA)
A. Applicability 9-1
B Federal Legislation 9-1
C. State/Local Regulations 9-2
D. Key Compliance Requirements 9-2
E. Key Compliance Definitions 9-3
F. Records to Review 9-6
G Physical Features to Inspect 9-6
H. Guidance for Checklist Users 9-7
Appendices
A9-1. Consolidated List of Chemicals Covered in Title III of SARA
A9-1
-------
A. Applicability
This section addresses facilities that manufacture, process, store, or otherwise use Extremely
Hazardous Substances (EHSs), as defined in 40 CFR 355, and toxic chemicals, as defined in 40
CFR 372.
Assessors are required to review agency, Federal, state, and local regulations to perform a
comprehensive assessment.
B. Federal Legislation
1. The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
This Act, also known as SARA Title III, was designed to promote emergency planning and
preparedness at both the state and local level. It provides citizens, local governments, and local
response authorities with information regarding the potential hazards in their community.
EPCRA requires the use of emergency planning and designates state and local governments as
recipients for information regarding certain chemicals used in the community
2. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
the agency funds meet applicable Federal, state, and local environmental requirements and for
correcting situations that are not in compliance with such requirements. In addition, the EO
requires that each agency ensure that sufficient funds for environmental compliance are included
in the agency budget.
3. EO 12856, Federal Compliance With Right-to-Know Laws and Pollution Prevention
Requirements
This EO, dated 3 August 1993, requires the heads of Federal agencies to develop a written
pollution prevention strategy for their agencies The head of each agency shall ensure that each
of its covered facilities develops a written pollution prevention plan no later than the end of
1995. Federal agencies are required to conduct assessments of their facilities as necessary to
ensure development of these plans and of the facilities pollution prevention program. Each
Federal agency will also develop voluntary goals to reduce the agency's total releases of toxic
chemicals to the environment, and to ensure that offsite transfers of such chemicals for treatment
and disposal are publicly reported. This also requires Federal agencies to comply with the
provisions of EPCRA, because Previous to the EO, Federal agencies were exempted from
compliance with EPCRA. As a result of EO 12856, Federal agencies that either own or operate a
"facility", as that term is defined in Section 329(4) of EPCRA, must now comply with EPCRA as
such facility meets the threshold requirements set forth in the regulations.
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-1
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4. Pollution Prevention Act of 1990 (PPA)
In 1990, Congress enacted the Pollution Prevention Act (PPA) aimed at preventing or
reducing pollution at the source whenever feasible; pollution that cannot be prevented should be
recycled in an environmentally safe manner whenever feasible; pollution that cannot be
prevented or recycled should be treated in an environmentally safe manner whenever feasible;
and disposal or other release into the environment should be employed only as a last resort and
conducted in an environmentally safe manner. The PPA required owners or operators of
facilities required to file an annual toxic chemical release form under EPCRA Section 313 to also
include with each annual filing a toxic chemical source reduction and recycling report for the
preceding calendar year. Not only did EO 12856 require Federal agencies to comply with the
provisions of EPCRA and file Toxic Release Inventory (TRI) reports for those chemicals
exceeding thresholds, it also requires Federal facilities to prepare pollution prevention plans.
C. State/Local Regulations
State and local emergency response agencies may establish more stringent reporting
requirements and may require the use of a state-specific inventory reporting form.
D. Key Compliance Requirements
1. Emergency Planning
A facility with extremely hazardous substances in amounts equal to or greater than the limits
found in Appendix 9-1 are required to notify the emergency response commission and designate
a representative to participate in local emergency planning (40 CFR 355.10 through 355.30 and
355 Appendix A).
2. Right-to-Know Requirements
Facilities which are required to prepare or have available a Material Safety Data Sheet
(MSDS) for a hazardous chemical under OSHA are required to submit the MSDSs to the
emergency commission and the fire department with jurisdictions over the facility for each
hazardous chemical present at the facility according to the following thresholds by 3 August
1994:
• For all hazardous chemicals present at the facility at any one time in amounts equal to or
greater than 10,000 lb (4540 kg) (not all hazardous chemicals requiring an MSDS are listed
in Appendix 9-1); and
• For all extremely hazardous substances present at the facility in amounts greater than or
equal to 500 lb (227 kg) or the threshold planning quantity (see Appendix 9-1).
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-2
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But, instead of submitting the MSDSs, the facility has the option to submit
• A list of hazardous chemicals for which the MSDS is required, grouped by hazard category,
• The chemical or common name of each hazardous chemical, and
• Any hazardous component of each hazardous chemical except when reporting mixture
3. Emergency and Hazardous Chemical Inventory Forms
Section 312 of EPCRA requires subject facilities to submit annual Emergency and
Hazardous Chemical Inventory forms to the state emergency response commission, the local
emergency planning committee, and the fire department having jurisdiction over the facility
The inventory form (Tier I) indicates chemical categories, quantities, and locations of chemicals
on site Additionally, more detailed information may be requested by state agencies, in which
case facilities would submit a Tier II form to emergency response organizations, which includes
more detailed chemical information. The reporting under this requirement does not include
accidental releases or permitted discharges and is specifically targeted toward chemicals present
on site for emergency response planning activities.
4. Toxic Chemical Release Reporting
Section 313 of EPCRA requires annual reporting to the Federal and state governments of all
releases of "toxic materials" (listed at 40 CFR 372.65) to the environment that occur as a result of
normal operations. Facilities subject to this requirement must complete and submit to EPA and
state officials a toxic chemical release form (Form R) for each toxic chemical manufactured,
processed, or otherwise used in quantities exceeding established minimum threshold values
during the preceding calendar year. EO 12856 requires Federal facilities to comply with Section
313 reporting regardless of the facility's Standard Industrial Classification (SIC) code, if the
facility manufactured, processed, or otherwise used a listed toxic chemical in excess of specified
threshold quantities.
5. Release Reporting
Section 304 of EPCRA establishes the reporting requirements for facilities that release any
extremely hazardous substance listed in 40 CFR 355. EPCRA release reporting requirements
apply to any facility where a hazardous chemical is produced, used, or stored and where there is a
release of a reportable quantity of CERCLA hazardous substance (listed at 40 CFR 302) or any
extremely hazardous substance (listed at 40 CFR 355).
E. Key Compliance Definitions
1. Article
A manufactured item-
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-3
-------
a. which is formed to a specific shape or design during manufacture;
b. which has end-use functions dependent in whole or in part upon its shape or design
during end use; and
c. which does not release a toxic chemical under normal conditions of processing or use of
that item at the facility or establishments (40 CFR 372.3).
2. Commission
The emergency response commission for the state in which the facility is located except
where the facility is located in Indian Country, in which case commission means the emergency
response commission for the tribe under whose jurisdiction the facility is located. In absence of
an emergency response commission, the Governor and the chief executive officer, respectively,
shall be the commission. Where there is a cooperative agreement between a state and a tribe, the
commission shall be the entity identified in the agreement (40 CFR 355.20, 370.2).
3. Committee or Local Emergency Planning Committee
The local emergency planning committee appointed by the emergency response commission
(40 CFR 355 20, 370.2).
4. Extremely Hazardous Substance
A substance listed in the Appendices to 40 CFR Part 355, Emergency Planning and
Notification (40 CFR 355.20, 370.2).
5. Facility
All buildings, equipment, structures, and other stationary items that are located on a single
site or on contiguous or adjacent sites and that are owned or operated by the same person (or by
any person which controls, is controlled by, or is under common control with, such person). The
facility shall include manmade structures as well as all natural structures in which chemicals are
purposefully placed or removed through human means such that it functions as a containment
structure for human use. For purposes of emergency release notification, the term includes motor
vehicles, rolling stock, and aircraft (40 CFR 355.20, 370.2, 372.3).
6. Hazardous Chemical
Any hazardous chemical as defined under 29 CFR 1910.1200(c), except where such term
does not include the following substances (40 CFR 355.20, 370.2)
• Any food, food additive, color additive, drug, or cosmetic regulated by the Food and Drug
Administration;
• Any substance present as a solid in any manufactured item to the extent that exposure to the
substance does not occur under normal conditions of use;
• Any substance to the extent it is used for personal, family, or household purposes, or is
present in the same form and concentration as a product packaged for distribution and use by
the general public;
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-4
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• Any substance to the extent it is used in a research laboratory or a hospital or other medical
facility under the direct supervision of a technically qualified individual; and
• Any substance to the extent it is used in routine agricultural operations or is fertilizer held
for sale by a retailer to the ultimate customer.
7. Import
To cause a chemical to be imported into the customs territory of the United States. For
purposes of this definition, to cause means to intend that the chemical be imported and to control
the identity of the imported chemical and the amount to be imported (40 CFR 372.3).
8. Inventory Form
The Tier I and Tier II emergency and hazardous chemical inventory forms set forth in
Subpart D of 40 CFR 370 (40 CFR 370 2).
9. Material Safety Data Sheet or MSDS
The sheet required to be developed under 29 CFR 1910.1200(g) (40 CFR 370 2).
10. Manufacture
To produce, prepare, import, or compound a toxic chemical. Manufacture also applies to a
toxic chemical that is produced coincidentally during the manufacture, processing, use, or
disposal of another chemical or mixture of chemicals, including a toxic chemical that is separated
from that other chemical or mixture of chemicals as a byproduct, and a toxic chemical that
remains in that other chemical or mixture of chemicals as an impurity (40 CFR 372.3)
11. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
12. Mixture
Any combination of two or more chemicals, if the combination is not, in whole or in part,
the result of a chemical reaction. However, if the combination was produced by a chemical
reaction but could have been produced without a chemical reaction, it is also treated as a mixture
A mixture also includes any combination that consists of a chemical and associated impurities
(40 CFR 372.3).
13. Otherwise Use of Use
Any use of a toxic chemical that is not covered by the terms manufacture or process and
includes use of a toxic chemical contained in a mixture or trade name product. Relabeling or
redistributing a container of a toxic chemical where no repackaging of the toxic chemical occurs
does not constitute use or processing of the toxic chemical (40 CFR 372 3).
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-5
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14. Process
The preparation of a toxic chemical, after its manufacture, for distribution in commerce (40
CFR 372.3):
• In the same form or physical state as, or in a different form or physical state from, that in
which it was received by the person preparing such substance, or
• As part of an article containing the toxic chemical.
• Process also applies to the processing of a toxic chemical contained in a mixture or trade
name product.
15. Release
Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, or disposing into
the environment (including the abandonment or discarding of barrels, containers, and other
closed receptacles) of any toxic chemical (40 CFR 355.20, 372.3).
16. Threshold Planning Quantity or TPQ
The threshold planning quantity for an extremely hazardous substance as defined in 40 CFR
355 (40 CFR 355 20).
17. Toxic Chemical
A chemical or chemical category listed in 40 CFR 372.65 (40 CFR 372.3).
F. Records to Review
• Chemical inventory
• Previous Tier I/Tier II reports
• Toxic Release Inventory (TRI) reports (TRI or Form R)
• Pollution prevention plan
• MSDSs
G. Physical Features to Inspect
• Chemical storage areas
• Chemical manufacturing areas
• Recordkeeping system
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-6
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H. Guidance to Checklist Users
Refer To
Checklist Items
Page Numbers
All Facilities
E 1 through E 3
9-8
Releases
E 4
9-9
E 5
9-10
E 6 through E 7
9-11
E 8
9-12
Pollution Prevention
E 9
9-13
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-7
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Compliance Category:
Emergency PtetmNg and Community Rjgbw^Kn&w (EPCRA)
Regulatory Requirements:
Reviewer Cbec}®;
All Facilities
E 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violations (NOVs), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements, or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
E 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding)
Determine if any new regulations have been issued since the finahzation of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities that are federally regulated but not
addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
E 3 Facilities are required to
abide by state and local
regulations concerning
hazardous materials (EO 12088,
Section
1-1)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
- Transportation of hazardous materials
- Notification requirements
- Response plan requirements
- Spill response requirements)
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-8
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Compliance Category:
EraergencyJtanmag ant* Community RigbHo-Know (EPCRA)
Regulatory Requirements:
Reviewer Ctiecks:
Releases
E 4 Facilities where any
hazardous chemical is used or
stored at which there is a
release of a reportable quantity
of any extremely hazardous
substance in amounts equal to
or greater than the threshold
limits (see Appendix 9-1) are
required to provide emergency
release notification (EO 12856,
40 CFR 355 40 and Part 355
Appendix A)
Determine if the facility has any of the extremely hazardous substances in amounts
equal to or greater than those listed in Appendix 9-1
Determine if there has been a spill of an extremely hazardous substance in an amount
exceeding the reportable quantity
Verify that if a spill has occurred in excess of the reportable quantity, the facility
immediately notified the
- Community emergency coordinator for the local emergency planning committee of
any area likely to be affected by the release
- State emergency response commission of any state likely to be affected by the
release
- Local emergency response personnel if there is no local emergency planning
committee
Verify that the notice contains the following, to the extent known at the time of
notice, so long as no delay in notice or emergency response results
- The chemical name or identity of any substance involved in the release
- An indication of whether the substance is an extremely hazardous substance
- An estimate of the quantity of any such substance that was released into the
environment
- The time and duration of the release
- The medium or media into which the release occurred
- Any known or anticipated acute or chronic health risks associated with the
emergency, and, where appropriate, advice regarding medical attention necessary
for exposed individuals
- Proper precautions to take as a result of the release, including evacuation (unless
such information is readily available to the community emergency coordination
because of the local emergency plan)
- The names and telephone numbers of the person or persons to be contacted for
further information
Verify that after the immediate verbal notification, a follow-up written emergency
notification is produced which contains the same information detailed in the verbal
notice plus
- Actions taken to respond to and contain the release
- Any known or anticipated acute or chronic health risks associated with the risk
- Advice regarding medical attention necessary for exposed individuals, as needed
(NOTE These release notification requirements do not apply to the following
- Any release that results in exposure to persons solely within the boundary of the
facility
- Any release that is a federally permitted release as defined in CERCLA
- Any release that is continuous and stable in quantity and rate
- Any release of a pesticide product exempt from CERCLA reporting
- Any release not meeting the definition of a release )
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-9
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* -< 0< ^
BBMBK i
;iiir <***«/ ?? j - -. * - % ., ^; xtzx . :ii
E 5 Facilities required to
prepare or have available a
MSDS for a hazardous
chemical under OSHA are
required to meet specific MSDS
reporting requirements for
planning purposes (EO 12856,
40 CFR370 20, 370 21, and
370.28)
Verify that MSDs are submitted to the emergency commission and the fire department
with jurisdictions over the facility for each hazardous chemical present at the facility
according to the following thresholds by 3 August 1994-
- For all hazardous chemicals present at the facility at any one time in amounts equal
to or greater than 10,000 lb (4,540 kg) (not all hazardous chemicals requiring an
MSDS are listed in Appendix 9-1)
- For all extremely hazardous substances present at the facility in amounts greater
than or equal to 500 lb (227 kg) or the threshold planning quantity, whichever is
lower (see Appendix 9-1).
(NOTE Commonly overlooked substances requiring a an MSDS are propane and
petroleum-based fuels)
Verify that if the facility has not submitted MSDSs, the following have been
submitted
- A list of hazardous chemicals for which the MSDS is required, grouped by hazard
category
- The chemical or common name of each hazardous chemical
- Any hazardous component of each hazardous chemical except when reporting
mixture
Verify that revised MSDS sheets are provided within 3 months after the discovery of
significant new information concerning the hazardous chemical.
(NOTE The facility may fulfill these reporting requirements for a hazardous
chemical that is a mixture of hazardous chemicals by doing one of the following
- Providing the required information on each component in the mixture that is a
hazardous chemical
- Providing the required information on the mixture itself)
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-10
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Compliance Category:
Emergency JMaimteg and Community Rlght-to-Know (EPCRA)
Regulatory Reqwr
-------
Compliance Category:
Emergency Planning and Community Right-to-Know (EPCRA)
Regulatory Requirements:
Review Checks;
E 8 Facilities where there are
extremely hazardous substances
present in amounts equal to or
greater than the threshold limits
found in Appendix 9-1 are
required to follow specific
emergency planning procedures
(EO 12856, 40CFR355 30,
and Part 355 Appendix A)
Determine if the facility has any of the items listed in Appendix 9-1 as extremely
hazardous substances in amounts equal to or greater than those listed in Appendix 9-1
Verify that the facility has notified the state emergency response commission, or
Governor if there is not emergency response commission, that the facility is subject to
emergency planning requirements within 60 days after the facility first becomes
subject to these requirements
Determine whether the facility has representatives TO contact by internal and external
parties
Verify that the facility has notified the local emergency planning committee, or
Governor if there is no committee, of the facility representative on or before 3 March
1994
Verify that the facility is actively participating in offsite planning by interviewing the
facility point of contact and reviewing the files
Verify that a procedure is in place to notify the local emergency planning committee
of changes at the facility that are relevant to emergency planning
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-12
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Compliance Category:
Emergency Haonfag and Cwftmttnlty RlgbKo-Kxtow (EPCRA)
Regvtetory Requirements:
[ Reviewer decks:
Pollution Prevention
E9 EO 12856 required
Federal facilities to develop a
written pollution prevention
plan (EO 12856, Section 3-
302)
Determine if the facility has prepared a written pollution prevention plan (EO 12856,
Section 3-302).
(NOTE This plan is required by the end of 1995 for each "covered facility" (e g , a
Federal facility that meets the threshold for toxic chemical release reporting under
EPCRA Section 313))
If so, review the plan to determine if the following components are included and
comment on the thoroughness of the plan based on the size of the facility
- Facility-wide methods to reduce pollutants to reach required Federal agency
reduction goals
- Goals and policies for the facility's pollution prevention achievements
- Management commitment to pollution prevention
- Baseline study/information on pollutant generation, environmental releases of
pollutants, worker exposures to hazardous chemicals, use and management of
hazardous materials, and adverse environmental impacts
- Identification of pollution prevention opportunities and options
- Criteria for prioritizing the opportunities and ranking the options
- Implementation schedule for completion of major milestones, identification of roles
and responsibilities, identification of barriers encountered or expected,
communication and training needs, and evaluation and measurement of success
Phase 1 - Section 9
Emergency Planning and Community Right-to-Know (EPCRA)
9-13
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Section 9
Emergency Planning and Community Right-to-Know
Appendix
-------
Appendix 9-1
Consolidated List of Chemicals Covered in Title III of SARA
This consolidated chemical list includes chemicals subject to reporting requirements under Title
III of SARA. This consolidated chemical list does not contain all chemicals that are subject to
reporting requirements in Sections 311 and 312 of SARA Title III. These hazardous chemicals,
for which MSDS must be developed under the Occupational Safety and Health Act Hazard
Communication Standards, are identified by broad criteria, rather than enumeration. There are
over 50,000 such substances that meet the criteria. The consolidated list has been prepared to
help determine whether there is a need to submit reports under Section 304 or 313 of Title III
and, for a specific chemical, what reports need to be submitted.
The list includes chemicals under the four following Federal statutory provisions
1 SARA Section 302 Extremely Hazardous Substances - The presence of which, in sufficient
quantities, requires certain emergency planning activities to be conducted. Releases of these
substances are also subject to reporting under Section 304 of Title III. The final rule listing
the extremely hazardous substances and their threshold planning quantities (TPQ), is found
in 40 CFR 355.
2 CERCLA Hazardous Substances (RQ) Chemicals - Releases of which are subject to
reporting under the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA or Superfund) of 1980. Such releases are also subject to reporting under
Section 304 of Title III. CERCLA hazardous substances, and their reportable quantities
(RQ), are listed in 40 CFR Part 302, Table 302 4.
3. SARA Section 313 Toxic Chemicals - Emissions or releases of which must be reported
annually as part of SARA Title Ill's community right-to-know provisions. A list of these
toxic chemicals is found in 40 CFR 372.65.
4. RCRA Hazardous Wastes - from the "P" and "U" lists (40 CFR 261.33), of specific
chemicals. RCRA hazardous wastes from the "F" and "K" lists are not included here, such
waste streams are also CERCLA hazardous substances. This listing is provided as an
indicator that you may already have data on a specific chemical that can be used for Title III
reporting purposes
There are four columns in the consolidated list corresponding to these four statutory provisions.
If a chemical is listed as an extremely hazardous substance under Section 302, its TPQ is given in
the extremely hazardous substance column. Similarly, the CERCLA RQ is given for those
chemicals that are listed as hazardous substances. A key to the symbols used in the Section 302
and CERCLA columns precedes the list. An "X" in the column for Section 313 indicates that the
chemical is subject to reporting under Section 313
The letter-and-digit code in the column for 40 CFR 261.33 is the chemical's RCRA hazardous
waste code. A blank in any of these columns indicates that the chemical is not subject to the
corresponding statutory authorities.
The Chemical Abstract Service (CAS) registry number is provided for each chemical on the list.
A9-1
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Key to Symbols in the Consolidated Chemical List
# Indicates that the RQ is subject to change when an assessment of potential carcinogenicity
and/or chronic toxicity is completed; until then, the statutory RQ applies.
M Indicates that an adjusted RQ has been proposed, but a final judgment has not been made.
+ USEPA has proposed to adjust the RQ for radionuclides by establishing RQs in units of
curies; until then, the 1 lb RQ applies.
* Indicates that the chemical is proposed for deletion from the list of extremely hazardous
substances.
** Indicates that no RQ is assigned to this generic or broad class.
A9-2
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Consolidated Chemical List
This is an alphabetical listing of the consolidated list of chemicals. Numbered chemicals are
listed first.
Chemical Name
Extremely
Haz Sub 40
CFR 355
foounds^
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
1 ,Amino-2-methyl-anthraquinone
X
82-28-0
1 -Butanamine,N-butyl-N-nitroso-
10
X
U172
924-16-3
1 -Chloro-1,1 -difluoroethane (HCFC-
142(b)
X
75-68-3
1 -Chloro-1,1,2,2-tetrafluoroethane
(HCFC-124a)
X
354-25-6
1-Methylbutadiene
100
U186
504-60-9
l-Naphthalamine
100
X
U167
134-32-7
1 -Propanamine
5000
U194
107-10-8
l-Propanol,2,3-dibromo-phosphate (3 1)
10
X
U235
126-72-7
(1,1 '-Biphenyl)-4,4'diamine,
3,3'dimethoxy-
100
X
U091
119-90-4
(1,1 '-Bipheny l)-4,4'diamine,
3,3'dimethyl-
10
X
U095
119-93-7
1,1 -Dichloro-1 -fluoroethane (HCFC-
141b)
X
1717-80-6
1,1 -Dichloro-1,2,2-tri fluoroethane
(HCFC-123b)
X
812-04-4
1,1-Dichloroethane
1000
U076
75-34-3
1,1-Dichloroethylene
100
X
U078
75-35-4
1,1,1,2-T elrachloroethane
X
630-20-6
1,2-Benzenedicarboxy lie acid,fbis(2-
ethylhexyl)]ester
100
X
U028
117-81-7
1,2-Benzenedicarboxylic acid, diethyl
ester (diethyl phthlate)
1000
X
U088
84-66-2
1,2-Benzenediol,4-[ 1 -hydroxy-2-
(methylamino) ethyl]-
1000
P042
51-43-4
1,2-Benzisothiazolin-3(2H) one, 1,1-
dioxide
100
X
U202
81-07-2
A9-3
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Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
1,2-Benzphenanthrene
100
U050
218-01-9
1,2-Butylene oxide
X
106-88-7
1,2-Dibromo-3-chloropropane
1
X
U066
96-12-8
1,2-Dichloro-1,1,2-trifluoroethane
(HCFC-123a)
X
354-23-4
1,2-Dichloroethane
100
X
U077
107-06-2
1,2-Dichloroethylene
X
540-59-0
1,2-Dichloropropane
1000
X
U083
78-87-5
1,2-Dimethylhydrazine
1
U099
540-73-8
1,2-Diphenylhydrazine
10
X
U109
122-66-7
l,2-Oxathiolane,2,2-dioxide
10
X
U193
1120-71-4
1,2-trans-Dichloroethylene
1000
U079
156-60-5
1,3-Benzenediol
5000
U201
108-46-3
1,3-Benzodioxole, 5-propyl
10
U090
94-58-6
l,3-Benzodioxole,5-)l-l propenyl
100
X
U141
120-58-1
1,3-Benzodioxole, 5-) 2,propenyl
100
X
U203
94-59-7
1,3-Butadiene
X
106-99-0
1,3-Dichloropropy lene
100
X
U084
542-75-6
1,3-Isobenzofurandione
5000
X
U190
85-44-9
1,4-Dichloro-2-butene
X
764-41-0
1,4-Diethylene dioxide (1,4-Dioxane)
100
X
U108
123-91-1
1,4-Naphttialenedione
5000
U166
130-15-4
2-Acetylaminofluorene
1
X
U005
53-96-3
2-AminoaJithraquinone
X
117-79-3
2-Butanone peroxide
10
U160
1338-23-4
2-Butanone (Methyl ethyl ketone)
5000
X
U159
78-93-3
2-Butene, 1,4-dichloro-
1
U074
764-41-0
2-Chloro-1,1,2,2-
tetrafluoroethane(HCFC 124)
X
2837-89-0
2-Chlcroacetophenone
X
532-27-4
A9-4
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.6§(a1
Haz Mat
which are
RCRA
wastes
CAS No.
2-Chloroethyl vinyl ether
1000
U042
110-75-8
2-Chlorophenol
100
U048
95-57-8
2-Cyclohexl-4,6-dimtrophenoll
100
P034
131-89-5
2-Ethoxyethanol
100
X
110-80-5
2-Furancarboxaldehyde
5000
U125
98-01-1
2-Methoxyethanol
X
109-86-4
2-Methylpyndine
X
109-06-8
2-Naphthylamine
10
X
U168
91-59-8
2-Nitropropane
10
X
U171
79-46-9
2-Phenylphenol
X
90-43-7
2-Picoline
5000
U191
109-06-8
2,2-Dichloro-1,1,1 -tnfluoroethane
(HCFC-I23)
X
306-83-2
2,2-Dichloropropiomc acid
5000
75-99-0
2,3-Dichloropropene
100
X
78-88-6
2,3,4-Trichlorophenol
10
X
15950-66-0
2,3,5-T richlorophenol
10
933-78-8
2,3,6-T nchloropheno!
10
933-75-5
2,3,7,8-Tetrachlorodibenzo p-dioxin
(TCDD)
1
1746-01-6
2,4-D acid
100
X
U240
94-75-7
2,4-D esters
100
94-11-1
2,4-D esters
100
94-79-1
2,4-D esters
100
94-80-4
2,4-D esters
100
1320-18-9
2,4-D esters
100
1928-38-7
2,4-D esters
100
2971-38-2
2,4-D esters
100
53467-11-1
2,4-D esters
100
1928-61-6
2,4-D esters
100
1929-73-3
A9-5
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
2,4-D esters
100
25168-26-7
2,4-Diaminoanisole sulfate
X
39156-41-7
2,4-Diaminosole
X
615-41-7
2,4-Diaminotoluene
10
U22I
823-40-5
2,4-Dichlorophenol
100
X
U081
120-83-2
2,4-Dimethylphenol
100
X
UI01
105-67-9
2,4-Dinitrophenol
10
X
P048
51-28-5
2,4,5-T esters
1000
25168-15-4
2,4,5-T salts
1000
13560-99-1
2,4,5-T amines
5000
1319-72-8
2,4,5-T amines
5000
3813-14-7
2,4,5-T amines
5000
6369-96-6
2,4,5-T amines
5000
6369-97-7
2,4,5-T amines
5000
2008-46-0
2,4,5-T esters
1000
93-79-8
2,4,5-T esters
1000
1928-47-8
2,4,5-T esters
1000
2545-59-7
2,4,5-T esters
1000
61792-07-2
2,4,5-T
1000
U232
93-76-5
2,4,5-TP acid esters
100
32534-95-5
2,5-Furandione
5000
X
U147
108-31-6
2,6-Dichlorophenol
100
U082
87-65-0
2,6-Xyhdme
X
87-62-7
3,3-Dichlorobenzidine
X
91-94-1
3,4-Diaminotoluene
10
X
U221
95-80-7
3,4-DinitrotoIuene
10
610-39-9
3,4,5-Tnchlorophenol
10
609-19-8
3,5-Dichloro-N-( 1,1 -dimethy 1-2-
propynyl) benzamide
5000
U192
23950-58-5
A9-6
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
4-Aminoazobenzene
X
60-09-3
4-Aminobiphenyl
X
92-67-1
4-Chloro-m-cresol
5000
U039
59-50-7
4-Chlorophenyl phenyl ether
5000
7005-72-3
4-Nitrobiphenyl
X
92-93-3
4,4'-Diaminodiphenyl ether
X
101-80-4
4,4'-Isopropylidenediphenol
X
80-05-7
4,4'-Methylene bis(N,N-di-methyl)
benzenamine
X
101-61-1
4,4'-Methylenedianiline
X
101-77-9
4,4'-Thiodianiline 6-dinitrophenoll
X
139-65-1
5-Nitro-o-anisidine
X
99-59-2
5-Nitro-o-toluidine
X
99-55-6
Acenaphthene
100
83-32-9
Acenaphthylene
5000
208-96-8
Acetaldehyde
1000
X
U00I
75-07-0
Acetaldehyde, trichloro-
5000
U034
75-87-6
Acetamide
X
60-35-5
Acetamide-N-(4-ethoxyphenyl)-
100
U187
62-44-2
Acetamide,N-(aminothi-oxomethyl)-
1000
P002
591-08-2
Acetic acid
5000
64-19-7
Acetic acid, ethyl ester
5000
U112
141-78-6
Acetic acid, fluoro, sodium salt
10/10,000
10
P058
62-74-8
Acetic acid, lead(2+) salt
10
U144
301-04-2
Acetic acid, thallium(l+) salt
100
U2I4
563-68-8
Acetic anhydride
5000
108-24-7
Acetone
5000
X
U002
67-64-1
Acetone cyanohydrin
1000
10
P069
75-86-5
Acetone thiosemicarbazide
1000/10,000
1752-30-3
A9-7
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.651a)
Haz Mai
which are
RCRA
wastes
CAS No.
Acetonitrile
5000
X
U003
75-05-8
Acetophenone
5000
X
U004
98-86-2
Acetyl bromide
5000
506-96-7
Acetyl chloride
5000
U006
75-36-5
Acrolein
500
1
X
P003
107-02-8
Acrylamide
1000/10,000
5000
X
U007
79-06-1
Acrylic acid
5000
X
U008
79-10-7
Acrylomtrile
10,000
100
X
U009
107-13-1
Acrylyl chloride
100
814-68-6
Adipic acid
5000
124-04-09
Adiponitrile
1000
111-69-3
Aldicarb
100/10,000
1
P070
116-06-3
Aldrin
500/10,000
1
X
P004
309-00-2
Allyl alcohol
1000
100
X
P005
107-18-6
Allyl chloride
1000
X
107-05-1
Allylamine
500
107-11-9
alpha,alpha-Dimethyl phenethylamine
5000
P046
122-09-8
alpha-Endosulfan
1
959-98-8
alpha-BHC
10
319-84-6
Aluminum (fume or dust)
X
7429-90-5
Aluminum oxide (fibrous forms)
X
1344-28-1
Aluminum phosphide
500
100
P006
20859-73-8
Aluminum sulfate
5000
10043-01-3
Aminoptenn
500/10,000
54-62-6
Amiton
500
78-53-5
Amiton oxalate
100/10,000
3734-97-2
Amitrole
10
X
U011
61-82-5
Ammonia
500
100
X
7664-41-7
Ammonium acetate
5000
631-61-8
A9-8
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Eitremely
Haz Sub 40
CFR355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Ammonium benzoate
5000
1863-63-4
Ammonium bicarbonate
5000
1066-33-7
Ammonium bichromate
10
7789-09-5
Ammonium bifluonde
100
1341-49-7
Ammonium bisulfite
5000
10192-30-0
Ammonium carbamate
5000
1111-78-0
Ammonium carbonate
5000
506-87-6
Ammonium chloride
5000
12125-02-9
Ammonium chromate
10
7788-98-9
Ammonium citrate,dibasic
5000
3012-65-5
Ammonium fluoborate
5000
13826-83-0
Ammonium fluoride
100
12125-01-8
Ammonium hydroxide
1000
336-21-6
Ammonium nitrate (solution)
X
6484-52-2
Ammonium oxalate
5000
5972-73-6
Ammonium oxalate
5000
6009-70-7
Ammonium oxalate
5000
14258-49-2
Ammonium picrate
10
P009
131-74-8
Ammonium silicofluonde
1000
16919-19-0
Ammonium sulfamate
5000
7773-06-0
Ammonium sulfate (solution)
x
7783-20-2
Ammonium sulfide
100
12135-76-1
Ammonium sulfite
5000
10196-04-0
Ammonium tartrate
5000
14307-43-8
Ammonium tartrate
5000
3164-29-2
Ammonium thiocyanate
5000
1762-95-4
Ammonium vanadate
1000
PI 19
7803-55-6
Amphetamine
1000
300-62-9
Amyl acetate
5000
628-63-7
A9-9
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
HazSub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Analine,2,4,6-trimethyl-
500
88-05-1
Aniline
1000
5000
X
U012
62-53-3
Anthracene
5000
X
120-12-7
Antimony
5000
X
7440-36-0
Antimony pentachloride
1000
7647-18-9
Antimony pentafluoride
500
7783-70-2
Antimony potassium tartrate
100
28300-74-5
Antimony tribromide
1000
7789-61-9
Antimony trichloride
1000
10025-91-9
Antimony trifluonde
1000
7783-56-4
Antimony tnoxide
1000
1309-64-4
Antimycin A
1000/10,000
1397-94-0
Antu
500/10,000
86-88-4
Aroclor 1016
1
12674-11-2
Aroclor 1221
1
11104-28-2
Aroclor 1232
1
11141-16-5
Aroclor 1242
1
53469-21-9
Aroclor 1248
1
12672-29-6
Aroclor 1254
1
11097-69-1
Aroclor 1260
1
11096-82-5
Arsenic
1
X
7440-38-2
Arsenic acid
1
P010
1327-52-2
Arsenic acid
1
P010
7778-39-4
Arsenic disulfide
1
1303-32-8
Arsenic pentoxide
100/10,000
1
P011
1303-28-2
Arsenic trisulfide
1
1303-33-9
Arsenic tnoxide
100/10,000
1
P012
1327-53-3
Arsenous trichloride
500
1
7784-34-1
Arsine
100
7784-42-1
A9-10
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(DOunds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa}
Haz Mat
which are
RCRA
wastes
CAS No.
Arsine, diethyl-
1
P038
692-42-2
Asbestos
1
X
1332-21-4
Azasenne
1
U015
115-02-6
Azinophos-ethyl
100/10,000
2642-71-9
Azinophos-methyl
10/10,000
86-50-0
Banum and compounds
X
7440-39-3
Barium cyanide
10
P013
542-62-1
Benzal chlonde
500
5000
X
U017
98-87-3
Benzamide
X
55-21-0
Benz[a]anthracene
10
U018
56-55-3
Benzanthracene,7,12-dimethy 1-
1
U094
57-97-6
Benz[c]acndine
100
U0I6
225-51-4
Benzenamine,2-methyl 5-mtro-
100
U181
99-55-8
Benzenamine,2-methyl, hydrochloride
100
X
U222
636-21-5
Benzenamine,3-(tnfluoro-methyl)-
500
98-16-8
Benzenamine-4-chloro
1000
P024
106-47-8
Benzenamine,4-chloro-2-methyl-
hydrochlonde
100
U049
3165-93-3
Benzenenamine, 4-methyl
100
U353
106-49-0
Benzenamine,4-nitro-
5000
P077
100-01-6
Benzenamine 4,4'-methylenebis-2-chloro
10
X
U158
101-14-4
Benzenamine,NN-dimethyl-4-phenylazo
10
X
U093
60-11-7
Benzene
10
X
U019
71-43-2
Benzene, 1 -bromo-4-phenoxy-
100
U030
101-55-3
Benzene, 1 -(chloromethy l)-4-nitro-
500/10,000
100-14-1
Benzene, 1 -melhy 1-2,4-dimtro-
10
X
U105
121-14-2
Benzene, 1 -methy lethy 1- (Cumene)
5000
X
U055
98-82-8
Benzene, 1,2-dichloro
100
X
U070
95-50-1
Benzene, 1,2,4,5-tetrachloro-
5000
U207
95-94-3
A9-U
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Flaz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Benzene, 1,3-dichloro
100
X
U071
541-73-1
Benzene, 1,3-diisocy-anatomethyl
100
X
U223
26471-62-5
Benzene, 1,3,5-trinitro-
10
U234
99-35-4
Benzene,l,4-dichloro
100
X
U072
106-46-7
Benzene,2-methy 1-1,3-dimtro-
100
X
UI06
606-20-2
Benzene, chloro-
100
X
U037
108-90-7
Benzene, dimethyl-
1000
X
U239
1330-20-7
Benzene, hexachloro-
10
X
U127
118-74-1
Benzene, hexahydro- (cyclohexane)
1000
X
U056
110-82-7
Benzene, m-dimethyl-
1000
X
108-38-3
Benzene, methyl-(toulene)
1000
X
U220
108-88-3
Benzene, o-dimethyl-
1000
X
95-47-6
Benzene, p-dimethyl-
1000
X
106-42-3
Benzene, pentachloro-
10
U183
608-93-5
Benzene, pentachloronitro-
100
X
U185
82-68-8
Benzenearsonic acid
10/10,000
98-05-5
Benzenesulfonyl chloride
100
U020
98-09-9
Benzidine
1
X
U021
92-87-5
Benzimidazole,4,5-dichloro-2-
(trifluoromethyl)
500/10,000
3615-21-2
Benz[)]aceanthrylene, l,2-dihydro-3-
methyl-
10
U157
56-49-5
Benzoic acid
5000
65-85-0
Benzo[a]pyrene
1
U022
50-32-8
Benzo[b]fluoranthene
1
205-99-2
Benzo[ghi]perylene
5000
191-24-2
Benzoic acid
5000
65-85-0
Benzo[jk]fluorene
100
UI20
206-44-0
Benzo[k]fluoranthene
5000
207-08-9
Benzonitrile
5000
100-47-0
A9-12
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fe)
Haz Mat
which are
RCRA
wastes
CAS No.
Benzotrichlonde
500
10
X
U023
98-07-7
Benzoyl chlonde
1000
X
98-88-4
Benzoyl peroxide
X
94-36-0
Benzyl chlonde
500
100
X
P028
100-44-7
Benzyl cyanide
500
140-29-4
Beryllium chloride
1
7787-47-5
Beryllium fluoride
1
7787-49-7
Beryllium nitrate
1
13597-99-4
Beryllium nitrate
1
7787-55-5
Beryllium powder
10
X
P015
7440-41-7
beta-Endosyulfan
1
33213-65-9
beta-BHC
1
319-85-7
beta-Chloronaphthalene
5000
U047
91-58-7
Bicyclo[2 2 l]heptane-2-carbonitnle, 5-
chloro-6-(methyla)
500/10,000
15271-41-7
Biphenyl
X
92-52-4
Bis(2-chloroethoxy) methane
1000
X
U024
111-91-1
Bis(2-chloroisopropyl) ether
1000
X
U027
108-60-1
Bis(2-ethylhexyl)adipate
X
103-23-1
Bis(chloromethyl)ketone
10/10,000
534-07-6
Bitoscanate
500/10,000
4044-65-9
Boron trichloride
500
10294-34-5
Boron trifluoride compound with methyl
ether (1 1)
1000
353-42-4
Boron trifluoride
500
7637-07-2
Bromadiolone
100/10,000
18772-56-7
Bromine
500
7726-95-6
Bromoacetone
1000
P017
598-31-2
Bromochlorodifluoromethan (Halon
1211)
X
353-59-3
A9-13
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title EH of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65M
Haz Mat
which are
RCRA
wastes
CAS No.
Bromoform
100
X
U225
75-25-2
Bromotrifluorometh-ane (Halon 1311)
X
75-63-8
Brucine
100
P018
357-57-3
Butanoic acid,4-[bis{2-
ch!oroethyl)amino] benzene-
10
U035
305-03-3
Butyl benzyl Phthalate
100
X
85-68-7
Butyl acetate
5000
123-86-4
Butyl aery late
X
141-32-2
Butyl amine
1000
109-73-9
Butyraldehyde
X
123-72-8
Butyric acid
5000
107-92-6
CI Acid Green 3
X
4680-78-8
CI Basic Green 4
X
569-64-2
CI Basic Red 1
X
989-38-8
CI Direct Black 38
X
1937-37-7
CI Direct Blue 6
X
2602-46-2
CI Direct Brown 95
X
16071-86-6
CI Disperse Yellow 3
X
2832-40-8
CI Food Red 15
X
81-88-9
CI Food Red 5
X
3761-53-3
CI Solvent Orange 7
X
3118-97-6
CI Solvent Yellow 14
X
824-07-0
CI Solvent Yellow 34 (Auramine)
100
X
U014
492-80-8
CI Solvent Yellow 3
X
97-56-3
CI Vat Yellow 4
X
128-66-5
Cacodylic acid
1
U136
75-60-5
Cadmium
10
X
7440-43-9
Cadmium acetate
10
543-90-8
Cadmium bromide
10
7789-42-6
A9-14
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
fooiinds')
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Cadmium chloride
10
10108-64-2
Cadmium oxide
100/10,000
1306-19-0
Cadmium stearate
1000/10,000
2223-93-0
Calcium arsenate
500/10,000
1
7778-44-1
Calcium arsenite
1
52740-16-6
Calcium carbide
10
75-20-7
Calcium chromate
10
U032
13765-19-0
Calcium cyanamide
X
156-62-7
Calcium cyanide
10
P021
592-01-8
Calcium dodecylbenzene sulfonate
1000
26264-06-2
Calcium hypochlorite
10
7778-54-3
Cantharidin
100/10,000
56-25-7
Captan
10
X
133-06-2
Carbachol chloride
500/10,000
51-83-2
Carbamic acid, ethyl ester
100
X
U238
51-79-6
Carbamic acid, methyl- mtroso-,ethyl
ester
1
U178
615-53-2
Carbamic acid, methyl-o- (((2,4-
dimethyl-1,3 dithiolan-2-y
100/10,000
26419-73-8
Carbamic chloride, dimethyl-
1
X
U097
79-44-7
Carbaryl
100
X
63-25-2
Carbofuran
10/10,000
10
1563-66-2
Carbon disulfide
10,000
100
X
P022
75-15-0
Carbon oxyfluonde
1000
U033
353-50-4
Carbon tetrachlonde
10
X
U211
56-23-5
Carbonyl sulfide
X
463-58-1
Carbophenothion
500
786-19-6
Catechol
X
120-80-9
Chloramben
X
133-90-4
Chlordane
1000
1
X
U036
57-74-9
A9-15
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
HazSub40
CFR355
foouods^
HazSubRQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65
HazMat
which are
RCRA
wastes
CAS No.
Chlorfenvinfos
500
470-90-6
Chlorinated fluorocarbon(Freon 113)
X
76-13-1
Chlorine
100
10
X
7782-50-5
Chlorine cyanide
10
P033
506-77-4
Chlorine dioxide
X
10049-04-4
Chlormephos
500
24934-91-6
Chlormequat chloride
100/10,000
999-81-5
Chlornaphazine
100
U026
494-03-1
Chloroacetaldehyde
1000
P023
107-20-0
Chloroacetic acid
100/10,000
X
79-11-8
Chlorobenzilate
10
X
U038
510-15-6
Chlorodibromomethane
100
124-48-1
Chlorodifluoromethane (HCFC-22)
X
75-45-6
Chloroethane
100
X
75-00-3
Chloroethanol
500
107-07-3
Chloroethyl chloroformate
1000
627-11-2
Chloroform
10,000
10
X
U044
67-66-3
Chloromethyl methyl ether
100
10
X
U046
107-30-2
Chlorophacinone
100/10,000
3691-35-8
Chloroprene
X
126-99-8
Chlorotetrafluoroe thane
X
63938-10-3
Chlorothalonil
X
1897-45-6
Chloroxuron
500/10,000
1982-47-4
Chlorpynfos
1
2921-88-2
Chlorsulfonic acid
1000
7790-94-5
Chlorthiophos
500
21923-23-9
Chromic acetate
1000
1066-30-4
Chromic acid
10
11115-74-5
Chromic acid
10
7738-94-5
A9-I6
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(oounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Chromic chloride
1/10,000
10025-73-7
Chromic sulfate
1000
10101-53-8
Chromium
5000
X
7440-47-3
Chromous chloride
1000
10049-05-5
Cobalt
X
7440-50-8
Cobalt, ((2,2'-1,2- ethanediylbis (ni-
tnlomethylidyne))bis(6)
100/10,000
62207-76-5
Cobalt carbonyl
10/10,000
10210-68-1
Cobaltous bromide
1000
7789-43-7
Cobaltous formate
1000
544-18-3
Cobaltous sulfamate
1000
14017-41-5
Colchicine
10/10,000
64-86-8
Copper
5000
X
7440-50-8
Copper cyanide
10
P029
544-92-3
Coumaphos
100/10,000
10
56-72-4
Coumatetralyl
500/10,000
5836-29-3
Cresol(s) (mixed isomers)
1000
X
U052
1319-77-3
Cresol.o-
1000/10,000
1000
X
U052
95-48-7
Creosote
1
X
U051
8001-58-9
Cnmidine
100/10,000
535-89-7
CrotonaIdehyde,(E)-
1000
100
U053
123-73-9
Crotonaldehyde
1000
100
U053
4170-30-3
Cumene hyroperoxide
X
80-15-9
Cupferron
X
135-20-6
Cupnc acetate
100
142-71-2
Cupnc chloride
10
7447-39-4
Cupnc nitrate
100
3251-23-8
Cupnc oxalate
100
5893-66-3
Cupnc sulfate
10
7758-98-7
A9-17
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(Doundsl
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Cupnc sulfate ammomated
100
10380-29-7
Cupric tartrate
100
815-82-7
Cyanides (soluble cyanide salts
10
P030
57-12-5
Cyanogen
100
P031
460-19-5
Cyanogen bromide
500/10,000
1000
U246
506-68-3
Cyanogen iodide
1000/10,000
506-78-5
Cyanophos
1000
2636-26-2
Cyanunc fluoride
100
675-14-9
Cyclohexanone
5000
U057
108-94-1
Cycloheximide
100/10,000
66-81-9
Cyclohexylamine
10,000
108-91-8
Cyclophosphamide
10
U058
50-18-0
D-Glucopyranose,2-deoxy-2-(3-methyl-
3-ni-trosoureido)-
1
U206
18883-66-4
Daunomycin
10
U059
20830-81-3
DDD
1
U060
72-54-8
DDE
1
72-55-9
DDT
1
U061
50-29-3
Decaborane(14)
500/10,000
17702-41-9
Decabromodiphenyl oxide
X
1163-19-5
Delta-BHC
1
319-86-8
Demeton
500
8065-48-3
Demeton-S-methyl
500
919-86-8
Di-(2-ethylhexyl)phthlate (DEHP)
x
177-81-7
Di-n-octyl phthalate
5000
X
U107
117-84-0
Di-n-propylnitrosamine(N-Nitrosodi-n-
propylamine)
10
X
Ulll
621-64-7
Dialifor
100/10,000
10311-84-9
Dial late
100
X
U062
2303-16-4
Diaminotoluene (mixed isomers)
10
X
U221
25376-45-8
A9-18
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Diaminotoluene(mixed isomers)
10
496-72-0
Diazinon
1
333-41-5
Diazomethane
X
334-88-3
Dibenz(a)lpyrene
10
U064
189-55-9
Dibenz[a,h] anthracene
1
U063
53-70-3
Dibenzofuran
X
132-64-9
Diborane
100
19287-45-7
Dibromotetrafluor- ethane (Halon 2402
X
124-73-2
Dibutyl phthalate
10
X
U069
84-74-2
Dicamba
1000
1918-00-9
Dichlonc
1
117-80-6
Dichloro-1,1,2-trifluoroethane
X
90454-18-5
Dichlorobenzene (mixed isomers)
100
X
25321-22-6
Dichlorobromomethane
5000
X
75-27-4
Dichlorodifluoromethane(CFC-12)
5000
X
U075
75-71-8
Dichloroethyl ether
10,000
10
X
U025
111-44-4
Dichloromethyl ether
100
10
X
P016
542-88-1
Dichloromethyl- phenylsilane
1000
149-74-6
Dichloropropane
1000
26638-19-7
Dichloropropane-
100
8003-19-8
Dichloropropene
100
26952-23-8
Dichlorotetrafluoro-ethane (CFC-114)
X
76-14-2
Dichlorotrifluoroethane
X
34077-87-7
Dichlorvos
1000
10
X
62-73-7
Dicholobenil
100
1194-65-6
Dicofol
X
115-32-2
Dicrotophos
100
141-66-2
Dieldnn
1
P037
60-57-1
Diepoxybutane
500
10
X
U085
1464-53-5
A9-19
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR3S5
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Diethanolamine
X
111-42-2
Diethyl chlorophosphate
500
814-49-3
Diethyl-p-nitrophenylphosphate
100
P041
311-45-5
Diethyl sulfate
X
64-67-5
Diethylamine
100
109-89-7
Diethylcarbamazine citrate
100/10,000
1642-54-2
Diethylstilbestrol
1
U089
56-53-1
Digitoxin
100/10,000
71-63-6
Diglycidyl ether
1000
2238-07-5
Digoxin
10/10,000
20830-75-5
Dihydrosafrole
X
94-58-6
Dusopropylfluorophosphate
100
100
P043
55-91-4
Dimefox
500
115-26-4
Dimethoate
500/10,000
10
P044
60-51-5
Dimethyl-p-phenyl-enediamine
10/10,000
99-98-9
Dimethyl phosphoro- chloridothioate
500
2524-03-0
Dimethyl phthalate
5000
X
U102
131-11-3
Dimethyl sulfate
500
100
X
U103
77-78-1
Dimethylamine
1000
U092
124-40-3
Dimethyldichlorosilane
500
75-78-5
Dimethylhydrazine
1000
10
X
U098
57-14-7
Dimetilan
500/10,000
644-64-4
Dinitrobenzene (mixed)
100
25154-54-5
Dinitrophenol
10
25550-58-7
Dinitrotoulene
10/10,000
10
X
P047
534-52-1
Dinitrotoluene (mixed isomers)
10
X
25321-14-6
Dinoseb
100/10,000
1000
P020
88-85-7
Dinoterb
500/10,000
1420-07-1
Dioxathion
500
78-34-2
A9-20
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Diphacinone
10/10,000
82-66-6
Diphosphoramide, octamethyl-
100
100
P085
152-16-9
Dipropylamine
5000
U110
142-84-7
Diquat
1000
85-00-7
Diquat
1000
2764-72-9
Disulfoton
500
1
P039
298-04-4
Dithiazinine iodide
500/10,000
514-73-8
Dithiobiuret
100/10,000
100
P049
541-53-7
Diuron
100
330-54-1
Dodecylbenzenesulfonic acid
1000
27176-87-0
Emetine, dihyrochlonde
1/10,000
316-42-7
Endosulfan
10/10,000
1
P050
115-29-7
Endosulfan sulfate
1
1031-07-8
Endothall
1000
P088
145-73-3
Endothion
500/10,000
2778-04-3
Endnn
500/10,000
1
P051
72-20-8
Endnn aldehyde
1
7421-93-4
Epichlorohydnn
1000
100
X
U041
106-89-8
EPN
100/10,000
2104-64-5
Ergocalciferol
1000/10,000
50-14-6
Ergotamine tartrate
500/10,000
379-79-3
Ethan amine,N-ethyl-N-nitroso-
1
X
U174
55-18-5
Ethane,l,l'-oxybis-
100
U117
60-29-7
Ethane, 1,2-dibromo-
1
X
U067
106-93-4
E thane, 1,1,2-trichloro
100
X
U227
79-00-5
Ethane, 1,1,1,2-tetrachloro-
100
U208
630-20-6
E thane, 1,1,2,2-tetrachloro-
100
X
U209
79-34-5
Ethane, hexachloro
100
X
U131
67-72-1
Ethanesulfonyl chloride, 2-chloro-
500
1622-32-8
A9-21
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
Wastes
CAS No.
Ethanethioamide
10
X
U218
62-55-5
Ethanol, 1,2-dichloro-acetate
1000
10140-87-1
Ethanol,2,2'-(nitroso imino) bis-
1
U173
1116-54-7
Ethene, tetrachloro
100
X
U210
127-18-4
Ethene, chloro-
1
X
U043
75-01-4
Ethion
1000
10
563-12-2
Ethoprophos
1000
13194-48-4
Ethyl acrylate
1000
X
U113
140-88-5
Ethyl chloroformate
X
541-41-3
Ethyl methacrylate
1000
U118
97-63-2
Ethyl methanesulfonate
1
U119
62-50-0
Ethylbenzene
1000
X
100-41-4
Ethylbis(2-chloroethyl)amine
500
538-07-8
Ethylene
X
74-85-1
Ethylene glycol
X
107-21-1
Ethylene oxide
1000
10
X
U115
75-21-8
Ethylene thiourea
10
X
U116
96-45-7
Ethylenebisdithiocarbamic- acid, salts &
esters
5000
U114
111-54-6
Ethylenediamine
10,000
5000
107-15-3
Ethylenediamine tetra-acetic acid
(EDTA)
5000
60-00-4
Ethyleneimine
500
1
X
P054
151-56-4
Ethylenethiocyanate
10,000
542-90-5
Ethylidene dichlonde
X
75-34-3
Famphur
1000
P097
52-85-7
Fenamiphos
10/10,000
22224-92-6
Fenitrothion
500
122-14-5
Fensulfothion
500
115-90-2
Feme ammonium citrate
1000
1185-57-5
A9-22
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(DOUnds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Feme ammonium oxalate
1000
2944-67-4
Feme ammonium oxalate
1000
55488-87-4
Feme chloride
1000
7705-08-0
Feme fluoride
100
7783-50-8
Feme nitrate
1000
10421-48-4
Feme sulfate
1000
10028-22-5
Ferrous ammonium sulfate
1000
10045-89-3
Ferrous chloride
100
7758-94-3
Ferrous sulfate
1000
7720-78-7
Ferrous sulfate
1000
7782-63-0
Florouracil
500/10,000
51-21-8
Fluenetil
100/10,000
4301-50-2
Fluometuron
X
2164-17-2
Fluorene
5000
86-73-7
Fluorine
500
10
P056
7782-41-4
Fluoroacetamide
100/10,000
100
P057
640-19-7
Fluoroacetic acid
10/10,000
144-49-0
Fluoroacetyl chloride
10
359-06-8
Fonofos
500
944-22-9
Formaldehyde
500
100
X
U122
50-00-0
Formaldehyde cyanohydnn
1000
107-16-4
Formetanate hydrochloride
500/10,000
23422-53-9
Formic acid
5000
X
U123
64-18-6
Formothion
100
2540-82-1
Formparanate
100/10,000
17702-57-7
Fosthietan
500
21548-32-3
Fubendazole
100/10,000
3878-19-1
Fulmmic acid, mercury(II) salt
10
P065
628-86-4
Fumaric acid
5000
110-17-8
A9-23
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title in of SARA
Chemical Name
Extremely
Haz Sub 40
CFR3S5
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa*
Haz Mat
which are
RCRA
wastes
CAS No.
Furan
500
100
U124
110-00-9
Furan, tetrahydro-
1000
U213
109-99-9
Gallium trichloride
500/10,000
13450-90-3
Glycidylaldehyde
10
U126
765-33-4
Guanidine,N-nitroso-N methyl-N'-nitro
10
LJI63
70-25-7
Heptachlor
1
X
P059
76-44-8
Heptachlor epoxide
1
1024-57-3
Hexachloro-1,3-butadiene
1
X
U128
87-68-3
Hexachlorocyclopentadiene
100
10
X
U130
77-47-4
Hexachloronaphthalene
X
1335-87-1
Hexachlorophene
100
X
U132
70-30-4
Hexachloropropene
1000
U234
1888-71-7
Hexaethyl tetraphosphate
100
P062
757-58-4
Hexamethylenediamine, N,N'-dibutyl-
500
4835-11-4
Hexamethylphosphoramide
X
680-31-9
Hydrazine
1000
1
X
UI33
302-01-2
Hydrazine sulfate
X
10034-93-2
Hydrochloric acid (Hydro-gen chloride
(gas only))**$
500
5000
X
7647-01-0
Hydrocyanic acid
100
10
X
P063
74-90-8
Hydrogen fluoride
100
100
X
U134
7664-39-3
Hydrogen penoxide (cone > 52%)
1000
7722-84-1
Hydrogen selenide
10
7783-07-5
Hydrogen sulfide
500
100
X
U135
7783-06-4
Hydroquinone
500/10,000
X
123-31-9
lndeno( 1,2,3-cd)pyrene
100
U137
193-39-5
Iron, pentacarbonyl-
100
13463-40-06
lSO-Amyl acetate
5000
123-92-2
iso-Butyl acetate
5000
110-19-0
A9-24
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
iso-Butylamme
1000
78-81-9
iso-Butyric acid
5000
79-31-2
Isobenzan
100/10,000
297-78-9
Isobutyl alcohol
5000
U140
78-83-1
Isobutyraldehyde
X
78-84-2
Isobutyronitrile
1000
78-82-0
Isocyanic acid,3,4-dichlorophenyl ester
500/10,000
102-36-3
Isodnn
100/10,000
1
P060
465-73-6
Isophorone
5000
78-59-1
Isophorone dnsocyanate
100
4098-71-9
Isoprene
100
78-79-5
Isopropanolamine dode-cyclbenzene
sulfonate
1000
42504-46-1
Isopropyl alcohol (mfg- strong acid
processes)
X
67-63-0
Isopropyl chloroformate
1000
108-23-6
Isopropylmethylpyrazolyl
dimethylcarbamate
500
119-38-0
Kepone
1
U142
143-50-0
Lactonitrile
1000
78-97-7
Lasiocarpine
10
U143
303-34-4
Lead
10
X
7439-92-1
Lead arsenate
1
10102-48-4
Lead arsenate
1
7645-25-2
Lead arsenate
1
7784-40-9
Lead chloride
10
7758-95-4
Lead fluoborate
10
13814-96-5
Lead fluoride
10
7783-46-2
Lead iodide
10
10101-63-0
Lead nitrate
10
10099-74-8
A9-25
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(Doundsl
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(81
Haz Mat
which are
RCRA
wastes
CAS No.
Lead phosphate
10
U145
7446-27-7
Lead stearate
10
1072-35-1
Lead stearate
10
52652-59-2
Lead stearate
10
7428-48-0
Lead stearate
10
56189-09-4
Lead subacetate
10
U146
1335-32-6
Lead sulfate
10
15739-80-7
Lead sulfate
10
7446-14-2
Lead sulfide
10
1314-87-0
Lead thiocyanate
10
592-87-0
Leptophos
500/10,000
21609-90-5
Lewisite
10
541-25-3
Lindane
1000/10,000
1
X
U129
58-89-9
Lithium chromate
10
14307-35-8
Lithium hydnde
100
7580-67-8
m-Cresol
1000
X
U052
108-39-4
m-Nitrophenol
100
554-84-7
m-Nitrotoluene
1000
99-08-1
Malathion
100
121-75-5
Maleic acid
5000
110-16-7
Maleic, hydrazide
5000
U148
123-33-1
Malononitrile
500/10,000
1000
X
U149
109-77-3
Maneb
X
12427-38-2
Manganese
X
7439-96-5
Manganese, tricarbonyl
methylcyclopentadienyl
100
12108-13-3
Mechloreth amine
10
X
51-75-2
Melphalan
1
U150
148-82-3
Mephosfolan
500
950-10-7
A9-26
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title EI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pouods)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Mercuric acetate
500/10,000
1600-27-7
Mercuric chloride
500/10,000
7487-94-7
Mercuric cyanide
1
592-04-1
Mercuric nitrate
10
10045-94-0
Mercuric oxide
500/10,000
21908-53-2
Mercuric sulfate
10
7783-35-9
Mercuric thiocyanate
10
592-85-8
Mercurous nitrate
10
7782-86-7
Mercurous nitrate
10
10415-75-5
Mercury
1
X
U151
7439-97-6
Methacrolein diacetate
1000
10476-95-6
Methacrylic anhydride
500
760-93-0
Methacryloyl chloride
100
920-46-7
Methacryloyloxyethyl isocyanate
100
30674-80-7
Methacrylonitnle
500
1000
X
U152
126-98-7
Methamidophos
100/10,000
10265-92-6
Methane, chloro
100
X
U045
74-87-3
Methane, dibromo-
1000
X
U068
74-95-3
Methane, dichloro-
1000
X
U080
75-09-2
Methane, lodide-
100
X
U138
74-88-4
Methane, trichlorofluoro- (CFC-11)
5000
UI21
75-69-4
Methanesulfany! chloride, trichloro
500
100
PI 18
594-42-3
Methanesulfonyl fluoride
1000
558-25-8
Methanol
5000
X
UI54
67-56-1
Methapyrilene
5000
U155
91-80-5
Methidathion
500/10,000
950-37-8
Methiocarb
500/10,000
10
2032-65-7
Methomyl
500/10,000
100
P066
16752-77-5
Methoxychlor
1
X
72-43-5
A9-27
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
CDOunds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
312.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Methoxyethylmercuncacetate
500/10,000
151-38-2
Methyl 2-chloroacrylate
500
80-63-7
Methyl acrylate
X
96-33-3
Methyl bromide
1000
1000
X
U029
74-83-9
Methyl chlorocarbonate
X
79-22-1
Methyl
chloroformate(Methylchlorocarbonate)
500
1000
U156
79-22-1
Methyl chloroform
1000
X
U226
71-55-6
Methyl hydrazine
10
X
P068
60-34-4
Methyl isobutyl ketone
5000
X
U161
108-10-1
Methyl isocyanate
500
10
X
P064
624-83-9
Methyl isothiocyanate
500
556-61-1
Methyl mercaptan
500
100
X
U153
74-93-1
Methyl methacrylate
1000
X
U162
80-62-6
Methyl phenkapton
500
3735-23-7
Methyl phosphonic dichloride
100
676-97-1
Methyl tert-butyl ether
X
1634-04-4
Methyl thiocyanate
10,000
556-64-9
Methyl vinyl ketone
10
78-94-4
Methylene-bis-(phenyliso-cyanate)(MBI)
X
101-68-8
Methylmercuric dicy-anamide
500/10,000
502-39-6
Methylthiouracil
10
U164
56-04-2
Methyltnchlorosilane
500
75-79-6
Metolcarb
100/10,000
1129-41-5
Mevinphos
500
10
7786-34-7
Mexacarbate
500/10,000
1000
315-18-4
Michler's ketone
X
90-94-8
Mitomycin C
500/10,000
10
U010
50-07-7
Molybdenum trioxide
X
1313-27-5
A9-28
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(rounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
311j6S(b\
Haz Mat
which are
RCRA
wastes
CAS No.
Moncrotophos
10/10,000
6923-22-4
(Mono)chloropenta- fluoroethane (CFC
115)
X
76-15-3
Monoethylamine
100
75-04-7
Monomethylamine
100
74-89-5
Muscimol
500/10,000
1000
P007
2763-96-4
Mustard gas
500
X
505-60-2
n-Butyl alcohol
X
71-36-3
N,N'-Dimethylaniline
X
121-69-7
N,N'-Diethylhydrazine
10
U086
1615-80-1
N-Nitroso-N-cthylurea
1
X
759-73-9
N-Nitroso-N-methylurea
1
X
684-93-5
N-Nitrosodiphenylamine
100
X
86-30-6
N-Nitrosomethylvinylamine
10
X
4549-40-0
N-Nitrosomorpholine
X
59-89-2
N-Nitrosonornicotine
X
16543-55-8
N-Nitrosopipendine
10
X
U179
100-75-4
N-Nitrosopyrrolidine
1
U180
930-55-2
Naled
10
300-76-5
Naphthalene
100
X
U165
91-20-3
Naphthemc acid
100
1338-24-5
Nickel
100
X
7440-02-0
Nickel ammonium sulfate
100
15699-18-0
Nickel carbonyl
1
10
P073
13463-39-3
Nickel chlonde
100
37211-05-5
Nickel chlonde
100
7718-54-9
Nickel cyanide
10
P074
557-19-7
Nickel hydroxide
10
12054-48-7
Nickel nitrate
100
14216-75-2
A9-29
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
< pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toiic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Nickel sulfate
100
7786-81-4
Nicotine
100
100
P075
54-11-5
Nicotine sulfate
100/10,000
65-30-5
Nitric acid
1000
1000
X
7697-37-2
Nitric oxide
100
10
P076
10102-43-9
Nitnlotriacetic acid
X
139-13-9
Nitrobenzene
10,000
1000
X
U169
98-95-3
Nitrocyclohexane
500
1122-60-7
Nitrogen
X
1836-75-5
Nitrogen dioxide
100
10
P078
10102-44-0
Nitrogen dioxide
10
P078
10544-72-6
Nitroglycerine
10
X
P081
55-63-0
Nitrophenol (mixed)
100
25154-55-6
Nitrosodimethylamine
1000
10
X
P082
62-75-9
Nitrotoluene
1000
1321-12-6
Norbormide
100/10,000
991-42-4
0,0-Diethyl S-methyl dithiophosphate
5000
U087
3288-58-2
o-Anisidine hydrochloride
X
134-29-2
o-Anisidine
X
90-04-0
o-Dimtrobenzene
100
X
528-29-0
o-Nitrophenol
100
X
88-75-5
o-Nitrotoluene
1000
88-72-2
o-Toluidinc
100
X
U328
95-53-4
Octachloronaphthalene
X
2234-13-1
Osmium tetroxide
1000
X
P087
20816-12-0
Ouabain
100/10,000
630-60-4
Oxamyl
100/10,000
23135-22-0
Oxetane,3,3- bis(chloromethyl)-
500
78-71-7
Oxydisulfoton
500
2497-07-6
A9-30
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Ozone
100
10028-15-6
p-Anisidine
X
104-94-9
p-Benzoquinone
10
X
U197
106-51-4
p-Cresidine
X
120-71-8
p-Cresol
1000
X
U052
106-44-5
p-Dimtrobenzene
100
X
100-25-4
p-Nitrophenol
100
X
U170
100-02-7
p-Nitrosodiphenylamine
X
156-10-5
p-NitrotoIuene
1000
99-99-0
p-Phenylenediamine
X
106-50-3
Paraformaldehyde
1000
30525-89-4
Paraldehyde
1000
X
123-63-7
Paraquat
10/10,000
1910-42-5
Paraquat methosulfate
10/10,000
2074-50-2
Parathion
100
10
X
P089
56-38-2
Parathion, methyl
100/10,000
100
P071
298-00-0
Pans green (Cupne acetoarsemte)
500/10,000
1
12002-03-8
Pentaborane
500
19624-22-7
Pentachloroethane
10
X
U184
76-01-7
Pentachlorophenol
10
X
U242
87-86-5
Pentadecyclamine
100/10,000
2570-26-5
Peracetic acid
500
X
79-121-0
Phenanthrene
5000
85-01-8
Phenol
500/10,000
1000
X
U188
108-95-2
Phenol,2,2'-thio bis (4-chloro-6-methyl
100/10,000
4418-66-0
Phenol,2,3,4,6-tetrachloro
10
U2I2
58-90-2
Phenol,2,4,5-trichloro
10
X
U230
95-95-4
Phenol,2,4,6-trichloro
10
X
U231
88-06-2
A9-31
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Doundsl
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fal
Haz Mat
which are
RCRA
wastes
CAS No.
Phenol, 3-( 1 -methy lethy 1),
methylcarbamate
500/10,000
64-00-6
Phenoxarsine, 10,1O'-oxydi-
500/10,000
58-36-6
Phenyl dichloroarsine
500
1
P036
696-28-6
Phenylhydrazine hydrochlonde
1000/10,000
59-88-1
Phenylmercury acetate
500/10,000
100
P092
62-38-4
Phenylsilatrane
100/10,000
2097-19-0
Phenylthiourea
100/10,000
100
P093
103-85-5
Phorate
10
10
P094
298-02-2
Phosacetim
100/10,000
4104-14-7
Phosfolan
100/10,000
947-02-4
Phosgene
10
10
X
P095
75-44-5
Phosmet
10/10,000
732-11-6
Phosphamidon
100
13171-21-6
Phosphine
500
100
P096
7803-51-2
Phosphonothioic acidmethyl-0-{4-
nitrophenyl)0-phenyl ester
500
2665-30-7
Phosphonothioic acid, methyl-O-ethyl-
0-(4-(methylthio)phenyk Ester
500
2703-13-1
Phosphonothioic acid, methyl-,s-(2-
(bis(l-methylethyl)amino Ethyl o-Ethyl
Ester
100
50782-69-9
Phosphoric acid
5000
X
7664-38-2
Phosphoric acid, dimethyl 4-
(methylthio)phenyl ester
500
3254-63-5
Phosphorothioc acid, 0,0-diethyl, 0-
pyrazinyl ester
500
100
P040
297-97-2
Phosphorothioic acid, 0,0-dimethyl-S-
(2-methylthio)ethyl est
500
2587-90-8
Phosphorus
100
1
X
7723-14-0
Phosphorus oxychloride
500
1000
10025-87-3
Phosphorus pentachloride
500
10026-13-8
A9-32
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title EI of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Phosphorus pentasulfide
100
U189
1314-80-3
Phosphorus pentoxide
10
1314-56-3
Phosphorus trichloride
1000
1000
7719-12-2
Physostigmine
100/10,000
57-47-6
Physostigmine, sali-cylate (1 1)
100/10,000
57-64-7
Picric acid
X
88-89-1
Picrotoxin
500/10,000
124-87-8
Piperidine
1000
110-89-4
Pirimifos-ethyl
1000
23505-41-1
Polychlorinated biphenyls
1
X
1336-36-3
Potassium arsenate
1
7784-41-0
Potassium arsemte
500/10,000
1
10124-50-2
Potassium bichromate
10
7778-50-9
Potassium chromate
10
7789-00-6
Potassium cyanide
100
10
P098
151-50-8
Potassium hydroxide
1000
1310-58-3
Potassium permanganate
100
7722-64-7
Potassium silver cyanide
500
1
P099
506-61-6
Promecarb
500/10,000
2631-37-0
Pronamide
X
23950-58-5
Propargite
10
2312-35-8
Propargyl alcohol
1000
P102
107-19-7
Propargyl bromide
10
106-96-7
Propiolactone.beta-
500
X
57-57-8
Propionaldehyde
X
123-38-6
Propionic acid
5000
79-09-4
Propionic acid,2-(2,4,5-
trichlorophenoxy)-
100
U233
93-72-1
Propionic anhydride
5000
123-62-6
A9-33
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title m of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds')
HazSub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa1
Haz Mat
which are
RCRA
wastes
CAS No.
Propiophenone,4'-amino-
100/10,000
70-69-9
Propenemtnle
500
10
P101
107-12-0
Propenenitrile,3-chloro-
1000
1000
P027
542-76-7
Propoxur
X
114-26-1
Propyl chloroformate
500
109-61-5
Propylene (Propene)
X
115-07-1
Propylene oxide
10,000
100
X
75-56-9
Propyleneimine
10,000
1
X
P067
75-55-8
Prothoate
100/10,000
2275-18-5
Pyrene
1000/10,000
5000
129-00-0
Pyrethnns
1
121-21-1
Pyrethrins
1
121-29-9
Pyrethnns
1
8003-34-7
Pyridine
1000
X
U196
110-86-1
Pyridine,2-methyl-5-vinyl-
500
140-76-1
Pyndine,4-amino-
500/10,000
1000
P008
504-24-5
Pyndine,4-nitro-1 -oxide
500/10,000
1124-33-0
Pyriminil
100/10,000
53558-25-1
Quinoline
5000
X
91-22-5
Reserpine
5000
U200
50-55-5
Salcomine
500/10,000
14167-18-1
Sarin
10
107-44-8
sec-Amyl acetate
5000
626-38-0
sec-Butyl acetate
5000
105-46-4
sec-Butyl alcohol
X
78-92-2
sec-Butylamine
1000
13952-84-6
sec-Butylamine
1000
513-49-5
Selenium
100
X
7782-49-2
Selenium dioxide
10
U204
7446-08-4
A9-34
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fal
Haz Mat
which are
RCRA
wastes
CAS No.
Selenium disulfide
10
U205
7448-56-4
Selenium oxychloride
500
7791-23-3
Selenious acid
1000/10,000
10
U204
7783-00-8
Selenouree
1000
P103
630-10-4
Semicarbazide hydrochloride
1000/10,000
563-41-7
Silane,(4-aminobutyl) diethoxymethyl-
1000
3037-72-7
Silver
1000
X
7440-22-4
Silver cyanide
1
P104
506-64-9
Silver nitrate
1
7761-88-8
Sodium
10
7440-23-5
Sodium arsenate
1000/10,000
1
7631-89-2
Sodium arsenite
500/10,000
1
7784-46-5
Sodium azide (Na(N3))
500
1000
P105
26628-22-8
Sodium bichromate
10
10588-01-9
Sodium bifluonde
100
1333-83-1
Sodium bisulfite
5000
7631-90-5
Sodium cacodylate
100/10,000
124-65-2
Sodium chromate
10
7775-U -3
Sodium cyanide (Na(CN))
100
10
P106
143-33-9
Sodium dodecylbenzene sulfonate
1000
25155-30-0
Sodium fluoride
1000
7681-49-4
Sodium fluoroacetate
10/10,000
10
P058
62-74-8
Sodium hydrosulfide
5000
16721-80-5
Sodium hydroxide
1000
1310-73-2
Sodium hypochlonte
100
10022-70-5
Sodium hypochlorite
100
7681-52-9
Sodium methylate
1000
124-41-4
Sodium nitrite
100
7632-00-0
Sodium phosphate,dibasic
5000
10039-32-4
A9-35
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Eitremely
Haz Sub 40
CFR 355
fooundat
HuSubRQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372M(a)
Haz Mat
which are
RCRA
tnitts
CAS No.
Sodium phosphate,dibasic
5000
10140-65-5
Sodium phosphate,dibasic
5000
7558-79-4
Sodium phosphate, tnbasic
5000
10101-89-0
Sodium phosphate,tnbasic
5000
10124-56-8
Sodium phosphate,tnbasic
5000
10361-89-4
Sodium phosphate,tnbasic
5000
7601-54-9
Sodium phosphate,tnbasic
5000
7758-29-4
Sodium phosphate,tnbasic
5000
7785-84-4
Sodium selenate
100/10,000
13410-01-0
Sodium selenite
100/10,000
100
10102-18-8
Sodium selenite
100
7782-82-3
Sodium tellurite
500/10,000
10102-20-2
Strannane.acetoxy-triphenyl-
500/10,000
900-95-8
Strontium chromate
10
7789-06-2
Strychnine
100/10,000
10
P108
57-24-9
Strychnine, sulfate
100/10,000
60-41-3
Styrene
1000
x
100-42-5
Styrene oxide
X
96-09-3
Sulfotep
500
100
P109
3689-24-5
Sulfoxide,3-chloropropyl octyl
500
3569-57-1
Sulfur dioxide
500
7446-09-5
Sulfur monochlonde
1000
12771-08-3
Sulfur tetrafluonde
100
7783-60-0
Sulfur tnoxide
100
7446-11-9
Sulfuric acid
1000
1000
X
7664-93-9
Sulfuric acid
1000
8014-95-7
Tabun
10
77-81-6
Tellurium
500/10,000
13494-80-9
Tellurium hexafluoride
100
7783-80-4
A9-36
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
(Dounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Tetraethyldithiopyr phosphate
100
10
Pill
107-49-3
Terbufos
100
13071-79-9
tert-Amyl acetate
5000
625-16-1
tert-Butyl acetate
5000
540-88-5
tert-Butyl alcohol
X
75-65-0
tert-Butylamine
1000
75-64-9
Tetrachlomnphos
X
961-11-5
Tetraethyllead
100
10
PI 10
78-00-2
Tetraethyltin
100
597-64-8
Tetramethyl Lead
100
75-74-1
Tetranitromethane
500
10
PI 12
509-14-8
ThaJlic oxide
100
PI 13
1314-32-5
Thallium
1000
X
7440-28-0
Thallium(l) carbonate
100/10,000
100
U215
6533-73-9
Thallium (I)sulfate
100/10,000
100
PI 15
10031-59-1
Thallium(l)nitrate
100
U217
10102-45-1
Thallium(I)selenide
1000
PI 14
12039-52-0
Thalious chloride
100/10,000
100
U216
7791-73-9
Thallous malonate
100/10,000
2757-18-8
Thalious sulfate
100/10,000
100
PI 15
7446-18-6
Thiocarbazide
1000/10,000
2231-57-4
Thiofanox
100/10,000
100
P045
39196-18-4
Thiram
10
X
U244
137-26-8
Thiophenol
500
100
P014
108-98-5
Thiosemicarbazide
100/10,000
100
PI 16
79-19-6
Thiourea
10
X
62-56-6
Thiourea,(2-chlorophenyl)-
100/10,000
100
P026
5344-82-1
Thiourea, (2- methylphenyl)-
500/10,000
614-78-8
Thonum dioxide
X
1314-20-1
A9-37
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65(a)
Haz Mat
which are
RCRA
wastes
CAS No.
Titanium dioxide
X
13463-67-7
Titanium tetrachloride
100
X
7550-45-0
Toluene2,4-dnsocyanate
500
100
X
584-84-9
T oluene2,6-di isocyanate
100
100
X
91-08-7
T oxaphene(Campheclor)
1
X
P123
8001-35-2
Trans 1,1-dichlorobutene
500
110-57-6
Triamiphos
500/10,000
1031-47-6
Tnaziquone
X
68-76-8
Triazofos
500
24017-47-8
Tnchloroacetyl chloride
500
76-02-8
Tnchloro(chloromethyl) silane
100
1558-25-4
Tnchloro(dichlorophenyl) silane
500
27137-85-5
Tnchloroethylene
100
X
U228
79-01-6
Trichloroethylsilane
500
115-21-9
Trichlorofon
100
X
52-68-6
Tnchloronate
500
327-98-0
Trichlorophenol
10
25167-82-2
Tnchlorophenylsilane
500
98-13-5
Triethanolamine dode-cylbenzene
sulfonate
1000
27323-41-7
Triethoxysilane
500
998-30-1
Tnethylamine
5000
121-44-8
Trifluralin
X
1582-09-8
Tnmethylamine
100
75-50-3
Trimethylchlorosilane
1000
75-77-4
Tnmethylolpropane phosphite
100/10,000
824-11-3
Trimethyltin chloride
500/10,000
1066-45-1
Tnphenyltin chloride
500/10,000
639-58-7
Tris(2-chloroethyl) amine
100
555-77-1
A9-38
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title III of SARA
Chemical Name
Extremely
Haz Sub 40
CFR 355
loounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65fa)
Haz Mat
which are
RCRA
wastes
CAS No.
Trypan blue
10
X
U236
72-57-1
Uracil,5-[bis(2-chloroethyl)amino]-
10
U237
66-75-1
Uranyl acetate
100
541-09-3
Uranyl nitrate
100
10102-06-4
Uranyl nitrate
100
36478-76-9
Valinomycin
1000/10,000
2001-95-8
Vanadium(fume or dust)
X
7440-62-2
Vanadium pentoxide
100/10,000
1000
P120
1314-62-1
Vanadyl sulfate
1000
27774-13-6
Vinyl acetater
1000
5000
X
108-05-4
Vinyl bromide
X
593-60-2
Warfarin
500/10,000
100
P001
81-81-2
Warfarin sodium
100/10,000
129-06-6
Xylenol
1000
1300-71-6
Xylylene dichlonde
100/10,000
28347-13-9
Zinc
1000
X
7440-66-6
Zinc acetate
1000
557-34-6
Zinc ammonium chlonde
1000
52628-25-8
Zinc ammonium chlonde
1000
14639-97-5
Zinc ammonium chlonde
1000
14639-98-6
Zinc borate
1000
1332-07-6
Zinc bromide
1000
7699-45-8
Zinc carbonate
1000
3486-35-9
Zinc chloride
1000
7646-85-7
Zinc cyanide
10
P121
557-21-1
Zinc, dichloro(4,4-dimethyl-
5(((methylamino) carbnyl)oxy)imino)
Pentane-nitnle)-,(T -4)
100/10,000
58270-08-9
Zinc fluonde
1000
7783-49-5
Zinc formate
1000
557-41-5
A9-39
-------
Appendix 9-1 (continued)
Consolidated List of Chemicals Covered in Title EH of SARA
Chemical Name
Extremely
Haz Sub 40
CFR355
(pounds)
Haz Sub RQ
40 CFR 302.4
(pounds)
Toxic
Chemicals 40
CFR
372.65M
Haz Mat
which are
RCRA
wastes
CAS No.
Zinc hydrosulfite
1000
7779-86-4
Zinc nitrate
1000
7779-88-6
Zinc phenolsulfonate
5000
127-82-2
Zinc phosphide
500
100
P122
1314-84-7
Zinc silicofluonde
5000
16871-71-9
Zinc sulfate
1000
7733-02-0
Zineb
X
12122-67-7
Zirconium nitrate
5000
13746-89-9
Zirconium potassium fluoride
1000
16923-95-8
Zirconium sulfate
5000
14644-61-2
Zirconium tetrachloride
5000
10026-11-6
A9-40
-------
Phase 1
Section 10
Cultural and Historic Resources Management
-------
Phase 1
Section 10
Table of Contents
Cultural and Historic Resources Management
A. Applicability 10-1
B. Federal Legislation 10-1
C. State/Local Regulations 10-4
D. Key Compliance Requirements 10-4
E. Key Compliance Definitions 10-5
F. Records to Review 10-11
G. Physical Features to Inspect 10-12
H. Guidance for Checklist Users 10-12
-------
A. Applicability
This section applies to any facility with cultural and historic resources. Plans and programs
for protection and management of cultural resources, which include historic and prehistoric
properties, are included in this section.
Assessors are required to review agency, Federal, state and local regulations in order to
perform a comprehensive assessment.
B. Federal Regulations
1. Antiquities Act of 1906
Within this Act, 16 U.S. Code (USC) 431-433, the President of the United States is
authorized to declare historic landmarks, historic and prehistoric structures, and other objects of
historic or scientific interest that are situated upon the lands owned or controlled by the Federal
government to be national monuments (16 USC 431). Permits for the examination of ruins, the
excavation of archaeological and paleontological sites, and the gathering of objects of antiquity
upon the lands under their respective jurisdictions may be granted by the Secretaries of the
Interior (SOI), Agriculture, and Army to institutions which they may deem properly qualified to
conduct such examination, excavation, or gathering, subject to such rules and regulations as they
may prescribe (16 USC 432).
2. Historic Sites Act of 1935
This Act, Public Law (PL) 74-292 (16 USC 470-470w-6), authorizes the designation of
national historic sites and landmarks, authorizes interagency efforts to preserve historic
resources, and establishes a maximum fine of $500 for violations of the Act.
3. National Historic Preservation Act (NHPA) of 1966
This Act, 16 USC 470-470w-6, last amended in August 1989, addresses the issue of
preserving our national history. The Congress declares that the historical and cultural
foundations of the nation should be preserved as a living part of our community life and
development; and that the preservation of this irreplaceable heritage is in the public interest so
that its vital legacy of cultural, educational, aesthetic, inspirational, economic, and energy
benefits will be maintained and enriched for future generations of Americans (16 USC
470(b)(2)(4)). The policy of the Federal government is to:
• Use measures, including financial and technical assistance, to foster conditions under which
our modern society and our prehistoric and historic resources can exist in productive
harmony and fulfill the social, economic, and other requirements of present and future
generations;
• Provide leadership in the preservation of the prehistoric and historic resources of the United
States and of the international community of nations;
Phase 1 - Section 10
Cultural and Historic Resources Management
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• Administer federally owned, administered, or controlled prehistoric and historic resources in
a spirit of stewardship for the inspiration and benefit of present and future generations;
• Contribute to the preservation of nonfederally owned prehistoric and historic resources and
give maximum encouragement to organizations and individuals undertaking preservation by
private means;
• Encourage the public and private preservation and utilization of all usable elements of the
nation's historic built environment; and
• Assist state and local governments and the National Trust for Historic Preservation in the
United States to expand and accelerate their historic preservation programs and activities (16
USC 470-1).
4. The National Environmental Policy Act (NEPA)
The purpose of this Act, 42 USC 4321-4370c, as last amended in November 1990, was to
declare a national policy which will encourage productive and enjoyable harmony between man
and his environment. Additionally, it provides for the promotion of efforts which will prevent or
eliminate damage to the environment and biosphere and stimulate the health and welfare of man
(42 USC 4321). It is the continuing responsibility of the Federal government to use practicable
means and resources to the end that the nation may preserve important historic, cultural, and
natural aspects of our national heritage (42 USC 4331(b)(4)).
5. Executive Order (EO) 11593, Protection and Enhancement of the Cultural
Environment
This EO, dated 13 May 1971, directs Federal agencies to: provide leadership in preserving,
restoring, and maintaining the historic and cultural environment of the nation; ensure the
preservation of historic resources; locate, inventory, and nominate to the national Register all
properties under their control that meet the criteria for nomination; and ensure that historic
resources are not inadvertently damaged, destroyed, or transferred before the completion of
inventories and evaluation for the National Register.
6. Archaeological and Historic Preservation Act of 1974
This Act, PL 93-291 (amends PL 86-523); (16 USC 469-469c), directs Federal agencies to
notify the SOI when they find that any Federal construction project or federally licensed activity
or program may cause irreparable loss or destruction of significant scientific, prehistoric,
historical, or archaeological data. It also provides criteria for funding historical and
archaeological protection for such projects.
7. Public Buildings Cooperative Use Act of 1976
This Act, 40 USC 490, 601 note, et seq., was last amended in November 1988. Under this
Act, the Administrator of General Services must, among other duties, acquire and use space in
suitable buildings of historic, architectural, or cultural significance, unless use of such space
would not prove feasible and prudent compared with available alternatives (40 USC 601a(a)(l)).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-2
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8. American Indian Religious Freedom Act of 1978
This Act, PL 95-341 (42 USC 1996), states the policy of the United States to protect and
preserve for American Indians their inherent rights of freedom to believe, express, and exercise
the traditional religions of the American Indian, Eskimo, Alert, and native Hawaiians. These
rights include, but are not limited to, access to sites, use and possession of sacred objects, and the
freedom to worship through ceremony and traditional rites.
9. Archaeological Resources Protection Act (ARPA) of 1979
This Act, 16 USC 470aa-470mm, was last amended in October 1988. The purpose of this
Act is to secure, for the present and future benefit of the American people, the protection of
archaeological resources and sites which are on public lands and Indian lands, and to foster
increased cooperation and exchange of information between governmental authorities, the
professional archaeological community, and private individuals having collections of
archaeological resources and data which were obtained before 1 October 1979 (16 USC
470aa(b)).
10. Native American Graves Protection and Repatriation Act (NAGPRA) of October 1990
This Act, 25 USC 3001-3013, permits the intentional removal from or excavation of Native
American cultural items from Federal or tribal lands for purposes of discovery, study, or removal
of such items only if:
• Such items are excavated or removed pursuant to a permit issued which must be consistent
with this Act;
• Such items are excavated or removed after consultation with or, in the case of tribal lands,
consent of the appropriate (if any) Indian tribe or Native Hawaiian organization;
• The ownership and right of control of the disposition of such items must be as provided in
subsections (a) and (b) of this section; and
• Proof of consultation or consent is shown (25 USC 3002(c)).
Each Federal agency and museum which has possession or control over holdings or
collections of Native American human remains and associated funerary objects must compile an
inventory of such items and, to the extent possible based on information processed by such
museum or Federal agency, identify the geographical and cultural affiliation of such item (25
USC 3003(a)). Each Federal agency or museum which has possession or control over holdings or
objects of Native American unassociated funerary objects, sacred objects, or objects of cultural
patrimony must provide a written summary of such objects based on available information held
by such agency or museum. The summary must describe the scope of the collection, kinds of
objects included, reference to geographical location, means and period of acquisition and cultural
affiliation, where readily ascertainable.
Phase 1 - Section 10
Cultural and Historic Resources Management
10-3
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11. Abandoned Shipwreck Act of 1987
This Act, PL 100-298, defines and clarifies access and ownership rights and directs the
Director of the National Park Service to prepare guidelines, in consultation with appropriate
public and private section interests, to administer and manage underwater resources.
12. Religious Freedom Restoration Act of 1993
This Act (PL 103-141) [H.R. 1308), states that the Government shall not substantially
burden a person's exercise of religion, except in instances where the burden furthers a
compelling governmental interest and is the least restrictive means of furthering that compelling
governmental interest.
C. State/Local Regulations
At the state level, the State Historic Preservation Officer (SHPO) provides assistance in
determining cultural significance and eligibility for the National Register, but may also nominate
properties, irrespective of ownership. The SHPO must be consulted during all cultural resources
planning. States may also issue regulations designating state historical sites.
D. Key Compliance Requirements
1. Historical Properties
All Federal agencies are required to establish a program to locate, inventory, and nominate
to the SOI all properties under the agency's control that qualify for inclusion on the National
Register of Historic Places. Facilities are required to take into account the effects of a new
undertaking on property in the National Register before beginning an undertaking. The facility is
required to consult the SHPO during identification, location, and evaluation of historic properties
and in assessing the effect of an undertaking on historic property (36 CFR 60.9(7)(f), 60.13,
800.1, 800.4, and 800.5; 32 CFR 229.4(a) and 229.5(b)).
2. Archaeological Requirements
When unrecorded historic property is discovered during construction or other undertakings,
work is required to halt until the situation is properly evaluated. Archaeological resources on
either public or Indian lands cannot be excavated, removed, damaged, or otherwise altered
without permit (32 CFR 229.4(a) and 229.5(b)).
3. Native American Graves and Artifacts
Federal law protects Native American graves and artifacts. Facilities are required to take
measures to identify and protect them and cooperate with Native American groups in returning
them to their rightful owners (PL 101-601, Sect. 3d, Sect. 5, and Sect 6).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-4
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4. Collection Management and Curation
Archaeological and historic collections owned or controlled by Federal facilities are required
to be assessed and evaluated. Facilities responsible for long-term management and preservation
of collections are covered by regulations dealing with curation, record keeping, long-term
curatorial services, repository security, curatorial staff qualifications, use of collections, and
conduct of inspections and inventories of the collections. Collection management centers are
also required to write annual reports updating the status of their collections (36 CFR 79).
E. Key Compliance Definitions
1. Advisory Council on Historic Preservation (ACHP)
The Council was established by Title II of the NHPS to advise the President and Congress,
to encourage private and public interest in cultural preservation, and to comment on Federal
agency action under Section 106 of the NHPA (36 CFR 65.3).
2. Archaeological Resource
Any material remains of prehistoric or historic human life or activities. Such resources
include, but are not limited to: pottery, basketry, bottles, weapons, weapon projectiles, tools,
structures or portions of structures, pit houses, rock paintings, rock carvings, intaglios, graves,
human skeletal materials, or any portion or piece of any of the foregoing items (16 USC 470bb).
3. Associated Funerary Objects
Objects that, as a part of the death rite or ceremony of a culture, are reasonably believed to
have been placed with individual human remains either at the time of death or later, and both the
human remains and associated funerary objects are presently in the possession or control of a
Federal agency or museum, except for other items exclusively made for burial purposes or to
contain human remains shall be considered as associated funerary objects (PL 101-601, Section
2)
4. Associated Records
Original records, or copies thereof, that are prepared or assembled and document efforts to
locate, evaluate, record, study, preserve, or recover a prehistoric or historic resource (36 CFR
79 4).
5. Building
A structure created to shelter any form of human activity, such as a house, barn, church,
hotel, or similar structure. Building may refer to a historically related complex such as a
courthouse and jail or a house and barn (36 CFR 60.3).
6. Burial Site
Any natural or prepared physical location, whether originally below, on, or above the surface
of the earth, into which as a part of the death rite or ceremony of a culture, individual human
remains are deposited (PL 101-601, Section 2).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-5
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7. Collection
Materials remains that are excavated or removed during a survey, excavation, or other study
of a prehistoric or historic resource, and associated records that are prepared or assembled in
connection with the survey, excavation or other study (36 CFR 79.4).
8. Cultural Affiliation
A relationship of shared group identity which can be reasonably traced historically or
prehistorically between a present day Indian tribe or Native Hawaiian organization and an
identifiable earlier group (PL 101-601, Section 2).
9. Cultural Items
Associated and unassociated funerary objects, sacred objects, and cultural patrimony (PL
101-106, Section 2(3)(a-d)).
10. Cultural Patrimony
An object having ongoing historical, traditional, or cultural importance central to the Native
American group or culture itself, rather than property owned by an individual Native American,
and which, therefore, cannot be alienated, appropriated, or conveyed by any individual regardless
of whether or not the individual is a member of the Indian tribe or Native Hawaiian organization
(PL 101-601, Section 2).
11. Curatorial Services
Managing and preserving a collection according to professional museum and archival
practices (36 CFR 79.4).
12. Determination of Eligibility
A decision by the Department of the Interior (DOI) that a district, site, building, structure, or
object meets the National Register criteria for evaluation although the property is not formally
listed in the National Register (36 CFR 60.3).
13. District
A geographically definable area, urban or rural, that possesses a significant concentration,
linkage or continuity of sites, structures, buildings, or objects united by past events or
aesthetically by plan or physical development. A district may also compromise individual
elements separated geographically but linked by association or history (36 CFR 60.3).
14. Effect
Direct effects are caused by the undertaking and occur at the place and time of the
undertaking. Indirect effects are those caused by the undertaking that are later in time or further
removed in distance, but are still reasonably foreseeable (50 CFR 1508.8).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-6
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15. Endangered Property
A historic property that is, or is about to be, subjected to a major impact that will destroy or
seriously damage the qualities of significance that make it eligible for National Historic
Landmark or National Register of Historic Places designation (36 CFR 65 3).
16. Federal Agency Official
Any officer, employer, or agent officially representing the secretary of the department or the
head of any other agency or instrumentality of the United States having primary management
authority over a collection that is subject to 36 CFR 79 (36 CFR 79.4).
17. Federal Lands
Any land other than tribal lands which are controlled or owned by the United States,
including lands selected by but not yet conveyed to Alaska Native Corporations and groups
pursuant to the Alaska Native Claims Settlement Act of 1971 (PL 101-601, Section 2).
18. Federal Preservation Officer
The person who is responsible for coordinating the agency's activities under the NHPA and
EO 11593, including nominating properties under the agency's ownership or control to the
National Register (36 CFR 60.3).
19. Historic Preservation
Identification, evaluation, documentation, curation, acquisition, protection, rehabilitation,
restoration, management, stabilization, maintenance, recording, and reconstruction of cultural
resources, and any combination of the foregoing (16 USC 470(w)(8)).
20. Historic Property or Resource
Any prehistoric or historic district, site, building, structure, or object included in, or eligible
for inclusion on the National Register; such term includes artifacts, records, and remains which
are related to such a district, site, building, structure, or object (16 USC 470W).
21. Indian Lands
All lands under the jurisdiction or control of an Indian tribe (36 CFR 800.2).
22. Indian Tribe or Tribe
An Indian Tribe, band, nation, or other organized group or community including a Native
village, Regional Corporation or Village Corporation as those terms are defined in section 3 of
the Alaska Native Claims Settlement Act (42 USC 1602), which is recognized as eligible for the
special programs and services provided by the United States to Indians because of their status as
Indians (NHPA, Sect. 301(4)).
23. Inventory
An itemized list of human remains and funerary objects along with their geographical and
cultural affiliations (PL 101-601, Section 5.(a) and (e)).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-7
-------
24. Landmark
A National Historic Landmark is a district, site, building, structure or object, in public or
private ownership, judged by the SOI to possess national significance in American history,
archeology, architecture, engineering, and culture, and is so designated by the Secretary (36 CFR
65.3).
25. Management Practice (MP)
Practices, that although not mandated by law, are encouraged to promote safe operating
procedures.
26. Material Remains
Artifacts, objects, specimens, and other physical evidence that are excavated or removed in
connection with efforts to locate, evaluate, document, study, preserve, or recover a prehistoric or
historic resource. Classes of material remains that may be in a collection include, but are not
limited to (36 CFR 79.4):
• Components of structures and features (such as houses, mills, piers, fortifications,
earthworks, and mounds);
• Intact or fragmentary artifacts of human manufacture;
• Intact or fragmentary natural objects used by humans (such as rock crystals, feathers, and
pigments);
• By-products, waste products, or debris resulting from manufacture or use of man-made or
natural materials;
• Organic materials (such as vegetable and animal remains);
• Human remains;
• Components of petroglyphs, pictographs, intaglios, or other works of artistic or symbolic
representation;
• Components of shipwrecks;
• Environmental and chronometric specimens; and
• Paleontological specimens that are found in direct physical relationship with a prehistoric or
historic resource.
27. Museum
Any institution or state or local government agency (including any institution of higher
learning) that receives Federal funds and has possession of, or control over, Native American
Phase 1 - Section 10
Cultural and Historic Resources Management
10-8
-------
cultural items. Such term does not include the Smithsonian Institution or any other Federal
agency (PL 101601, Section 2).
28. National Historic Landmark
A National Historic Landmark is a district, site, building, structure, or object, in public or
private ownership, judged by the SOI to possess national significance in American history,
archaeology, architecture, engineering, and culture, and is so designated by the Secretary (36
CFR 65.3).
29. National Historic Landmarks Program
The program that identifies, designates, recognizes, lists, and monitors National Historic
Landmarks, conducted by the Secretary through the National Park Service (36 CFR 65.3)
30. National Park Service
The bureau of the DOI to which the SOI has delegated the authority and responsibility for
administering the National Register program (36 CFR 60 3(h)).
31. National Register of Historic Places (National Register)
The listing of districts, sites, buildings, structures, and objects of national, state, or local
significance in American history, architecture, archaeology, or culture that is maintained by the
SOI (Keeper of the Register) (36 CFR 65.3).
32. Native American
Of, or relating to, a tribe, people, or culture that is indigenous to the United States (PL 101-
106, Section 2)
33. Native Hawaiian
Any individual who is a descendent of the aboriginal people who, prior to 1778, occupied
and exercised sovereignty in the area that now constitutes the state of Hawaii (PL 101-106,
Section 2).
34. Nominate
To complete and submit National Register of Historic Places form proposing that a resource
be included in the National Register. Nominations can be made for individual resources, multiple
resources, or thematic groups (36 CFR Part 60.4)
35. Preservation
Identification, evaluation, recordation, documentation, curation, acquisition, protection,
management, rehabilitation, restoration, stabilization, maintenance, and reconstruction of any
constituents of the foregoing activities (16 USC 470W).
36. Property
A site, building, object, structure, or a collection of the above that forms a district (36 CFR
65 3).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-9
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37. Public Lands
Lands owned and administered by the United States including the national park system,
national wildlife refuge system, and national forest system. Additional public lands are those
whose fee title is held by the United States, the Outer Continental Shelf, and lands under the
jurisdiction of the Smithsonian Institute (PL 96-95, Section 3(3)).
38. Qualified Museum Professional
A person who possesses knowledge, experience, and demonstrable competence in museum
methods and techniques appropriate to the nature and content of the collection under the person's
management and care and commensurate with the person's duties and responsibilities (36 CFR
79.4).
<
39. Religious Remains
Material remains that the Federal Agency Official (FAO) has determined are of traditional,
religious, or sacred importance to an Indian tribe or other group because of customary use in
religious rituals or spiritual activities. This determination is made in consultation with
appropriate Indian tribes or other groups (36 CFR 79.4).
40. Repository
A facility such as a museum, archeological center, laboratory or storage facility managed by
a university, college, museum, other educational or scientific institution, a Federal, state or local
government agency or Indian tribe that can provide professional, systematic, and accountable
curatorial services on a long-term basis (36 CFR 79.4).
41. Restoration
The act or process of accurately recovering the form and details of property and its setting as
it appeared at a particular period of time by means of the removal of later work or by the
replacement of missing earlier work (36 CFR 68.2).
42. Sacred Objects
Specific ceremonial objects which are needed by traditional Native American religious
leaders for the practice of their traditional Native American religions by their present day
adherents (PL 101-601, Section 2).
43. Section 106 Consultation
A compliance procedure in which an agency requests the comments of the SHPO and/or the
ACHP when an undertaking may affect a property on, or eligible for, the National Register (36
CFR 800.3 through 800.9).
44. Significant
Having a characteristic that makes a property eligible for listing on the National Register
(DOD Directive 4710.0).
Phase 1 - Section 10
Cultural and Historic Resources Management
10-10
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45. State Historic Preservation Officer (SHPO)
The official who is responsible for administering the NHPA within the state of jurisdiction,
or a designated representative authorized to act for the SHPO (36 CFR 60.3)
46. Tribal Official
The chief executive officer or any officer employee or agent officially representing the
Indian tribe (36 CFR 79.4).
47. Unassociated Funerary Objects
Objects that, as a part of the death rites or ceremony of a culture are reasonably believed to
have been placed with individual human remains either at the time of death or later, where the
remains are not in the possession or control of the Federal agency or museum and the objects can
be identified by a preponderance of the evidence as related to specific individuals or families or
to known human remains or, by a preponderance of the evidence, as having been removed from a
specific burial site of an individual culturally affiliated with a particular Indian tribe (PL 101-
106, Section 2).
48. Undertaking
A project, activity, or program funded in whole or in part under the direct or indirect
jurisdiction of a Federal agency, including (NHPA 301(7)).
a. Those carried out by or on behalf of the agency;
b. Those carried out with Federal financial assistance,
c. Those requiring a Federal permit, license, or approval, and
d. Those subject to state or local regulation administered pursuant to a delegation of approval
by a Federal agency.
F. Records to Review
For construction activities: documentation of finding of no adverse effect, finding of adverse
effect, or Memorandum of Agreement (MOA) with the SHPO or requests for comment when
there is no agreement on historic properties;
• Cultural resources inventory/survey;
• Land use plans;
• Local zoning maps (historic districts);
• Environmental assessments;
Phase 1 - Section 10
Cultural and Historic Resources Management
10-u
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• Environmental impact documentation; and
• Federal (Section 10 and 404) and state dredge and/or fill of wetlands and water bodies
permits.
G. Physical Features to Inspect
• Sites of historic, archaeological, or Native American interest (designation, protection, and
interpretation); and
• Buildings and structures of potential historical significance (National, state, or local).
H. Guidance For Checklist Users
Refer To
Checklist Items
Page Numbers
All Facilities
CH 1 through CH 4
10-13
Historic Properties
CH 5 through CH 7
10-14
Religious/Heritage Access
CH 8
10-14
Archaeological and Indian Sites
CH 9
10-15
CH.10
10-16
Collection Management and Curation
CH 11
10-16
CH 12 through CH 14
10-17
CH. 15 through CH 17
10-18
CH 18 through CH.19
10-19
Phase 1 - Section 10
Cultural and Historic Resources Management
10-12
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Compliance Category:
Cultural «ttd Historic Resources Management
Regulatory Requirements:
Reviewer Checks!
All Facilities
CH 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements, or equivalent state enforcement actions.
For those open items, indicate what corrective action is planned and milestones
established to correct problems
CH 2 Facilities are required to
comply with all applicable
Federal and state regulatory
requirements not contained in
this checklist (A finding under
this checklist item will have the
citation of the applied
regulation as a basis of finding)
Determine if any new Federal or state regulations concerning cultural resources
management have been issued since the finalization of the manual If so, annotate
checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued Federal
and state regulations
CH 3 Facilities should comply
with state and local regulations
concerning cultural resources
management (MP)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
• Designation of historic and archeological sites
- Protection of historic and archeological sites )
CH 4 All facilities should have
a Compliance Management
Plan for cultural and hisiorical
resources (MP)
(NOTE Based in part on inventories of such resources contained in facility-specific
environmental documents such as those prepared under NEPA )
Verify through consultation with other team specialists that the cultural resource
planning process has been integrated into the compliance actions driven by other
environmental statutes such as CERCLA and RCRA
Verify that the site has developed a proactive cultural resources management
program, identifying both short-term and long-term management goals (NHPA,
Section 101(0)
Verify that historic preservation is an integral part of the site's environmental mission
Phase 1 - Section 10
Cultural and Historic Resources Management
10-13
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Compliance Category:
Cultural ami Historic Resources Management
Regulatory Rmulremftttts;
| Iteviewer CtoeteK
Historic Properties
CH 5. All Federal agencies are
required to establish a program
to locate, inventory, and
nominate to the SOI all
properties under the agency's
ownership or control that
appear (o qualify for inclusion
on the National Register of
Historic Places (36 CFR 60 9).
Determine if the facility has a program to locate, inventory, and nominate properties
that include the following
- Assignment of responsibility for recognizing and maintaining cultural resources
- An inventory and evaluation of all known cultural resources
- Identification of the likelihood (based on scientific study) of the presence of other
significant cultural resources
- Description of the facility's strategies for maintaining cultural resources and the
methods used for compliance with this regulation
- Clear identification of the impacts on historic resources of ongoing projects and the
mitigation of those impacts
Determine if the SHPO is given the opportunity to review and comment on all aspects
of the program.
Verify that known historic properties have been nominated
CH 6 Prior to the start of a
new undertaking, facilities are
required to take into account the
effects of the undertaking on
property included in or eligible
for the National Register of
Historic Places (36 CFR 800 1)
Verify that prior to the start of a new undertaking, the impact of that undertaking on
property included in or eligible for the National Register of Historic places has been
investigated through the Section 106 process of consultation and documentation
Verify that the facility determines the area of potential effect for every undertaking
Determine if a MOA has been drafted and review a copy for compliance
Verify that the MOA was reviewed by the ACHP
CH 7. The facility is required
to consult with the SHPO
during the identification,
location, and evaluation of
historic properties and in
assessing the effect of any
undertaking on historic property
(36 CFR 800 4 and 800 5)
Determine if the SHPO and staff have been consulted during all cultural resources
planning including
- Identification of cultural properties
- Research design
- Applying criteria of National Register
- Requesting a determination of eligibility from the Keeper (Chief of Registration) of
the National Register when an agency and a SHPO disagree on eligibility
- Interaction with ACHP
- Determination-of-effect in a single property compliance procedure
Religious/Heritage Access
CH.8, Facilities cannot
substantially burden a person's
exercise of religion (Religious
Freedom Restoration Act of
1993, Sec 3)
Determine if the facility has on its property a site which is an integral part of a
religious ceremony Examples might include a burial ground or holy site
Verify that access to and use of these sites is allowed unless denial of access/use
furthers a compelling government interest and is the least restrictive means of
furthering a government interest
Phase 1 - Section 10
Cultural and Historic Resources Management
10-14
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Compliance Category:
Cultural and Historic Resourtts Manageiaettt
Regulatory Re
-------
Compliance Category:
Cultural
-------
Compliance Category:
Cttltatt) aiMlBistoric Resources Management
Regulatory Requirements;
: Hevie*er Cfeecfctt
CH 12 Facilities responsible
for the long-term management
and preservation of new
archaeological collections are
required to meet specific
curation standards (36 CFR
79 5(b))
Determine if the facility has responsibility for the long-term management and
preservation of new archaeological collections which were obtained/placed after 12
October 1990
Verify that new archeological collections are deposited in a repository only after the
following criteria have been met
- The repository has the capability to provide adequate long-term curatorial services
- The repository's facilities, written curatorial policies and operating procedures are
consistent with 36 CFR 79
- The repository has certified, in writing, that the collection will be cared for,
maintained and made accessible in accordance with 36 CFR 79
- When the collection is from Indian lands, written consent to the disposition has
been obtained from the Indian landowner and the Indian tribe having jurisdiction
over the lands
- The initial processing of the material remains (including appropriate cleaning,
sorting, labeling, cataloging, stabilizing, and packaging) has been completed by
qualified museum professionals, and associated records have been prepared and
organized in accordance with the repository's processing and documentation
procedures
CH.13 Facilities responsible
for the long-term management
and preservation of pre-existing
and new archaeological
collections are required to keep
specific administrative records
(36 CFR 79.5(c))
Verify that the following administrative records on the disposition of each collection
includes.
- The name and location of the repository where the collection is deposited
- A copy of the contract, memorandum, agreement or other appropriate written
instrument, and any subsequent amendments, between the facility, the repository,
and any other party for curatorial services
- A catalog list of the contents of the collection that is deposited in the repository
- A list of any other Federal personal property that is furnished to the repository as
part of the contract, memorandum, or agreement
- Copies of reports documenting inspection, inventories and investigations of loss,
damage, or destruction that are conducted
- Any subsequent permanent transfer of the collection to another repository
CH 14 Facilities responsible
for the long-term management
and preservation of pre-existing
and new archaeological
collections are required to
provide long-term curatorial
services conducted by qualified
museum professionals (36 CFR
79 9(a) and 79.9(b)(1))
Verify that the repository provides the following as adequate long-term care
- Accession, labeling, cataloging, storage, maintenance, inventory, and conservation
of the particular collection on a long-term basis using professional museum and
archival practices
- Maintenance of complete and accurate records of the collection, including
— records on acquisition
-- catalogs and artifact inventory lists
-- descriptive information, including field notes, site forms, and reports
-- photographs, negative, and slides
— locational information, including maps
— approved loans and other uses
-- inventory and inspection records, including any environmental monitoring
records
-- records on lost, deteriorated, damaged, or destroyed government property
Phase 1 - Section 10
Cultural and Historic Resources Management
10-17
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Compliance Category:
Cultural d
-------
Compliance Category:
Cultural Historic Resources Matwgejaeat
Regulatory Requirements*
¦ Reviewer Cfcecfca
CH 18 Facilities responsible
for the long-term management
and preservation of pre-existing
and new archeological
collections are required to
follow specific practices
regarding the use of the
collections (36 CFR 79 10)
Verify that the collection is available for scientific, educational and religious uses,
subject to such terms and conditions as are necessary to protect and preserve the
condition, research potential, religious or sacred importance, and uniqueness of the
collection
CH 19 Facilities responsible
for the long-term management
and preservation of pre-existing
and new archaeological
collections are required to
inventory and inspect those
collections (36 CFR 79.9(b)(7),
79 9(b)(8), and 79 11(b)
through 79 11(d)).
Verify that inspections and inventories of the collection are conducted periodically
Verify that inspection of the collection for possible deterioration and damage is
conducted
Verify that the inventories include the material remains and associated records, and
any other U S Government-owned personal property in the possession of the
repository.
Verify that qualified museum professionals conduct the inspections and inventories
Verify that following each inspection and inventory, the personnel responsible for the
inspection and inventory prepare and provides the responsible person with a written
report of the results, including the status of the collection, treatments completed, and
recommendations for additional treatments
(NOTE- For collections from Indian lands, the Indian landowner, and the Tribal
Official, and the Indian tribe that has jurisdiction over the lands, are provided with a
copy of the notification also)
Verify that within five days of the discovery of any loss or theft of, deterioration and
damage to, or destruction of the collection (or a part thereof) or any other U.S.
Government-owned property, the personnel responsible for the curation of the
collection prepare and provide the responsible person with written notification of the
circumstances surrounding the loss
Verify that the collection is available for inspection by the responsible person, the
Indian landowner and Tribal Official (when the collection is from Indian lands), the
Indian tribal elder, religious leaders, and other officials representing the Indian tribe
or other group for which the remains have religious or sacred importance
Phase 1 - Section 10
Cultural and Historic Resources Management
10-19
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Phase 1
Section 11
Storage Tank Management
-------
Phase 1
Section 11
Table of Contents
Storage Tank Management
A. Applicability 11-1
B. Federal Legislation 11-1
C State/Local Requirements 11-2
D. Key Compliance Requirements 11-2
E. Key Compliance Definitions 11-7
F. Records to Research 11-19
G. Physical Features to Inspect 11-19
H. Guidance for Checklist Users 11-20
Appendices
All-1. UST Applicability Guide All-1
All-2. Schedule for Phase-In Release Detection All-2
All-3. Release Detection Requirements for USTs and Underground Piping All-3
-------
A. Applicability
This section applies to facilities that utilize storage tanks and pipelines, whether
aboveground or underground, for the storage and/or conveyance of hazardous materials,
petroleum products, or hazardous waste. The section presents review action items for emissions
from tanks, structural concerns, monitoring, and recordkeeping requirements.
Assessors are required to review agency, state, and local regulations in order to perform a
comprehensive assessment.
B. Federal Legislation
1. The Resource Conservation and Recovery Act (RCRA) Subtitles I and C
Subtitle I, Public Law (PL) 99-49 (42 U.S. Code (USC) 6991-699(l)(i)), established the
standards and procedures for Underground Storage Tanks (UST). It required the EPA to issue
standards on leak detection, record maintenance, release reporting, corrective actions, tank
upgrading, and replacement (42 USC 6991(b)(a)(c)). Subtitle C, PL 98-616 (42 USC 6921 -
6939(b)) establishes standards and procedures for handling, storage, treatment, and disposal of
hazardous waste Specifically, RCRA prohibits the placement of bulk or noncontainerized liquid
hazardous waste or free liquids containing hazardous waste into a landfill
2. The Clean Air Act (CAA) Amendments of 1990
This Act (PL 101-549; 42 USC 7401 -7671 (q)), is currently the effective, comprehensive
Federal legislation that regulates the prevention and control of air pollution. See the Air Pollution
Control checklist for further information on the CAA
3. Clean Water Act of 1977
The Clean Water Act (CWA) of 1977 established a program to regulate certain
nontransportation related aboveground and belowground oil storage tanks that have the potential
to release oil into or upon the navigable waters of the United States adjoining shorelines.
4. The Federal Facilities Compliance Act (FFCA) of 1992
This act provides for a waiver of sovereign immunity with respect to Federal, state, and local
procedural and substantive requirements relating to RCRA.
5. The Occupational Safety and Health Act (OSHA)
This Act, last amended in November 1990 (29 USC 651-678), is a Federal statute which
governs the issues related to occupational safety and health. The purpose and policy of this Act is
to assure every working man and woman in the nation safe and healthful working conditions and
to preserve our human resources by, among other things, providing for the development and
publication of occupational safety and health standards, providing for an effective enforcement
program, and providing for appropriate reporting procedures with respect to occupational safety
and health which procedures will help achieve the objectives of this Act and accurately describe
the nature of the occupational safety and health (29 USC 651 (b)(9)( 10)( 12)).
Phase 1 - Section 11
Storage Tank Management
11-1
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6. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
the agency funds meet applicable Federal, state, and local environmental requirements or for
correcting situations that are not in compliance with such requirements. In addition, the EO
requires that each agency ensure that sufficient funds for environmental compliance are included
in the agency budget.
C. State/Local Requirements
Since the primary mechanisms regulating air pollutant emissions are the state or Air Quality
Control Region (AQCR) regulations, some states and/or municipalities may be regulating
emissions from storage vessels.
Many state and local governments have active UST programs. These various governments
have developed regulations specific to the physical environment and the regulated communities'
needs. It is important to review regulations at the state and local level to ensure that any
differences such as permitting, reporting or notification requirements, and monitoring
requirements are complied with.
D. Key Compliance Requirements
1. Aboveground Storage Tanks (AST)
All bulk storage tanks are required to be provided with a secondary means of containment
for the entire contents of the largest single tank, plus sufficient freeboard to allow for
precipitation. ASTs are required to undergo periodic integrity testing and keep a written log of
this testing. Drainage of rainwater from diked areas must be controlled by a valve that is closed
when not in active use. Drainage water that is determined to contain petroleum products in
harmful quantities must be treated before discharge to meet applicable water quality standards
(40 CFR 112.7(e)(1) through 112.7(e)(2)).
2. Bulk Gasoline Terminals
Bulk gasoline terminals with greater than 75,000 L (19,997.82 gal) gasoline throughput per
day that deliver liquid product into greater tank trucks, and that started construction or
modification after 17 December 1980 are required to ensure that vapor tightness documentation
is available for each gasoline tank truck, and that the tank identification number is recorded as
each gasoline tank truck is loaded (40 CFR 60.500 through 60.506).
3. Petroleum Storage Vessels
Storage vessels for petroleum liquids with a storage capacity greater than 151,416 L (40,000
gal) but less than 246,052 L (65,000 gal), that started construction or modification after 8 March
1974 but before 19 May 1978, or with a capacity greater than 246,052 L (65,000 gal) that started
Phase 1 - Section 11
Storage Tank Management
11-2
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construction or modification after 11 June 1973 but before 19 May 1978, are required to meet
specific standards for emissions and monitoring. These standards vary depending upon whether
the true vapor pressure of the petroleum liquid is greater or less than 11.1 psia. Storage vessels
with a storage capacity greater than 151,416 L (40,000 gal) constructed after 18 May 1978 are
required to ensure that the vessel has an external floating roof, or a fixed roof with an internal
floating type cover, and a vapor recovery system (40 CFR 60 110 through 60.113 and 60 110(a)
through 60.115(a)).
4. Volatile Organic Liquid (VOL) Storage Vessels
Storage vessels for VOLs having a capacity of greater than or equal to 40 m3 (10,566.88 gal)
for which construction, reconstruction, or modification started after 23 July 1984 are required to
meet specific inspection, documentation, and notification requirement standards. These include
ensuring that certain inspections are made, notifying the EPA in advance of performing gap
measurements, and providing it certain records upon request (40 CFR 60.110(b) through
60.115(b)).
5. Substandard USTs
Substandard UST systems must be upgraded, closed, or removed from service by 22
December 1998. If a release detection system is not available for the UST, it must be phased out
in one to five years (40 CFR 280.21(a) through 280.21(c)).
6. New or Upgraded USTs
New or upgraded USTs are required to be fitted with spill and overfill prevention equipment.
Notice must be given to the appropriate authority within 30 days when a UST system is brought
into service after 8 May 1986. If the UST is installed after 22 December 1988, it must be
constructed so that it will remain structurally sound for its operating life. Installation of USTs
must be done by a certified installer and UST systems must be made of or lined with materials
compatible with the substance stored (40 CFR 280.20,280.21(d), 280.22, and 280.32).
7. Metallic USTs
Buried metallic storage tanks installed after 1973 must be protected from corrosion by
coatings, cathodic protection, or other effective methods. They must also undergo regular
pressure testing (40 CFR 112.7(e)(2)(iv)).
8. Spill and Overfill Prevention for USTs
The filling of an UST must include the prevention of overfilling and spilling of the
substance. If a spill does occur, facilities with UST systems are required to contain and
immediately clean up a spill or overfill and report it to the implementing agency within 24 hours
if (40 CFR 280.30, 280.53):
a. Spills or overfills of petroleum that resulted in a release to the environment of more than 25
gal (93.89 L) or that caused a sheen on nearby surface water; and
Phase 1 - Section 11
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11-3
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b. Spills or overfills of hazardous substances that result in a release to the environment in
excess of the reportable quantity.
9. Corrosion Protection and Repairs for USTs
Corrosion protection on USTs must operate continuously to provide corrosion protection to
the metal components that routinely contain regulated substances and are in contact with the
ground. UST systems with impressed current cathodic protection are required to be inspected
every 60 days by a qualified cathodic protection tester. Repairs to USTs must be performed
according to industry code. Tanks and piping that have been replaced or repaired are required to
be tested for tightness within 30 days. Records of repairs shall be maintained for the life of the
tank (40 CFR 280.31, 280.33, 280.43, and 280.44).
10. Release Detection for USTs
Facilities with new and existing USTs are required to provide a method, or combination of
methods of release detection. Release detection requirements in 40 CFR 280.40 through 280.45
do not apply to USTs which store fuel solely for use by emergency power generators. Release
detection records are required to be kept as follows (40 CFR 280.40 through 280.45):
a. All written performance claims pertaining to any release detection system used for five
years from the date of installation;
b. The results of any sampling testing or monitoring for one year;
c. The results of tank tightness testing, until the next test is done;
d. Written documentation of calibration, maintenance, repair, of release detection
equipment permanently located onsite, at least one year after the servicing is done; and
e. Schedules of required calibration and maintenance provided by the release detection
equipment manufacturer, five years after the date of installation.
Depending on the age, size, and construction of the tank, acceptable methods of release
detection include the following:
a. Inventory control;
b. Manual tank gauging;
c. Tank tightness testing;
d. Automatic tank gauging;
e. Vapor monitoring;
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11-4
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f. Groundwater monitoring; and
g. Interstitial monitoring.
Existing UST system tanks must implement release detection requirements based on when
the system was installed. The table below identifies the deadline for providing release detection:
\
Deadline for Release Detection
UST System Installation Date
Leaitllefcetfosi Required by 22 December of
All others
1992
1980-December 1988
1993
11. Release Detection for Underground Piping Associated with UST Systems
40 CFR 280, Subpart D establishes separate release detection requirements for underground
piping depending on whether it conveys substances under pressure or suction. These include:
a. Pressurized piping may be equipped with an automatic line leak detector and have an
annual line tightness test conducted; or pressurized piping may be equipped with an
automatic line leak detector and a permanent release detection system that allows
monthly monitoring. Permanent release detection methods acceptable for piping
include: vapor monitoring, interstitial monitoring, and groundwater monitoring. The
deadline for implementing release detection requirements on pressurized piping was 22
December 1990.
b. Suction piping either may have a line tightness test conducted every three years or may
use a permanent release detection system that allows monthly monitoring. Deadlines for
implementing release detection requirements on suction piping are based on when the
UST system was installed. The table above identifies the deadline for providing release
detection. For suction piping constructed to certain standards, no release detection
monitoring is required. It must meet five criteria:
(1) Below-grade piping must operate at less than atmospheric pressure
(2) Below-grade piping must be sloped to drain back into the tank when
suction is released
(3) Only one check valve can be included in each suction line
(4) The check valve is located directly below and as close as practical to
the suction pump
(5) Criteria in paragraphs b through d must be verifiable.
c Corrosion expert's analysis of site corrosion potential if corrosion protection equipment
is not used.
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11-5
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d. Documentation of operation of corrosion protection equipment.
e. Documentation of repairs.
f. Closure records.
g. Results of any site investigations (40 CFR 280.34. 280.45, and 280.74).
12. Change in Service or Closure of USTs
USTs which are put out of service temporarily must have continued maintenance. If the UST
has been out-of-service for near or over one year, plans must be made for permanent closure. The
facility must notify the implementing agency for any closure or change in service 30 days in
advance or within a reasonable time frame as determined by the implementing agency. UST
closure must be done by either removing the tank from the ground or leaving it in place with the
contents removed and filled with an inert solid material and closing it to all future outside access.
If a tank is undergoing a change-in-service, it must be emptied and cleaned and a site assessment
conducted. Prior to the completion of permanent closure or change-in-service, measurements
must be made for the presence of a release where contamination is most likely to be present at
the site. Facilities with UST systems closed prior to 22 December 1988 must assess the
excavation zone and close the UST according to current standards if releases from the UST may
pose a current or potential threat to human health and the environment (40 CFR 280.70 through
280.73).
13. Hazardous Waste Storage Tanks
Storage tanks are one storage option that facilities which produce or store hazardous waste
can use. The storage tank requirements are based on whether the facility is a Small Quantity
Generator (SQG), a Generator, or a Treatment, Storage or Disposal Facility (TSDF). Refer to the
sections titled Hazardous Waste Management for more details on the definitions of these
classifications.
14. Flammable Combustible Liquid Storage Tanks
Storage tanks that hold flammable/combustible liquids must not be below ground or inside
buildings. They are to be built of steel except in certain circumstances. Outside aboveground
tanks for flammable liquids are to meet requirements for distance between tanks, firefighting
access, and containment. When flammable vapor may be present from storage tanks, heat sources
will be kept from the tanks. Tanks are required to have been strength tested before being used (29
CFR 1910.106(b)).
Phase 1 - Section 11
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15. Onshore Oil Pipelines
Facilities with onshore oil pipelines that because of location could reasonably be expected to
cause substantial harm to the environment by discharging oil into navigable waters are required
to prepare a response plan. Copies of the response plan are required to be submitted to the EPA
Research and Special Programs Administration (RSPA) for approval. Copies of the response
plan are required to be kept at the operators headquarters, pump stations, and other places where
response activities might be conducted. Training is required for the implementation of the
response plan. The response plan is required to be reviewed every three years from the date of
submission and modified to address new or different operating conditions or information (49
CFR 194).
16. Service Stations
The storage of liquids at service stations, specifically Class I liquids, has to be done in
containers that are secure and which prevent excess release of vapors (29 CFR 1910.106(g)).
17. Transfer Terminals
Terminals transferring oil or hazardous materials to vessels with a capacity of more than 250
bbl (30,746.83 L) are required to have an operations manual If the reception facility at the
terminal or port loads a daily average of more than 1,000 metric tons (1,100 short tons) of oil, it
has to be able to receive waste such as oily bilge water, sludge, oily ballast, and cargo residue (33
CFR 154.100 through 154.300 and 158.220 through 158.230).
E. Key Compliance Definitions
1. Aboveground Release
Any release to the surface of the land or to surface water. This includes, but is not limited to,
releases from the aboveground portion of an UST system and aboveground releases associated
with overfills and transfer operations as the regulated substance moves to or from an UST system
(40 CFR 280.12).
2. Aboveground Storage Tank
In relation to hazardous waste, a device that meets the definition of tank in 40 CFR 260.10
and that is situated in such a way that the entire surface area of the tank is completely above the
plane of the adjacent surrounding surface and the entire surface area of the tank (including the
tank bottom) is able to be visually inspected (40 CFR 260.10),
3. Ancillary Equipment
Any devices including, but not limited to, such devices as pipings, fittings, flanges, valves,
and pumps used to distribute, meter, or control the flow of regulated substances to and from the
UST (40 CFR 280.12).
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11-7
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4. Atmospheric Tank
A storage tank which has been designed to operate at pressures from atmospheric through
0.5 psig (29 CFR 1910.106(a)(2)).
5. Automotive Service Station
That portion of property where flammable or combustible liquids used as motor fuels are
stored and dispensed from fixed equipment into the fuel tanks of motor vehicles and shall include
any facilities available for the sale and service of tires, batteries, and accessories, and for minor
automotive maintenance work. Major automotive repairs, painting, body, and fender work are
excluded (29 CFR 1910.106(a)(3)).
6. Belowground Release
Any release to the subsurface of the land and to groundwater. This includes, but is not
limited to, releases from the belowground portion of an underground storage tank system and
belowground releases associated with overfills and transfer operations as the regulated substance
moves to or from an UST (40 CFR 280.12).
7. Bulk Gasoline Plant
Any gasoline distribution facility that has a throughput less than or equal to 75,000 L
(19,997.82 gal/day) (40 CFR 60.111(b)).
8. Cathodic Protection
A technique to prevent corrosion of a metal surface by making that surface the cathode of an
electrochemical cell. For example, a tank system can be cathodically protected through the
application of either galvanic anodes or impressed current (40 CFR 280.12).
9. Cathodic Protection Tester
A person who can demonstrate understanding of the principles and measurements of all
common types of cathodic protection systems as applied to buried or submerged metal piping
and tank systems. At a minimum, such persons must have education and experience in soil
resistivity, stray current, structure-to-soil potential, and component electrical isolation
measurements of buried metal piping and tank systems (40 CFR 280.12).
10. CERCLA
Comprehensive Environmental Response Compensation and Liability Act of 1980 as
amended (40 CFR 280.12).
11. Combustible Liquid
A liquid having a flashpoint at or above 100° F (37.8° C). Combustible liquids are
categorized as Class II or Class III liquids and are further subdivided as follows (29 CFR
1910.106(a)(l 8)):
a. Class II liquids are those having a flashpoint at or above 100° F (37.8° C) and below
140° F (60° C) except any mixture having components with flashpoints of 200° F (93.3°
Phase 1 - Section 11
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C) or higher, the volume of which makes up 99 percent or more of the total volume of
the mixture.
b. Class IIIA liquids are those having flashpoints at or above 140° F (60° C) and below
200° F (93.3° C) except any mixture having components with flashpoints of 200° F
(93.3° C) or higher, the total volume of which make up 99 percent or more of the total
volume of the mixture.
c. Class IIIB liquids are those having flashpoints at or above 200° F (93.3° C).
12. Compatible
The ability of two or more substances to maintain their respective physical and chemical
properties upon contact with one another for the design life of the tank system under conditions
likely to be encountered in the UST (40 CFR 280.12).
13. Connected Piping
All underground piping including valves, elbows, joints, flanges, and flexible connectors
attached to a tank system through which regulated substances flow. For the purpose of
determining how much piping is connected to any individual UST system, the piping that joins
two UST systems should be allocated equally between them (40 CFR 280.12).
14. Consumptive Use
With respect to heating oil, means consumed on the premises (40 CFR 280.12).
15. Corrosion Expert
A person who, by reason of thorough knowledge of the physical sciences and the principles
of engineering and mathematics acquired by a professional education and related practical
experience, is qualified to engage in the practice of corrosion control on buried or submerged
metal piping systems and metal tanks. Such a person must be accredited or certified as being
qualified by the National Association of Corrosion Engineers or be a registered professional
engineer who has certification or licensing that includes education and experience in corrosion
control of buried or submerged metal piping systems and metal tanks (40 CFR 280.12).
16. Deferred USTs
USTs which are exempt from meeting the requirements in 40 CFR 280 except those
concerning release response and corrective action for UST systems containing petroleum or
hazardous substances in 40 CFR 280.60 through 280.67. These tanks include (40 CFR
280.10(e)).
a Wastewater treatment tank systems;
b. Any UST systems containing radioactive material that are regulated under the Atomic
Energy Act of 1954;
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c. Any UST system that is a part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10 CFR
50, Appendix A;
d. Airport hydrant fuel distribution systems; and
e. UST systems with field-constructed tanks.
17. Dielectric Material
A material that does not conduct direct electrical current. Dielectric coatings are used to
electrically isolate UST systems from the surrounding soils. Dielectric bushings are used to
electrically isolate portions of the UST system (e.g., tank from piping) (40 CFR 280.12).
18. Electrical Equipment
Underground equipment that contains dielectric fluid that is necessary for the operation of
equipment such as transformers and buried electric cable (40 CFR 280.12).
19. Environmentally Sensitive Area
An area of environmental importance which is in or adjacent to navigable waters (49 CFR
194.5).
20. Excavation Zone
The volume containing the tank system and backfill material bounded by the ground surface,
walls, and floor of the pit and trenches into which the UST system is placed at the time of
installation (40 CFR 280.12).
21. Excluded USTs
These are USTs which are not required to meet the requirements found in 40 CFR 280 and
include (40 CFR 280.10(b)):
a. Any UST system holding hazardous wastes listed under Subtitle C of the Solid Waste
Disposal Act, or a mixture of such hazardous waste and other regulated substances.
b. Any wastewater treatment tank system that is part of a wastewater treatment facility
regulated under Section 402 or 307(b) of the Clean Water Act (CWA)
c. Equipment of machinery that contains regulated substances for operational purposes
such as hydraulic lift tanks and electrical equipment
d. Any UST system whose capacity is 110 gal (416.40 L) or less
e. UST system that contains a de minimis concentration of a regulated substance
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f. Any emergency spill or overflow containment UST system that is expeditiously
emptied after use.
22. Existing Tank System
A tank system used to contain an accumulation of regulated substances or for which
installation has commenced on or before 22 December 1988. Installation is considered to have
commenced if (40 CFR 280.12):
a. The owner or operator has obtained all Federal, state, and local approvals or permits
necessary to begin physical construction of the site or installation of the tank system.
b. Either a continuous onsite physical construction or installation program has begun, or
the owner or operator has entered into any contractual obligations: which cannot be
canceled or modified without substantial loss for physical construction at the site or
installation of the tank system to be completed within a reasonable time.
23. Farm Tank
A tank located on a tract of land devoted to the production of crops or raising animals;
including fish and associated residences and improvements. A farm tank must be located on the
farm property. "Farm" includes fish hatcheries, rangeland, and nurseries with growing operations
(40 CFR 280.12).
24. Flammable Liquid
A liquid with a flashpoint below 100°F (37.8°C) except any mixture having components
with flashpoints of 100°F (37.8°C) or higher, the total of which make up 99 percent or more of
the total volume of the mixture. Flammable liquids are categorized as Class I liquids, and are
further subdivided as follows (29 CFR 1910.106(a)( 19)):
a. Class IA are those that have a flashpoint below 73 °F (22.8°C) and boiling point below
100° F (37.8°C)
b. Class IB are those that have flashpoints below 73 °F (22.8 °C) and boiling points at or
above 100°F (37.8°C)
c. Class IC are those that have flashpoints at or above 73 °F (22.8 °C) and below 100°F
(37.8 °C).
25. Flow-through Process Tank
A tank that forms an integral part of a production process through which there is a steady,
variable, recurring, or intermittent flow of materials during the operation of the process. Flow-
through process tanks do not include tanks used for the storage of material prior to their
introduction into the production process or for the storage of finished products or byproducts
from the production (40 CFR 280.12).
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26. Free-product
A regulated substance that is present as a nonaqueous phase liquid (e.g., liquid not dissolved
in water) (40 CFR 280.12).
27. Gathering Lines
Any pipeline, equipment, facility, or building used in the transportation of oil or gas during
oil or gas production (40 CFR 280.12).
28. Generator
Any person, by site, whose act or process produces hazardous waste identified or listed in 40
CFR Part 261, or whose act first causes a hazardous waste to become subject to regulation (40
CFR 260.10). (NOTE: This typically is used to refer to a facility producing hazardous waste in
quantities greater than 1000 kg/mo (2204.62 lb/mo)).
29. Hazardous Substance UST System
Any underground storage tank system that contains a hazardous substance defined in section
101(14) of the Comprehensive Environmental Compensation and Liability Act of 1980 (but not
including any substance regulated as a hazardous waste under Subtitle C) or any mixture of such
substances and petroleum, and which is not a petroleum UST system (40 CFR 280.12).
30. Hazardous Waste
A solid waste identified as a characteristic or listed hazardous waste in 40 CFR 261.3 (40
CFR 260.10)
31. Heating Oil
Petroleum that is No. 1, No. 2, No. 4—light, No. 4~heavy, No.5 —heavy, and No. 6 technical
grades of fuel oil; other residual fuel oils (including Navy Special Fuel Oil and Bunker C); and
other fuels when used as substitutes for one of these fuel oils. Heating oil is typically used in the
operation of heating equipment, boilers, or furnaces (40 CFR 280.12).
32. Hydraulic Lift Tank
A tank holding hydraulic fluid for a closed-loop mechanical system that uses compressed air
or hydraulic fluid to operate lifts, elevators, and other similar devices (40 CFR 280.12).
33. In-ground Tank
A device meeting the definition of tank in 40 CFR 260.10 whereby a portion of the tank is
situated to any degree within the ground, thereby preventing visual inspection of the external
surface of that tank that is in the ground (40 CFR 260.10).
34. Liquid Trap
Sumps, well cellars, and other traps used in association with oil and gas production,
gathering, and extracting operations (including gas production plants), for the purpose of
collecting oil, water, and other liquids. These liquid traps may temporarily collect liquids for
Phase 1 - Section 11
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subsequent disposition or reinjection into a production or pipeline stream, or may collect and
separate liquids from a gas stream (40 CFR 280.12).
35. Low Pressure Tank
A storage tank which has been designed to operate at a pressure above 0.5 psig but not more
than 15 psig (29 CFR 1910.106(a)(21)).
36. Maintenance
The normal operational upkeep to prevent an UST system from releasing product (40 CFR
280.12).
37. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures
38. Motor Fuel
Petroleum or a petroleum-based substance that is motor gasoline, aviation gasoline, No 1 or
No.2 diesel fuel, or any grade of gasohol, and is typically used in the operation of motor engines
(40 CFR 280.12).
39. New Tank
In relation to used oil, a tank that will be used to store or process used oil and for which
installation has started after the effective date of the authorized used oil program for the state in
which the tank is located (40 CFR 279.1).
40. New Tank System
For USTs, a tank system that will be used to contain an accumulation of regulated
substances and for which installation has commenced after 22 December 1988 (40 CFR 280.12)
41. New Tank System or New Component System
In relation to hazardous waste, a tank system or component that will be used for the storage
and treatment of hazardous waste and for which installation has commenced after 14 July 1986,
except however, for purposes of 40 CFR 264 193(g)(2) and 265.193(g)(2), a new tank system is
one for which construction commenced after 14 July 1986 (40 CFR 260 10)
42. Noncommercial Purposes with Respect to Motor Fuel
Not for resale (40 CFR 280.12).
43. On the Premises Where Stored (heating oil)
UST systems located on the same property where the stored heating oil is used (40 CFR
280 12).
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44. Onground Tank
In relation to hazardous waste, a device meeting the definition of tank in 40 CFR 260.10 and
that is situated in such a way that the bottom of the tank is on the same level as the adjacent
surrounding surface so that the external tank bottom cannot be visibly inspected (40 CFR
260.10).
45. Onshore Oil Pipeline Facilities
New and existing pipe, rights-of-way and any equipment, facility, or building used in the
transportation of oil located in, on, or under, any land within the United States other than
submerged land (49 CFR 194.5).
46. Operator
Any person in control of or having responsibility for the daily operation of the UST system
(40 CFR 280.12).
47. Operator
In relationship to onshore oil pipeline facilities, a person who owns or operates onshore oil
pipeline facilities (49 CFR 194.5).
48. Overfill Release
A release that occurs when a tank is filled beyond its capacity, resulting in a discharge of the
regulated substance to the environment (40 CFR 280.12).
49. Person
An individual, trust, firm, joint stock company, Federal agency, corporation, state,
municipality, commission, political subdivision of a state, or any interstate body. Person also
includes a consortium, a joint venture, a commercial entity, and the U. S. Government (40 CFR
280.12).
50. Petroleum UST System
An UST system that contains petroleum or a mixture of petroleum with de minimis
quantities of other regulated substances. Such systems include those containing motor fuels, jet
fuels, distillate fuel oils, residual fuel oils, lubricants, petroleum solvents, and used oils (40 CFR
280.12).
51. Pipe or Piping
A hollow cylinder or tubular conduit that is constructed of non-earthen materials (40 CFR
280.12).
52. Pipeline
All parts of an onshore pipeline facility through which oil moves, including, but not limited
to, line pipe, valves, and other appurtenances connected to the line pipe, pumping units,
fabricated assemblies associated with pumping units, metering and delivery stations and
fabricated assemblies therein, and breakout tanks (49 CFR 194.5).
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53. Pipeline Facilities (including gathering lines)
Are new and existing pipe rights-of-way and any associated equipment, facilities, or
buildings (40 CFR 280.12).
54. Portable Tank
A closed container having a liquid capacity over 60 gal (227.12 L) and not intended for fixed
installation (29 CFR 1910.106(a)(25)).
55. Pressure Vessel
A storage tank or container designed to operate at pressures above 15 psig (29 CFR
1910.106(a)(29)).
56. Qualified Individual
An English-speaking representative of an operator, located in the United States, available on
a 24-hour basis, with full authority to: activate and contract with required oil spill removal
organizations, activate personnel and equipment maintained by the operator; act as liaison with
the On-Scene Coordinator (OSC); and obligate any funds required to carry out all required or
directed oil response activities (49 CFR 194.5).
57. Regulated Substance
This includes (40 CFR 280 12)(40 CFR 280 10(b)):
a. Any substance defined in section 101(14) of CERCLA of 1980 (but not including any
substance regulated as a hazardous waste under Subtitle C); and
b. Petroleum, including crude oil or any fraction thereof that is liquid at standard
conditions of temperature and pressure (60°F (15 56°C) and 14 7 lb/psia).
(NOTE: The term regulated substance includes, but is not limited to, petroleum and
petroleum based substances comprised of a complex blend of hydrocarbons derived from crude
oil though processes of separation, conversion, upgrading, and finishing, such as motor fuels, jet
fuels, distillate fuel oils, residual fuel oils, lubricants, petroleum solvents, and used oils.)
58. Reid Vapor Pressure
The absolute vapor pressure of volatile crude oil and volatile nonviscous petroleum liquids
except liquified petroleum gases as determined by the ASTM, Part 17, 1973, D-323-72
(reapproved 1977) (40 CFR 60.111(a)).
59. Release
Any spilling, leaking, emitting, discharging, escaping, leaching, or disposing from an UST
into groundwater, surface water, or subsurface soils (40 CFR 280 12).
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60. Release Detection
Determining whether a release of a regulated substance has occurred from the UST system
into the environment or into the interstitial space between the UST system and its secondary
barrier or secondary containment around it (40 CFR 280.12).
61. Repair
To restore a tank or UST system component that has caused a release of product from the
UST system (40 CFR 280.12).
62. Residential Tank
A tank located on property used primarily for dwelling purposes (40 CFR 280.12).
63. Response Activities
The containment and removal of oil from the water and shorelines, the temporary storage
and disposal of recovered oil, or the taking of other actions as necessary to minimize or mitigate
damage to the environment (49 CFR 194.5).
64. Response Area
The inland zone or coastal zone, as defined in the National Contingency Plan, in which
response activity is occurring (49 CFR 194.5).
65. Response Plan
The operator's core plan and the response zone appendices for responding, to the maximum
extent practicable, to a worst case discharge of oil, or the substantial threat of such a discharge
(49 CFR 194.5)
66. Response Zone
A geographic area, either along a length of pipeline or including multiple pipelines,
containing one or more adjacent line sections, for which the operator must plan for the
deployment of, and provide, spill response capabilities (49 CFR 194.5).
67. SARA
Superfund Amendments and Reauthorization Act (40 CFR 280 12)
68. Septic Tank
A water-tight covered receptacle designed to receive or process, through liquid separation or
biological digestion, the sewage discharged from a building sewer. The effluent from such
receptacle is distributed through the soil and settled solids and scum from the tank are pumped
out periodically and hauled to a treatment facility (40 CFR 280.12).
69. Small Quantity Generator
A generator who generates less than 1,000 kg/mo (2,204.62 lb/mo) of hazardous waste in a
calendar month but more than 100 kg (220.46 lb) (40 CFR 260 10)
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70. Stormwater or Wastewater Collection System
Piping, pumps, conduits, and any other equipment necessary to collect and transport the flow
of surface water runoff resulting from precipitation, or domestic, commercial, or industrial
wastewater to and from retention areas or any areas where treatment is designated to occur. The
collection of stormwater and wastewater does not include treatment except where incidental to
conveyance (40 CFR 280.12).
71. Surface Impoundment
A natural topographic depression, manmade excavation, or diked area formed of primarily of
earthen materials (although it may be lined with manmade materials) that is not an injection well
(40 CFR 280 12)
72. Tank
A stationary device designed to contain an accumulation of regulated substances and
constructed of non-earthen materials (e.g. concrete, steel, plastic) that provide structural support
(40 CFR 280.12)
73. Tank
In relation to hazardous waste, a stationary device designed to contain an accumulation of
hazardous waste that is constructed primarily of nonearthen materials (e.g., wood, concrete, steel,
plastic) which provide structural support (40 CFR 260 10).
74. Tank System
A hazardous waste storage or treatment tank and its associated ancillary equipment and
containment system (40 CFR 260.10).
75. True Vapor Pressure
The equilibrium partial pressure exerted by a petroleum liquid as determined in accordance
with methods described in American Petroleum Institute (API) Bulletin 2517, Evaporation Loss
From Floating Roof Plants, 1962 (40 CFR 60.111(a)).
76. Underground Area
An underground room such as a basement, cellar, shaft, or vault, providing enough space for
physical inspection of the exterior of the tank situated on or above the surface of the floor (40
CFR 280.12).
77. Underground Release
Any belowground release (40 CFR 280 12).
78. Underground Storage Tank (UST)
Any one or a combination of tanks (including underground pipes connected thereto) that is
used to contain an accumulation of regulated substances, and the volume of which (including the
volume of underground pipes connected thereto) is 10 percent or more beneath the surface of the
ground. This term does not include any (40 CFR 280.12):
Phase I - Section 11
Storage Tank Management
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a. Farm or residential tank of 1,100 gal (4,163.95 L) or less capacity used for storing
motor fuel for non-commercial purposes.
b. Tank used for storing heating oil for consumptive use on the premises where stored
c. Septic tanks.
d. Pipeline facility (including gathering lines) which are regulated by other acts.
e. Surface impoundment, pit, pond, or lagoon.
f. Storm-water or waste water collection system.
g. Flow-through process tank.
h. Liquid trap or associated gathering lines directly related to oil or gas production and
gathering operations.
i. Storage tank situated in an underground area if the storage tank is situated upon or
above the surface of the floor such as basements or tunnels.
j. Tanks holding 110 gal (106.21 L) or less.
k. Emergency spill and overfill tanks.
(NOTE: The definition of UST does not include any pipes connected to any tank which is
described in paragraph (a) through (i) of this definition.)
79. Underground Tank
In relation to hazardous waste, a device meeting the definition of tank in 40 CFR 260.10
whose entire surface area is totally below the surface and covered by the ground (40 CFR
260.10).
80. Unfit-for-Use Tank System
A tank system that has been determined through an integrity assessment or other inspection
to be no longer capable of storing or treating hazardous waste without posing a threat of release
of hazardous waste to the environment (40 CFR 260.10).
81. Upgrade
The addition or retrofit of some systems such as cathodic protection, lining, or spill and
overfill controls to improve the ability of an UST system to prevent the release of product (40
CFR 280.12).
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82. UST System or Tank System
UST, connected underground piping, underground ancillary equipment, and containment
system, if any (40 CFR 280.12).
83. Volatile Organic Liquid (VOL)
Any organic liquid which can emit volatile organic compounds into the atmosphere except
those VOLs that emit only those compounds which the Administrator has determined do not
contribute appreciably to the formation of ozone. These compounds are identified in EPA
statements on ozone abatement policy for State Implementation Plan (SIP) revisions (40 CFR
60.11 l(b)(k))
84. Wastewater Treatment Tank
A tank that is designed to receive and treat influent waste water through physical, chemical,
or biological methods (40 CFR 280.12).
85. Worst Case Discharge
The largest foreseeable discharge of oil, including a discharge from fire or explosion, in
adverse weather conditions (49 CFR 194.5).
F. Records to Research
• Records of all spills, leaks, and associated site assessment/cleanup activities (for three years)
• Official correspondence with state implementing agency
• Spill Prevention and Response Plan
• Results of all AST/UST testing, sampling, monitoring, inspection, maintenance, and repair
work (for one year)
• Registration records for all in-service, temporarily out-of-service, and permanently closed
tanks
• Records of all spills, leaks, and associated site assessment/cleanup activities (for three years)
• Records for AST/UST disposal, closure, and removal from activity and results of excavation
area assessment (for three years)
G. Physical Features to Inspect
• Refueling facilities, including:
Belowground storage tanks and dikes
Venting
Fill pipe
Gauges
Vehicle Maintenance areas
• Oil and hazardous substance site
• Any site with a UST
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11-19
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• Fuel farms
• Transfer terminals/transfer stations
• Pipelines.
H. Guidance For Checklist Users
Refer To
Checklist Items
Page Numbers
All Facilities
ST 1 through ST 3
11-22
Aboveground Storage Tanks
ST 4 through ST 5
ST 6 through ST 7
11-23
11-24
Emissions from Bulk Gasoline Terminals
ST 8
11-25
Emissions from Storage Vessels
ST 9
ST 10
11-26
11-27
Emissions from VOL Storage Vessels
ST 11
ST 12
ST 13
11-28
11-29
11-30
Substandard USTs
ST 14
11-31
New or Upgraded USTs
ST 15 through ST 16
ST. 17
ST 18 through ST 19
11-32
11-33
11-34
Metallic USTs
ST 20
11-35
UST Filling
ST 21
ST 22
11-35
11-36
UST Corrosion Protection and Repairs
ST.23
ST.24
11-37
11-38
Release Detection for USTs
General
Petroleum USTs
Hazardous Substance UST
Exempt USTs
ST 25
ST 26
ST 27
ST 28
ST 29
11-39
11-39
11-41
11-42
11-43
UST Releases
ST.30 through ST.31
ST.32 through ST.33
ST 34
ST.35 through ST 36
11-44
11-45
11-46
11-47
Deferred UST Systems
ST 37
11-48
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KeferTo
Checklist Items
Page Numbers
UST Documentation
ST 38
11-48
ST 39
11-49
Changes in Service or Closure of USTs
ST 40
11-50
ST 41 through ST 42
11-51
ST 43 through ST 44
11-52
ST 45 through ST 46
11-53
Hazardous Waste Storage Tanks
Small Quantity Generators
ST 47
11-54
ST 48 through ST 49
11-55
Generators
ST 50 through ST 51
11-56
ST 52 through ST 53
11-57
ST 54 through ST 56
11-58
ST 57 through ST 58
11-59
ST 59 through ST 60
11-60
ST 61 through ST 62
11-61
ST 63 through ST 64
11-62
TSDFs
ST 65 through ST 67
11-63
ST 67 through ST 69
11-64
ST 70 through ST 71
11-65
Flammable/Combustible Liquid Storage Tanks
ST 72
11-66
ST 73
11-67
ST 74 through ST 76
11-68
Pipelines
ST 77
11-69
ST 78
11-70
ST 79
11-71
ST 80 through ST 82
11-72
ST 83 through ST 84
11-73
Service Stations
ST 85 through ST 87
11-74
ST 88
11-75
Transfer Terminals
ST 89 through ST 91
11-76
POL Loading and Unloading
ST 92 through ST 93
11-77
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Compliance Category:
Storage tank Management
Regulatory Requirements:
| Reviewer Checks:
All Facilities
ST 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
ST 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist.
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding)
Determine if any new regulations have been issued since the flnalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued
regulations
ST 3 Facilities are required to
comply with state and local
regulations concerning storage
tank management (EO 12088,
under "Federal Legislation"
section)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
- Operational standards
- Permitting requirements
- Replacement and removal schedules
- Cathodic protection requirements
- Alarm system requirements)
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Compliance Category:
Storage tank Management
Regulatory Requirements;
Reviewer Cheeks;
Aboveground Storage Tanks (AST)
ST 4 All bulk storage tanks
(over 660 gal (2,498 37 L)) are
required to be provided with a
secondary means of
containment for the entire
contents of the largest single
tank plus sufficient freeboard to
allow for precipitation (40 CFR
112 7(e)(2)(H))
Verify that adequate containment is provided for bulk storage tanks in the storage area
and at remote tanks by looking for signs of cracks, erosion, animal burrows, and
vegetation growth
Verify that diked areas are impervious enough to contain spilled oil
(NOTE Dikes, containment curbs, and pits are commonly employed for this purpose,
but they may not always be appropriate An alternative system could consist of a
complete drainage trench enclosure arranged so that a spill could terminate and be
safely contained in an in-plant catchbasin or holding pond )
(NOTE Facilities are exempt from the requirements outlined in 40 CFR 112 if
- The facility, equipment, or operation is not subject to the jurisdiction of the EPA as
follows
-- onshore and offshore sites which, due to their location, could not be reasonably
expected to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines
- equipment or operations of vessels or transportation related onshore and
offshore sites which are subject to the authority of the Department of
Transportation (DOT)
- Both of the following criteria are met
- the underground buried storage capacity of the facility is 42,000 gal (15,987 30
L) or less of oil
- the storage capacity which is not buried at the facility is 1,320 gal (4,996 74 L)
of oil or less and no single container exceeds a capacity of 660 gal (2,498 37 L)
(40 CFR 112 1(d)(2))
ST 5 Drainage of rainwater
from diked areas must be
controlled by a valve which is
closed when not in active use
(40 CFR 112 7(e)(1) and
112 7(e)(2)(in))
Verify that valves are closed when not in use by inspecting drainage valves at diked
areas
Verify that drainage valves are attended when opened to drain diked/bermed area by
interviewing personnel.
Determine if operating personnel understand the meaning of a harmful discharge as
described in 40 CFR 110 6
Inspect records for any drainage water which was inspected to determine if it would
represent a harmful discharge
Phase 1 - Section 11
Storage Tank Management
11-23
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—BE
lil „ ^ 4l
ST.6 Drainage water which is
determined to contain
petroleum products in harmfiil
quantities must be treated prior
to discharge to meet applicable
water quality standards (40
CFR 112.7(e)(2))
Determine if discharges containing harmful quantities of petroleum products were
properly treated, recovered, or disposed and reported by interviewing onsite
personnel
ST 7 Aboveground Storage
Tanks (ASTs) are required to
undergo periodic integrity
testing (40 CFR
112 7(e)(2)(vi))
Verify that periodic leak tests have been conducted (a decrease in converted fuel
volume equal to or greater than 1/4 in (0 64 cm) constitutes a suspected leak) and
check the results of these tests
Determine if leaking tanks have been repaired or replaced
(NOTE Periodic testing should take tank design into account and involve such
techniques as hydrostatic testing, visual inspection, or a system of non-destructive
shell thickness testing.)
Verify that a written log of integrity testing has been maintained
Phase 1 - Section 11
Storage Tank Management
11-24
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Compiferoee Category:
Storage Tank Management
Regulatory Ke^uirenwats;
| Reviewer Checks:
Emissions From Bulk Gasoline Terminals
ST 8 Bulk gasoline terminals
with greater than 75,700 L
(19,997 82 gal) gasoline
throughput per day that delivers
liquid product into greater tank
trucks and that started
construction or modification
after 17 December 1980 are
required to meet specific
operating standards (40 CFR
60 500 through 60.506)
Verify that each terminal has a vapor collection system designed to collect the total
organic compound vapors displaced from tank trucks during product loading and to
prevent the total organic compounds collected at the on-loading rack from passing to
another loading rack
Verify that emissions from the vapor collection system do not exceed 35 mg of total
organic compound per liter of gasoline loaded except those terminals with existing
vapor processing systems that were constructed or refurbished before 17 December
1980 may emit 80 mg of total organic compounds per liter of gasoline loaded
Determine if the following loading procedures are followed
- Vapor tightness documentation is available for each gasoline tank truck
- The tank identification number is recorded as each gasoline tank truck is loaded
- Each tank identification number is cross-checked with the file of tank vapor
tightness documentation within two weeks after the tank is loaded
- Steps are taken to ensure that only vapor-tight tanks are loaded and vapor collection
systems are operational
Verify that the vapor collection and liquid loading equipment is designed and
operated to prevent gauge pressure in the delivery tank from exceeding 4,500 pascals
(450 mm of water) during product loading
Verify that pressure vacuum vents in the vapor collection system do not open at a
system pressure of less than 4,500 pascals (450 mm of water).
Verify that a monthly inspection of the vapor collection system, the vapor processing
system, and each loading rack handling gasoline is done during loading, and
inspection records are kept on file for two years
Verify that leaks are repaired within 15 calendar days after detection.
Verify that records of all replacements or additions of components performed on
existing vapor processing systems are kept for at least three years
Phase 1 - Section 11
Storage Tank Management
11-25
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Checks
Emissions From Storage Vessels
ST 9 Storage vessels for
petroleum liquids are required
to meet specific standards for
emissions and monitoring (40
CFR60 110 through 60 113)
(NOTE These requirements only apply to storage vessels for petroleum liquids with
a storage capacity greater than 151,416 L (40,000 gal), but less than 246,052 L
(65,000 gal), that started construction or modification after 8 March 1974 but before
19 May 1978, or with a capacity greater than 246,052 L (65,000 gal) and started
construction or modification after 11 June 1973 but before 19 May 1978.)
Determine if the facility has any petroleum storage tanks meeting these parameters.
Determine what the vapor pressure is of the petroleum liquids being stored
Verify that if the true vapor pressure of the petroleum stored is equal to or greater
than 78 mm Hg (1 5 psia) but not greater than 570 mm Hg (11 1 psia) the storage
vessel is equipped with a floating roof and a vapor recovery system or their
equivalents.
Verify that if the true vapor pressure of the petroleum liquid being stored is greater
than 570 mm Hg (11 1 psia,) the storage vessel is equipped with a vapor pressure
recovery system or its equivalent
Verify that if proper vapor recovery and return or disposal systems are not in place, a
record is maintained of the petroleum liquid stored, the period of storage, and the
maximum true vapor pressure of the liquid during the storage period.
(NOTE1 Facilities storing petroleum liquids with a Reid vapor pressure of less than
6.9 kPa (1.0 psia) are not required to keep records )
Phase 1 - Section 11
Storage Tank Management
11-26
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Checks:
ST 10 Storage vessels for
petroleum liquids with a storage
capacity greater than 151,416 L
(40,000 gal) constructed after
18 May 1978 are required to
meet specific standards (40
CFR60 110a through 60 115a)
Determine if the facility has any liquid petroleum storage vessels meeting these
parameters
Determine the true vapor pressure of the liquids stored
Verify that vessels storing petroleum liquid with a true vapor pressure equal to or
greater than 10 3 kPa (1 5 psia) but less than 76 6 kPa (11 1 psia) are equipped with
one of the following.
- An external floating roof meeting design requirements outlined in 40 CFR 60.112a
- A fixed roof with an internal floating type cover equipped with a continuous
closure device between the tank wall and edges
- A vapor recovery system that collects all VOC vapors and gases discharged from
the storage vessel and a vapor return or disposal system to process the VOC vapors
and gases to reduce emissions by at least 95 percent by weight
- An equivalent approved system
Verify that vessels storing petroleum liquids with a vapor pressure greater than 76 6
kPa (11 1 psia) are equipped with a vapor recovery system that collects all VOC
vapors and gases and a vapor return or disposal system that is designed to process the
VOC vapors to reduce emissions by at least 95 percent by weight
Verify that the following testing is done
- Gap measurement for primary seals of external floating roofs are measured at least
once every five years
- Gap measurement for secondary seals of external floating roofs are measured at
least once every year.
Verify that the following records are kept-
- Records of gap measurement are to be kept for at least two years following the date
of measurement
- The petroleum liquid stored, the period of storage, and the maximum true vapor
pressure during the storage unless the storage vessel has a vapor recovery and
return or disposal system
Phase 1 - Section 11
Storage Tank Management
11-27
-------
Compliance Category;
Storage Ta&fc Management
Regulatory ttequiremtate;
| Jtevtaver duafew
Emissions From VOL Storage Vessels
ST 11 Storage vessels for
Volatile Organic Liquids (VOL)
having a capacity of greater
than or equal to 40 m3
(10,566 88 gal) for which
construction, reconstruction, or
modification was started after
23 July 1984 are required to
meet specific standards (40
CFR 60 110(b) through
60 115(b))
(NOTE These standards do not apply to
- Pressure vessels designed to operate in excess of 204 9 kPa (29 72 psi) and without
emissions to the atmosphere
- Vessels which are permanently attached to mobile vehicles
- Vessels located at bulk gasoline plants
- Vessels located at gasoline service stations.)
Determine if any of the storage vessels on the facility meet these parameters
Determine the vapor pressure of the liquids being stored in the vessels
Verify that storage vessels with a design capacity greater than or equal to 151 m3
(39,889 98 gal) containing VOL with a vapor pressure equal to or greater than 5 2
kPa, but less than 76 6 kPa or storage vessels with a capacity greater than or equal to
75 m3 (19,812 90 gal) but less than 151m3 (39,889.98 gal) containing VOL that has a
maximum vapor pressure equal to or greater than 27 6 kPa but less than 76 6 kPa are
equipped with one of the following
- A fixed roof in combination with an internal floating roof
- An external floating roof
- A closed vent system and control device that reduces emissions by 95 percent by
weight
- An approved equivalent system
Verify that storage vessels with a design capacity greater than or equal to 75 m3
(19,812 90 gal) containing a VOL with a maximum true vapor pressure greater than
or equal to 76 6 kPa is equipped with one of the following'
- A closed vent system and control device that reduces emissions by 95 percent by
weight
- An approved equivalent alternative method
Verify that the accumulated areas or gaps do not exceed.
- 212 cm2/m of tank diameter between the tank wall and the primary seal and the
width of any portion of any gap does not exceed 3.81 cm (1.5 in.)
- 21 2 cmVm of tank diameter between the tank wall and the secondary seal and the
width of any portion of any gap does not exceed 1.27 cm (0 5 in.)
Phase 1 - Section 11
Storage Tank Management
11-28
-------
Compliance Category:
Storage Tanfe Management
Regulatory Keqiiiremeatft
Reviewer Ctoeclts:
ST 12 Storage vessels for
VOLs having a capacity of
greater than or equal to 40 m3
(10,566 88 gal) for which
construction, reconstruction, or
modification was started after
23 July 1984 are required to
meet specific inspection,
documentation, and notification
requirements standards (40 CFR
60 110b through 60 115b)
(NOTE These standards do not apply to pressure vessels designed to operate in
excess of 204.9 kPa (29.72 psi) and without emissions to the atmosphere, vessels
which are permanently attached to mobile vehicles, vessels located at bulk gasoline
plants, vessels located at gasoline service stations)
Verify that the following inspections are made
- Inspection of internal floating roofs, primary seals, and secondary seals for holes,
tears, or defects before filling the tank
- Visual inspection of vessels with a liquid-mounted or mechanical shoe primary seal
shall have the internal floating roof and primary or secondary seals at least once
every 12 months after the initial fill
- Nessels with a double seal system at least every five years
- Internal floating roofs, primary seals, gaskets, slotted membranes, and sleeve seals
each time the storage vessel is emptied and degassed
- When control equipment is installed, measurement of gap areas is done
- At least once every five years for gaps between the tank wall and the primary seal
- At least once a year for gaps between the tank wall and the secondary seal
Verify that as problems are found, the vessel is either repaired or removed from
service within 45 days
Verify that a procedure is in place to notify the EPA in advance of performing gap
measurement and provide them, upon request, with copies of the following records
which are to be maintained for two years
- Inspection records
- Repair or removal from service of a vessel
- Operating plans
- Monitoring records
- Records showing the dimensions of storage vessels and capacity
Verify that for vessels with a design capacity greater than or equal to 151 m3
(39,889 98 gal) storing a liquid with a maximum true vapor pressure greater than or
equal to 3 5 kPa or with a design capacity greater than or equal to 75 m3 (19,812 90
gal) but less than 151m3 (39,889 98 gal), storing a liquid with a true vapor pressure
greater than or equal to 15 0 kPa, a record is kept of the VOL stored, the period of
storage, and the maximum true vapor pressure of that VOL during the storage period
(NOTE- This does not apply to vessels storing a waste mixture of indefinite or
variable composition or vessels equipped with a closed vent system and control
device )
Phase 1 - Section 11
Storage Tank Management
11-29
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Cheeks
ST 12 Continued
Verify that, except for vessels equipped with a closed vent system and control device,
a procedure exists to notify EPA within 30 days if the maximum true vapor pressure
of a liquid exceeds the following limits for the capacities listed
- Vessels with a design capacity greater than or equal to 151 m3 (39,889 98 gal)
storing a liquid with a maximum vapor pressure that is normally less than 5 2 kPa
- Vessels with a design capacity greater than 75 m3 (19,812.90 gal) but less than 151
m5 (39,889.98 gal) storing a liquid with a maximum true vapor pressure that is
normally less than 27 6 kPa, notify EPA within 30 days when the maximum true
vapor pressure of the liquid exceeds the allowed maximum true vapor pressure
according to capacity.
ST 13 Facilities with benzene
storage vessels are required to
comply with specific
recordkeeping requirements (40
CFR61 276(b))
Verify that facilities with benzene storage vessels keep readily accessible records of
the dimensions and capacity of the vessel.
(NOTE This applies regardless of the size of the vessel)
Phase 1 - Section 11
Storage Tank Management
11-30
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Checks;
Substandard USTs
(NOTE See Appendix 11-1 for guidance on applicability of checklist items)
ST 14 Substandard UST
systems are required to be
upgraded, closed, or removed
from service by 22 December
1998(40 CFR 280 21(a)
through 280 21(c))
(NOTE If a release detection system is not available for the UST, it must be phased
out in one to five years )
Determine if there are currently any plans for upgrading or decommissioning a
substandard UST
Verify that upgrading of steel USTs includes one of the following methods
- Internal lining according to the following requirements
-- lining is installed so that it prevents releases due to structural failure or
corrosion and meets a recognized code of practice
-- within 10 years after installation of lining, and every five years thereafter, the
lined tank is inspected internally and found to be structurally sound, with the
lining still performing in accordance with original design specifications
- Cathodic protection with field-installed systems designed by an expert, impressed
current systems, or an approved equivalent system and the integrity is assured by
one of the following
- tank is internally inspected and assessed to ensure that the tank is structurally
sound and free of corrosion
- the tank has been installed for less than 10 years and is monitored monthly for
releases
- the tank has been installed for less than 10 years and is assessed for corrosion
holes by conducting two tightness tests, one before and one three to six months
after installation of the cathodic protection system
-- tank is assessed for corrosion holes by a method that is determined to be equally
protective by the implementing agency
- Lining combined with cathodic protection
- if lining is installed according to requirements
-- if cathodic protection system meets requirements
Verify that when spill and overfill equipment is added, the tank meets the same
standards as new USTs
Verify that piping that routinely contains regulated substances and is in contact with
the ground is cathodically protected.
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-31
-------
Compliance Category:
Storage TaaJt Mattagettuart
Regulatory Kequiremeoti: | Reviewer Checks
New or Upgraded USTs
ST. 15 New or upgraded USTs
are required to be fitted with
spill and overfill prevention
equipment (40 CFR 280 20(c)
and 280 21(d))
Verify that spill prevention equipment will prevent a release of product to the
environment when the transfer hose is detached from the fill pipe.
Verify that overfill prevention equipment does one of the following:
- Automatically shuts off flow into the tank when the tank is no more than 95 percent
full
- Alerts the transfer operator when the tank is no more than 90 percent full by
restricting the flow into the tank or triggering a high-level alarm
- Restrict flow 30 minutes prior to overfilling, alert the operator with a high-level
alarm one minute before overfilling, or automatically shut off flow into the tank so
that none of the fittings are exposed to product due to overfilling.
(NOTE. This equipment is not required if approved equivalent equipment is used or
the UST system is filled by transfers of no more than 25 gal (94 64 L) at one time)
(NOTE All existing tanks must be upgraded by 1998 The state may have a sooner
deadline.)
(NOTE. The following types of USTs are not subject to these requirements.
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST 16 Notice must be given
within 30 days when a UST
system is brought into service
after 8 May 1986.(40 CFR
280.22)
Determine if the facility has brought any USTs into service after 8 May 1986.
Verify that the appropriate notification was issued
(NOTE State forms may be used for notification in lieu of an EPA form 7530 These
notices must be sent to the appropriate agency) (See 40 CFR 280 for a list of
agencies)
(NOTE The following types of USTs are not subject to these requirements.
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-32
-------
Category:
Storage Tattk Management
Regulatory Requlromeats;
Beviewer Checks:
ST 17 UST systems installed
after 22 December 1988 must
be constructed in such a manner
that they will remain
structurally sound for their
operating life (40 CFR
280 20(a) and 280 20(b))
Verify that USTs conform to industry standards by reviewing records
Verify that USTs meet the following
- They have leak/spill prevention protection
- The tank is constructed of one of the following materials
- fiberglass-reinforced plastic
-- steel which has one of the following types of cathodic protection
coated with a suitable dielectric material
field installed cathodic protection (expert installed)
impressed current systems which allow determination of current operating
status
- steel fiberglass reinforced plastic composite
- metal without additional corrosion protection provided that
the site has been determined not to cause corrosion to the tank by a
corrosion expert
records are maintained for the life of the tank that it is in a corrosion free
environment
- construction is in a manner that is deemed to prevent release of the regulated
substance
(NOTE Piping must also meet these criteria with the exception of not being
constructed of steel fiberglass reinforced plastic composite.)
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-33
-------
Compliance Category:
Storage Taofe Management
Regulatory Requirements:
Jtevlmr Chectew
ST. 18 Installation of UST must
be done by a certified installer
and according to standard
practices (40 CFR 280 20(d)
and 280 20(e))
Determine if new UST systems have been properly installed by reviewing records for
certification.
Verify that if the facility does its own installation of USTs, the installation is done
according to standard practices
(NOTE- The following types of USTs are not subject to these requirements:
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST 19. Facilities are required to
use UST systems made of or
lined with materials compatible
with the substance stored (40
CFR 280.32).
Verify that the substances stored in UST systems are compatible with the system
Determine which USTs are being used to store a substance other than that for which it
was originally intended
(NOTE: The following types of USTs are not subject to these requirements:
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-34
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements?
Beviewer Checks
Metallic USTs
ST 20 Buried metallic storage
tanks installed after 1973 must
be protected from corrosion by
coatings, cathodic protection, or
other effective methods (40
CFR 112 7(e)(2)(iv)).
Verify that new USTs are appropriately protected from corrosion by inspecting
records and interviewing personnel
Verify that the tanks are pressure tested regularly
(NOTE. Facilities are exempt from the requirements outlined in 40 CFR 112 if:
- The facility, equipment, or operation is not subject to the jurisdiction of the EPA as
follows:
-- onshore and offshore sites which, due to their location, could not be reasonably
expected to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines
-- equipment or operations of vessels or transportation related onshore and
offshore sites which are subject to the authority of the DOT
- The facility, which although otherwise subject to EPA jurisdiction meets both of the
following criteria are met
-- the underground buried storage capacity of the facility is 42,000 gal (158,987.3
L) or less of oil
-- the storage capacity which is not buried at the facility is 1320 gal (4,996.74 L)
of oil or less and no single container exceeds a capacity of 660 gal (2,498 37 L)
(40 CFR 112.1(d)(2).)
UST Filling
ST.21. The filling of a UST
must include the prevention of
overfilling and spilling of the
substance (40 CFR 280.30(a)).
Determine if there is a problem with overfilling of USTs or spills by observing the
filling operations, reviewing records, and checking the ground around the fill-lines for
visible or odorous indications of contamination.
Determine if the level of the UST is checked before a transfer is made and that the
volume available in the tank is greater than the volume of the product to be
transferred.
Verify that fill-lines are capped and locked
Verify that the transfer is monitored constantly
(NOTE: The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-35
-------
1^ - - * -
fjtevW Che#;
ST.22. Facilities with UST
systems are required to contain
and immediately clean up a spill
or overfill and report it to the
implementing agency within 24
hours in specific situations (40
CFR 280.30(b) and 280 53)
Determine if the facility has reported, contained, and cleaned up any and all spills or
overfills which met the following criteria
- Spills or overfills of petroleum that resulted in a release to the environment of more
than 25 gal (94.64 L) or that caused a sheen on nearby surface water
- Spills or overfills of hazardous substances that result in a release to the environment
in excess of the reportable quantity (see the Hazardous Materials Management
Appendices)
(NOTE. Spills or overfills of hazardous substances equal to or greater than the
reportable quantity must be immediately reported to the National Response Center
(NRC).)
Verify that the facility has contained and immediately cleaned-up a spill or overfill of
petroleum that is less than 25 gal (94 64 L) and a spill or overfill of a hazardous
substance that is less than the reportable quantity.
Verify that if these lesser quantities cannot be accomplished within 24 hours, or
another reasonable time period established by the implementing agency, the
implementing agency is notified
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-36
-------
Compliance Category:
Storage Tattk Management
Regulatory Requirements:
. Reviewer Checks:
UST Corrosion Protection and
Repairs
ST 23 UST systems with
corrosion protection must meet
specific requirements (40 CFR
280 10(c) and 280 31).
Determine which UST systems have corrosion protection
Verify that the corrosion protection systems operate continuously to provide corrosion
protection to the metal components that routinely contain regulated substances and are
in contact with the ground
Verify that all cathodic protection systems are tested within six months after
installation and every three years thereafter
Verify that UST systems with impressed current cathodic protection are inspected
every 60 days
Verify that inspection records are maintained of the last three inspections for systems
with impressed current cathodic protection and of the last two inspections for all other
cathodic protection systems
Verify that inspections are carried out by a qualified cathodic protection tester
(NOTE- The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-37
-------
Compliance Category:
Storage Tank Management
Regulatory Requir«tneots:
Reviewer Checks:
ST.24 Repairs to USTs must be
performed according to industry
code (40 CFR 280 10 (c) and
280 33)
Determine if there have been any repairs by reviewing the records and interviewing
personnel
Determine who does repairs to USTs and that the following procedures are used to
repair USTs
- Fiberglass reinforced tanks are repaired by the manufacturer's authorized
representative or according to industry standards
- Metal pipe fittings and sections that have leaked due to corrosion are replaced,
whereas fiberglass may be repaired according to manufacturer's specifications
Verify that tanks and piping that have been replaced or repaired are tested for
tightness within 30 days
(NOTE. Tanks and piping need not be tested if
- Repairs are internally inspected
- The repaired portion is already monitored monthly
- An equally protective test is used )
Verify that within six months of repair, tanks with cathodic protection systems are
tested as follows
- Every three years thereafter for all cathodic protection systems
- Every 60 days for impressed current cathodic protection systems
Verify that records of repairs are maintained for the life of the tank
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks).
Phase 1 - Section 11
Storage Tank Management
11-38
-------
Compliance Category:
Storage Taofc Management
Regulatory Requiremeato
Reviewer Checks:
Release Detection for USTs
General
ST 25 Facilities with new and
existing USTs are required to
provide a method, or
combination of methods of
release detection (40 CFR
280 10(c), 280 10(d) and
280 40)
Verify that the installed release detection system can detect a release from any portion
of the tank and the connected underground piping
Verify that the appropriate schedule has been complied with (see Appendix 11-2)
(NOTE Any pressurized delivery lines must be retrofitted by 22 December 1990 )
(NOTE: The following types of USTs are not subject to these requirements'
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Petroleum USTs
ST 26. UST systems containing
petroleum must meet specific
release detection system
requirements (40 CFR 280 10,
280 10(d), 280 40, 280 41,
280 43 and 280 44)
Verify that tanks are monitored every 30 days using one of the following methods
(details of methods are provided in Appendix 11-3)
- Tank automatic gauging
- Vapor monitoring
- Groundwater monitoring
- Interstitial monitoring
- Other acceptable methods
(NOTE: The following are exceptions:
- UST systems which meet performance standards for new or upgraded systems and
monthly inventory requirements may use tank tightness testing at least every five
years until 22 December 1998 or until 10 years after the tank is upgraded or
installed
- UST systems which do not meet performance standards for new or upgraded
systems, may use monthly inventory controls and annual tank tightness testing until
22 December 1998, at which time the tank must be upgraded or permanently closed
- Tanks which hold less than 550 gal (2,081 98 L) may use weekly tank gauging)
Phase 1 - Section 11
Storage Tank Management
11-39
-------
Compliance Category:
Storage Taoit MtmagetftCrtt
Regulatory Re^ulrtaaeats:
fteviewer Ckecfesi
S T 26 continued
Verily that underground piping which routinely contains a regulated substance has the
following release detection done as described in Appendix 11-3.
- Pressurized piping.
- equipped with automatic line leak detector
-- annual tightness testing or monthly monitoring
- Suction piping
-- line tightness testing every three years or monthly monitoring
-- no release detection system is needed for suction piping which is below grade
and:
operates at less than atmospheric pressure
is sloped so that contents of pipe will roll back to tank when suction is
released
only one check valve is included in each suction line
the check valve is located directly below and as close as practical to the
suction pump
(NOTE' The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system thai stores fuel solely for use by emergency power generator)
Phase 1 - Section 11
Storage Tank Management
11-40
-------
Compliance! Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Cheefctf
Hazardous Substance USTs
ST 27 Hazardous substance
USTs must meet specific
release detection standards (40
CFR280 10(c), 280 10(d),
280 42(a), 280 43, and 280 44)
Verify that tanks are monitored every 30 days using one of the following methods
(details of methods are provided in Appendix 11-3):
- Tank automatic gauging
- Vapor monitoring
- Groundwater monitoring
- Interstitial monitoring
- Other acceptable methods
(NOTE The following are exceptions
- UST systems which meet performance standards for new or upgraded systems and
monthly inventory requirements may use tank tightness testing at least every five
years until 22 December 1998 or until 10 years after the tank is upgraded or
installed
- UST systems which do not meet performance standards for new or upgraded
systems may use monthly inventory controls and annual tank tightness testing until
22 December 1998, at which time the tank must be upgraded or permanently closed
- Tanks which hold less than 550 gal (2,081 98 L) may use weekly tank gauging)
Verify that underground piping which routinely contains a regulated substance has the
following release detection done as described in Appendix 11-3
- Pressurized piping
- equipped with automatic line leak detector
— annual tightness testing or monthly monitoring
- Suction piping
-- line tightness testing every three years or monthly monitoring
-- no release detection system is needed for suction piping which is below grade
and
operates at less than atmospheric pressure
is sloped so that contents of pipe will roll back to tank when suction is
released
only one check valve is included in each suction line
the check valve is located directly below and as close as practical to the
suction pump
ST 27 Continued
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system that stores fuel solely for use by emergency power generator)
Phase 1 - Section 11
Storage Tank Management
11-41
-------
Compliance Category:
Storage Taolc Management
Regulatory ftaguirttttttftft
Reviewer Checks:
ST 28 Hazardous substance
USTs must meet specific
release detection standards by
22 December 1998 (40 CFR
280.10(c), 280 10(d),
280.42(b), 280.43, and 280.44)
Verify that existing hazardous substance USTs meet the requirements for new
hazardous substance USTs by 22 December 1998 as stated below
- Secondary containment is checked for evidence of a release at least every 30 days
and is designed and constructed to
- contain regulated substances released until they are detected and removed
- prevent releases of regulated substances to the environment at any time during
the operational life of the UST
- Double-walled tanks are designed, constructed, and installed to°
- contain releases from any portion of the inner tank within the outer-wall
- detect failure of the inner wall
- External liners, including vaults, are designed, constructed, and installed in such a
manner that:
- 100 percent of the capacity of the largest tank is contained within its boundary
- the interference of precipitation or groundwater intrusion is prevented with the
ability to contain or detect release of regulated substances
- the tank is completely surrounded.
Verify that underground piping is equipped with secondary containment which
satisfies the requirements for UST secondary containment.
Verify that piping which delivers regulated substances under pressure is equipped
with an automatic line leak detector.
Verify that when other release detection methods are used, they are approved by the
implementing agency.
(NOTE: The following types of USTs are not subject to these requirements:
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system that stores fuel solely for use by emergency power generator.)
Phase 1 - Section 11
Storage Tank Management
11-42
-------
Compliance Category:
Storage Tattl Management
Regulatory Rfcjuireifteota:
Reviewer ChecfcK
Exempt USTs
ST 29 UST systems containing
fuel used solely for emergency
generators should meet specific
release detection system
requirements (MP).
Verify that tanks are monitored every 30 days using the method in Appendix 11-3
except for1
- UST systems which meet performance standards for new or upgraded systems and
monthly inventory requirements may use tank tightness testing at least every five
years until 22 December 1998 or until 10 years after the tank is upgraded or
installed
- UST systems which do not meet performance standards for new or upgraded
systems may use monthly inventory controls and annual tank tightness testing until
22 December 1998, at which time the tank must be upgraded or permanently closed
- Tanks which hold less than 550 gal (2089 98 L) may use weekly tank gauging
Verify that underground piping which routinely contains a regulated substance has the
following release detection done according to the methods in Appendix 11-3
- Pressurized piping
-- equipped with automatic line leak detector
-- annual tightness testing or monthly monitoring
- Suction piping.
-- line tightness testing every three years or monthly monitoring
-- no release detection system is needed for suction piping which is below grade
and'
operates at less than atmospheric pressure
is sloped so that contents of pipe will roll back to tank when suction is
released
only one check valve is included in each suction line
the check valve is located directly below and as close as practical to the
suction pump.
Phase 1 - Section 11
Storage Tank Management
11-43
-------
CompIiance'Category:
Storage-TMfeMaiujtgemertt
' > ' \
-
% \ * s
UST Releases
ST 30 Facilities with UST
systems are required to report
releases under specific
conditions (40 CFR 280 10(c)
and 280 50)
Determine if the facility reported any and all releases which met the following
criteria:
- Released regulated substances found at the UST site or in the surrounding area
(such as the presence of free product or vapors in soils, basements, sewer and utility
lines, and nearby surface waters
- Unusual operating conditions observed such as the erratic behavior of dispensing
equipment or a sudden loss of product unless it is determined the problem lies in the
equipment but it is not leaking and is immediately repaired or replaced
- Monitoring results indicate a possible release
Verify that the implementing agency was notified within 24 hours (or time period
specified by the implementing agency) of the release
(NOTE- The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST 31 Installations must
investigate and confirm all
suspected releases of a
regulated substances requiring
reporting within seven days
unless a corrective action is
started immediately as detailed
in 40 CFR 280 10(c) and
280 52)
Verify that tightness testing is done within seven days of a suspected release to
determine whether a leak is in the tank or the delivery piping.
Verify that if environmental contamination is the basis for suspecting a leak, and the
tightness test does not indicate that a leak exists, a site check is done that measures for
the presence of a release in the areas where contamination is most likely to be present.
(NOTE.
- If the results indicate that a leak has occurred corrective actions must be started out
- If the tightness test does not indicate a leak and environmental contamination is not
the basis for suspecting a release, no further investigation is needed)
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-44
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements;
Eevlewer Checks
ST 32 Facilities with a
confirmed release from
petroleum or hazardous
substance USTs are required to
perform specific initial response
actions within 24 hours of a
release (40 CFR 280 60 and
280 61)
Verify that facility personnel are aware of the following initial response actions
- The release is reported
- Immediate action is taken to prevent further release of the regulated substance into
the environment
- Fire, explosion, and vapor hazards are identified and mitigated
(NOTE
- These requirements do not apply to excluded USTs (see the definitions) or USTs
exempted under the RCRA Subtitle C Section 3004(u) corrective action
requirements
- A RCRA Subtitle C, Section 3004(u) UST is a UST holding a hazardous material at
a RCRA Subtitle C permitted facility A release from such a UST would be handled
as required under the RCRA permit's corrective action plan )
ST 33 Facilities with a
confirmed release from
petroleum or hazardous
substance USTs are required to
perform specific initial
abatement measures and site
checks unless directed to do
otherwise by the implementing
agency (40 CFR 280 60 and
280 62)
Verify that the following actions are performed
- As much of the substance as is necessary to prevent further release is removed from
the UST system
- Visual inspection of aboveground releases or exposed belowground releases is done
and further migration of the released substance into surrounding soils and
groundwaters is prevented
- Monitoring and mitigation of any fire and safety hazards caused by vapors or free
product is done
- Hazards from contaminated soils that are excavated or exposed are remedied
- Measurements are done for the presence of a release where the contamination is
most likely to be present unless the presence and source of the release has
previously been confirmed
- An investigation is done for the presence of free product and the removal of free
product is done as soon as possible
Verify that within 20 days after release confirmation a report is submitted to the
implementing agency summarizing the initial abatement measures, site checks, and
the resulting information and data collected
(NOTE
- These requirements do not apply to excluded USTs (see the definitions) or USTs
exempted under the RCRA Subtitle C Section 3004(u) corrective action
requirements
- A RCRA Subtitle C, Section 3004(u) UST is an UST holding a hazardous material
at a RCRA Subtitle C permitted facility A release from such a UST would be
handled as required under the RCRA permit's corrective action plan )
Phase 1 - Section 11
Storage Tank Management
11-45
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Checks:
ST 34. Facilities with a
confirmed release from
petroleum or hazardous
substance USTs are required to
assemble information about the
site and nature of the release
unless exempted by the
implementing agency (40 CFR
280 60 and 280 63)
Verify that the following information is collected
- Data on the nature and estimated quantities of the release
- Data from available sources and/or site investigations concerning surrounding
population, water quality, use and approximate locations of wells potentially
affected, subsurface soil conditions, locations of subsurface sewers, climatological
conditions, and land use
- Results of site check
- Results of free product investigation
Verify that within 45 days of the release confirmation this information is submitted to
the implementing agency in a manner that demonstrates the applicability and
technical adequacy or according to a format required by the implementing agency
(NOTE-
- These requirements do not apply to excluded USTs (see the definitions) or USTs
exempted under the RCRA Subtitle C Section 3004(u) corrective action
requirements
- A RCRA Subtitle C, Section 3004(u) UST is a UST holding a hazardous material at
a RCRA Subtitle C permitted facility A release from such a UST would be handled
as required under the RCRA permit's corrective action plan )
Phase 1 - Section 11
Storage Tank Management
11-46
-------
Compliance Category:
Storage Tank Management
Regulator)' Requirements:
Reviewer Cheeks:
ST 35 Facilities with a
confirmed release from
petroleum or hazardous
substance USTs where site
investigations have indicated
free product must, to the
maximum extent possible as
required by the implementing
agency, remove the free product
(40 CFR 280 60 and 280 64)
Determine if there are any release sites at the facility where free product has been
confirmed
Verify that free product removal is done so that the spread of contamination is
minimized
Verify that, unless exempted by the implementing agency, within 45 days after
confirming a release, a free product removal report is submitted to the implementing
agency that includes the following
- The name of the person responsible for implementing the free product removal
system
- The estimated quantity, type, and thickness of free product observed or measured
- The type of free product recovery system used
- Whether there will be any onsite or offsite discharges during the recovery operation
and where this discharge will be located
- The type of treatment used for any discharge during the recovery operation and
where this discharge will be located
- The steps taken to obtain any required permits
- The disposition of the recovered free product
(NOTE-
- These requirements do not apply to excluded USTs (see the definitions) or USTs
exempted under the RCRA Subtitle C Section 3004(u) corrective action
requirements)
- A RCRA Subtitle C, Section 3004(u) UST is a UST holding a hazardous material at
a RCRA Subtitle C permitted facility A release from such an UST would be
handled as required under the RCRA permit's corrective action plan )
ST 36 Facilities with a
confirmed release from
petroleum or hazardous
substance USTs are required to
perform an investigation for soil
and groundwater contamination
(40 CFR 280 60 and 280 65)
Verify that an investigation of the release, the release site, and possibly affected
surrounding areas has been done and identified if any of the following conditions
exists.
- Evidence that groundwater wells have been affected
- Free product is evident
- Evidence that contaminated soil is in contact with groundwater
- The implementing agency requests an investigation
Verify that the results of the investigation are submitted to the implementing agency
according to a time schedule defined by the implementing agency
(NOTE
- These requirements do not apply to excluded USTs (see the definitions) or USTs
exempted under the RCRA Subtitle C Section 3004(u) corrective action
requirements)
- A RCRA Subtitle C, Section 3004(u) UST is a UST holding a hazardous material at
a RCRA Subtitle C permitted facility A release from such a UST would be handled
as required under the RCRA permit's corrective action plan )
Phase 1 - Section 11
Storage Tank Management
11-47
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Check#
Deferred UST Systems
ST 37 Deferred UST systems
(see definition) are required to
meet specific standards (40
CFR280 10(c) and 280 11).
Verify that deferred UST systems (whether single or double-walled) are not installed
to store regulated substances unless
- Releases due to corrosion or structural failure will be prevented for the operational
life of the system
- They are cathodically protected against corrosion, constructed of non-corrodible
materials, steel clad with a noncorroding material, or designed to prevent release
- They are constructed or lined with material that is compatible with the stored
substance
Verify that deferred systems meet the standards concerning release response and
action for USTs containing petroleum or a hazardous substance found in 40 CFR
280 60 through 280 67 (see checklist items ST 32 through ST 36)
(NOTE- The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
UST Documentation
ST 38 Facilities with USTs are
required to meet specific
reporting requirements (40 CFR
280 10(c) and 280 34(a))
Verify that the facility has submitted the following when applicable
- Notifications of new USTs
- Release reports
- Planned or complete corrective actions
- Notice of closure or change-in-service
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-48
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Check#
ST 39 Facilities with USTs are
required to meet specific
recordkeeping requirements (40
CFR280 10(c), 280 34(b),
280 34(c), 280 45, and 280 74)
Verify that records are kept of the following
- A corrosion expert's analysis of site corrosion potential if corrosion protection
equipment is not used
- Documentation of operation of corrosion protection equipment
- Documentation of repairs
- Closure records
- Results of any site investigations
Verify that records are available at one of the following
- At the UST site and immediately available for inspection
- At a readily available alternative site and provided for inspection
Verify that records are kept as follows
- All written performance claims pertaining to any release detection system used for
five years from the date of installation
- The results of any sampling, testing, or monitoring for one year except the tank
tightness results are kept until the next tank tightness test
- The results of tank tightness testing until the next test is done
- Written documentation of calibration, maintenance, repair of release detection
equipment permanently located onsite at least one year after the servicing is done
- Schedules of required calibration and maintenance provided by the release
detection equipment manufacturer for five years after the date of installation.
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-49
-------
Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer Checks
Changes in Service or Closure g
fUSTs
ST 40 USTs which are put out
of service temporarily, must
have continued maintenance
(40 CFR280 10(c) and 280 70)
Determine if the facility has any out-of-service USTs
Verify that proper maintenance is being performed for the following
- Corrosion protection
- Release detection.
Verify that if the UST has been out-of-service for near or over one year, plans have
been made for permanent closure
(NOTE
- If the UST is empty, release detection is not required
- An empty UST is one which has no more than 2 5 cm (1 in ) of residue or less than
0 3 percent by weight of total capacity of the UST system )
Verify that if a UST system is closed for three months or more, the vent lines are open
and functioning and all other lines, pumps, manways, and ancillary equipment is
capped and secured
Verify that if the UST has been out of service for more than 12 months and does not
meet the standards for new or upgraded USTs, it is permanently closed unless the
implementing agency has provided an extension
(NOTE. The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-50
-------
Compliance Category:
Storage Tank. Management
Regulatory K^uirem^dts;
Reviewer Check*;
ST 41 Notification must be
given to the implementing
agency for any closure or
change in service 30 days in
advance or within a reasonable
time frame as determined by the
implementing agency (40 CFR
280 10(c) and 280 71(a)
Determine if the facility is planning to close or change any USTs
Verify that notification of changes were given within 30 days
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST 42 UST closure must be
done according to specific
requirements (40 CFR
280 10(c) and 280 71(b)
Verify that if there are any closed USTs or USTs in the process of being closed at the
facility, one of the following methods is used
- It is removed from ground
- It is left in place with the contents removed, and filled with an inert solid material
and closing it to all future outside access
Verify that tanks being permanently closed are emptied and cleaned by removing all
liquids and accumulated sludges
Determine if there are any possible abandoned USTs and if there are plans to close the
UST off in an appropriate manner
Determine if a site assessment was made to ensure that no releases to the environment
have occurred by reviewing records
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-51
-------
Compliance Category:
Storage Taalt Mftitagemeot
Regulatory Requirements;
Eevie*er Check*:
ST 43 Prior to a change-in-
service, tanks must be emptied
and cleaned and a site
assessment conducted (40 CFR
280.10(c) and 280 71(c))
Determine if there are any tanks which the facility has continued to use to store a non-
regulated substance (a change-in-service)
Verify that prior to the change, the tank was emptied and cleaned.
Verify that prior to die change a site assessment was done
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST.44 Prior to permanent
closure or change-in-service,
measurements must be made for
the presence of a release where
contamination is most likely to
be present at the site (40 CFR
280 10(c) and 280 72)
Verify that measurements for the presence of a release have been done
(NOTE These requirements are met if one of the leak detection methods outlined in
40 CFR 280 43(e) and 280 43(f) have been met (see checklist items ST 24, ST 26, and
ST.27 through ST 28)
(NOTE1 The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-52
-------
Compliance Category:
Storage Tattfc Management
Regulatory Requirements;
Reviewer Checks
ST 45 Facilities with UST
systems closed prior to 22
December 1988 must assess the
excavation zone and close the
UST according to current
standards if releases from the
UST pose a current or potential
threat to human health and the
environment (40 CFR 280 10(c)
and 280 73)
Determine if the facility has any USTs which were closed prior to 22 December 1988
Verify that the excavation zone of these USTs has been assessed and cleanup done as
needed.
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
ST 46 Excavation zone
assessment records shall be
maintained for three years (40
CFR 280 10(c) and 280 74)
Verify that excavation zone assessment records are maintained for three years in one
of the following ways
- By the facility
- At the implementing agency if they cannot be maintained at the closed facility
(NOTE The following types of USTs are not subject to these requirements
- Wastewater treatment tank systems
- Any UST systems containing radioactive material that are regulated under the
Atomic Energy Act of 1954
- Any UST system that is part of an emergency generator system at nuclear power
generation facilities regulated by the Nuclear Regulatory Commission under 10
CFR 50, Appendix A
- Airport hydrant fuel distribution systems
- UST system with field-constructed tanks)
Phase 1 - Section 11
Storage Tank Management
11-53
-------
Compliance Category:
Storage TaoR Management
Regulatory Requirements;
Reviewer Checks:
Hazardous Waste Storage Tanks
Small Quantity Generators (SQG)
ST 47 SQGs must comply with
Determine if the facility is a SQG that stores or treats wastes in tanks
certain storage tank
requirements (40 CFR
Verify that
262 34(d)(3) and 40 CFR
- The tank prevents
265 201(a) through
-- generation of extreme heat or pressure, fire or explosions, or violent reactions
265 201(c))
- production of uncontrolled toxic mists, fumes, dusts, or gases in quantities that
would threaten human health or the environment
— production of uncontrolled flammable fumes or gases in quantities that would
pose a risk of fire or explosion
-- damage to structural integrity of the device or facility
- threats to human health or the environment through other means
- No treatment reagent or hazardous wastes are placed in the tank that would cause it
to rupture, leak, corrode, or otherwise fail before the end of its intended life
- Uncovered tanks have at least 60 cm (2 ft) of freeboard unless the tank has a
containment structure, drainage control system, or a diversion structure with a
volume that equals or exceeds the capacity of the top 60 cm (2 ft) of the tank
- Continuous feed tanks have a wastefeed cutoff or other stop/bypass system
Verify that the following are inspected at the indicated times
- Discharge control equipment at least once each operating day
- Monitoring equipment (pressure and temperature gauges) at least once each
operating day
- Waste level in tank at least once each operating day
- Construction material of the tank for corrosion or leakage weekly
- Surrounding area for leakage and/or contamination at least weekly
Phase 1 - Section 11
Storage Tank Management
11-54
-------
Compliance Category:
Storage Tank Management
Regulatory Jtequtremsots;
Revtewr Checks:
ST 48 Tank systems at SQGs
must comply with requirements
for ignitable, reactive, or
incompatible wastes (40 CFR
262 34(d)(3) and 40 CFR
265 201(e) through 265 201(0)
Verify that ignitable or reactive wastes are not placed in a tank system unless one of
the following is done
- The waste is treated, rendered, or mixed before or immediately after placement in
the tank system so that it is no longer reactive or ignitable and the minimum
requirements for reactive and ignitable wastes are met
- The waste is treated or stored in such a way that it is protected from any material or
conditions that may cause the waste to ignite or react
- The tank system is used solely for emergencies
Verify that the minimum protective distances between waste management areas and
any public ways, streets, alleys, or an adjoining property line that can be built upon as
required in Tables 2-1 through 2-6 of the National Fire Protection Association's
Flammable and Combustible Liquids Code are maintained
Verify that incompatible waste, or incompatible wastes and materials, are not placed
tn the same tank system unless minimum safety requirements are met
Verify that hazardous waste is not placed in a tank system that has not been
decontaminated and that previously held an incompatible waste or material unless
minimum safety requirements are met
ST 49 SQGs must comply with
specific tank closure
requirements (40 CFR
265 201(d))
Verify that tank systems in the process of being closed or closed had all hazardous
waste removed from tanks, discharge control equipment, and discharge confinement
structures
Phase 1 - Section 11
Storage Tank Management
11-55
-------
Compliance Category:
Storage Ta&fc Maaagment
Regulatory Requirements;
| Stevlewer Cfceeittf
Generators
ST 50 Secondaiy containment
is required for specific types of
tank systems used to store or
treat hazardous waste at
generators (40 CFR
262 34(a)(l)(n) and 40 CFR
265 190(a), 265 190(b), and
265 193(a))
Verily that the following types of tanks used to store or treat hazardous waste have
secondary containment-
- All new tank systems or components
- All existing tank systems used to store or treat EPA Hazardous Waste Numbers
F020, F02!, F022, F023, F026 and F027
- Existing tank systems of known documented age of 15 years
Verify that existing tank systems for which the age cannot be determined within eight
years of 12 January 1987 and are at a facility that is older than seven years old are
provided with secondary containment by time the facility reaches 15 years of age or
12 January 1989, which ever comes later
(NOTE The following are exempt from these requirements
- Tank systems that are used to store or treat hazardous waste that contains no free
liquids and are situated inside a building with an impermeable floor
- Tank systems, including sumps, that serve as part of a secondary containment
system to collect or contain releases of hazardous wastes.)
ST 51 Secondary containment
on tank systems at generators
must meet specific requirements
(40 CFR 262 34(a)(l)(ii) and 40
CFR 265 190(a), 265 193(b)
through 265 193(d))
Verify that secondary containment meets the following criteria
- It is designed, installed, and operated to prevent the migration of liquid out of the
system
- It is capable of detecting and collecting releases and accumulated liquids until
removal is possible
- It is constructed of or lined with materials compatible with the wastes
- It is placed on a foundation or base that can provide appropriate support and
prevent failure due to settlement, compression, or upset
- A leak-detection system is present that is designed and operated to detect the failure
of either the primary or secondary containment structure or the release of any
hazardous waste within 24 hours or the earliest practicable time
- It is sloped or designed to drain and remove liquids from leaks, spills, or
precipitation
Verify that spilled or leaked wastes are removed from secondary containment within
24 hours or as timely as possible
Verify that secondary containment for tanks includes one or more of the following
- A liner (external to the tank)
- A vault
- A double-walled tank
- An equivalent approved device
(NOTE Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements)
Phase 1 - Section 11
Storage Tank Management
11-56
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CompifeiH# Category:
Storage Taafe Management
Rogatory Btquirctoeats;
Reviewer Chec&i
ST 52 External liners, vaults
and double-walled tanks at
generators are required to meet
specific standards (40 CFR
262 34(a)(l)(n) and 40 CFR
265 190(a) and 265 193(e))
Verify that external liner systems meet the following requirements
- They are designed and operated so that 100 percent of the capacity of the largest
tank within the boundary would be contained
- They prevent runon and infiltration of precipitation into the secondary containment
unless the collection system has sufficient capacity to handle runon or infiltration
- They are free of cracks or gaps
- They surround the tank completely and cover all surrounding earth likely to come
into contact with the waste if there is a release
- Capacity is sufficient to contain precipitation from a 25 year, 24 hour rainfall event
Verify that vault systems meet the following criteria
- It will contain 100 percent of the capacity of the largest tank within its boundary
- It prevents runon and infiltration of precipitation unless there is sufficient excess
capacity
- It is constructed with chemical-resistant water stops at all joints
- It has an impermeable interior coating that is compatible with the wastes it contains
- It has a means to protect against the formation and ignition of vapors within the
vault if the waste is ignitable or reactive
- It has an exterior moisture barrier or otherwise operated to prevent migration of
moisture into the vault
Verify that double-walled tanks meet the following criteria
- It is designed as an integral structure so that any release is contained by the outer
shell
- It is protected from both corrosion of the primary tank and the external surface of
the outer shell if constructed of metal
- It has a built-in continuous leak detection system capable of detecting a release
within 24 hours
(NOTE Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements)
ST 53 Tank ancillary
equipment at generators must
also be provided with secondary
containment (40 CFR
262 34(a)(l)(n) and 40 CFR
265 190(a) and 265.193(f))
Verify that ancillary equipment, except for the following, has secondary containment
- Aboveground piping that is visually inspected for leaks on a daily basis
- Welded flanges, welded joints, and welded connections that are visually inspected
for leaks on a daily basis
- Seamless or magnetic coupling pumps and seamless valves, that are visually
inspected for leaks on a daily basis
- Pressurized aboveground piping systems with automatic shutoff valves that are
visually inspected for leaks on a daily basis
(NOTE Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements)
Phase 1 - Section 11
Storage Tank Management
11-57
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Compliance Category:
Storage Tank Management
Regulatory Requirements:
Reviewer CheefcM
ST 54 Tank systems that are
required to have secondary
containment at generators that
do not have secondary
containment are required to
meet specific requirements 40
CFR 262 34 (a)(1)(h) and 40
CFR265 190(a), 265 191(a)
through 265 191(c), and
265 193(0)
Verify that tank systems without secondary containment meet the following
- For non-enterable underground tanks a leak test is conducted annually
- For other than non-enterable underground tanks either a leak test is done annually
or the facility develops a schedule and procedure for an assessment of the overall
condition by an independent, qualified, registered, professional engineer
Verify that the facility maintains a record of the results of testing and assessments
Verify that tank systems which store or treat materials that become hazardous waste
after 14 July 1986 are assessed within 12 months after the waste becomes hazardous
(NOTE. Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements.)
ST.55 Generators with new
tank systems must submit to the
Regional Administrator a
written assessment review
certified by an independent,
qualified, registered,
professional engineer to certify
that it was installed according to
specific standards (40 CFR
262.34(a)(1)(H) and 40 CFR
265 192).
Determine if the facility has any new tank systems
Verify that when the tanks are installed they are handled so as to prevent damage to
the tank and any backfill material that is used is a noncorrosive, porous, homogeneous
substance.
Verify that the facility keeps on file the written assessments from the individuals
required to certify the tank and supervise the installation of the tank.
ST 56. Tanks used for
hazardous waste treatment or
storage at generators must
follow certain operating
requirements (40 CFR
262 34(a)(l)(n) and 265 194).
Verify that hazardous wastes or treatment reagents are not placed in tanks if they
could cause the tank system (including ancillary equipment, or containment system)
to fail.
Verify that appropriate measures are taken to prevent overfill, including
- Spill prevention controls
- Overfill prevention controls
- Maintenance of sufficient freeboard to prevent overtopping by wave, wind action,
or precipitation for uncovered tanks
Phase 1 - Section 11
Storage Tank Management
11-58
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Compliance Category:
Storage Tank Management
Rogatory
Reviewer Checks:
ST 57 Tank systems at
generators must comply with
requirements for ignitable,
reactive, or incompatible wastes
(40 CFR 262 34(a)(l)(ii) and 40
CFR265 J 98 and 265 199)
Verify that ignitable or reactive wastes are not placed in a tank system, unless one of
the following is met
- The waste is treated, rendered, or mixed before or immediately after placement in
the tank system so that it is no longer reactive or ignitable and the minimum
requirements for reactive and ignitable wastes are met
- The waste is treated or stored in such a way that it is protected from any material or
conditions that may cause the waste to ignite or react
- The tank system is used solely for emergencies
Verify that the minimum protective distances between waste management areas and
any public ways, streets, alleys, or an adjoining property line that can be built upon as
required in Tables 2-1 through 2-6 of the National Fire Protection Association's
Flammable and Combustible Liquids Code are maintained
Verify that incompatible waste, or incompatible wastes and materials, are not placed
in the same tank system unless minimum safety requirements are met
Verify that hazardous waste is not placed in a tank system that has not been
decontaminated and that previously held an incompatible waste or material unless
minimum safety requirements are met
ST 58 Generators must conduct
inspections of tank systems and
associated equipment (40 CFR
262 34(a)(l)(ii) and 40 CFR
265 195)
Verify that a schedule and procedure has been developed and is followed to inspect
overfill controls at permitted sites
Determine if the following inspections are conducted at least once a day
- Data gathered from monitoring and detection equipment
- Overfill/spill control equipment at interim state facilities to ensure it is in good
working order
- Aboveground portions of the tank to detect corrosion or releases
- Tank monitoring equipment (e g , pressure and temperature gauges)
- Area surrounding tank including the secondary containment system for signs of
leakage (wet spots, dead vegetation)
Verify that the proper operation of cathodic protection systems are inspected within
six months after initial installation and annually thereafter
Verify that all sources of impressed current are inspected and/or tested every other
month.
Verify that inspections are documented
Phase 1 - Section 11
Storage Tank Management
11-59
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Compliance Category:
Storage Tattk Management
Regulatory Requirements:
Itevietver Chetfta
ST 59 Tank systems or
secondary containment systems
at generators from which there
has been a leak or spill or which
have been declared unfit for use
must be removed from service
immediately and meet specific
requirements (40 CFR
262 34(a)(l)(n) and 40 CFR
265 196)
Verify that the following steps are taken-
- The flow or addition of hazardous wastes to the tank is stopped
- The hazardous waste is removed from the tank
-- within 24 hours of detection (or other reasonable time as demonstrated by the
owner/operator) remove as much waste form the tank as necessary to prevent
further release and allow inspection and repair
- within 24 hours (or in as timely a manner as is possible to prevent harm to
human health and the environment) remove waste released to secondary
containment system
- A visual inspection of the release is done and
- action is taken to prevent further migration to soils or surface or groundwater
- any visible contamination of soil and surface water is removed and disposed
Verify that notification is made within 24 hours for any release to the environment to
the Regional Administrator
Verify that a report is submitted within 30 days.
(NOTE. Releases of 0 45 kg (1 lb) or less that are immediately contained and cleaned
up are exempt from reporting)
Verify that the tank and/or secondary containment is repaired prior to its return to
service and that extensive repairs are certified by an independent, qualified,
registered, professional engineer
ST 60 Generators are required
to follow specific procedures
when closing a tank system (40
CFR 262 34(a)(1)(H) and 40
CFR 265 197(a) and
265 197(b))
Determine if the facility has closed any tank systems
Verify that all waste residues, contaminated containment system components,
contaminated soils, and structures and equipment contaminated with waste have been
removed or decontaminated
Verify that if it is not possible and/or practicable to remove or decontaminate all soils,
the facility closes the tank and performs postclosure care as required for landfills
Phase 1 - Section 11
Storage Tank Management
11-60
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Compliance Category:
Storage Taok Management
Regulatory Requirements;
Reviewer Checiw:
TSDFs
ST 61 Secondary containment
is required for specific types of
tank systems used to store or
treat hazardous waste at TSDFs
(40 CFR 264 190(a) and
264 190(b), 264 193(a), 40
CFR 265 190(a), 265 190(b),
and 265 193(a))
Verify that the following types of tanks used to store or treat hazardous waste have
secondary containment
- All new tank systems or components
- All existing tank systems used to store or treat EPA Hazardous Waste Numbers
F020, F021, F022, F023, F026 and F027
- Existing tank systems of known documented age that are 15 years of age
Verify that existing tank systems for which the age cannot be determined within eight
years of 12 January 1987 and are at an facility that is older than seven years old are
provided with secondary containment by the time the facility reaches 15 years of age
or 12 January 1989, whichever comes later
(NOTE The following are exempt from these requirements
- Tank systems that are used to store or treat hazardous waste that contain no free
liquids and are situated inside a building with an impermeable floor
- Tank systems, including sumps, that serve as part of a secondary containment
system to collect or contain releases of hazardous wastes )
ST 62 Secondary containment
on tank systems at TSDFs must
meet specific requirements (40
CFR 264 190(a), 264 193(b)
through 264 193(d), 40 CFR
265 190(a), 265 193(b) through
265 193(d))
Verify that secondary containment meets the following criteria
- It is designed, installed, and operated to prevent the migration of liquid out of the
system
- It is capable of detecting and collecting releases and accumulated liquids until
removal is possible
- It is constructed of or lined with materials compatible with the wastes
- It is placed on a foundation or base that can provide appropriate support and
prevent failure due to settlement, compression, or upset
- A leak-detection system is present that is designed and operated to detect the failure
of either the primary or secondary containment structure or the release of any
hazardous waste within 24 hours or the earliest practicable time
- It is sloped or designed to drain and remove liquids from leaks, spills, or
precipitation
Verify that spilled or leaked wastes are removed from secondary containment within
24 hours or as timely as possible
Verify that secondary containment for tanks includes one or more of the following
- A liner (external to the tank)
- A vault
- A double-walled tank
- An equivalent approved device
(NOTE Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements)
Phase 1 - Section 11
Storage Tank Management
11-61
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Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Checks:
ST 63 Externa! liners, vaults
and double-walled tanks at
TSDFs are required to meet
specific standards (40 CFR
264 190(a) and 264.193(e), 40
CFR 265 190(a) and
265 193(e))
Verify that external liner systems meet the following requirements
- It is designed and operated so that 100 percent of the capacity of the largest tank
within the boundary would be contained
- It prevents runon and infiltration of precipitation into the secondary containment
unless the collection system has sufficient capacity to handle runon or infiltration
- It is free of cracks or gaps
- It surrounds the tank completely and covers all surrounding earth likely to come
into contact with the waste if there is a release
- Capacity is sufficient to contain precipitation from a 25-year, 24-hour rainfall event
Verify that vault systems meet the following criteria
- It will contain 100 percent of the capacity of the largest tank within its boundary
- It prevents runon and infiltration of precipitation unless there is sufficient excess
capacity
- It is constructed with chemical-resistant water stops at all joints
- It has an impermeable interior coating that is compatible
- It has a means to protect against the formation of, and ignition of, vapors within the
vault if the waste is ignitable or reactive
- It has an exterior moisture barrier or otherwise operated to prevent migration of
moisture into the vault
Verify that double-walled tanks meet the following criteria
- It is designed as an integral structure so that any release is contained by the outer
shell
- It is protected from both corrosion of the primary tank and the external surface of
the outer shell if constructed of metal
- It has a built-in continuous leak detection system capable of detecting a release
within 24 hours
(NOTE Tank systems used to store or treat hazardous waste that contains no free
liquids and are situated inside a building with an impermeable floor are exempt from
these requirements.)
ST 64 Tank ancillary
equipment at TSDFs must also
be provided with secondary
containment (40 CFR
264 190(a) and 264 193(0,40
CFR 265.190(a) and
265.193(0)
Verify that ancillary equipment, except for the following, has secondary containment
- Aboveground piping that is visually inspected for leaks on a daily basis
- Welded flanges, welded joints, and welded connections that are visually inspected
for leaks on a daily basis
- Seamless or magnetic coupling pumps and seamless valves that are visually
inspected for leaks on a daily basis
- Pressurized aboveground piping systems with automatic shutoff valves that are
visually inspected for leaks on a daily basis
(NOTE Tank systems used to store or treat hazardous waste that contains no free
liquids and are situated inside a building with an impermeable floor are exempt from
these requirements)
Phase 1 - Section 11
Storage Tank Management
11-62
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Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Checks:
ST 65 Tank systems at TSDFs
that are required to have
secondary containment that do
not have secondary containment
must meet specific requirements
(40CFR264 190(a),
264 191 (a) through 264 191 (c),
and 264 I93(i), 40 CFR
265 190(a), 265 191(a) through
265 191(c), and 265 193(0)
Verify that tank systems without secondary containment meet the following
- For nonenterable underground tanks,a leak test is conducted annually
- For other than nonenterable underground tanks either a leak test is done annually or
the facility develops a schedule and procedures for an assessment of the overall
condition by an independent, qualified, registered professional engineer
- For ancillary equipment a leak test or other approved integrity assessment at least
annually
Verify that the TSDF maintains a record of the results of testing and assessments
Verify that tank systems which store or treat materials that become hazardous waste
after 14 July 1986 are assessed within 12 months after the waste becomes hazardous
(NOTE Tank systems that are used to store or treat hazardous waste that contains no
free liquids and are situated inside a building with an impermeable floor are exempt
from these requirements)
ST 66 TSDFs with new tank
systems must submit to the
Regional Administrator a
written assessment review
certified by an independent,
qualified, registered
professional engineer and install
the tank according to specific
standards (40 CFR 264 192 and
40 CFR 265 192)
Determine if the TSDF has any new tank systems
Verify that when the tanks are installed they are handled so as to prevent damage to
the tank and any backfill material that is used is a noncorrosive, porous, homogeneous
substance
Verify that the facility keeps on file the written assessments from the individuals
required to certify the tank and supervise the installation of the tank
ST 67 Tanks used for
hazardous waste treatment or
storage at TSDFs must follow
certain operating requirements
(40 CFR 264 194 and 40 CFR
265 194)
Verify that hazardous wastes or treatment reagents are not placed in tanks if they
could cause the tank system (including ancillary equipment or containment system) to
fail
Verify that appropriate measures are taken to prevent overfill, including
- Spill prevention controls
- Overfill prevention controls
- Maintenance of sufficient freeboard to prevent overtopping by wave, wind action,or
precipitation for uncovered tanks
Phase 1 - Section 11
Storage Tank Management
11-63
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Compliance Category:
Storage Ta&ft ManageiBertt
Regulatory Requirements;
Reviewer Checks
ST 68 Tank systems at TSDFs
must comply with requirements
for ignitable, reactive, or
incompatible wastes (40 CFR
264 198 and 264 199,40 CFR
265 198 and 265 199).
Verify that ignitable or reactive wastes are not placed in a tank system, unless one of
the following is met
- The waste is treated, rendered, or mixed before or immediately after placement in
The tank system so that it is no longer reactive or ignitable and the minimum
requirements for reactive and ignitable wastes are met
- The waste is treated or stored in such a way that it is protected from any material or
conditions that may cause the waste to ignite or react
- The tank system is used solely for emergencies
Verify that the minimum protective distances between waste management areas and
any public ways, streets, alleys, or an adjoining property line that can be built upon as
required in Tables 2-1 through 2-6 of the National Fire Protection Association's
Flammable and Combustible Liquids Code are maintained
Verify that incompatible waste, or incompatible wastes and materials, are not placed
in the same tank system unless minimum safety requirements are met.
Verify that hazardous waste is not placed in a tank system that has not been
decontaminated and that previously held an incompatible waste or material unless
minimum safety requirements are met
ST 69. Personnel at TSDFs
must conduct inspections of
tank systems and associated
equipment (40 CFR 264 195
and 40 CFR 265 195)
Verify that a schedule and procedure has been developed and is followed to inspect
overfill controls at permitted facilities
Determine if the following inspections are conducted at least once a day
- Data gathered from monitoring and leak detection equipment
- Overfill/spill control equipment at interim state facilities to ensure it is in good
working order
- Aboveground portions of the tank to detect corrosion or releases
- Tank monitoring equipment (e g , pressure and temperature gauges)
- Area surrounding tank including the secondary containment system for signs of
leakage (wet spots, dead vegetation)
Verify that the proper operation of cathodic protection systems are inspected within
six months after initial installation and annually thereafter
Verify that all sources of impressed current are inspected and/or tested every other
month
Verify that inspections are documented
Phase 1 - Section 11
Storage Tank Management
11-64
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Compliance Category:
Storage Taafe Management
Regulatory Requirements;
Reviewer Chceb;
ST 70. Tank systems or
secondary containment systems
at TSDFs from which there has
been a leak or spill or which
have been declared unfit for use
must be removed from service
immediately and specific
requirements met (40 CFR
264 196 and 40 CFR 265 196)
Verify that the following steps are taken
- The flow or addition of hazardous wastes to the tank is stopped
- The hazardous waste is removed from the tank
-- within 24 hours of detection (or other reasonable time as demonstrated by the
owner/operator) remove as much waste from the tank as necessary to prevent
further release and allow inspection and repair
— within 24 hours (or in as timely a manner as is possible to prevent harm to
human health and the environment) remove waste released to secondary
containment system
- A visual inspection of the release is done and
— action is taken to prevent further migration to soils or surface or groundwater
-- any visible contamination of soil and surface water is removed and disposed
Verify that notification is made within 24 hours for any release to the environment to
the Regional Administrator.
Verify that a report is submitted within 30 days
(NOTE Releases of 1 lb (0 45 kg) or less that are immediately contained and cleaned
up are exempt from reporting)
Verify that the tank and/or secondary containment is repaired prior to its return to
service and that extensive repairs are certified by an independent, qualified,
registered, professional engineer
ST 71 TSDFs are required to
follow specific procedures
when closing a tank system (40
CFR 264 197(a), 264 197(b),
40 CFR 265 197(a),
265 197(b))
Determine if the TSDF has closed any tank systems
Verify that all waste residues, contaminated containment system components,
contaminated soils, and structures and equipment contaminated with waste have been
removed or decontaminated
Verify that if it is not possible and/or practicable to remove or decontaminate all soils,
the facility closes the tank and performs post-closure care as is required for landfills
Phase 1 - Section 11
Storage Tank Management
11-65
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Compliance Category:
Storage Tank Management
Regulatory Requirenveatsj
Reviewer Checks:
Flammable/Combustible Liquid Storage Tanks
ST 72 Tanks used for the
storage of flammable/
combustible liquids are required
to meet specific design and
construction standards (29 CFR
1910 106(b)(1))
Verify that tanks are built of steel unless
- The tank is installed underground
- The properties of the liquid being stored requires materials other than steel be used
- The tank is designed according to specifications embodying principles recognized
as good engineering design for the materials used
- It is an unlined concrete tank that stores flammable or combustible liquids having a
gravity of 40 degrees API or heavier
(NOTE' API gravity is a scale adopted by the American Petroleum Institute for
measuring the density of oils )
Verify that tanks located aboveground or inside buildings are of noncombustible
construction
(NOTE Tanks designed for underground service not exceeding 2,500 gal (9,463 53
L) capacity may be used aboveground and low-pressure tanks and pressure vessels
may be used as atmospheric tanks)
Verify that atmospheric tanks are not used for the storage of a flammable or
combustible liquid at a temperature at or above its boiling point
Verify that the normal operating pressure of a low pressure tank does not exceed the
design pressure of the tank
Phase 1 - Section 11
Storage Tank Management
11-66
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Compliance Category:
Storage Tank Management
Regulatory Requirements:
Kevlewer Checks:
ST 73 Outside aboveground
tanks used for the storage of
flammable/ combustible liquids
are required to be installed
according to specific parameters
(29 CFR 1910 106(b)(2)(i)
through 1910 106(b)(2)(ii))
Verify that there is a minimum distance of 3 ft (0 91 m) between any two tanks
Verify that the distance between any two adjacent tanks is not less than one-sixth the
sum of their diameters
(NOTE. When the diameter of one tank is less than half the diameter of the adjacent
tank, the distance between the two tanks is not less than one-half the diameter of the
smaller tank.)
Verify that where unstable flammable or combustible liquids are stored, the distance
between the tanks is not less than one-half the sum of their diameters
Verify that when tanks are compacted in three or more rows or in an irregular pattern,
greater spacing or other means is provided for firefighting access
Verify that there is a minimum distance of 20 ft (6 1 m) between a Liquefied
Petroleum Gas (LPG) container and a flammable or combustible liquid storage tank
(NOTE In the case of flammable of combustible liquid tanks operating at pressure
exceeding 2.5 psig or equipped with emergency venting which will permit pressures
to exceed 2 5 psig spacing of 3 ft (0 91 m) or the use of the formula concerning one-
sixth of diameters may be used )
Verify that means such as diversion curbs or grading are provided to prevent the
accumulation of flammable or combustible liquids under adjacent LPG containers
Verify that if flammable combustible liquid storage tanks are within a diked area,
LPG containers are outside the diked area and at least 10 ft (3 05 m) away from the
centerline of the wall of the diked area
(NOTE- The requirement concerning LPG containers and diked areas does not apply
if LPG containers of 125 gal (473 18 L) or less capacity are installed adjacent to fuel
oil supply of 550 gal (2,081 98 L) or less capacity)
Phase 1 - Section 11
Storage Tank Management
11-67
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Compliance Category:
Storage Taofe Management
Regulatory Requirements:
Reviewer Checks;
ST 74 Tanks for the storage of
flammable/ combustible liquids
are required to meet specific
containment requirements (29
CFR 1910 106(b)(2)(vn))
Verify that the area surrounding a tank, or a group of tanks, is either provided with
drainage or diked as follows
- Drainage systems terminate in vacant land or other area or in an impounding basin
having a capacity not smaller than that of the largest tank served
- Diked areas have a volumetric capacity of not less than the greatest amount of
liquid that can be released from the largest tank within the diked area, assuming a
fuel tank
Verify that walls of diked areas are of earth, concrete, steel, or solid masonry
designed to be liquid tight
Verify that earthen walls 3 ft (0 91 m) or more in height have a top that is no less than
2 ft (0 61 m) wide
Verify that the walls of the diked area are restricted to an average height of 6 ft (1 83
m) above interior grade.
Verify that there are no loose combustible materials, empty or full drums,or barrels
within the diked area.
ST 75 In locations where
flammable vapors may be
present from storage tanks,
precautions are required to be
taken to prevent ignition (29
CFR 1910 106(b)(6))
Verify that sources of ignition such as open flames, smoking, welding and cutting, hot
surfaces, sparks, and radiant heat are avoided
ST.76. Tanks used for the
storage of flammable/
combustible liquids are required
to be strength tested before
being placed into service (29
CFR 1910 106(b)(7)).
Verify that the tank is marked with a American Society of Mechanical Engineers
(ASME) code stamp, API monogram, or the label of the Underwriters Laboratory as
evidence of having had a strength test
Phase 1 - Section 11
Storage Tank Management
11-68
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Compliance Category:
Storage Ta&k Management
Itegatotory Itagttireateat&;
¦ Reviewer Checks
Pipelines
ST 77 In specific instances of
failure in a pipeline for
hazardous liquids, a report must
be submitted (49 CFR 195 1,
195 50, and 195.54).
Verify that when there is a release of hazardous liquid or C02 that results in the
following, an accident report is submitted to DOT within 30 days
- Explosion or fire not intentionally set by the operator
- Loss of 50 or more barrels (bbl) of hazardous liquid or C02
- Escape to the atmosphere of more than 5 bbl a day of highly volatile liquids
(NOTE- 1 barrel = 42 gallons as defined by this regulation)
- Death of any person
- Bodily harm resulting in
— loss of consciousness
— necessity to carry the person from the scene
— necessity for medical treatment
~ disability which prevents the discharge of normal duties or pursuit of normal
activities
- Estimated property damage to the property of the operator of others or both,
exceeding $5,000
(NOTE This requirement does not apply to the transportation of
- A hazardous liquid that is transported in a gaseous state
- A hazardous liquid through a pipeline by gravity
- A hazardous liquid through pipelines that operate at a stress level of 20 percent or
less of the specified minimum yield strength of the line pipe
- Petroleum in onshore gathering lines in rural areas except gathering lines in the
inlets of the Gulf of Mexico
- A hazardous liquid or C02 in offshore pipelines which are located upstream from
the outlet flange of each facility on the Outer Continental Shelf where hydrocarbons
or C02 are produced or where produced hydrocarbons or C02 are first separated,
dehydrated, or otherwise processed, whichever facility is further downstream
- A hazardous liquid or C02 through onshore production, refining, or manufacturing
facilities, storage or in plant piping systems associated with such facilities
- A hazardous liquid or C02 by vessel, aircraft, tank truck, tank car or other vehicle
or terminal facilities used exclusively to transport hazardous liquids or C02 between
such modes of transportation
- C02 downstream from a point in the vicinity of the well site at which C02 is
delivered to a production facility )
Phase 1 - Section 11
Storage Tank Management
11-69
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Compliance Category:
Storage Tank Management
Regulatory Requireiacats:
Reviewer Cheetw:
ST 78 Under specific
circumstances, if there is a
release of a hazardous liquid or
C02 transported in a pipeline,
telephone notification must be
made as soon as possible after
discovery of the release (49
CFR 195 1 and 195 52)
Verify that telephone notification is made as soon as possible of any failure that.
- Caused a death or a personal injury requiring hospitalization
- Resulted in either a fire or explosion not intentionally set by the operator
- Caused estimated damage to the property of the operator or other or both,
exceeding $5,000
- Resulted in pollution of any stream, river, lake, reservoir, or other similar body of
water that violated applicable water quality standards, caused a discoloration of the
surface of the water or adjoining shoreline, or deposited a sludge or emulsion
beneath the surface of the water or upon adjoining shoreline
- Is significant in the judgement of the operator even though it did not meet any of
the above criteria
(NOTE' Telephone reports are to be made to 1-800-424-8802 )
(NOTE This requirement does not apply to the transportation of
- A hazardous liquid that is transported in a gaseous state
- A hazardous liquid through a pipeline by gravity
- A hazardous liquid through pipelines that operate at a stress level of 20 percent or
less of the specified minimum yield strength of the line pipe
- Petroleum in onshore gathering lines in rural areas except gathering lines in the
inlets of the Gulf of Mexico
- A hazardous liquid or C02 in offshore pipelines which are located upstream from
the outlet flange of each activity on the Outer Continental Shelf where
hydrocarbons or C02 are produced or where produced hydrocarbons or C02 are
first separated, dehydrated, or otherwise processed, whichever is further
downstream
- A hazardous liquid or C02 through onshore production, refining, or manufacturing
facilities, storage or in plant piping systems associated with such facilities
- A hazardous liquid or C02 by vessel, aircraft, tank truck, tank car or other vehicle
or terminal facilities used exclusively to transport hazardous liquids or C02 between
such modes of transportation
- C02 downstream from a point in the vicinity of the well site at which C02 is
delivered to a production facility)
Phase 1 - Section 11
Storage Tank Management
11-70
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Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Checks:
ST 79 Facilities with onshore
oil pipelines that, because of
location, could reasonably be
expected to cause substantial
harm or significant and
substantial harm to the
environment by discharging oil
into or on any navigable waters
of the United States or
adjoining shorelines are
required to prepare an oil spill
response plan (49 CFR 194 3
and 194 101 through 194 107)
Verify that the response plan includes
- A statement indicating which sections in a response zone can be expected to cause
significant and substantial harm to the environment if there is a discharge of oil into
or on the navigable water or adjoining shorelines
- Indications of the worst case discharge
- Immediate notification procedures
- Spill detection and mitigation procedures
- The name address and phone number of an oil spill response organization
- Response activities and response resources
- Training procedures
- Equipment testing
- Schedules for drills
- Plan updating procedures
- An appendix for each response zone indicating all the above general information in
a way that is tailored to that response zone
Verify that the response plan is in english and if necessary, any other language
understood by personnel responsible for carrying out the plan
(NOTE Significant and substantial harm can be expected if the line is greater than 6
5/8 in (16 83 cm) in outside nominal diameter, greater than 10 miles (16 09 km) in
length and the line section
- Has experienced a release greater than 1,000 bbl (158,987 3 L) in the previous five
years
- Has experienced two or more reportable releases in the previous five years
- Contains any electric resistance welded pipe, manufactured prior to 1970, operated
at maximum operating pressure that corresponds to a stress level greater than 50
percent of the specified minimum yield strength of the pipe
- Is located within a 5 mile (8 05 km) radius of potentially affected public drinking
water intakes and could reasonably be expected to reach the intake
- Is located within 1 mile (1 61 km) radius of potentially affected environmentally
sensitive areas, and could reasonably be expected to reach these areas)
(NOTE. The requirement to submit a response plan is effective 18 February 1993
After 18 August 1993, the onshore pipeline must be operated according to the details
outlined in the response plan )
(NOTE A response plan is not required for the following
- A pipeline that is 6 5/8 in (16 83 cm) or less in outside nominal diameter and is 10
miles (16 09 km) or less in length, and all the following conditions apply
-- the pipeline has not experienced a release greater than 1,000 bbl (158,987.3 L)
within the previous five years
~ the pipeline has not experienced at least two reportable releases within the
previous five years
— the pipeline contains any electric resistance welded pipe, manufactured prior to
1970, does not operate at a maximum operating pressure that corresponds to a
stress level greater than 50 percent of the specified minimum yield strength of
the pipe
-- the pipeline is not in proximity to navigable waters, public drinking water
intakes, or environmentally sensitive areas
Phase 1 - Section 11
Storage Tank Management
11-71
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Compliance Category:
Storage Taak Management
Regulatory RfepiremedtSf
Reviewer ChecfcM
ST.79 (continued)
- A line section that is greater than 6 5/8 in (16 83 cm) in outside nominal diameter
and is greater than 10 miles (16 09 km) in length, where the operator determines
that it is unlikely that the worst case discharges from any point on the line section
would adversely affect, within 12 hours after the start of discharge, any navigable
waters, public drinking water intakes, or environmentally sensitive areas
- A line section that is 6 5/8 in. (16 83 cm) or less in outside nominal diameter and is
10 miles (16 09 km) or less in length, where the operator determines that it is
unlikely that the worst case discharge from any point on the line section would
adversely affect, within four hours after the initiation of the discharge, any
navigable waters, public drinking water intakes, or environmentally sensitive areas.)
ST 80 Copies of the response
plan are required to be
submitted to the EPA RSPA (49
CFR 194 119(a) through
194 119(d))
Verify that two copies were submitted to the following address
Pipelines Response Plans Office
Research and Special Programs Administration
Department of Transportation
400 Seventh St SW
Washington DC 20590-0001
Verify that the RSPA approved the response plan.
ST 81 If the RSPA does not
approve a response plan for a
pipeline identified as expected
to cause significant and
substantial harm to the
environment, the operator must
submit certification to the
RSPA by 18 July 1993 that the
operator has obtained, through
contract or other means, the
necessary personnel and
equipment to respond to a worst
case discharge or a substantial
threat of a discharge (49 CFR
194 119(e))
Determine if the facility has an approved response plan
Verify that if there is not an approved response plan, the necessary certification has
been submitted to the RSPA
ST 82 Copies of the response
plan are required to be kept at
specific locations (49 CFR
194 111)
Verify that a copy of the complete response plan is at the operators headquarters and a
copy is provided to each responsible individual
Verify that a copy of the core portion of the plan and relevant response zone
appendices for each line section whose pressure may be affected by the operation of a
particular pump station is provided at the pump station
Verify that a copy of the core portion of the plan and relevant response zone
appendices is kept at locations where response activities might be conducted
Phase 1 - Section 11
Storage Tank Management
11-72
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Compliance Category:
StorageTaufe Management
Regulatory Requirements;
Reviewer Checks:
ST 83 Training is required for
the implementation of the
response plan (49 CFR
194 117)
Verify that training is conducted such that all personnel know
- Their responsibilities under the plan
- The names, addresses, and procedures for contacting the operator on a 24-hour
basis and a qualified individual
Verify that reporting personnel know
- The content of the information summary
- The toll free number of the National Response Center (NRC)
- The notification process
Verify that personnel engaged in response activities know
- The characteristics and hazards of oil discharged
- The conditions that are likely to worsen emergencies and appropriate corrective
actions
- The steps needed to control any accidental discharge of oil and to minimize the
potential for fire, explosion, toxicity, or environmental damage
- The proper firefighting procedures and use of equipment, fire suits and breathing
apparatus
Verify that training records exist for each individual that has been trained, specifically
records for'
- Operator personnel are at the operators headquarters
- Personnel engaged in response are maintained as determined by the operator
(NOTE This training does not take the place of emergency response training
requirements as found in 29 CFR 1910 120)
ST 84 Pipeline response plans
are required to be reviewed
every three years from the date
of submission and modified to
address new or different
operating conditions or
information (49 CFR 194 121)
Verify that the plan is reviewed every three years
Phase 1 - Section 11
Storage Tank Management
11-73
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Compliance Category:
Storage Tank Management
Regulatory Requirements;
Reviewer Checks:
Service Stations
ST 85 Liquids at service
stations are required to be
stored in approved closed
containers not exceeding 60 gal
(227.12 L) capacity, in tanks
underground, tanks in special
enclosures, or in aboveground
tanks that meet specific
requirements (29 CFR
1910.106(g)( 1 )(i)(a) through
1910 106(g)(1) (i)(e),
1910 106(g)(1)(H), and
1910.106(g)(l)(iii)).
Verify that if aboveground tanks are located in an adjoining bulk plant, they are
connected by piping to service station underground tanks if, in addition to valves at
the aboveground tank, there is a valve installed within the control of service station
personnel
Verify that apparatus for dispensing Class I liquids into the fuel tanks of motor
vehicles of the public is not located at a bulk plant unless it is separated by a fence or
similar barrier from the area in which bulk operations occur.
(NOTE' These requirements do not prohibit the dispensing of flammable liquids in
the open from a tank vehicle to a motor vehicle if
- The tank vehicle complies with the requirements in Standard on Tank Vehicles for
Flammable Liquids, NFPA 385-1966
- The dispensing is done on premises not open to the public
- The dispensing hose does not exceed 50 ft (15 24 m)
- The dispensing nozzle is a listed automatic closing type without a latchopen device
Verify that underground tanks are installed as required by the Storage Tank
Management checklist.
Verify that if tanks for flammable or combustible liquids are installed in enclosures
because it is impractical due to property or building limitations to correctly install
USTs, the enclosure meets the following.
- It is substantially liquid and vapor tight without backfill
- Sides, top, and bottom of the enclosure are of reinforced concrete at least 6 in
(15.24 cm) thick
- Openings for inspection are only on the top
- Tank connections are piped or closed so that neither vapors or liquid can escape
into the enclosed space
- Means are provided so that portable equipment can be used to discharge to the
outside any liquid or vapors that might accumulate if leakage occurs.
Verify that no Class I liquids are stored within any service station building in closed
containers of aggregate capacity exceeding 60 gal (227.12 L) unless the container
meets the enclosure requirements
Verify that Class 11 and III liquids are not stored or dispensed inside service station
buildings from tanks of more than 120 gal (454 25 L) capacity each.
ST 86. Class I liquids at service
stations are required to not be
stored or handled within a
building having a basement or
pit into which flammable
vapors can travel (29 CFR
1910.106(g)( 1 )(i)(0)
Verify that Class I liquids are not stored or handled in a building with a basement or
pit into which flammable vapors can travel unless the area is provided with adequate
ventilation
ST 87 Dispensing of Class I
liquids into portable containers
is restricted (29 CFR
1910.106(g)( 1 )(v)).
Verify that Class I liquids are not dispensed into portable containers unless the
container is constructed of metal, has a tight closure with screwed or spring cover, and
is fitted with a spout or designed to prevent spilling.
Phase 1 - Section 11
Storage Tank Management
11-74
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Compliant Category:
Storage Tattk Managenjertt
Regulatory Requirements;
Reviewer Chedtat
ST 88 Dispensing devices at
automotive service stations are
required to meet specific
standards (29 CFR
1910 106(g)(3))
Verify that dispensing systems are located so that all parts of the vehicle being served
are located on the premises of the station
Verify that if the dispensing unit is located inside a building the following are met
- The dispensing area is separated from other areas
- The unit and its piping are mounted whether on a concrete island or protected
against collision damage
- The area has an approved mechanical or gravity ventilation system
(NOTE: When indoor dispensing units are below grade, only approved mechanical
ventilation can be used)
Verify that all dispensing units are equipped with a clearly identified and easily
accessible switch or circuit breaker at a location remote from the dispensing devices
to shut off power in case of an emergency
Verify that Class 1 liquids are transferred from tanks by means of a fixed pump that is
designed and operated to prevent leakage or accidental discharge
Verify that Class 1 liquids are not dispensed by pressure from drums, barrels, or
similar containers.
Verify that all dispensing units, except those attached to a container, are mounted so
as to prevent damage from a collision
Verify that the nozzles on Class I dispensing units are listed manual or automatic
closing type hose nozzles
Phase 1 - Section 11
Storage Tank Management
11-75
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Compliance Category:
Storage Tank Management
Regulatory Repiremeuts;
: Reviewer Cfcecfc»t
Transfer Terminals
ST.89. Facilities that can
transfer oil or hazardous
materials, in bulk, to or from a
vessel with a capacity of 250
bbl (30746 83 L) or more are
required to develop an
operations manual to aid in the
prevention of spills and
discharges (33 CFR 154.100
and 154 300).
Determine if the facility can transfer oil or hazardous materials, in bulk, to or from a
vessel with a capacity of 250 bbl (30746 83 L) or more
Verify that the facility has an operating manual that describes
- How the facility is meeting the regulatory requirements for operations, including
spill prevention
- Responsibilities of personnel
- Translations into additional languages as needed.
Verify that the facility has received a letter of adequacy from the Coast Guard
indicating the manual is sufficient
(NOTE: This also applies to each mobile facility that is used, or intended to be used
to transfer oil or hazardous material, in bulk, to or from a vessel with a capacity of
250 bbl (30746 83 L) or more )
(NOTE- This requirement does not apply to transfer facilities in caretaker status)
ST.90 Reception facilities for
an oil loading port or terminal
that loads a daily average of
more than 1000 metric tons
(1100 short tons) of oil other
than crude oil or bunker oil to
oceangoing tankers must have
the capacity to receive specific
types of waste (33 CFR
158 220)
Determine if the installation operates a reception facility for an oil loading port or
terminal that loads a daily average of more than 1000 metric tons (1100 short tons) or
oil other than crude oil or bunker oil to oceangoing tankers
Verify that the reception facility has the capacity to receive the following
- Sludges from on-board fuel and lubricating oil processing in the amount of 10
metric tons (11 short tons)
- Oily bilge water in the amount of 10 metric tons (11 short tons) or 2 metric tons
(2 2 short tons) multiplied by the daily vessel average, whichever quantity is greater
- Oily ballast in the amount of 30 percent of the deadweight tonnage of the largest of
oceangoing tankers loading oil other than crude oil or bunker oil, at the port or
terminal, that do not have an appropriate clean ballast tank or an appropriate
segregated ballast tank multiplied by one or the daily vessel average, whichever
quantity is greater
- Cargo residue in the amount of 0 2 percent of the total cargo capacity of the largest
of the oceangoing tankers loading oil other than crude oil or bunker oil, at the port
or terminal, multiplied by one or the daily vessel average, whichever quantity is
greater.
ST 91 Reception facilities
other than those in 33 CFR
158 220 (see checklist item
P 31) and other than ship repair
yards, ports and terminal
loading crude oil and those used
exclusively by non-self-
propelled tank barges are
required to have specific types
of reception facilities (33 CFR
158 230)
Verify that the reception facility has the capacity for receiving the following
- Sludge from on-board fuel and lubricating oil processing in the amount of 10 metric
tons (11 short tons) or 1 metric ton (1 1 short tons) multiplied by the daily vessel
average, whichever is greater
- Oil ballast water in the amount of 10 metric tons (11 short tons) or 2 metric tons
(2.2 short tons) multiplied by the daily vessel average, whichever quantity is
greater
Phase 1 - Section 11
Storage Tank Management
11-76
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Compliance Category:
Storage Tmk Management
Regulatory RtquircmeotSf
Jtevlewer Check#
POL Loading and Unloading
ST 92. Onshore tank car and
tank truck loading/ unloading
racks are required to meet
specific structural standards (40
CFR 112.7(e)(4)(n) and 40 CFR
112 7(e)(4)(in))
Verify that where rack drainage does not flow into a catchment basin or treatment
facility designed to handle spills, a quick drainage system is used
Verify that any containment system is designed to hold at least the maximum capacity
of any single compartment of a tank car or tank truck loaded or unloaded at the site
Verify that an interlocked warning light or physical barrier system, or warning signs
are provided in loading/unloading areas to prevent vehicular departure before
complete disconnect of flexible or fixed transfer lines
(NOTE Facilities are exempt from the requirements outlined in 40 CFR 112 if
- The facility, equipment, or operation is not subject to the jurisdiction of the EPA as
follows
-- onshore and offshore sites which, due to their location, could not be reasonably
expected to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines
-- equipment or operations of vessels or transportation related onshore and
offshore sites which are subject to the authority of the DOT
- Both of the following criteria are met
- the underground buried storage capacity of the facility is 42,000 gal (15,987 30
L) or less of oil
-- the aggregate storage capacity which is not buried at the facility is 1,320 gal
(4,996 74 L) of oil or less or no single container exceeds a capacity of 660 gal
(2,498 37 L) (40 CFR 112 1(d)(2))
ST 93 Specific operational
procedures are required to be
performed at facility tank car
and tank truck loading/
unloading sites (40 CFR
112 7(e)(iv))
Verify that before filling and departure of any tank car or tank truck, the lowermost
drain and all outlets of the vehicle are closely examined for leakage and if necessary
tightened, adjusted, or replaced to prevent leakage while in transit
(NOTE Facilities are exempt from the requirements outlined in 40 CFR 112 if
- The facility, equipment, or operation is not subject to the jurisdiction of the EPA as
follows
~ onshore and offshore sites which, due to their location, could not be reasonably
expected to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines
-- equipment or operations of vessels or transportation related onshore and
offshore sites which are subject to the authority of the DOT
- Both of the following criteria are met
-- the underground buried storage capacity of the facility is 42,000 gal (15,987 30
L) or less of oil
- the aggregate storage capacity which is not buried at the facility is 1,320 gal
(4,996 74 L) of oil or less or no single container exceeds a capacity of 660 gal
(2,498 37 L) (40 CFR 112 1(d)(2))
Phase 1 - Section 11
Storage Tank Management
11-77
-------
Section 11
Storage Tank Management
Appendices
-------
Appendix 11-1
UST Applicability Guide
tfteoffiST "
AgjpMte CIB Citation
s
Underground Storage Tanks as
defined in 40 CFR 280.12 (see
definitions)
40 CFR 280
ST. 14 through ST.46
Excluded USTs (see definitions)
none
none
Deferred USTs (see definitions)
40 CFR 280 11
ST 37
USTs storing fuel for
emergency generators
40 CFR 280 20 through 280 22
280 30 through 280 34
280 50 through 280 53
280 60 through 280 67
280.70 through 270.74
ST 14 through ST. 19,
ST 21 through ST.24,
ST 29 through ST.36,
ST 38 through ST 46
All-1
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Appendix 11-2
Schedule for Phase-in of Release Detection
(40 CFR 280.40(c))
Year system was installed
Year when release detection is required
(by December 22 of tlie year indicated)
s s f s s
X % ....
im
.1#^ ^ !
mt ""
Before 1965 or date unknown
RD
P
1965-69
P/RD
1970-74
P
RD
1975-79
P
RD
1980-88
P
RD
P = must begin release detection for all pressurized piping as defined in 40 CFR 280.41(b)(1).
RD = must begin release detection for tanks and suction piping
All-2
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Appendix 11-3
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
A. UST Options (see NOTE for additional guidance)
1. Inventory control
Product inventory control must be conducted monthly to detect a release of at
least 1.0 percent of flow-through plus 130 gal on a monthly basis in the following
manner:
a. Inventory volume measurements for regulated substance inputs, withdrawals, and
the amount still remaining in the tank are recorded each operating day;
b The equipment used is capable of measuring the level of product over the full
range of the tanks height to the nearest 1/8 in.;
c. The regulated substance inputs are reconciled with delivery receipts by
measurements of the tank inventory volume before and after delivery;
d. Deliveries made through a drop tube that extends to within 1 ft of the tank
bottom;
e. Product dispensing is metered and recorded within the local standards of product
withdrawn, and
f. The measurement of any water level in the bottom of the tank is made to the
nearest 1/8 in. at least once a month.
2. Manual gauging
Manual tank gauging must meet the following requirements:
a. Tank liquid level measurements are taken at the beginning and end of a period of
at least 36 hours during which no liquid is added to or removed from the tank;
b. Level measurements are based on an average of two consecutive stick readings at
both the beginning and end of the period,
c. The equipment used is capable of measuring the level of product over the full
range of the tank's height to the nearest 1/8 in.;
d. A leak is suspected and subject to the requirements of subpart E if the variation
between beginning and ending measurements exceeds the weekly or monthly
standards of Table A below;
e. Only tanks of 550 gal or less nominal capacity may use this as a sole method of
release detection Tanks of 551 to 2000 gal may also use inventory control. See
paragraph 1 in this appendix Tanks of greater than 2000 gal nominal capacity
may not use this method to meet release detection requirements.
All-3
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Appendix 11-3 (continued)
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
hi: . ..
>;>r;"V
..u.f. j. +
Task Q»jpdgr
" fonetest)
faveraee of four)
550 gal or less
10 gal
5 gal
551-1000 gal
13 gal
7 gal
1001-2000 gal
26 gal
13 gal
3. Tank Tightness Testing
Tank tightness testing must be capable of detecting a 0.1 gal/hour leak rate from
any portion of the tank that routinely contains product while accounting for the effects
of thermal expansion or contraction of the product, vapor pockets, tank deformation,
evaporation or condensation, and the location of the water table.
4. Tank Automatic Gauging
Equipment for automatic tank gauging that tests for the loss of product and
conducts inventory control; must meet the following requirements:
a. The automatic product level monitor test can detect a 0.2 gal/hour leak rate from
any portion of the tank that routinely contains product; and
b. Inventory control is conducted according to requirements (see paragraph 1 above).
5. Vapor Monitoring
Testing or monitoring for vapors within the soil gas of the excavation zone must
meet the following requirements:
a. The materials used as backfill are sufficiently porous (e.g., gravel, sand, crushed
rock) to easily allow diffusion of vapors from releases into the excavation area;
b. The stored regulated substance, or a tracer compound placed in the tank system,
is sufficiently volatile (e.g., gasoline) to result in a vapor level that is detectable
by the monitoring devices located in the excavation zone in the event of a release
from the tank;
c. The measurement of vapors by the monitoring device is not rendered inoperative
by the ground water, rainfall, or soil moisture or other unknown interferences so
that a release could go undetected for more than 30 days;
d. The level of background contamination in the excavation zone will not interfere
with the method used to detect releases from the tank;
All-4
-------
Appendix 11-3 (continued)
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
e. The vapor monitors are designed and operated to detect any significant increase in
concentration above background of the regulated substance stored in the tank
system, a component or components of that substance, or a tracer compound
placed in the tank system;
f In the UST excavation zone, the site is assessed to ensure compliance with the
requirements of paragraph 5 a-d above and to establish the number and
positioning of monitor wells that will detect any releases within the excavation
zone from any portion of the tank that routinely contains product; and
g. Monitoring wells are clearly marked and secured to avoid unauthorized access and
tampering.
6. Groundwater Monitoring
Testing or monitoring for liquids in the ground water must meet the following
requirements-
a. The regulated substance stored is immiscible in water and has a specific gravity of
less than one;
b. Groundwater is never more than 20 ft from the ground surface and the hydraulic
conductivity of the soil(s) between the UST system and the monitoring wells or
devices is not less than 0.01 cm/s (e.g., the soil should consist of gravels, coarse
to medium sands, coarse silts or other permeable materials;
c. The slotted portion of the monitoring well casing must be designed to prevent
migration of natural soils or filter pack into the well and to allow entry of
regulated substance on the water table into the well under both high and low
ground water conditions;
d. Monitoring wells should be sealed from the ground surface to the top of the filter
pack;
e. Monitoring wells or devices intercept the excavation zone or are as close to it as
is technically feasible;
f. The continuous monitoring devices or manual methods used can detect the
presence of at least 1/8 in. of free product on tip of the ground water in the
monitoring wells;
g. Within and immediately below the UST system excavation zone, the site is
assessed to ensure compliance with the requirements of paragraphs 6 a-e above
and to establish the number and positioning of monitoring wells or devices that
All-5
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Appendix 11-3 (continued)
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
will detect releases from any portion of the tank that routinely contains product;
and
h. Monitoring wells are clearly marked and secured to avoid unauthorized access and
tampering.
7. Interstitial Monitoring
Interstitial monitoring between the UST system and a secondary barrier
immediately around or beneath it may be used, but only if the system is designed,
constructed and installed to detect a leak from any portion of the tank that routinely
contains product and also meets one of the following requirements-
a. For double-walled systems, the sampling or testing method can detect a release
through the inner wall in any portion of the tank that routinely contains product;
b. For UST systems with a secondary barrier within the excavation zone, the
sampling or testing method used can detect a release between the UST system and
the secondary barrier;
c. The secondary barrier around or beneath the UST system consists of artificially
constructed material that is sufficiently thick and impermeable (at least 10"6 cm/s
for the regulated substance stored) to direct a release to the monitoring point and
permit its detection;
d. The barrier is compatible with the regulated substance stored so that a release
from the UST system will not cause a deterioration of the barrier allowing a
release to pass through undetected;
e. For cathodically protected tanks, the secondary barrier must be installed so that it
does not interfere with the proper operation of the cathodic protection system;
f. The ground water, soil moisture, or rainfall will not render the testing or
sampling method used inoperative so that a release could go undetected for more
than 30 days;
g. The site is assessed to ensure that the secondary barrier is always above the
ground water and not in a 25 year floodplain, unless the barrier and monitoring
designs are for use under such conditions; or
h. Monitoring wells are clearly marked and secured to avoid unauthorized access and
tampering
All-6
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Appendix 11-3 (continued)
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
i. For tanks with an internally fitted liner, an automated device can detect a release
between the inner wall of the tank and the liner. The liner is compatible with the
substance stored.
8. Other Methods
Any other type of release detection method, or combination of methods, can be
used if:
a. It can detect a 0.2 gal/hour leak rate or a release of 150 gal within a month with a
probability of detection of 0.95 and a probability of false alarm of 0.05; or
b. The implementing agency may approve another method, if it can be demonstrated
that this method can detect releases as effectively as the methods listed in this
appendix
NOTE: The following are alternatives on the above listings for UST release detection
options:
• USTs meeting the requirements in 40 CFR 280.20 for new tanks and the monthly
inventory requirements in All-1 and All-2 above can use tank tightness testing
as outlined in A11-3 at least every five years until 22 December 1998, or until 10
years after the tank is installed or upgraded under 40 CFR 280.21(b),
• USTs that do not meet the standards of 40 CFR 280.20 or 280.21 may use
monthly inventory as outlined in All-1 or All-2 and annual tank tightness testing
done according to All-3 until 22 December 1998 when the tank must be
upgraded or permanently closed.
• USTs with a capacity of 550 gal or less may use weekly tank gauging done
according to All-2.
B. Underground Piping Options
1. Automatic Line Detectors
Methods which alert the operator to the presence of a leak by restricting or
shutting off the flow of regulated substances through piping, or triggering an audible
or visual alarm may be used only if they detect leaks of 3 gal/hour at 10 lb/in2 line
pressure within one hour. An annual test of the operation of the leak detector must be
conducted in accordance with the manufacturer's requirements.
2. Line Tightness Testing
A periodic test of piping may be conducted only if it can detect a 0.1 gal/hour
leak one and one-half times the operating pressure.
All-7
-------
Appendix 11-3 (continued)
Release Detection Requirements for USTs and Underground Piping
(40 CFR 280.41 through 280.43)
3. Applicable Tank Methods
The methods outlined in All-2 through All-4 may be used if they are designed
to detect a release from any portion of the underground piping that routinely contains
regulated substances.
NOTE: The following is additional information on the above listings for
underground piping release detection options:
• Pressurized piping must meet both of the following:
Be equipped with an automatic line leak detector as outlined in B1
Have an annual line tightness test done according to B2 or have monthly
monitoring done in accordance with B3.
• Underground suction piping must either have a line tightness test done according
to B2 at least every three years or use a monthly monitoring method in accordance
with B3. No release detection is required for suction piping that is designed and
constructed to meet the following standards:
The below-grade piping operates at less than atmospheric pressure
The below-grade piping is sloped so that the contents of the pipe will drain
back into the Storage tank is the suction is released
Only one check valve is included in each suction line
The check valve is located directly below and as close as practical to the
suction pump
A method is provided that allows compliance with these standards to be
readily determined.
All-8
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Phase 1
Section 12
Drinking Water Management
-------
Phase 1
Section 12
Table of Contents
Drinking Water Management
A. Applicability 12-1
B. Federal Legislation 12-1
C. State/Local Regulations 12-3
D. Key Compliance Requirements 12-3
E. Key Compliance Definitions 12-5
F. Records to Review 12-11
G. Physical Features to Inspect 12-11
H. Guidance for Checklist Users 12-12
Appendices
A12-1. Primary Drinking Water Standards for Organic Contaminants A12-1
A12-2. Primary Drinking Water Standards for Inorganic Contaminants A12-4
A12-3. Detection Limitations for Inorganic Contaminants A12-6
A12-4. Detection Limitations A12-7
A12-5. Unregulated Organic and Inorganic Contaminants A12-8
A12-6. Coliform Bacteria Sampling Frequency A12-9
A12-7. Monitoring and Sampling Parameters for Lead and Copper in
Drinking Water A12-10
-------
A. Applicability
This section identifies rules, regulations, and requirements for any facility that has
jurisdiction over any public water supply system. A public water system is defined as a system
for providing piped water to the public for human consumption, if such system has at least 15
service connections or regularly serves an average of at least 25 individuals daily at least 60 days
out of the year. This term includes.
1 Any collection, treatment, storage, and distribution facilities under control of the operator of
such system.
2. Any collection or pretreatment storage facilities not under such control that are used
primarily in connection with such system
A public water system is either a community water system or a noncommunity water system
(40 CFR 1412)
Facilities that meet all the criteria listed below are not required to comply with the
requirements of the Safe Drinking Water Act (SDWA) since, by definition, they are not public
water systems (40 CFR 141.3):
1 The system consists only of distribution and storage facilities and does not have any
collection and treatment facilities.
2 The system gets all of its water from a public water system that is owned or operated by
another party.
3 The system does not sell water to any party.
Assessors are required to review agency, Federal, state and local regulations in order to perform a
comprehensive assessment.
This section also identifies rules, regulations, and requirements for facilities that have
Underground Injection Control (UIC) activities.
B. Federal Legislation
1. The Safe Drinking Water Act (SDWA)
This Act, Public Law (PL) 99-339, 42 U.S. Code (USC) 201, 300(f)-300(j)(25), 6939(b),
6979(a), 6979(b), 7401-7402, etc., is the Federal legislation which regulates the safety of
drinking water in the country. Each department, agency, and instrument of the executive,
legislative, and judicial branches of the Federal government having jurisdiction over any
potential source of contaminants identified by a state program must be subject to and observe all
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12-1
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requirements of the state program applicable to such potential source of contaminants, both
substantive and procedural, in the same manner, and to the same extent, as any other person,
including payment of reasonable charges and fees (42 USC 300(h)-7(h)) [Please note that this
revision of the Generic Protocol for Conducting Environmental Audits of Federal Facilities does
not include the 1996 amendments to the Safe Drinking Water Act.]
If a Federal agency has jurisdiction over any federally owned or maintained public water
system, or is engaged in any activity resulting, or which may result in, underground water
injection which endangers drinking water, it is subject to, and must observe, any Federal, state,
and local regulations, administrative authorities, and process and sanctions respecting the
provision of safe drinking water and respecting any underground injection program in the same
manner, and to the same extent as any nongovernmental entity. This requirement applies (42
USC 300(j)-6(a)):
a. To any rules, substantive or procedural (including any recordkeeping or reporting, permits,
and other requirements);
b To the exercise of any Federal, state, or local authorities; and
c. To any process or sanction, whether enforced in Federal, state, or local courts or in any other
manner.
National primary drinking water regulations apply to each public water system in each state.
However, such regulations do not apply to a public water system (42 USC 300(g)):
a. Which consists only of distribution and storage facilities (and does not have any collection
and treatment facilities).
b. Which obtains all its water from, but is not owned or operated by, a public water system to
which such regulations apply;
c. Which does not sell water to any person; and
d. Which is not a carrier which conveys passengers in interstate commerce.
2. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
the agency funds meet applicable Federal, state, and local environmental requirements or to
correct situations that are not in compliance with such requirements. In addition, the EO requires
that each agency ensure that sufficient funds for environmental compliance are included in the
agency budget.
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C. State/Local Regulations
States have primary responsibility to enforce compliance with national primary drinking
water standards and sampling, monitoring, and notice requirements in conformance with 40 CFR
Part 141. EPA executes the enforcement responsibilities until individual state programs are
approved.
States that have primacy may establish drinking water regulations, monitoring schedules and
reporting requirements more stringent than, or in addition to, those in the Federal regulations.
Generally speaking, most states who have primacy adopt drinking water regulations which
closely reflect the Federal requirements. Almost all states have achieved authorization from EPA
to administer drinking water compliance programs including Underground Injection Control
(UIC) programs. Some states also require certification of operators of public water systems.
Furthermore, some states require operators to receive approval of plans and specifications prior
to constructing or modifying a public drinking water system.
D. Key Compliance Requirements
1. Plans and Records
The drinking water facility manager must keep records of actions taken to correct or repair
any part of the treatment and distribution system for at least three years. Plans for water system
modifications should be reviewed. Facilities are required to survey public water systems and
maintain records of those reviews (MP, 40 CFR 141.21(d) and 141.33(b)).
2. Physical Requirements for Drinking Water Systems
There will not be any cross-connection, open or potential, between a system furnishing
potable water and a system furnishing nonpotable water. All water systems shall install and
operate optimal corrosion control treatment and/or comply with corrosion control requirements
specified by the state (40 CFR 141 80(d)).
3. Maximum Contaminant Level (MCL) Standards
Drinking water is to be supplied from sources approved by Federal, state, or local health
authorities, or treated to specific standards. Community water systems, noncommunity water
systems, except as defined under exempted water systems, and community and nontransient,
noncommunity water systems are required to meet specific MCLs for organic, inorganic, and
microbiological contaminants. These are outlined in Appendices 12-1 and 12-2 (40 CFR
141.11(a) through 1141.11(c), 141.12,141.15, 141.16(a), and 141.60 through 141.63).
4. Monitoring
The monitoring schedule and what constituents are to be monitored is based on what type of
drinking water facility is being operated. Facilities with community water systems and/or
nontransient, non-community water systems are required to monitor for inorganic contaminants
All public water systems are required to conduct monitoring to determine compliance for nitrate
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and nitrite levels. Monitoring for Endrin is required to be done according to specific schedules.
Community and non-community water systems are required to monitor for total coliforms and
facilities are required to monitor for radioactivity in community water systems (40 CFR
141.21(a), 141.23,141.24, and 141.26).
5. Total Coliform and Turbidity Sampling
Total coliform samples are required to be collected at regular intervals throughout the month
except at systems that use only groundwater and serve 4900 people or fewer. Public water
systems that use surface water or groundwater under the direct influence of surface water and do
not practice filtration are required to collect at least one total coliform sample near the first
service connection each day the turbidity level of the source water exceeds 1 Nephelometric
Turbidity Unit (NTU). When a routine sample is total coliform-positive, the public water system
must collect a set of repeat samples within 24 hours of being notified of the positive result.
Sampling for turbidity is required to be done at public water systems that use water obtained in
whole or part from surface water sources according to a specific schedule and any excesses
reported (40 CFR 141.21 and 141.22).
6. Water Analysis
Facilities with community water systems that add a disinfectant to the water are required to
analyze for Total Trihalomethanes (TTHM). Suppliers of water for community public water
systems are required to analyze for sodium and collect samples from representative entry points
to the water distribution system and analyze for corrosivity. Bacteriological analysis of samples
used to determine compliance with MCLs must be performed in a state-approved lab or by a
state-approved individual (40 CFR 141.28, 141.30,141.41 and 141.42).
7. Filtration and Disinfection
Facilities that have a public water system that uses surface water sources or groundwater
sources under direct influence of a surface water source, must provide filtration as a treatment
technique for microbiological contaminants which meets specific standards, provide disinfection
treatment by 29 June 1993, and report specific information monthly to the state starting 29 June
1993, or when filtrating.
8. Notification and Reporting Requirements
Records of chemical analyses are required to be kept for not less than 10 years. When
primary drinking water standards are exceeded, public notifications must be made. Facilities that
operate public water systems must send reports to the state on any failure to comply with the
applicable biological, turbidity, radioactivity, and chemical standards, and on any failure to
comply with monitoring requirements that apply (40 CFR 141.31,141.32, and 141.33(a)).
9. Lead and Copper in Drinking Water Systems
Facilities with community or nontransient, noncommunity water systems must notify their
users about lead in drinking water systems and must meet specific standards for lead and copper
action levels and reporting requirements when these levels are exceeded. Facilities with water
systems exceeding the lead action level after the implementation of corrosion control and source
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12-4
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water treatment requirements are required to replace lead service lines. Monitoring for lead and
copper is required to start on a specified date, be done at a specified number of sites. The facility
is required to fulfill specific reporting requirements and retain onsite all the original records of
sampling data, analysis, reports, surveys, letters, evaluations, state determinations, and any other
pertinent documents for at least 12 years (40 CFR 141.80 through 141.90).
E. Key Compliance Definitions
1. Action Level
The concentration of lead or copper in the water specified in 40 CFR 141.80(c) which
determines, in some cases, the treatment requirements that a water system is required to complete
(40 CFR 141.2).
2. Best Available Technology (BAT)
The best technology treatment techniques, or other means which the administrator finds,
examined for efficacy under field conditions and not solely under lab conditions that are
available (taking cost into consideration). For the purposes of setting MCLs for synthetic
organic chemicals, any BAT must be at least as effective as granular activated carbon (40 CFR
141.2).
3. Coagulation
A process using coagulant chemicals and mixing by which colloidal and suspended materials
are destabilized and agglomerated into floes (40 CFR 141.2).
4. Community Water System
A public water system that serves at least 15 service connections used by year round
residents or regularly serves at least 25 year-round residents (40 CFR 141.2).
5. Contaminant
Any physical, chemical, biological, or radiological substance or matter in water (40 CFR
141.2).
6. Conventional Filtration Treatment
A series of processes including coagulation, flocculation, sedimentation, and filtration
resulting in substantial particulate removal (40 CFR 141.2).
7. Diatomaceous Earth Filtration
A process resulting in substantial particulate removal in which (40 CFR 141.2):
a. A precoat cake of diatomaceous earth filter media is deposited on a support membrane
(septum), and
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12-5
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b. While the water is filtered by passing through the cake on the septum, additional filter media
known as body feed is continuously added to the feed water to maintain the permeability of
the filter cake.
8. Direct Filtration
A series of processes including coagulation and filtration but excluding sedimentation
resulting in substantial particulate removal (40 CFR 141.2).
9. Disinfectant
Any oxidant, including but not limited to chlorine, chlorine dioxide, chloramines, and ozone
added to water in any part of the treatment or distribution process that is intended to kill or
inactivate pathogenic micro-organisms (40 CFR 141.2).
10. Disinfection
A process which inactivates pathogenic organisms in water by chemical oxidants or
equivalent agents (40 CFR 141.2).
11. Domestic or Other Non-Distribution System Plumbing Problem
A coliform contamination problem in a public water system with more than one service
connection that is limited to the specific service connection from which the coliform-positive
sample was taken (40 CFR 141.2).
12. Exempted Public Water Systems
The following are public water systems which are not required to meet the standards
outlined in 40 CFR 141 (40 CFR 141.3):
• Systems which consist only of distribution and storage facilities and do not have any
collection and treatment facilities;
• Systems that obtain all of their water from, but one not owned by or operated by, a public
water system to which 40 CFR 141 applies;
• Systems that do not sell water to any person; and
• Systems that are not carriers that convey passengers in interstate commerce.
13. Filtration
A process for removing particulate matter from water by passage through porous media (40
CFR 141.2).
14. Flocculation
A process to enhance agglomeration or collection of smaller floe particles into larger, more
easily settleable particles through gentle stirring by hydraulic or mechanical means (40 CFR
141.2).
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Drinking Water Management
12-6
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15. Gross Alpha Particle Activity
The total radioactivity due to alpha particle emissions as inferred from measurements on a
dry sample (40 CFR 141.2).
16. Groundwater Under the Direct Influence of Surface Water
Refers to any water beneath the surface of the ground with:
a. Significant occurrence of insects or other macro-organisms, algae, or large-diameter
pathogens such as Giardia lamblia, or
b. Significant and relatively rapid shifts in water characteristics such as turbidity, temperature,
conductivity, or pH which closely correlate to climatological or surface water conditions.
Direct influence must be determined for individual sources in accordance with criteria
established by the state (40 CFR 141.2).
17. Halogen
One of the chemical elements chlorine, bromine, or iodine (40 CFR 141.2).
18. Initial Compliance Period
The first full three year compliance period which begins at least 18 months after
promulgation, except for Dichloromethane, 1,2,4-Trichlorobenzene, 1,1,2-Trichloroethane,
Benzo(a)pyrene, Dalapon, Di(2-ethythexyl) adipate, Di(2-ethythexyl) phthalate, Dinoseb, Diquat,
Endrin, Endothall, Glyphosate, Hexachlorobenzene, Hexachlorocyclopentadiene, Oxamyl
(Vydate), Picloram, Simazine, 2,3,7,8,-TCDD (Dioxin), Antimony, Beryllium, Cyanide (as free
Cyanide), Nickel, and Thallium, the initial compliance period means the first full three year
compliance period after promulgation for systems with 150 or more service connections (January
1993 December 1995), and first full three year compliance period after the effective date of the
regulation (January 1996 December 1998) for systems having fewer than 150 service
connections (40 CFR 141.2).
19. Large Water System
In reference to lead and copper in systems, this refers to a water system that serves more
than 50,000 persons (40 CFR 141.2).
20. Lead Service Line
A service line made of lead which connects the water main to the building inlet and any lead
pigtail, gooseneck, or other fitting which is connected to such a lead line (40 CFR 141.2).
21. Legionella
A genus of bacteria, some species of which have caused a type of pneumonia called
Legionaries Disease (40 CFR 141.2).
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12-7
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22. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
23. Maximum Contaminant Level (MCL)
The maximum permissible level of a contaminant in water that is delivered to any user of a
public water system (40 CFR 141.2).
24. Maximum Contaminant Level Goal (MCLG)
Refers to the maximum level of a contaminant in drinking water at which no known or
anticipated adverse effect on the health of persons would occur, and which allows an adequate
margin of safety. MCLGs are nonenforceable health goals (40 CFR 141.2).
25. Maximum Total Trihalomethane Potential
Means the maximum concentration of total trihalomethanes produced in a given water
containing a disinfectant residual after seven days at a temperature of 25°C or above (40 CFR
141.2).
26. Medium Size Water System
In reference to lead and copper in systems, this refers to a water system that serves greater
than 3300 and less than or equal to 50,000 persons (40 CFR 141.2).
27. Near the First Service Connection
Means at one of the 20 percent of all service connections in the entire system that are nearest
the water supply treatment facility as measured by water transport time within the distribution
system (40 CFR 141.2).
28. Noncommunity Water System
A public water system that is not a community water system (40 CFR 141.2).
29. Nontransient, Noncommunity Water System
A public water system that is not a community water system and that regularly serves at least
25 of the same persons over six months per year (40 CFR 141.2).
30. Person
An individual, corporation, company, association, partnership, municipality, or state,
Federal, or tribal agency (40 CFR 141.2).
31. Picocurie (pCi)
Quantity of radioactive material producing 2.22 nuclear transformations/min (40 CFR
141.2).
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Drinking Water Management
12-8
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32. Point of Disinfectant Application
The point where the disinfectant is applied and water downstream of that point is not subject
to recontamination by surface water runoff (40 CFR 141.2).
33. Point-of-Entry Treatment Device
A treatment device applied to the drinking water entering a house or building for the purpose
of reducing contaminants in the drinking water distributed throughout the house or building (40
CFR 141.2).
34. Point-of-Use Treatment Device
A treatment device applied to a single tap used for the purpose of reducing contaminants in
drinking water at that one tap (40 CFR 141.2).
35. Public Water System
A system for providing piped water to the public for human consumption, if such system has
at least 15 service connections or regularly serves an average of at least 25 individuals daily at
least 60 days out of the year. This term includes:
• Any collection, treatment, storage, and distribution facilities under control of the operator of
such system, and
• Any collection or pretreatment storage facilities not under such control that are used
primarily in connection with such system.
A public water system is either a community water system or a noncommunity water system
(40 CFR 141.2).
36. Rem
The unit of dose equivalent from ionizing radiation to the total body or any internal organ or
organ system. A millirem (mrem) is 1/1,000 of a rem (40 CFR 141.2).
37. Residual Disinfectant Concentration
("C" in CT calculations) is the concentration of disinfectant measured in mg/L in a
representative sample of water (40 CFR 141.2).
38. Sanitary Survey
An onsite review of the water source, facilities, equipment, operation and maintenance of a
public water system for the purpose of evaluating the adequacy of such source, facilities,
equipment, operation and maintenance for producing and distributing safe drinking water (40
CFR 141.2).
39. Sedimentation
A process for removal of solids before filtration by gravity or separation (40 CFR 141.2).
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12-9
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40. Slow Sand Filtration
A process involving passage of raw water through a bed of sand at low velocity (generally
less than 0.4 m/hr (1.31 ft/hr)) resulting in substantial particulate removal by physical and
biological mechanisms (40 CFR 141.2).
41. Standard Sample
The aliquot of finished drinking water that is examined for the presence of coliform bacteria
(40 CFR 141.2).
42. State
The agency of the state or tribal government that has jurisdiction over public water systems.
During any period when a state or tribal government does not have primary enforcement
responsibility pursuant to Section 1413 of the SDWA (42 USC 300g-2), the term "state" means
the Regional Administrator of the EPA (40 CFR 141.2).
43. Supplier of Water
Any person who owns or operates a public water system (40 CFR 141.2).
44. Surface Water
All water that is open to the atmosphere and subject to surface runoff (40 CFR 141.2).
45. System with a Single Service Connection
A system which supplies drinking water to consumers via a single service line (40 CFR
141.2).
46. Total Trihalomethanes (TTHM)
The sum of the concentration in mg/L of the trihalomethane compounds rounded to two
significant figures (40 CFR 141.2).
47. Trihalomethane (THM)
One of the family of organic compounds, named as derivatives of methane, wherein three of
the four hydrogen atoms in methane are each substituted by a halogen atom in the molecular
structure (40 CFR 141.2).
48. Virus
Means a virus of fecal origin which is infectious to humans by waterborne transmission (40
CFR 141.2).
49. Waterborne Disease Outbreak
The significant occurrence of acute infectious illness, epidemiologically associated with the
ingestion of water from a public water system which is deficient in treatment, as determined by
the appropriate local or state agency (40 CFR 141.2).
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12-10
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F. Records To Review
• Bacterial and chemical analyses of drinking water, including sampling dates and locations,
dates of analyses, analytical methods used, and results of analyses
• Monthly operating reports (flow, chlorine residual, etc.)
• State and public notification of noncompliance with primary drinking water regulations
• Action taken by the facility to correct violations of primary drinking water regulations
• Sanitary surveys of the water system conducted by the installations/CW facility itself, a
private consultant, or any local, state, or Federal agency
• Public notification of noncompliance with secondary MCL for fluoride; and
• Variance or exemption granted to the facility for its water supply system.
G. Physical Features to Inspect
• Laboratory analysis facilities;
• Drinking water treatment facility; and
• Well sites.
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12-11
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H. Guidance For Checklist Users
Refer
Cfrwfclfci Items
Pagsffwabers
All Facilities
DW. 1 through DW 3
12-13
General Requirements
DW 4 through DW.6
12-14
Standards
DW 7 through DW.9
12-15
Monitoring/Sampling
DW 10
12-16
DW 11 through DW 12
12-17
DW.13
12-18
DW.14
12-19
DW 15
12-20
DW 16
12-21
DW.17
12-22
DW 18 through DW 19
12-23
DW 20 through DW 22
12-24
DW.23 through DW 24
12-25
DW.25 through DW.27
12-26
DW.28 through DW.29
23-27
Disinfecting and Filtration
DW 30
12-28
DW 31
12-29
DW 32 through DW 33
12-30
DW.34 through DW.35
12-31
DW.36 throug DW.37
12-32
Notification and Reporting
DW 38
12-32
DW.39 through DW 41
12-33
Lead and Copper in Drinking Water
DW 42 through DW 43
12-34
Systems
DW 44 through DW 46
12-35
DW 47 through DW 48
12-36
DW 49 through DW 50
12-37
DW 51 through DW.53
12-38
Sole Source Aquifer
DW 54
12-39
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12-12
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Compliance Category;
Driafeing Water Maeagemettt
Regulatory Requirements
[ Reviewer Checks
All Facilities
DW 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined. (A finding
under this checklist item will
have the enforcement
action/identifying information as
the citation.)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
DW 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained m this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding )
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued
regulations
DW 3 Facilities are required to
comply with state and local
drinking water regulations (EO
12088, Sect. 1-1 and 42 USC
300h-7(h))
Verify that the facility is abiding by state and water air quality requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include.
- More stringent contaminant level requirements certification and training
requirements
- Water system surveys
- Reporting requirements
- Monitoring frequency
- Use of groundwater
- Use and maintenance of wells
- Wellhead protection programs
- Cross connection control and backflow prevention
- 0 & M practices such as maintenance of a disinfectant residual throughout the
distribution system, proper maintenance of the distribution system, proper
disinfection of replaced or repaired mains, main flushing.)
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12-13
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Compliance Category*
Drinking Water Management
Regulatory Requirements
[ Reviewer Cbecfc*
General Requirements
DW.4. Facility must keep
records of actions taken to
correct or repair any part of the
treatment and distribution
system for at least three years
(40 CFR 141.33(b)).
Determine if facility or operational changes to the water system have taken place
since the previous review. Review map of complete potable water system.
Verify that as-built drawings are updated to reflect changes in water supply.
Determine if there have been operational changes by examining water system records.
Verify that water system records are maintained for at least three years.
Determine if there are recurring work programs, spare parts and supplies list,
equipment calibration and maintenance history records.
DW.5. Facilities are required to
survey public water systems
according to a specified
schedule and maintain records
of those reviews (40 CFR
141.21(d) and 141 33(c)).
Verify that non-community water systems which do not collect five or more routine
samples per month have undergone an initial sanitary survey by 29 June 1999 and are
than surveyed every five years thereafter
Verify that community water systems that collect less than five routine biological
samples per month are surveyed every five years since 29 June 1994.
(NOTE: Non-community water systems using only protected and disinfected
groundwater are only required to conduct a survey every 10 years after the initial
survey.)
Verify that records of sanitary system surveys are kept for 10 years.
Verify that the results of the sanitary surveys have been submitted to the state and
determine whether the state has requested an alternate monitoring frequency.
DW.6. All public water systems
shall install and operate optimal
corrosion control treatment
and/or comply with corrosion
control requirements specified
by the state (40 CFR 141.80(d)).
Verify that water systems are operating corrosion control systems and/or meeting state
requirements.
Phase 1 - Section 12
Drinking Water Management
12-14
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Coj&pli&wse Category
ifcrintdng Water Management
Regulatory Requirements
: Reviewer Checks-
Standards
DW.7 Community water
systems, except as defined under
exempted water systems in the
definitions, are required to meet
specific MCLs for inorganic and
organic chemicals, fluorides,
radium 226, radium-228, gross
alpha particle radioactivity, beta
particles and photon
radioactivity from man-made
radionuclides (40 CFR
141.11(a) through 141.11(c),
141.12,141.15, and 141.16(a)).
Verify that combined radium-226 and radium-228 do not exceed 5 pCi/L
Verify that gross alpha particle radioactivity does not exceed 15 pCi/L
Verify that the average annual concentration of beta particles and photon radioactivity
from man-made radionuclides does not produce an average dose rate equal to the total
body or any internal organ greater than 4 millirems/yr.
Verify that the MCL of 4.0 mg/L for fluoride is not exceeded.
Verify that the MCLs outlined in Appendix 12-1 and 14-2 are met.
DW.8. Non-community water
systems, except as defined under
exempted water systems, will
not exceed a MCL for nitrate of
10 mg/L (40 CFR 141.11(a)).
Verify that the nitrate level at non-community water systems does not exceed 10 mg/
L.
DW.9. Community and non-
transient, non-community water
systems, except as defined under
exempted water systems, are
required to meet specific MCLs
for organic contaminants,
inorganic contaminants and
microbiological contaminants
(40 CFR 141.60 through
141.63).
Verify that the standards outlined in Appendix 12-1 and 12-2 are met.
Verify that systems which collect at least 40 bacteriological samples per month have
no more than five percent of the samples collected during a month that are total
coliform positive.
Verify that systems which collect less than 40 bacteriological samples per month have
no more than one sample collected per month that is total coliform positive.
Verify that there are no fecal coliform-positive repeat sampling or E coli positive
repeat samples, or any total coliform-positive repeat samples following a fecal
coliform-positive or E coli-positive routine sample.
Phase 1 - Section 12
Drinking Water Management
12-15
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Coaijillaocs Category
: Drinking Water Management
Regulatory Requlremeats
i Reviewer <%eete
Monitoring/Sampling
DW.10. Facilities with
community water systems
and/or non-transient,
noncommunity water systems
are required to meet specific
monitoring requirements for
inorganic contaminants (40 CFR
141 23(a))
Verify that groundwater systems:
- Take a minimum of one sample at every entry point to the distribution system
which is representative of each well after treatment beginning in the compliance
period starting 1 January 1993
- Take each sample at the same sampling point unless conditions make another
sampling point more representative of each source or treatment plant.
Verify that surface water systems-
- Take a minimum of one sample at every entry pomt to the distribution system after
any application of treatment or in the distribution system at a point that is
representative of each source after treatment beginning in the compliance period
starting 1 January 1993
- Takes each sample at the same sampling point unless conditions make another
sampling point more representative of each source or treatment plant.
(NOTE. In relation to these requirements, surface water systems include systems with
a combination of surface and ground sources)
Verify that if the system draws water from more than one source and the sources are
combined before distribution, the system samples at an entry point to the distribution
system during periods of normal operating conditions.
(NOTE: The state may reduce the total number of samples which must be analyzed
by allowing the use of compositing. Composite samples from a maximum of five
sampling points are allowed if the detection limit of the method used for analysis is
less than one fifth the MCL and compositing is done in a laboratory.)
Verify that if the concentration in a composite sample is greater than or equal to one-
fifth of the MCL of any inorganic chemical, a follow-up sample is analyzed within 14
days from each sampling point included in the composite and analyzed for the
contaminants which exceeded one fifth of the MCL in the composite sample.
(NOTE Detection limits for each analytical methods and MCLs for each inorganic
contaminant are listed in Appendix 12-3.)
Verify that for groundwater systems, inorganic monitoring is repeated at least once
every compliance period (every three years), and samples are taken quarterly for at
least two quarters if a MCL is violated.
Verify that for surface water systems, inorganic sampling is repeated annually and
samples are taken quarterly for at least four quarters if a MCL is violated.
(NOTE: The state may issue a waiver reducing the required monitoring)
Phase 1 - Section 12
Drinking Water Management
12-16
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ComgJIa&ce Category;
Of inking Water Managtment
Regulatory Requirements
¦Reviewer Cbecta
DW.U. Facilities with
community and non-transient,
non-community water systems
are required to meet specific
monitoring requirements for
asbestos (40 CFR 141 23(b))
Verify that asbestos is monitored during the first three year compliance penod of each
nine year compliance cycle starting 1 January 1993
(NOTE The facility may apply to the state for a waiver of monitoring if they believe
that asbestos is not an issue)
Verify that if the system is vulnerable to asbestos contamination only because of
corrosion of asbestos-cement pipe, one sample is taken at a tap served by asbestos
cement pipe and under conditions where asbestos contamination is most likely to
occur
Verify that if the system is vulnerable to asbestos contamination due to both its source
water supply and corrosion of asbestos-cement pipe, one sample is taken at a tap
served by asbestos-cement pipe and under conditions where contamination is most
likely to occur
Verify that when the MCL is exceeded, monitoring is done quarterly
DW 12. Facilities with
community water systems
and/or non-transient,
noncommunity water systems
are required to meet specific
monitoring requirements for
antimony, barium, beryllium,
cadmium, chromium, cyanide,
fluoride, mercury, selenium, and
thallium (40 CFR 141 23(c))
Verify that monitoring is done as follows
- Groundwater systems take one sample at each sampling point every three years
- Surface water systems (or combined surface/ground) take one sample annually at
each sampling point
- When MCLs are exceeded, monitoring is done quarterly
Phase 1 - Section 12
Drinking Water Management
12-17
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1 Compl&oce Category!
Drinking Water Management
j BeguJatory Requirements
Reviewer Checks
DW. 13 All public water
systems are required to conduct
monitoring to determine
compliance for nitrate and nitrite
levels according to specific
parameters (40 CFR 141 23(d)
and 141 23(e))
Verify that the following schedules are met for monitoring of nitrate
- Community and non-transient, non-community water systems served by
groundwater monitor annually starting 1 January 1993
- Community and non-transient, non-community water systems served by surface
water monitor quarterly starting 1 January 1993
- Transient non-community water systems monitor annually starting 1 January 1993
Verify that when the MCL for nitrate are exceeded community and non-transient,
non-community water systems do repeat monitoring quarterly for at least one year
following any one sample in which the concentration exceeds more than SO percent of
the MCL
(NOTE. After the initial round of quarterly sampling is completed, each community
and non-transient non-community system which is monitoring annually shall take the
subsequent samples during the quarters which previously resulted in the highest
analytical result)
Verify that public water systems take one sample at each sampling point in the
compliance penod beginning 1 January 1993 and ending 31 December 1995 for
nitrite
(NOTE: After the initial sample, systems where an analytical result for nitrite is less
than 50 percent of the MCL will monitor at the frequency specified by the state.)
Verify that community, non-transient, non-community and transient non-community
systems repeat monitoring for nitrites quarterly for at least one year after any one
sample is greater than 50 percent of the MCL.
Verify that systems which are monitormg annually for nitrites take each subsequent
sample during the quarters which previously resulted in the highest analytical result.
Verify that when nitrate or nitrite samples indicate an exceedence of the MCL, a
confirmation sample is taken within 24 hours of receipt of the results.
(NOTE: If the system is unable to take a confirmation sample within 24 hours, it
must notify consumers of the exceedence)
Phase 1 - Section 12
Drinking Water Management
12-18
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Compllawe Category;
Drinking Water Management
Regulatory Requirements
Reviewer Checks
DW 14. Monitoring for endnn
is required to be done according
to specific schedules (40 CFR
141.24(a) through 141 24(d))
Verify that community water systems using surface water sources have completed
endrin analyses by 30 July 1993.
(NOTE For community water systems, samples will be taken during the time of the
year designated by the state as most likely for pesticide contamination and the
analyses repeated at intervals specified by the state but no less frequently than every
three years)
Verify that when the MCL is exceeded the state is notified within seven days and
three additional analyses are initiated within one month
Verify that when an average of four analyses exceeds the MCL level, the facility
reports to the state and gives notice to the public and continues to monitor at a
frequency designated by the state
(NOTE Instead of the initial analyses, data for surface water acquired within one year
prior to 30 July 1992 and data for groundwater acquired within three years of 30 July
1992 may be substituted at the discretion of the state.)
Phase 1 - Section 12
Drinking Water Management
12-19
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Compliance Categoryi
ftrinkinfc Water Management
Begwlatory Keqwiremeats
Reviewer Clecks
DW. 15 Beginning with the
initial compliance period,
monitoring of the contaminants
listed in Table 2 of Appendix
12-1 at community and
nontransient, non-community
water systems is required to be
done according to specific
parameters (40 CFR 141 24(f)).
Verify that groundwater systems take a minimum of one sample at every entry point
of the distribution system which is representative of each well after treatment.
Verify that surface water systems (or combined surface/ground) take a minimum of
one sample at points in the distribution system that are representative of each source
or at each entry point to the distribution system after treatment
(NOTE For both groundwater and surface water systems, each sample must be taken
at the same sampling point unless conditions make another sampling point more
representative of each source, treatment plant, or within the distribution system)
Verify that if the system draws water from more than one source and the sources are
combined before distribution, the system samples at an entry point to the distribution
system during periods of normal operating conditions
Verify that each community and non-transient non-community water system takes
four consecutive quarterly samples for each contaminant, except vinyl chlorides
(NOTE: If the initial monitoring for contaminants is completed by December 1992
and none of the contaminants listed are found, then each system shall take one sample
annually starting with the initial compliance period )
(NOTE- After a minimum of three years of sampling, the state may reduce the
number of samples to one each compliance period )
Verify that if a contaminant, except vinyl chloride, is detected at a level exceeding
0 0005 mg/L in any sample, the system monitors quarterly at each sampling point
which resulted in a detection.
Verify that groundwater systems which have detected one or more of the following
two-carbon organic compounds, trichloroethylene, tetrachloroethylene, 1,2-
dich loroethane, 1,1,1 -trichloroethane, cis-1,2-dichloroethy lene, trans-1,2-
dichloroethylene, or 1,1-dichloroethylene monitor quarterly for vinyl chlorides at
each sampling point at which one or more of the two-carbon organic compounds was
detected
Verify that when the MCLs are exceeded, monitoring is conducted quarterly until the
state determines that the system is reliably and consistently below the MCL
Phase 1 - Section 12
Drinking Water Management
12-20
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CojitjpgtetKg Category
Or inking WaterManagement
Repertory Bcqoircments
Reviewer
DW 16 Monitoring for organic
contaminants listed in Table 3 of
Appendix 12-1 at community
water systems and non-transient,
noncommunity water systems is
required to be done according to
specific parameters (40 CFR
141 24(h))
Verify that groundwater systems take a minimum of one sample at every entry point
to the distribution system which is representative of each well after treatment.
Verify that surface water systems (or surface/ground) take a minimum of one sample
at points in the distribution system that are representative of each source or at each
entry point to the distribution system after treatment
(NOTE' For both groundwater and surface water systems, each sample must be taken
at the same sampling point unless conditions make another sampling point more
representative of each source, treatment plant, or within the distribution system )
Verify that if the system draws water from more than one source and the sources are
combined before distribution, the system samples at an entry point to the distribution
system during periods of normal operating conditions.
Verify that each community and non-transient, non-community water system takes
four consecutive quarterly samples for each contaminant during each compliance
period starting 1 January 1993
(NOTE Systems serving more than 3,300 persons which do not detect a contaminant
in the initial compliance period may reduce sampling to two quarterly samples in one
year during each repeat compliance period.)
(NOTE Systems serving less than or equal to 3,300 person that do not detect a
contaminant in the initial compliance period may reduce sampling to one sample
during each repeat compliance period.)
Verify that when an organic contaminant is detected (see Appendix 12-4), the system
monitors quarterly at each sampling point that resulted in a detection
Verify that if monitoring results in detection of one or more of aldicarb, aldicarb
sulfone, aldicarb sulfoxide, and heptachlor, heptachlor epoxide then subsequent
monitoring analyzes for all related contaminants
(NOTE The state may reduce the number of samples required and/or the frequency
of sampling.)
Phase 1 - Section 12
Drinking Water Management
12-21
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Compliance Category:
Drinking Water Management
Regulatory Requiremwts
Reviewer Checks
DW.17. Community and non-
transient, noncommunity water
systems are required to monitor
for specific organic and
inorganic contaminants (40 CFR
141.35 and 141 40(a) through
141.40(m))
Verify that monitoring is being done for the following contaminants. Chloroform;
Bromodichloromethane; Bromoform, Chlorodibromomethane, Chlorobenzene; m-
Dichlorobenzene; 1,1-Dichloropropene, 1,1-Dichloroethane; 1,1,2,2-
Tetrachloroethane, 1,3-Dichloropropane; Chloromethane, Bromomethane, 1,2,3-
Trichloropropane, 1,1,1,2-Tetrachloroethane, Chloroethane, 2,2,-Dichloropropane; o-
Chlorotoluene, p-Chlorotoluene; Bromobenzene, 1,3-Dichloropropene
Verify that surface water systems sample at points in the distribution system that are
representative of each water source or at entry point to the distribution system after
any application of treatment
Verify that for surface water systems, the minimum number of samples taken is one
year of quarterly samples per water system.
Verify that groundwater systems sample at points of entry to the distribution system,
representative of each well after any application of treatment.
Verify that for groundwater systems the minimum number of samples taken is one
sample taken per entry point to the distribution system.
Verify that initial monitoring was done by the dates specified in the following, and
that all community and non-transient, non-community water systems repeat the
monitoring every five years after the specified dates:
Number of persons served
Over 10,000
3300 to 10,000
less than 3300
Monitoring to Begin No Later Than:
1 January 1988
1 January 1989
1 January 1991
(NOTE: Public water systems may use monitoring data collected any time after 1
January 1983 to meet the requirements for unregulated monitoring, provided the
monitoring program was consistent with these requirements. Additionally the results
of EPA's Groundwater Supply Survey may be used in a similar manner for systems
supplied by a single well.)
(NOTE: The state may require monitoring of additional contaminants.)
(NOTE: Instead of doing the monitoring required here, a community water system or
non-transient, non-community water system serving fewer than 150 service
connections may send a letter to the state by 1 January 1991 stating that the system is
available for sampling.)
Verify that the facility notifies the systems users of the availability of the results of
sampling.
Verify that the facility sends copies of the monitoring results within 30 days after
public notification
Phase 1 - Section 12
Drinking Water Management
12-22
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Compliance Category!
thinking 'Waier Management
Regulatory Requirements
Reviewer Check*
DW. 18 Monitoring of specific
contaminants must be completed
by 31 December 1995 (40 CFR
141 35 and 141.40(n))
Verify that the substances listed in Appendix 12-5 are monitored for by 31 December
1995
Verify that each community and non-transient, non-community water systems takes
four consecutive quarterly samples for the unregulated organic contaminants listed in
Appendix 12-5 at each sampling point and reports the results to the state
Verify that each community and non-transient non-community water system takes one
sample at each sampling points for the unregulated inorganic compounds listed in
Appendix 12-5 and reports the results to the state
Verify that groundwater systems take a minimum of one sample at every entry point
to the distribution system which is representative of each well after treatment and that
each sample is taken from the same sampling point unless conditions make another
sampling point more representative of each source or treatment.
Verify that surface water systems, including systems with a combination of surface
and ground sources, take a minimum of one sample at points in the distribution
system that are representative of each source or at each entry pomt to the distribution
system after treatment and that each sample is taken from the same sampling point
unless conditions make another sampling point more representative of each source or
treatment
Verify that if the system draws water from more than one source and the sources are
combined before distribution, the system samples at the entry pomt to the distribution
system during periods of normal operating conditions
Verify that the facility notifies the systems users of the availability of the results of
sampling.
Verify that the facility sends copies of the monitoring results within 30 days after
public notification.
DW. 19 Community water
systems, except as defined as
exempted water systems, are
required to monitor for total
coliforms at a frequency based
on the population served by the
system (40 CFR 141.21(a)(2)).
Verify that the facility's community water systems is sampling according to the
schedule in Appendix 12-6
Phase 1 - Section 12
Drinking Water Management
12-23
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C&mpltow* Category?
Drinking Water Management
Regulatory Requirements
; Be vtewer decks
DW.20. Non-community water
systems, except as defined under
exempted water systems, are
required to monitor for total
coliforms according to a specific
schedule (40 CFR 141 21(a)(3)).
Verify that non-community water systems using only groundwater (except
groundwater under the direct influence of surface water) and serving 1,000 persons or
less, monitors each calendar quarter the system provides water to the public.
Verify that the following non-community water systems are monitoring for total
coliforms according to the schedule outlined in Appendix 12-6°
- Systems using only groundwater (except groundwater under the direct influence of
surface water) and serving more than 1,000 persons during any month
- Systems using surface water, in total or in part
- Systems using groundwater under the direct influence of surface water
DW.21. Total coliform samples
are required to be collected at
regular time intervals
throughout the month except at
system which use only
groundwater and serves 4,900
person or fewer (40 CFR
141 21(a)(4)).
Verify that total coliform samples are collected at regular intervals.
(NOTE: Systems which use groundwater (except groundwater under the influence of
surface water) and serves 4,900 persons or fewer may collect all required samples on
a single day if they are being taken from different sites.)
DW.22. Public water systems
that use surface water or
groundwater under the direct
influence of surface water that
do not practice filtration are
required to collect at least one
total coliform sample near the
first service connection each day
the turbidity level of the source
water exceeds 1 NTU (40 CFR
141 21(a)(5))
Verify that when the turbidity exceeded 1 NTU, total coliform samples were taken
within 24 hours of the first exceedence by reviewing the records on turbidity levels
Phase 1 - Section 12
Drinking Water Management
12-24
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Compliance Category:
! £hriakmg Water Management
Hegwtetory Requirements
Reviewer Checks
DW.23. When a routine sample
is total cohform-positive, the
public water system must collect
a set of repeat samples within 24
hours of being notified of the
positive result (40 CFR
141.21(b)(1) through
141 21(b)(4), and 141 21(e)(1))
Verify that if more than one routine sample per month is collected, at least three
repeat samples are taken for each total cohform-positive sample found
Verify that if one or less routine sample per month is collected, no less than four
repeat samples are collected for each total cohform-positive sample found
Verify that at least one of the repeat samples is collected from the sampling tap where
the original total coliform positive sample was taken
Verify that at least one repeat sample was taken at a tap within five service
connections upstream and at least one repeat sample at a tap within five service
connections downstream of the original sampling site.
Verify that the sampling process is repeated until either total coliforms are not
detected in one complete set of repeat samples or the system determines that the MCL
for total coliforms is exceeded and the state is notified
Verify that all repeat samples are collected on the same day
Verify that if one or more of the repeat samples is total cohform-positive, an
additional set of repeat samples is collected within 24 hours of notification of the
positive result
Verify that if a repeat sample is total cohform-positive it is also analyzed for fecal
coliforms
(NOTE. The system may test for E coll instead of fecal coliforms)
DW 24 Sampling for turbidity
is required to be done at public
water systems which must install
filtration according to a specific
schedule until the time at which
the systems installs filtration (40
CFR 141 22)
Verify that suppliers of water for both community and non-community water systems
sample for turbidity at a representative entry point to the water distribution system at
least once daily
Verify that when the turbidity levels are exceeded immediate resampling is done
Verify that the state is notified within 48 hours
(NOTE These systems must monitor for turbidity according to 40 CFR 141 73 and
141 74)
Phase 1 - Section 12
Drinking Water Management
12-25
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: DrinkingWater Management
Begutotory Requirements
Reviewer Check?
DW 25 Facilities are required
to monitor for radioactivity in
community water systems (40
CFR 141.26).
Verify that compliance for standards of gross alpha particle activity, radium-226 and
radium-228 are based on an annual composite of four consecutive samples that are
obtained at quarterly intervals or the average of the analyses of four samples obtained
at quarterly intervals
(NOTE- A gross alpha particle activity measurement may be substituted for the
required radium-226 and radium-228 analysis if the measured gross alpha particle
activity does not exceed 5 pCi/L at a confidence level of 95 percent)
Verify that when the gross alpha particle activity exceeds 5 pCi/1 the same or an
equivalent sample is analyzed for radium-226 and if the concentration of radium-226
exceeds 3 pCi/L, the same or equivalent sample is analyzed for radium-228.
Verify that suppliers of water monitor for gross alpha particle activity, radium-226
and radium-228 every four years and within one year of the introduction of a new
water source for a community water system
(NOTE The state has the power to order additional samples, waive required samples
and impose additional requirements.)
Verify that if the MCL for gross alpha particle activity or total radium is exceeded and
the facility is the supplier of a community water system, the installation notifies the
state and the public of the exceedence
Verify that systems using surface water sources and serving more than 100,000
persons are initially monitored quarterly for compliance with man-made radioactivity
limitations and after the initial analysis, monitoring is done at least every four years
Verify that suppliers of any community water system using waters contaminated by
nuclear facilities initiate quarterly monitoring for gross beta particle and iodine-131
radioactivity and annual monitoring for strontium-90 and tritium.
DW.26 Facilities with
community water systems that
add a disinfectant to the water
are required to analyze for
TTHM (40 CFR 141 30)
(NOTE: The minimum number of samples that is required is based on the number of
treatment plants used by the system )
Verify that community water systems serving a population of 10,000 or more
individuals that adds a disinfectant to the water and uses surface water sources or only
groundwater sources analyze for total TTHM on a quarterly basis on at least four
samples
DW.27. Suppliers of water for
community public water systems
are required to analyze for
sodium (40 CFR 141 41)
Verify that one sample is taken per plant at the entry point of the distribution system
annually for systems using surface water in whole or in part and every three years for
systems using solely groundwater sources
Verify that the results of the sampling were reported to the EPA and/or state within 10
days following the end of the required monitoring period or within the first 10 days of
the month following the month in which the sample was taken.
Phase 1 - Section 12
Drinking Water Management
12-26
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Owgrfteott category!
Dr inkingWater Management
Regulatory Requirements
Reviewer decte
DW 28 Suppliers of water for
community water systems shall
collect samples from
representative entry points to the
water distribution system and
analyze for corrosivity (40 CFR
141 42)
Verify that the supplier collects two samples per plant for analyses for each plant
using surface water sources wholly or in part
Verify that the samples are taken one in mid-winter and one during mid-summer
Verify that one sample per plant is collected for each plant using groundwater
sources
(NOTE Determination of corrosivity includes measurement of pH, calcium,
hardness, alkalinity, temperature, total dissolved solids, and calculation of the
Langelier Index)
Verify that the results for the analyses of corrosivity are reported to the EPA and/or
state within the first 10 days of the month following the month in which the sample
results were received
(NOTE The state might require monitoring for additional parameters which may
indicate corrosivity, such as sulfates and chlorides)
DW.29 Analysis for inorganic
chemicals volatile organic
contaminants, pesticides, and
bacteria to determine
compliance with MCLs must be
performed in a state-approved
laboratory or by a state-
approved individual (40 CFR
141.23(k)(5), 141 24(f)(17),
141.24(l)(l 9), and 141.28).
Verify that laboratory is approved by reviewing documentation of state certification
for laboratory analysis
Phase 1 - Section 12
Drinking Water Management
12-27
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Category:
Drinking Water Management
Begufetory ftequfrenttttts
Reviewer Cbecte
Disinfection And Filtration
DW.30 Facilities that have a
public water system that uses
surface water sources or
groundwater sources under
direct influence of a surface
water source must provide
filtration as a treatment
technique for microbiological
contaminants unless certain
criteria are met (40 CFR
141.71(a) and 141 71(b))
(NOTE. Public water systems that use a groundwater source under the direct
influence of surface water are not required to meet these conditions to avoid filtration
until 18 months after the state has determined that the system is under the direct
influence of surface water.)
Verify that filtration of drinking water is performed unless all of the following
conditions for surface water are met*
- The fecal coliform concentration is less than or equal to 20/100 mL or total
coliform concentration is equal to or less than 100/100 mL in representative
samples of the source water immediately prior to the first or only point of
disinfectant application in at least 90 percent of the measurements made in the last
six months that the system served water to the public on an ongoing basis
- The turbidity level does not exceed 5 NTU in representative samples of the source
water immediately prior to the first or only point of disinfectant application the
unless state determines otherwise and there has not been more than two events in
the past 12 months the system served water to the public or more than five events in
the past 120 months the system served water to the public
Verify that filtration of drinking water is done unless all the following site specific
conditions are met*
- Meets the requirements of 40 CFR 141 72(a)(1) for disinfection treatment of
Giardia lamblia for at least 11 of the 12 previous months
- Meets 40 CFR 141 72(a)(2) through 141 72(a)(4) at all times
- Maintains a watershed control program for Giardia larnblia in the source water,
including.
identification of watershed characteristics
monitoring occurrence of activities that have adverse effects
demonstrates through ownership and/or written agreements that the control of
adverse effects of human activities are regulated
submits annual reports to the state
subject to annual onsite inspection by the state or a party approved by the
state, to assess watershed control program
has not been identified as a source of waterborne disease or threat or has been
modified sufficiently to prevent recurrence
- Complies with MCL for total coliforms as defined in 40 CFR 141 63 for at least 11
of the previous 12 months (see Appendix 12-1)
- Complies with requirements for trihalomethanes as listed on 40 CFR 141 12 and
141 13 (see Appendix 12-1)
Phase 1 - Section 12
Drinking Water Management
12-28
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OtmgrffotKe Categoxyj
thfa&sg Wa&ir Management
Regulatory Requirements
Reviewer Cbecta
DW 31. Systems that do not
meet the criteria necessary for
exclusion from nitration for
public water systems that use a
surface water source or a
groundwater source under the
direct influence of surface water
must provide filtration that
meets specific standards by 29
June 1993, or within 18 months
after being required to provide
filtration, whichever is later (40
CFR 141.73 and 141.74(c)(2)).
Verify that if conventional or direct filtration is used the following are met-
- A turbidity level of 0 5 NTU or less in 95 percent of measurements taken each
month
- The turbidity level of representative samples of filtered water at no time exceeds 5
NTU
Verify that if slow sand filtration is used the following are met:
- The turbidity level of representative samples of a systems filtered water is 1 NTU or
less in 95 percent of the monthly measurements
- The turbidity level of representative samples of a systems filtered water at no time
exceeds 5 NTU
Verify that if diatomaceous earth filtration is used the following is met.
- The turbidity level of representative samples of a systems filtered water is less than
or equal to 1 NTU in at least 95 percent of the measurements taken each month
- The turbidity level of representative samples of a systems filtered water at no time
exceeds 5 NTU.
Verify that if other filtration technologies are used, they have been approved by the
state
Verify that, starting 29 June 1993, or when filtration is installed, turbidity
measurements are performed on representative samples of the systems filtered water
every four hours that the system serves water to the public.
Verify that as of 29 June 1993, or whenever filtration is installed, the residual
disinfectant concentration of water entering the distribution system is monitored
continuously and the lowest value recorded each day
Verify that if there is a failure in the continuous monitoring equipment, grab sampling
is done every four hours
(NOTE Grab sampling can be done for no more than five working days following
the failure of the continuous monitoring system )
(NOTE Systems serving 3300 or fewer person can use grab sampling instead of
continuous monitoring if the following daily frequencies are met
System size by population Samples/day
500 or less 1
501 to 1,000 2
1,001 to 2,500 3
2,501 to 3,300 4
Verify that any time the residual disinfectant concentration falls below 0 2 mg/L in a
system using grab sampling, the system takes a grab sample every four hours until the
residual disinfectant concentration is equal to or greater then 0.2 mg/L
Verify that the residual disinfectant concentration is measured at least at the same
points in the distribution system and at the same time as total coliforms are sampled.
Phase 1 - Section 12
Drinking Water Management
12-29
-------
Compltotto! Category:
l>ri&kmg Water Management
Keplatory Requirements
Reviewer Checks
DW 32. Facilities with publtc
water systems that use a surface
water source or a groundwater
source under direct influence of
a surface water source that is not
required to provide filtration are
required to provide disinfection
treatment by 30 December 1991
(40CFR 141 72(a))
Verify that the following requirements for disinfection are met:
- It ensures 99.9 percent (3-log) inactivation of Giardia lamblia cysts every day
except for once per month by meeting the required CT applicable to the systems
particular drinking water parameters as outlmed in 40 CFR 141.74
- It ensures 99 99 percent (4-log) inactivation of virus every day except for once per
month by meeting the required CT applicable to the systems particular drinking
water parameters as outlined in 40 CFR 343 74
- The CT values are calculated daily as specified in 40 CFR 141.74(b)(3)
- Throughout the disinfection system there is either
automatic startup and alarm for insuring continuous disinfection application
while water is delivered through the distribution system
automatic shutoff when there is less than 0.2 mg/L residual disinfectant
- The residual disinfectant concentration in water entering distribution system is not
less than 0.2 mg/L for more than four hours
- The residual disinfectant concentration, measured as total chlorine, combined
chlorine, or chlorine dioxide is not undetectable in more than 5 percent of samples
each month for more than two consecutive months.
(NOTE: Water in a distribution system with a heterotrophic bacteria concentration
less than or equal to 500 mL, measured as Heterotrophic Plate Count (HPC) is
deemed to have a detectable disinfectant residual.)
DW.33. Facilities with public
water systems that use a surface
water source or a groundwater
source under direct influence of
a surface water source that
provide filtration or that are
required by the state to install
filtration must meet specific
disinfection requirements by 29
June 1993 or within 18 months
of being required to install
filtration (40 CFR 141.72(b) and
141.73).
Determine if the facility provides filtration for drinking water
Verify that the following requirements for disinfection are provided:
- It ensures 99.9 percent (3-(og) inactivation of Giardia lamblia cysts
- It ensures 99.99 percent (4-log) inactivation of viruses
- The residual disinfectant concentration in water entering distribution system is not
less than 0.2 mg/L for more than four hours.
- The residual disinfectant concentration throughout the distribution system is not
undetectable in more than five percent of samples each month for any two months
the system serves water to the public
- Analytical methods as specified in 40 CFR 141.74 are used to demonstrate
compliance with the requirements for filtration and disinfection.
(NOTE- Systems which filter are given an inactivation credit dependant on the type
of filtration used.)
Phase 1 - Section 12
Drinking Water Management
12-30
-------
Compliance Category:
Drinking Water Management
Kegwl«tory Requirements
Reviewer Checks
DW.34 Facilities with public
water systems that use a surface
water source and do not provide
filtration are required to report
specific information monthly to
the state beginning 31 December
1990 (unless the state has
determined that filtration is not
required) until filtration is in
place (40 CFR 141 75(a))
Verify that the following listed information is reported to the state at the indicated
times:
- Source drinking water information within 10 days after the end of each month the
system serves water to the public
- Disinfection information within 10 days after the end of each month the system
serves water to the public
- A report summarizing compliance with all watershed control programs no later than
10 days after the end of each Federal Year (FY)
- A report on the onsite inspection conducted during that year, unless it was
conducted by the state, no later than 10 days after the end of the Federal FY
- The occurrence of a waterbome disease outbreak potentially attributable to that
water system as soon as possible, but no later than by the end of the next business
day
- When turbidity exceeds 5 NTU, as soon as possible, but no later than the end of the
next business day
- Any time the residual falls below 0 2 mg/L in the water entering the distribution
system as soon as possible, but no later than by the end of the next business day.
(NOTE See the complete text of 40 CFR 141 75(a) for more details on how this
information is to be reported )
DW 35. Facilities with public
water systems that use a
groundwater source under the
direct influence of surface water
and does not provide filtration
treatment must report specific
information to the state monthly
starting 31 December 1990, or
six months after the state
determines that the groundwater
source is under the direct
influence of surface water,
whichever is later (40 CFR
141.75(a)).
Verify that the following listed information is reported to the state at the indicated
times.
- Source drinking water information within 10 days after the end of each month the
system serves water to the public
- Disinfection information within 10 days after the end of each month the system
serves water to the public
- A report summarizing compliance with all watershed control programs no later than
10 days after the end of each Federal FY
- A report on the onsite inspection conducted during that year, unless it was
conducted by the state, no later than 10 days after the end of the Federal FY
- The occurrence of a waterbome disease outbreak potentially attributable to that
water system as soon as possible, but no later than by the end of the next business
day
- When turbidity exceeds 5 NTU, as soon as possible but no later than the end of the
next business day
- Any time the residual falls below 0.2 mg/L in the water entenng the distribution
system as soon as possible, but no later than by the end of the next business day
(NOTE: See the complete text of 40 CFR 141.75(a) for more details on how this
information is to be reported.)
Phase 1 - Section 12
Drinking Water Management
12-31
-------
Category:
Drinking WaterManagtment
Regulatory Requirements
; Bevtewer-Olecte
DW 36. Facilities with public
water systems that use a surface
water source or a groundwater
source under the direct influence
of surface water that provide
filtration must report specific
information monthly to the state
starting 29 June 1993 or when
filtration is installed, whichever
is later (40 CFR 141 75(b))
Verify that by 29 June 1993, or whenever filtration is installed, the following
information is provided to the state in the indicted time frame*
- Turbidity measurements within 10 days after the end of each month the system
serves water to the public
- Disinfection information within 10 days after the end of each month the system
serves water to the public
- Notice of an occurrence of a waterbome disease outbreak, as soon as possible but
no later than by the end of the next business day
- When the turbidity exceeds 5 NTU, as soon as possible, but no later than the end of
the next business day
- Any time the residual falls below 0 2 mg/L in the water entering the distribution
system, as soon as possible, but no later than by the end of business the next day
(NOTE: See the complete text of 40 CFR 141 75(b) for more details on how this
information is to be reported)
DW.37 EPA has set certain
standards for analytic
procedures that must be used
and followed to demonstrate
compliance with disinfection
and filtration requirements (40
CFR 141.74)
Verify that analytic methods as specified in 40 CFR 141 74 are used to demonstrate
compliance with the requirements for filtration and disinfection
Notification and Reporting Requirements
DW 38 Public water systems
are required to maintain on the
premises, or at a convenient
location specific records (40
CFR 141.33(a), 141 33(b) and
141.33(d))
Verify that records of bacteriological analyses are kept for a minimum of five years.
Verify that records of chemical analyses are kept for a minimum of 10 years.
Verify that records of actions taken to correct violations of primary drinking water
regulations are kept for a minimum of three years after the last action taken for a
particular violation.
Verify that records concerning a variance or exemption granted to the system are kept
for a period ending not less than five years following the expiration of the variance or
exemption.
Phase 1 - Section 12
Drinking Water Management
12-32
-------
Compliance Caiepryi
i Drinking Water Management
; Regtttetory Requirements
'Reviewer Clecta -
DW.39 When primary drinking
water standards are exceeded,
public notifications must be
made (40 CFR 141 32)
Verify that tf there was an excess, the following public notification procedures were
followed
- Notices were placed in a daily newspaper of general circulation in the area served
by the system as soon as possible, but no later than 14 days after the violation or
failure
- Notices were placed in a weekly newspaper of general circulation if there is no
daily newspaper
- Notices were issued by mail delivery, by direct mail or with the water bill, or by
hand delivery within 45 days after the violation or failure.
(NOTE The state may waive mail or hand delivery if it is determined that the
violation or failure is corrected within the 45 day period.)
Verify that if it was an acute violation, the public radio and TV stations were notified.
Verify that if public notification was made, it was made according to EPA guidelines
Verify that following the initial notice, additional notice is given at least once every
three months by mail delivery, or by hand delivery, for as long as the violation exists
(NOTE- Instead of the requirements outlined here, community water systems in an
area that is not served by a daily or weekly newspaper of general circulation must
give notice by hand delivery or by continuous posting in conspicuous places within
the area served by the system. Notice must be given within 72 hours for acute
violations and 14 days for other violations )
DW 40. Community water
systems that exceed the
secondary MCL of 2.0 mg/L for
fluoride but not the MCL of 4 0
mg/L are required to notify
specific individuals (40 CFR
143.5)
Verify that notice has been provided to the following
- All billing units annually
- All new billing units at the time service begins
- The state public health officer
(NOTE A copy of the text of the notice is found in 40 CFR 243.5(b))
DW 41 Facilities that operate
public water systems must send
reports to the state on any failure
to comply with applicable
biological, turbidity,
radioactivity, and chemical
standards, and on any failure to
comply with monitoring
requirements that apply (40 CFR
141 31)
Verify that, in general, reports are sent within the first 10 days following the month in
which the result is received or the first 10 days following the end of the required
monitoring period whenever standards are not met
Verify that the facility reported failure to comply with any national primary drinking
water regulations to the state within 48 hours.
Phase 1 - Section 12
Drinking Water Management
12-33
-------
CompHtewe Category:
Drinking Water Management
1 Regulatory Requtrcm«#fc
Lead and Copper in Drinking Water Systems 1
DW.42. The use of pipe, solder,
or flux that contains lead is not
allowed in specific situations
(40 CFR 141.43(a)(1) and
141.43(d)).
Verify that lead pipe, solder, or flux is not used in the installation or repair of either of
the following:
- Any public water system
- Any plumbing in a residential facility providing water for human consumption
which is connected to a public water system
(NOTE This does not apply to leaded joints necessary for the repair of cast iron
pipes)
(NOTE: Lead-free is defined as not more than 0.2 percent content for solders and
flux and not more than 8 0 percent lead in reference to pipes and pipe fittings.)
DW 43. Community waters
systems and each non-transient,
non-community water systems
were required to issue a notice
by 19 June 1988 to persons
served by the system that might
be affected by lead
contamination (40 CFR 141.34
and 141.43(a)(2)).
Verify that the notice was issued by one of the following methods:
- Three newspaper notices
- A notice included with the water bill
- A hand delivered notice
(NOTE For non-transient, non-community water systems notice may be given by
continuous posting.)
(NOTE: The notice is not required if the system can demonstrate to the state that the
water system, including the non-residential and residential portion connected to the
water system, are lead free )
(NOTE- Notice must be provided even if there is no violation of the national primary
drinking water standards The required wording of the notice is outlined in 40 CFR
141.34)
Phase 1 - Section 12
Drinking Water Management
12-34
-------
Compliance Category-.
Ih-i&femg Water Management
Regulatory Requirements
Reviewer Checks
DW.44. Facilities with
community or non-transient,
non-community water systems
must notify their users about
lead in drinking water systems
(40 CFR 141 85 and 141 91(0)
Verify that public education materials are distributed in the following manner when a
water system exceeds the lead action level based on tap water samples'
- The material is in the appropriate languages where languages other than English are
spoken by a significant proportion of the population
- Within 60 days after exceeding the lead action level
notices are insert in each customer's water utility bill
information is provided to the editorial departments of the major daily and
weekly newspapers circulated in the community
pamphlets or brochures are delivered to pertinent facilities, organizations,
schools and medical centers
public service announcements are submitted to at least five of the radio and
television stations broadcasting to the community
Verify that the notification tasks are repeated every six months for as long as a
community water system exceeds the lead action level
Verify that a non-transient, non-community water system delivers the public
education materials by posting informational posters and distributing brochures
Verify that a non-transient, non-community water system repeats distribution of
information at least once each calendar year in which the system exceeds the lead
action level
(NOTE The text of written materials and broadcast materials can be found in 40
CFR 141 85(a) and 141 85(b))
Verify that by December 31st any water system that has had to issue public education
materials submits a letter to the state indicating that the system has delivered the
public education materials as required each year that the levels are exceeded
DW 45. Community water
systems and nontransient, non-
community water systems are
required to meet specific
standards for lead and copper
action levels and reporting
requirements when these levels
are exceeded (40 CFR
141.80(a)(1), 141 80(c),
141 80(e), 141 86(b) and
141 90(e))
Verify that the concentration of lead does not exceed 0 015 mg/L in more than 10
percent of tap water samples collected during any monitoring period.
Verify that the concentration of copper does not exceed 1 3 mg/L in more than 10
percent of tap water samples collected during any monitoring period
DW 46. All water systems are
required to install and operate
optimal corrosion control (40
CFR 141.80(d))
Verify that the water system has corrosion control that minimizes the lead and copper
concentrations at users' taps while insuring that the treatment does not cause the water
system to violate any of the national primary drinking water standards
(NOTE See 40 CFR 181 and 40 CFR 183 for design details for corrosion control
systems in relationship to the size of the water system )
Phase 1 - Section 12
Drinking Water Management
12-35
-------
Compliance Category! , ,
XhrinkingWater M&Q4&tttent
Rotatory »equlrcm«ots
DW.47. Systems that exceed
the lead or copper action level
are required to implement
applicable source water
treatment standards (141 80(e)
and 141 83).
Verify that systems exceeding the lead or copper action level do lead and copper
source water monitoring and make a treatment recommendation to the state within six
months after exceeding the lead or copper action rate.
Verify that if the state requires the installation of source water treatment, the
installation is done within 24 months after the state's initial response.
Verify that follow-up tap water monitoring and source water monitoring is completed
within 36 months after the states initial response.
DW 48. Facilities with water
systems exceeding the lead
action level after
implementation of corrosion
control and source water
treatment requirements are
required to replace lead service
lines (40 CFR 141.80(f) and
141 84).
Verify that lead service line replacement is done according to the schedules and
parameters outlined in 40 CFR 141.84.
(NOTE A system is not required to replace an individual lead service line if the lead
concentration in all service line samples from that line is less than 0.0IS mg/L.)
(NOTE: Replacement of lead service lines can stop when the first draw samples that
are collected meet the lead action levels during two consecutive monitoring periods
and the system submits the results to the state.)
Phase 1 - Section 12
Drinking Water Management
12-36
-------
Compliance Category*
Drinking Water Management
i Regulatory Beq»irem«#fef
Reviewer Checks
DW.49. Monitoring for lead
and copper is required to start on
a specified date and be done at a
specified number of sites
according to the chart in
Appendix 12-7 (40 CFR
141 80(g), 141 86(a)(1),
141.86(c), and 141.86(d)).
Verify that sample sites have been selected and sampling started as of the dates
indicated in Appendix 12-7.
Verify that monitoring is done according to the schedules outlined in 40 CFR 141.86
and as required by the state
Verify that the procedures for sampling and granting of variances found in 40 CFR
141 86 are followed.
Verify that for the initial tap sample, all large water systems monitor during two
consecutive six month periods and all small and medium-size water systems monitor
during each six month period until
- The system exceeds the lead or copper action levels and is then required to
implement corrosion control treatment
- The system meets the lead and copper action levels during two consecutive six
month monitoring periods.
(NOTE: A small or medium-sized water system that meets the lead and copper action
levels during each of two consecutive six month monitoring periods can reduce the
frequency of sampling to once a year If action levels are met during three consecutive
years of monitoring, the frequency may be reduced to once every three years.)
Verify that for monitoring after the installation of corrosion control and source water
treatment, large systems with optimal corrosion control by 1 January 1997 monitor
during two consecutive six month periods by 1 January 1988
Verify that for monitoring after the installation of corrosion control and source water
treatment, small or medium-size systems that install optimal corrosion control within
24 months after being required to do so by the state, monitor during two consecutive
six month periods within 36 months after being required to install optimal corrosion
control treatment.
Verify that for monitoring after the installation of corrosion control and source water
treatment required by the state, all systems that install state required systems monitor
during two consecutive months within 36 months after the initial state requirement
Verify that after the state has specified drinking water parameter values for optimal
corrosion control that monitoring is done during each subsequent six month
monitoring period beginning when the state specified the optimal values
DW 50. All large water systems
and all small and medium size
systems that exceed the lead or
copper action level are required
to monitor for drinking water
parameters in addition to lead
and copper (40 CFR 141 40(h)
and 141 87)
Verify that monitoring for drinking water parameters is done according to
Appendix 12-8.
Phase 1 - Section 12
Drinking Water Management
12-37
-------
CwttgriteMtt Category*
Dr mkingWater Management
Reptetory Requirements
Reviewer Cbecks
DW.51. Water systems that fail
to meet the lead or copper action
levels are required to meet
specific monitoring
requirements (40 CFR 141.80(h)
and 141.88)
Verify that systems that exceed lead or copper action levels at the tap collect one
source water sample from each entry point to the distribution system within six
months after the exceedence.
Verify that systems which install source water treatment as required by the state
collects an additional source water sample from each entry point to the distribution
system during two consecutive six month monitoring periods.
Verify that the system monitors as follows when the state specifies maximum
permissible source water levels.
- Once during the three year compliance period for water systems using only
groundwater
- Annually for water systems using surface water or a combination of surface and
groundwater.
(NOTE Frequency of monitoring may be reduced by the state upon request.)
DW 52. In reference to lead and
copper in water systems, all
water systems are required to
fulfill specific reporting
requirements (40 CFR 141.90(a)
and 141.90(b)).
Verify that waste systems report sampling results for all tap water samples within the
first 10 days following the end of each monitoring period.
Verify that water systems report the sampling results for all source water samples
within the first 10 days following the end of each source water monitoring period.
DW 53. All systems subject to
the lead and copper
requirements are required to
retain onsite all the original
records of sampling data,
analysis, reports, surveys,
letters, evaluations, state
determinations, and any other
pertinent documents for at least
12 years (40 CFR 141.800),
141.91).
Verify that records are kept onsite for at least 12 years.
Phase 1 - Section 12
Drinking Water Management
12-38
-------
Comjpllawre Category:
Drinking Water Management
Regulatory Requirements
Reviewer Checks
Sole Source Aquifer
DW 54 Projects that may affect
the recharge zone or stream flow
source zone of a designated sole
source aquifer are regulated (40
CFR 149 103 and 149 104)
(NOTE- Currently the only federally designated sole source aquifer is the Edwards
Aquifer in the San Antonio, Texas area )
Determine if the facility is located near a designated sole source aquifer
Verify that the facility maintains a list of projects for which environmental impact
statements will be prepared.
Verify that if any projects may potentially cause direct or indirect contamination
through its recharge zone a petition has been submitted to the EPA Regional
Administrator
Phase 1 - Section 12
Drinking Water Management
12-39
-------
Section 12
Drinking Water Management
Appendices
-------
Appendixl2-1
Primary Drinking Water Standards for Organic Contaminants
Table 1
Maximum Contaminant Levels Applicable to Community Water Systems
(40 CFR 141.12)
¦WSISSSi&^ ;
Total Trihalomethanes (TTHM)
(the sum of the concentrations of
bromodichloromethane, dibromochloromethane,
tnbromomethane (bromoform) and
trichloromethane (chloroform)
0.10
(NOTE The standard for TTHM only applies to community water systems serving greater than 10,000
individuals which add a disinfectant during treatment)
A12-1
-------
Appendix 12-1 (continued)
Primary Drinking Water Standards for Organic Contaminants
Table 2
Maximum Contaminant Levels Applicable to Community and Non-Transient,
Non-Community Water Systems (40 CFR 141.61(a))
CtodbltHlttJMtf: , -
.;.v "• s % v s
1,1-Dichloroethylene
0.007
1,1,1 -T richloroethane
0.20
1,2-Dichloroethane
0 005
1,2-Dichloropropane
0.005
Benzene
0.005
Carbon Tetrachloride
0 005
cis-1,2-Dichloroethylene
0 07
Ethylbenzene
07
Monochlorobenzene
0 1
O-Dichlorobenzene
0.6
para-Dichlorobenzene
0 075
Styrene
0.1
Tetrachloroethy lene
0 005
Toluene
1.0
trans-1,2-Dichloroethylene
0 1
Trichloroe thy lene
0.005
Vinyl chloride
0 002
Xylenes (total)
10.0
Dichloromethane
0 005*
1,2,4-T richlorobenzene
.07*
1,1,2-T richloroethane
.005*
* The effective date for these MCLs is 17 January 1994
A12-2
-------
Appendix 12-1 (continued)
Primary Drinking Water Standards for Organic Contaminants
Table 3
Maximum Contaminant Levels For Synthetic Organic Contaminants Applicable to
Community Water Systems and Non-Transient, Non-Community Water Systems
(40 CFR 141.61(c))
i" \ v
WW';-1:
Alachlor
0 002
Aldicarb
0 003**
Aldicarb sulfoxide
0 004**
Aldicarb sulfone
0.003**
Atrazine
0 003
Carbofuran
0.04
Chlordane
0.002
Dibromochloropropane
0 0002
2,4-D
0 07
Ethylene dibromide
0.00005
Heptachlor
0 0004
Heptachlor epoxide
0.0002
Lindane
0.0002
Methoxychlor
0 04
Pentachlorophenol
0.001
Polychlonnated biphenyls
0.0005
Toxaphene
0 003
2,4,5-TP
0 05
Benzo(a)pyrene
0 0002*
Delapon
0 2*
Di(2-ethythexyl) adipate
0 4*
Di(2-ethythexyl) phthalate
0.006*
Dinoseb
0.007*
Diquat
0 02*
Endothall
0 1*
Endrin
0 002*
Glyphosate
0 7*
Hexachlorobenzene
0.001*
Hexachlorocyclopentadiene
0.05*
Oxamyl (Vydate)
0 2*
Picloram
0 5*
Simazin
0.004*
2,3,7,8,-TCDD (Dioxin)
3 x 10*
*The effective date for these MCLs is 17 January 1994
**The MCLs for these substances have been postponed by the USEPA
A12-3
-------
Appendix 12-2
Primary Drinking Water Standards for Inorganic Contaminants
Table 1
Maximum Contaminant Levels Applicable to Community Water Systems
(40 CFR 141.11,141.12(c) and 141.62(b)(1))
- ,, - ' - -
Arsenic
0 05
Fluoride
4.0
Total Trihalomethanes
0.10*
* This MCL only applies to community water systems which serve a population of 10,000 individuals or more and
which add a disinfectant (oxidant) to the water in any part of the drinking water treatment process.
Table 2
Maximum Contaminant Levels Applicable to Community Water Systems and
Non-Transient, Non-Community Water Systems
(40 CFR 141.62(b)(2) throughl41.62(b)(6) and 141.62(b)(10) through 141.62(b)(15))
'mm**:- ¦: '¦ ......
I V/iw'
Asbestos
*
7 million
fibers/L
(longer than
10
micrometers)
Barium
2.0
Cadmium
0.005
Chromium
0.1
Mercury
0.002
Selenium
0.05
Antimony
0.006
Beryllium
0.004
Cyanide (as free Cyanide)
0.2
Nickel
0.1
Thallium
0.002
A12-4
-------
Appendix 12-2 (continued)
Primary Drinking Water Standards for Inorganic Contaminants
Table 3
Maximum Contaminant Levels Applicable to Community, Non-Transient,
Non-Community and Transient Non-Community Water Systems
(40 CFR 141.62(b)(7) through 141.62(b)(9))
Nitrate (as N)
10.0
Nitrite (as N)
1.0
Total Nitrate and Nitrite (as N)
10.0
-------
Appendix 12-3
Detection Limitations for Inorganic Contaminants
(40 CFR 141.23(a))
: < % s %
« O s^. s s s
¦¦7 ^
¦
Antimony
0 005
Atomic Absorption Furnace
ICP Mass spectrometry
Hydride Atomic Absorption
0 003
0 00086
00004
0 001
Asbestos
7 million
fibers/L
Transmission Electron Microscopy
0 01 million fibers/L
Barium
20
Atomic Absorption; furnace technique
Atomic Absorption; direct aspiration
Inductively Coupled Plasma
0 002
0 1
0 002(0 001»)
Cadmium
0 005
Atomic Absorption; furnace technique
Inductively Coupled Plasma
0 0001
0 001'
Chromium
0 1
Atomic Absorption, furnace technique
Inductively Coupled Plasma
0.001
0 007
(0 001)*
Cyanide
02
Distillation, Spectrophotometry4
Distillation, Automated, Spectrophotometry4
Distillation, Selective Electrode4
Distillation, Amenable, Spectrophotometry3
0.02
0.05
002
Mercury
0 002
Manual Cold Vapor Technique
Automated Cold Vapor Technique
0 0002
0 0002
Nickel
0 1
Atomic Absorption, Furnace
Inductively Coupled Plasma3
ICP Mass Spectrometry
0 001
0.00066
0 005
0 0005
Nitrate
10 as N
Manual Cadmium Reduction
Automated Hydrazine Reduction
Automated Cadmium Reduction
Ion Selective Electrode
Ion Chromatography
0 01
0.01
0.05
1.0
0.01
Nitrite
1 as N
Spectrophotometry
Automated Cadmium Reduction
Manual Cadmium Reduction
Ion Chromatography
0 01
0 05
0 01
0 004
Selenium
0.05
Atomic Absorption, furnace
Atomic Absorption, gaseous hydride
0 002
0.002
Thallium
0 002
Atomic Absorption Furnace
ICP-Mass Spectrometry
0 001
0 00076
0 0003
1 Using concentration techniques n Appendix A to HPA Method 200 7
3 Using a 2x preconcentranon step as noted in Method 200 7 Lower MDLs may be achieved by using a 4x preconcentranon
4 Screening method for total cyanides
5 Measures "free" cyanides
6 Lower MDLs are reported using stabilized temperature graphite furnace atomic absorption
A12-6
-------
Appendix 12-4
Detection Limitations
(40 CFR 141.24(h)(18»
Cottlamin&ni: "
\
Detection
-liaift
Alachlor
0 0002
Aldicarb
0.0005
Aldicarb sulfoxide
0.0005
Aldicarb sulfone
0 0008
Atrazine
0 0001
Benzo[a)pyrene
0 00002
Carbofuran
0 0009
Chlordane
0.0002
Dalapon
0.001
Dibromochloropropane (DBCP)
0 00002
Di (2-ethylhexyl) adipate
0.0006
Di (2-ethylhexyl) phthalate
0.0006
Dinoseb
0 0002
Diquat
0.0004
2,4-D
0.0001
Endothall
0 009
JJuai
\s ^ %
Endrin
0 00001
Ethylene dibromide (EDB)
0 00001
Heptachlor
0 00004
Heptachlor epoxide
0 00002
Hexachlorobenzene
0 0001
Hexachlorocyclopentadiene
0 0001
Lindane
0 00002
Methoxychlor
0 0001
Oxamyl
0 002
Picloram
0 0001
Pentachlorophenol
0 00004
Polychlorinated biphenyls
0 0001
Simazine
0.00007
Toxaphene
0 001
1,3,7,8-TCDD (Dioxin)
0 000000005
2,4,5-TP
0 0002
A12-7
-------
Appendix 12-5
Unregulated Organic and Inorganic Contaminants
(40 CFR 141.40(n)(ll) and 141.40(n)(12))
Aldrin
Butachlor
Carbaryl
Dicamba
Dieldrin
3-Hydroxycarbofuran
Methomly
Metolachlor
Metnbuzin
Propachlor
Sulfate
A12-8
-------
Appendix 12-6
Coliform Bacteria Sampling Frequency
(40 CFR 141.21(a)(2))
Population Served Minimum Number of
Per Month Samples Per Month
25 to 1000
1
1001 to 2500
2
2501 to 3300
3
3301 to 4100
4
4101 to 4900
5
4901 to 5800
6
5801 to 6700
7
6701 to 7600
8
7601 to 8500
9
8501 to 12,900
10
12,901 to 17,200
15
17,201 to 21,500
20
21,501 to 25,000
25
25,001 to 33,000
30
33,001 to 41,000
40
41,001 to 50,000
50
50,001 to 59,000
60
59,001 to 70,000
70
70,001 to 83,000
80
83,001 to 96,000
90
96,001 to 130,000
100
130,001 to 220,000
120
220,001 to 320,000
150
320,001 to 450,000
180
450,001 to 600,000
210
600,001 to 780,000
240
780,001 to 970,000
270
970,001 to 1,230,000
300
1,230,001 to 1,520,000
330
1,520,001 to 1,850,000
360
1,850,001 to 2,270,000
390
2,270,001 to 3,020,000
420
3,020,001 to 3,960,000
450
3,960,001 or more
480
A12-9
-------
Appendix 12-7
Monitoring and Sampling Parameters for Lead and Copper in Drinking Water
(40 CFR 141.86(c) and 141.86(d))
Itemed s * '
^ \ ...
* W
lEstaadw-#
j&M* ;
>100,000
100
50
10,001 - 100,000
60
30
3301 - 10,000
40
20
501 - 330
20
10
101 - 500
10
5
il00
5
5
>50,000
1 Jan 1992
3301 - 50,000
1 July 1992
*3300
1 July 1993
A12-10
-------
Phase 1
Section 13
PCB Management
-------
Phase 1
Section 13
Table of Contents
PCB Management
A. Applicability 13-1
B. Federal Legislation.... 13-1
C. State/Local Regulations 13-2
D. Key Compliance Requirements 13-2
E. Key Compliance Definitions 13-5
F Records to Review 13-8
G. Physical Features to Inspect .... ... 13-8
H. Guidance for Checklist Users .. 13-9
Appendices
A13-1. PCB Label Format A13-1
A13-2. Dielectric Fluid Trend Names and Manufacturers A13-2
-------
A. Applicability
This section is used to determine the compliance status of the management activities
associated with PCBs and in-service and out-of-service PCB items.
Assessors are required to review agency, Federal, state, and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. The Toxic Substances Control Act (TSCA)
This Act, as last amended in 1986 (15 U.S. Code (USC) 2601-2671), is the Federal
legislation which deals with the control of toxic substances The Act consists of three
subchapters, one of which regulates the control of toxic substances (such as PCBs), another
governs asbestos hazard emergency response, and another subchapter regulates indoor radon
abatement. The policy developed in TSCA on chemical substances is as follows (15 USC
2601(b)):
a. Adequate data should be developed with respect to the effect of chemical substances
and mixtures on health and the environment and that the development of such data
should be the responsibility of those who manufacture and those who process such
chemical substances and mixtures;
b. Adequate authority should exist to regulate chemical substances and mixtures which
present an unreasonable risk of injury to health or the environment, and to take action
regarding chemical substances and mixtures, and
c. Authority over chemical substances and mixtures should be exercised in such a manner
as not to impede unduly or create unnecessary economic barriers to technological
innovation while fulfilling the primary purpose of this Act to assure that such
innovation and commerce in such chemical substances and mixtures do not present an
unreasonable risk of injury to health or the environment
Upon request by the EPA, each Federal department and agency is authorized to (15 USC
2625(a)):
a Make its services, personnel, and facilities available (with or without reimbursement) to
the EPA to assist the EPA in the administration of this Act, and
b. Furnish the EPA with information, data, estimates, and statistics, and allow the EPA
access to all information in its possession as the EPA may reasonably determine to be
necessary for the administration of this Act
Phase 1 - Section 13
PCB Management
13-1
-------
2. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
it funds meet applicable Federal, state, and local environmental requirements or to correct
situations that are not in compliance with such requirements. In addition, the EO requires that
each agency ensure that sufficient funds for environmental compliance are included in the agency
budget.
C. State/Local Regulation
1. PCBs
According to the general structure of Federal regulatory programs, any state regulations
must adopt the Federal regulations as a minimum set of requirements. In some cases, state
regulations have been developed which regulate PCBs more stringently than the Federal
program. State PCB regulations may provide additional regulatory requirements beyond the
Federal program to address a specific concern or activity sensitive in that state. State regulations
may supersede the Federal regulations in areas including the following:
a. PCBs may be regulated as a hazardous waste;
b. PCBs may be regulated to a lower concentration. For example, regulated PCBs in one
state are defined to be materials and fluids which contain PCBs at a concentration
greater than 7 ppm;
c. Shipments of PCBs may require manifest documents,
d. Analysis may be required to quantify the PCB concentration in all PCB items;
e. Additional inspections of select PCB items and specific disposal requirements for PCBs
and PCB items may also be required; and
f. Generators of PCBs and PCB items may be required to obtain disposal permits.
D. Key Compliance Requirements
1. Personnel and PCBs
Certain regulations and practices should be followed to ensure the health of personnel who
come in contact with PCBs. These include provision of protective work-clothing, shower
facilities, and facilities for washing hands during shift. Airborne contaminations of PCBs
should be assessed and certain precautionary practices followed to protect personnel, which
Phase 1 - Section 13
PCB Management
13-2
-------
include the wearing of respirators if contamination is above a certain level. Certain records and
practices should be maintained for employees exposed to PCBs, including medical histories and
physical examinations emphasizing liver and skin condition.
2. PCB Equipment Marking
The following equipment is required to be marked indicating that they contain PCBs (40
CFR 761.40 and 761 45):
• PCB containers with PCBs in concentrations of 50 to 500 parts per million (ppm);
• PCB transformers (500 ppm or greater);
• PCB large high voltage capacitors;
• Equipment containing a PCB transformer (500 ppm or greater) or a PCB large high voltage
capacitor at the time of removal from service;
• PCB large low voltage capacitors at the time of removal from service;
• Electric motors using PCB coolants with a concentration of 50 to 500 ppm;
• Hydraulic systems using PCB hydraulic fluid with concentrations of 50 to 500 ppm;
• Heat transfer systems (other than PCB transformers) using PCB concentrations of 50 to 500
ppm;
• PCB article containers containing any of the above;
• Each storage area used to store PCBs and PCB items for disposal;
• Transport vehicles loaded with PCB containers that contain more than 45 kg (99.4 lb) of
PCBs in the liquid phase with PCB concentrations of 50 to 500 ppm or one or more PCB
transformers with PCB concentrations of greater than 500 ppm- mark on each end and side,
and
• Vault doors, machinery room doors, fences, hallways, or means of access, other than a
manhole or grate cover, to a PCB transformer (500 ppm or greater).
3. Records for PCBs
A written annual document log must be prepared by 1 July of each calendar year, covering
the previous year for all facilities that use or store at any time at least 45 kg (99.4 lb) of PCBs
contained in PCB containers, or one or more PCB transformers. Owners and operators of PCB
chemical waste landfills shall keep records on water analysis and operational records, including
Phase 1 - Section 13
PCB Management
13-3
-------
burial coordinates for 20 years after disposal has ceased. Generators of PCBs shall keep copies
of manifests and certificates of disposal for three years.
4. PCB Transformers
PCB transformers with PCBs of 500 ppm or greater that are in use or in storage for reuse,
must not pose an exposure risk to food and feed and are subject to registration requirements.
Combustible materials, including, but not limited to, paints, solvents, plastics, paper, and sawn
wood, must not be stored by a PCB transformer. PCB transformers are required to be properly
serviced, and inspections must be performed once every three months for all in-service
transformers. If the transformer is found to be leaking, it must be repaired or replaced to
eliminate the source of the leak. When a PCB transformer is involved in a fire, the facility is
required to immediately report the incident to the National Response Center (NRC) (40 CFR
761 120(a), 761.120(b), 761.120(c), 761.123(d)(2), and 761.125)
5. PCB Spills
Facilities are required to report spills of more than 10 lb (4.56 kg) of PCBs of concentrations
of 50 ppm to the EPA regional office. Spills of greater than 1 lb (0.45 kg) must be cleaned up.
The criteria for cleanup is based on whether the spill is of high or low concentration of PCBs (40
CFR 761.120, 761,123, 761.125).
6. PCB Items
The use of PCBs in electromagnetic switches, voltage regulators, capacitors, heat transfer
and hydraulic systems, circuit breakers, reclosers, and cable is allowed if applicable restrictions
are met and precautions taken (40 CFR 761.30).
7. PCB Storage
PCBs and PCB items at concentrations greater than 50 ppm that are to be stored before
disposal must be stored in a facility that will assure the containment of PCBs. Storage prior to
disposal is not to exceed one year. Nonleaking and structurally undamaged PCB large, high-
voltage capacitors and PCB contaminated electric equipment that have not been drained of
freeflowing dielectric fluid may be stored on pallets next to a storage area that complies with the
storage area requirements. Containers used for the storage of PCBs must comply with the
shipping container specification of the Department of Transportation (DOT) (40 CFR 761.65)
8. PCB Transportation
A generator who offers a PCB waste for transport to commercial offsite storage or offsite
disposal must prepare a manifest. If the generator does not receive a signed copy of the manifest
with 35 days from the date the waste was accepted by the initial transporter, the generator must
immediately contact the transporter and/or owner or operator of the designated facility to
determine the status of the PCB waste (40 CFR 761.207 through 761.210, 761.215).
9. PCB Disposal
For each shipment of manifested PCB waste that a disposal facility accepts, the owner or
Phase 1 - Section 13
PCB Management
13-4
-------
operator of the disposal facility must prepare a Certificate of Disposal (COD). PCB
contaminated fluids of concentrations greater than 50 ppm, but less than 500 ppm, are required to
be disposed of in a EPA approved incinerator, or chemical waste landfill, or a high efficiency
boiler. PCB liquids and transformers with concentrations of 500 ppm or greater must be disposed
of in a EPA approved PCB incinerator. PCB capacitors must be disposed of either a solid waste
landfill or an approved incinerator depending on the concentration of PCBs. PCB hydraulic
machines containing PCBs at concentrations greater than 50 ppm may be disposed of as
municipal solid waste when drained. PCB-contaminated electrical equipment, except capacitors,
shall be disposed of by draining off the free-flowing liquid. PCB articles and containers shall be
disposed of in a EPA approved incinerator or chemical waste landfill if all free-flowing liquids
have been removed (40 CFR 761.60, 761.218).
E. Key Compliance Definitions
1. Capacitor
A device for accumulating and holding a charge of electricity and consisting of conducting
surfaces separated by a dielectric. Types of capacitors are as follows (40 CFR 761.3):
• Small capacitor - a capacitor which contains less than 1.36 kg (3 lb) of dielectric fluid;
• Large high-voltage capacitor - a capacitor which contains 1.36 kg (3 lb) or more of dielectric
fluid and which operates at 2000 volts (a.c. or d.c.) or above; and
• Large Low-voltage Capacitor - a capacitor which contains 1.36 kg (3 lb) or more of
dielectric fluid and which operates at 2000 volts (a.c. or d.c.).
2. Chemical Waste Landfill
Landfill at which protection against risk of injury to health or the environment from
mitigation of PCBs to land, water, or the atmosphere is provided from PCBs and PCB items
deposited therein by locating, engineering, and operationing the landfill as required (40 CFR
761.3).
3. Commercial Storer of PCB Waste
The owner or operator of each facility that is subject to the PCB storage facility standards of
40 CFR 761.65, and who engages in storage activities involving PCB waste generated by others,
or PCB waste that was removed while servicing the equipment owned by others and brokered for
disposal. The receipt of a fee or any other forms of compensation for services is not necessary to
qualify as a commercial storer of PCB waste. It is sufficient under this definition that the facility
stores PCB waste generated by others or the facility removed the PCB waste while servicing
equipment owned by others. If a facility's storage of PCB waste at no time exceeds 500 gal
(1892.71 L) of PCBs, the owner or operator is not required to seek approval as a commercial
storer of PCB waste (40 CFR 761.3).
Phase 1 - Section 13
PCB Management
13-5
-------
4. Disposal
Intentionally or accidentally to discard, throw away, or otherwise complete or terminate the
useful life of PCBs and PCB items (40 CFR 761.3)
5. Double Wash/Rinse
A minimum requirement to cleanse solid surfaces (both impervious and nonimpervious) two
times with an appropriate solvent or other material in which PCBs are at least five percent
soluble (by weight) (40 CFR 761.123).
6. Emergency Situations
For continuing use of a PCB transformer exists when (40 CFR 761.3):
a. Neither a non-PCB transformer nor a non-PCB contaminated transformer is currently in
storage for reuse or readily available within 24 hours for installation, or
b. Immediate replacement is necessary to continue service for power users.
7. High Concentration PCBs
PCBs that contain 500 ppm or greater PCBs, or those materials which the EPA requires to
be assumed to contain 500 ppm or greater PCBs in the absence of testing (40 CFR 761.123).
8. In or Near Commercial Buildings
Within the interior of, on the roof of, attached to the exterior wall of, in the parking area
serving, or within 30 meters of a non-industrial, non-substation building (40 CFR 761.3).
9. Industrial Building
A building directly used in manufacturing or technically productive enterprises (40 CFR
761.3).
10. Leak or Leaking
Any instance in which a PCB article, PCB container, or PCB equipment has any PCBs on
any portion of its external surface (40 CFR 761.3).
11. Low Concentration PCBs
PCBs that are tested and found to contain less than 500 ppm PCBs or those PCB-containing
materials which EPA requires to be assumed to be at concentrations below 500 ppm (e.g.,
untested mineral oil dielectric fluid) (40 CFR 761.123).
12. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
Phase 1 • Section 13
PCB Management
13-6
-------
13. Mark
The descriptive name, instructions, cautions, or other information applied to PCBs and PCB
items, or other objects subject to these regulations (40 CFR 761.3).
14. Marking
The marking of PCB items and PCB storage areas and transport vehicles by means of
applying a legible mark by painting, fixation of an adhesive label, or by any other method that
meets the requirements of these regulations (40 CFR 761 3).
15. Mineral Oil PCB Transformers
Any transformer originally designed to contain mineral oil as the dielectric fluid and which
has been tested and found to contain 500 ppm or greater PCBs (40 CFR 761.3).
16. Non-PCB Transformers
Any transformer that contains less than 50 ppm PCB except any transformer that has been
converted from a PCB transformer or a PCB-contaminated transformer cannot be classified as a
non-PCB transformer until reclassification has occurred in accordance with the requirements of
40 CFR 761.30(a)(2)(v) (40 CFR 761.3).
17. PCB or PCBs
An chemical substance that is limited to the biphenyl molecule that has been chlorinated to
varying degrees or any combination of substances which contains such substance (40 CFR
761.3).
18. PCB Article
Any manufactured article, other than a PCB container, that contains PCBs and whose
surface(s) has been in direct contact with PCBs. This includes capacitors, transformers, electric
motors, pumps, and pipes (40 CFR 761.3).
19. PCB Article Container
Any package, can, bottle, bag, barrel, drum, tank, or other device used to contain PCB
articles or PCB equipment, and whose surface(s) has not been in direct contact with PCBs (40
CFR 761.3).
20. PCB-Contaminated Electrical Equipment
Any electrical equipment, including but not limited to transformers, capacitors, circuit
breakers, reclosers, voltage, regulators, switches, electromagnets, and cable, that contain 50 ppm
or greater PCB, but less than 500 ppm PCB (40 CFR 761.3).
21. PCB Equipment
Any manufactured item, other than a PCB container or a PCB article container, which
contains a PCB article or other PCB equipment, and includes microwave ovens, electronic
equipment, and fluorescent light ballasts and fixtures (40 CFR 761.3).
Phase 1 - Section 13
PCB Management
13-7
-------
22. PCB Item
Any PCB article, PCB article container, PCB container, or PCB equipment that deliberately
or unintentionally contains or has as a part of it any PCB or PCBs (40 CFR 761.3).
23. PCB Transformer
Any transformer that contains 500 ppm PCB or greater (40 CFR 761.3).
24. PCB Waste
Those PCBs and PCB items that are subject to the disposal requirements of Subpart D of 40
CFR 761 (40 CFR 761.3).
25. Posing an Exposure Risk to Food or Feed
Being in any location where human food or animal feed products could be exposed to PCBs
released from a PCB item (40 CFR 761.3).
26. Retroflll
To remove PCB or PCB contaminated dielectric fluid and replace it with either PCB, PCB
contaminated, or non-PCB dielectric fluid (40 CFR 761.3).
27. Rupture of a PCB Transformer
A violent or non-violent break in the integrity of a PCB transformer caused by an
overtemperature and/or overpressure condition that results in the release of PCBs (40 CFR
761.3).
F. Records to Review
• Inspection, storage, maintenance, and disposal records for PCBs/PCB items;
• PCB Equipment inventory and sampling results;
• Correspondence with regulatory agencies concerning noncompliance situations;
• Annual reports;
• Spill Prevention Control and Countermeasure (SPCC) Plan;
• Manifests; and
• Certificates of Disposal.
G. Physical Features to Inspect
• PCB storage areas; and
• Equipment, fluids, and other items used or stored at the facility containing PCBs.
Phase 1 - Section 13
PCB Management
13-8
-------
H. Guidance For Checklist Users
Refer To
Checklist Items
Page Numbers
All Facilities
PCB 1 through PCB 3
13-10
PCB Management
PCB 4
PCB 5
13-11
13-12
PCB Records
PCB 6 through PCB 7
PCB 8
13-13
13-14
PCB Transformers
PCB 9 through PCB 12
PCB. 13
PCB 15 through PCB 17
13-14
13-15
13-16
PCB Spills
PCB 18 through PCB 19
PCB 20
13-17
13-18
PCB Items
PCB 21 through PCB 23
PCB 24
13-19
13-20
PCBs in Research
PCB.25
13-20
PCB Storage
PCB 26 through PCB 28
PCB.29 through PCB 31
13-20
13-21
PCB Transportation
PCB 32 through PCB 33
13-22
PCB Disposal
PCB 34
PCB 35 through PCB 36
PCB 37 through PCB.39
PCB 40 through PCB 45
13-22
13-23
13-24
13-25
Phase 1 - Section 13
PCB Management
13-9
-------
Compliance Category;
PCB Management
Kegvtetory Retirements; j Reviewer Checks;
All Facilities
PCB 1. The current status of
any ongoing or unresolved
Consent rders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information as
the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective action is planned and milestones
established to correct problems
PCB.2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding )
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
PCB 3. Facilities are required to
comply with state and local
regulations concerning PCB
management (EO 12088, Sect
1-D
Verify that the facility is abiding by state and local requirements.
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include'
- Definitions of PCB-contaminated
- PCB storage, labeling, and disposal requirements )
Phase 1 - Section 13
PCB Management
13-10
-------
Compiiawe Category:
PCB Management
Regulatory Reqatremeirrts:
Reviewer Checks:
PCB Management
PCB 4 Certain equipment that
contains PCBs must be marked
with an ML marking (40 CFR
761 40 and 761 45)
(NOTE Marking Format Large PCB Mark (ML) letters and striping, on a white or
yellow background, sufficiently durable to equal or exceed the life of the PCB Article
The size shall be 15 25 cm (6 in ) on each side If the article is too small to
accommodate this size, a smaller label (Ms) may be used )
Verify that equipment containing PCBs is marked with an ML marking that can be
easily read by any person inspecting or servicing the equipment (see Appendix 13-1
for a sample of the marking)
- PCB containers with PCBs in concentrations of 50 to 500 ppm
- PCB transformers (500 ppm or greater)
- PCB large high voltage capacitors
- Equipment containing a PCB transformer (500 ppm or greater) or a PCB large high
voltage capacitor at the time of removal from service
- PCB large low voltage capacitors at the time of removal from service
- Electric motors using PCB coolants with a concentration of 50 to 500 ppm
- Hydraulic systems using PCB hydraulic fluid with concentrations of 50 to 500 ppm
- Heat transfer systems (other than PCB transformers) using PCB concentrations of
50 to 500 ppm
- PCB article containers containing any of the above
- Each storage area used to store PCBs and PCB items for disposal
- Transport vehicles loaded with PCB containers that contain more than 45 kg (99 4
lb) of PCBs in the liquid phase with PCB concentrations of 50 to 500 ppm or one or
more PCB transformers with PCB concentrations of greater than 500 ppm are
marked on each end and side
- Vault doors, machinery room doors, fences, hallways, or means of access, other
than a manhole or grate cover, to a PCB transformer (500 ppm or greater)
Verify that if one or more PCB large high voltage capacitors is installed in a protected
location such as a pole, structure, or behind a fence, the pole, structure, or fence is
marked and a record or procedure identifying the PCB capacitor is maintained by the
facility
(NOTE Marking of PCB contaminated electrical equipment (50 500 ppm) is not
required)
(NOTE Appendix 13-2 contains a list of manufacturers that produced PCB
contaminated dielectric fluid)
(NOTE The annual document log should contain a list of all PCB equipment at the
site)
Phase 1 - Section 13
PCB Management
13-11
-------
CoH»#k»«Categairyi
PCB Management
Regulatory Req&tremeirts:
Reviewer-OtittlaB
PCB.5 Generators,
transporters, and disposers of
PCB waste are
required to have an EPA
identification number (40 CFR
761 202 through 761 205).
(NOTE Some facilities are exempt from the notification requirement and do not
have a specified PCB storage area as regulated by 40 CFR 761 65 and just temporarily
store before they transport for disposal)
Determine if the facility is a generator, transporter, or disposer of PCB waste
Verify that facilities which generate PCB waste have an EPA identification number
before processing, storing, dispensing, transporting, or offering for transport PCB
waste.
Verify that facilities which transport or dispose of PCB waste have an EPA
identification number.
Verify that if an facility must file, Form 7710-53, Notification of PCB Waste Activity,
it was filed with EPA by 4 April 1990 and a EPA identification number was obtained
Phase 1 - Section 13
PCB Management
13-12
-------
Cowpllams Category:
PCB Management
Regulatory Req&tretnents;
Reviewer Cbecfcs:
PCB Records
PCB 6 A written annual
document log must be prepared
by July 1 of each calendar year,
covering the previous year for
all facilities that use or store at
any time at least 45 kg (99 4 lb)
of PCBs contained in PCB
containers or one or more PCB
transformers (500 ppm or
greater), or 50 or more PCB
large, high, or low voltage
capacitors (40 CFR 761 180(a))
Verify that the annual document log and annual records (manifests certificates of
disposal) are kept for at least five years after the facility stops using or storing PCBs
and PCB items in the listed quantities
Review the written annual document log for the following
- Identification of facility
- Calendar year covered
- Manifest number for every manifest generated
- Total number (by type) of PCB articles, PCB article containers, and PCB containers
placed into storage for disposal or disposed of during the calendar year
- Total weight placed into storage for disposal or disposed of during the calendar year
of
-- PCBs in PCB articles
- contents of PCB article container
-- contents of PCB containers
-- bulk PCB Waste
- A list of PCBs and PCB items remaining in-service at the end of the calendar year
The total weight of any PCBs and PCB items in containers including identification
of container contents and the total number of PCB transformers, PCB large, high-
and low-voltage capacitors, and the total weight of PCBs in PCB transformers
- A record of each telephone call or other form of verification to confirm the receipt
of PCB waste transported by independent transport
Verify that the annual document log contains the following for each manifest, for
unmanifested waste, and for any PCBs or PCB items received from or shipped from
another facility owned or operated by the generator
- Date removed from service for disposal (first date material placed in PCB
container)
- Date placed into transport for offsite storage/disposal
- Date of disposal (if known)
- Weight of PCB Wastes
- total bulk for PCB wastes
- in each article for PCB transformers or capacitors
- total in each container for PCB containers
-- total weight of contents and of the PCB article (in kg) in each PCB article
container
- Serial number or other unique identification number (except for bulk wastes)
- Description of the contents for PCB containers and article containers
Determine if the following information is provided by reviewing the annual document
log'
- All signed manifests generated or received at the facility during the calendar year
- All CODs that have been generated or received during the calendar year
PCB 7 Owners and operators
of PCB chemical waste landfills
shall keep records on water
analysis and operational records,
including burial coordinates, for
20 years after disposal has
ceased (40 CFR 761 180(d))
Verify that records on water analysis and operations are being kept for the required 20
years
Phase 1 - Section 13
PCB Management
13-13
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Compliance Category:
PCB Management
Regulatory Requirements:
Reviewer Checks:
PCB 8 Storage and disposal
facilities for PCBs shall
maintain
specific records for three years
(40CFR761 180(0)
Verify that facilities which store or dispose of PCBs
collect and maintain the following records for three years
- All documents, correspondence, and data that have been provided by any state or
local government
- All documents, correspondence, and data provided to the state or local governments
by the facility
- Any applications and related correspondence concerning wastewater discharge
permits, solid waste permits, building permits, or other permits and authorizations
PCB Transformers
PCB.9 PCB Transformers with
PCBs of 500 ppm or greater that
are in use or in storage for reuse
shall not pose an exposure risk
to food and feed (40 CFR
761 30(a)(l)(i))
Determine if there are any PCB transformers on the installation/CW
facility, in use or in storage for reuse, that pose an exposure risk to
food and feed by reviewing the inventory
PCB 10 PCB Transformers
with concentrations of PCBs of
500 ppm or greater are subject
to certain registration
requirements (40 CFR
761 30(a)(l)(vi))
Verify that all PCB transformers, including those in storage for reuse, are registered
with the facility fire department, or the fire department with jurisdiction, with the
following information'
- Physical location of PCB transformers)
- Principle constituent of dielectric fluid (e.g., PCBs, mineral oil, silicone oil, etc)
- Name and telephone number of contact person knowledgeable of PCB
transformer(s).
PCB 11 Railroad transformers
must not contain dielectric fluid
with greater than 1000 ppm
PCB and must be serviced
according to specific
requirements
(40 CFR 761 30(b)((l)(vi),
761 30(b)(2)(iu) and
761 30(b)(2)(iv))
Verify that railroad transformers do not exceed 1000 ppm PCB
Verify that servicing of a railroad transformer is only done with dielectric fluid
containing less than 1000 ppm PCB
Verify that if the coil is removed from the casing of a railroad transformer, it is
refilled with dielectric fluid containing 50 ppm or less PCB
(NOTE: Dielectric fluid may be filtered through activated carbon or otherwise
industrially processed for the purpose of reducing the PCB concentration in the fluid )
PCB 12 Combustible materials,
including but not limited to
paints, solvents, plastics, paper,
and sawn wood, must not be
stored by a PCB transformer (40
CFR 761.30(a)(l)(vni))
Verify that all combustible materials have been removed from the area within a PCB
transformer enclosure (e g , vault or partitioned area) and the area within 5 meters
(16.40 ft) of a PCB transformer or PCB transformer enclosure.
Phase 1 - Section 13
PCB Management
13-14
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Compliance Category:
PCB Management
Regulatory Requtretncnts;
Reviewer Checks:
PCB 13 PCB transformers of
concentrations of 500 ppm or
greater in use in or near
commercial buildings are
subject to certain requirements
(40 CFR761 30(a)(1)(H)
through 761 30(a)(l)(v) and
761 30(a)(l)(vn))
Determine if there are any transformers located in or near commercial buildings by
reviewing the inventory
Verify that procedure/policy exists prohibiting installation of PCB transformers which
have been placed into storage for reuse or which have been removed from another
location
Verify that there are no network PCB transformers with higher secondary voltages
(equal to or greater than 430 V, including 480/277 V systems) in or near commercial
buildings.
Determine where any of the following PCB transformers are in use in or near
commercial buildings or located in sidewalk vaults and if a plan exists to equip such
PCB transformers with electrical protection to avoid transformer failure that would
result in release of PCBs
- Radial PCB transformers and lower secondary voltage network PCB transformers
(voltage less than 480 V)
- Radial PCB transformers with higher secondary voltages (greater than or equal to
480 V including 480/277 V system)
Determine if lower secondary voltage network PCB transformers which have not been
electrically protected are registered with the EPA Regional Administrator and plans
are being made to remove them from service by 1 October 1993
Verify that all higher secondary voltage radial PCB transformers, in use in or near
commercial buildings, and lower secondary voltage network PCB transformers not
located in sidewalk vaults in or near commercial buildings are equipped with:
- Electrical protection such as current-limiting fuses to avoid transformer ruptures
- Disconnect equipment to insure complete de-energization of the transformer in case
of a sensed abnormal condition
Verify that all lower secondary voltage radial PCB transformers, in use in or near
commercial buildings, are equipped with electrical protection such as current limiting
fuses or equivalent technology and provide for the complete de-energization of the
transformer or complete de-energization of the faulted phase of the transformer within
several hundredths of a second
PCB. 14 PCB transformers are
required to be properly serviced
(40 CFR 761.30(a)(2)).
Verify that servicing activities are properly conducted as follows by reviewing
servicing records
- Transformers classified as PCB-contaminated electrical equipment (50-500 ppm
PCBs) are only serviced with dielectric fluid containing less than 500 ppm PCB
- The transformer coil is not removed during servicing of PCB transformers with
PCB concentrations of 500 ppm or greater
- PCBs removed during servicing are captured and are either reused as dielectric fluid
or disposed of properly
- The PCBs from a PCB Transformer with PCB concentrations of 500 ppm or greater
are not mixed with or added to dielectric fluid from PCB-contaminated electrical
equipment (50-500 ppm PCBs)
- Dielectric fluids containing less than 500 ppm PCBs that are mixed with fluids
containing 500 ppm or greater are not used as dielectric fluid in any transformers
classified as PCB-contaminated electrical equipment (50-500 ppm PCBs)
(NOTE PCB transformers may be serviced with dielectric fluid at any
concentration.)
Phase 1 - Section 13
PCB Management
13-15
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i r , r ?
Reviewer C&eekfe \ ; , „ j
PCB 15. Inspections must be
performed once every three
months for all in-service PCB
transformers with greater than
500 ppm PCB (40 CFR
761.30(a) (l)(ix) and
761 30(a)(l)(xii) through
761 30(a)(l)(xiv))
Verify that applicable transformers are inspected at least once every three months by
reviewing inspection records
Determine whether any PCB transformers have been leaking
Verify that the following information is recorded for each PCB Transformer
inspection:
- Location of transformer
- Dates of each visual inspection
- Date when any leak was discovered
- Name of person conducting inspection
- Location and estimate of the dielectric fluid quantity for any leaks
- Data and description of any cleanup, containment, or repair performed
- Results of any daily inspections for transformers with uncorrected active leaks.
(NOTE Reduced visual inspections of at least once every 12 months is allowed for
PCB transformers with impervious, undrained secondary containment capacity of 100
percent of dielectric fluid and for PCB transformers tested and found to contain less
than 60,000 ppm PCBs)
(NOTE' Increased visual inspections of once a week is required for any PCB
Transformer in use or stored for reuse which poses an exposure risk to food or feed.)
Verify that records of inspection and maintenance are kept for three years after
disposal
PCB 16 PCB transformers with
PCB concentrations of 500 ppm
or greater found to be leaking
during an inspection must be
repaired or replaced to eliminate
the source of the leak (40 CFR
761 30(a)( 1 )(x))
Determine if cleanup and/or containment of released PCBs has been initiated within
48 hours of its detection or as soon as possible
Verify that leaking PCB transformers are inspected daily
Determine if plans exist to repair or replace transformers to eliminate the source of the
leak
Verify that cleaned up material is disposed of according to appropriate requirements
PCB 17 When a PCB
Transformer with concentrations
of PCBs 500 ppm or greater is
involved in a fire, the facility is
required to immediately report
the incident to the NRC (40
CFR 761 30(a)(l)(xi))
Determine if any PCB transformers have been involved in any incident where
sufficient heat and/or pressure was generated to result in the violent or nonviolent
rupture of a PCB Transformer and the release of PCBs.
Verify that the NRC was notified and the following measures were taken
- Floor drains were blocked
- Water runoff was contained
Phase 1 - Section 13
PCB Management
13-16
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Cotttpltem* Category:
PCB Management
Itegtttet&ry fteqetreownts}
PCB Spills
PCB 18 Facilities are required
to report spills of more than 10
lb (4.53 kg) of PCBs of
concentrations of 50 ppm or
greater (40 CFR 761 120(a)(1),
761 123(d)(2), and 761 125(a))
Verify that when a spill of 10 lb (4 53 ke) or more directly contaminates surface
water, sewers, or drinking water, the facility notifies the regional EPA office within
24 hours after discovery of the spill and acts on the guidance given by the EPA
Verify that if a spill of 10 lb (4 53 kg) or more directly contaminates grazing land or a
vegetable garden the facility notifies the EPA regional office within 24 hours after
discovery and begins the cleanup of the spill.
Verify that when a spill of 10 lb (4.53 kg) or more occurs which does not directly
contaminate surface waters, sewers, drinking water supplies, grazing land, or a
vegetable garden the facility notifies the EPA Regional office within 24 hours after
discovery of the spill and begins decontamination of the spill area
(NOTE: Spills of greater than 1 lb (0.45 kg) must be reported to the NRC under 40
CFR 302 1 through 302 6, see appropriate checklist items in Hazardous Materials
Management protocol)
PCB. 19 Cleanup of low
concentration spills of less than
1 lb (0 45 kg) of PCBs (less than
270 gal (1,022 26 L) of untested
mineral oil) must be done
according to specific
requirements (40 CFR
761 120(a)(2), 761.120(b),
761 120(c), and 761 125(b)).
Verily that solid surfaces are double washed/rinsed and all indoor, residential surfaces
other than vault areas are cleaned to 10 jng/100 cm2 by standard commercial wipe
tests
Verify that all soil within the spill area (visible traces of soil and buffer of 1 lateral
foot (3 28 lateral meters) around the visible traces) is excavated and the ground
restored to its original status by backfilling with clean soil (soil with less than 1 ppm
PCBs)
Verify that the above cleanup requirements are done within 48 hours after identifying
the spill unless an emergency or adverse weather delays the process
Verify that the cleanup is documented with records and certification of
decontamination and the records are maintained for six years
(NOTE. The final numerical cleanup standards do not apply to spills directly into
surface waters, drinking water, sewers, grazing lands, and vegetable gardens )
(NOTE The EPA may impose more stringent or less stringent cleanup requirements
on a case by case basis depending on conditions such as possibility of groundwater
contamination.)
Phase 1 - Section 13
PCB Management
13-17
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Compliance Category:
PCB Management
Regulatory Requirements
Reviewer Checks;
PCB 20 Cleanup of high
concentration spills and low
concentration spills involving 1
lb (0 45 kg) or more of PCBs by
weight (270 gal (1,022 64 L) or
more of untested mineral oil)
must be done according to
specific requirements (40 CFR
761 120(a)(2), 761 120(b),
761 120(c), and 761.125(c))
Verify that the following actions are taken within 24 hours (or within 48 hours for
PCB Transformer with PCB concentrations of greater than 500 ppm) of discovery of
the spill
- Notification of the EPA regional office and the NRC
- The area of the spill is cordoned off or otherwise identified to include the area with
visible traces of the spill and a 3 ft (0 91 m) buffer zone If there are no visible
traces the area of the spill may be estimated
- Clearly visible signs are placed advising persons to avoid the area
- The area of visible contamination is recorded and documented, identifying the
extent and center of the spill
- Cleanup of visible traces of the fluid from hard surfaces is initiated
- Removal of all visible traces of the spill on soil and other media such as gravel,
sand, etc is started
Verify that if the spill occurs in an outdoor substation-
- Contaminated solid surfaces are cleaned to a PCB concentration of 100 mg/cm2 (as
measured by standard wipe tests)
- Soil contaminated by the spill is cleaned to either 25 ppm PCBs by weight or 50
ppm PCBs by choice of the facility if a label to notice is placed in the area
indicating the level of cleanup
- Post-cleanup sampling is done
Verify that if the spill occurs in a restricted access area other than an outdoor
substation
- High-contact solid surfaces are cleaned to 10 mg/100 cm2 (as measured by standard
wipe tests)
- Low-contact, indoor, impervious solid surfaces are decontaminated to 10 mg/100
cm2
- Low contact, indoor, nonimpervious surfaces are cleaned to either 10 mg or 100
mg/100 cm2 and encapsulated at the option of the facility
- Low-contact, outdoor surfaces (both impervious and non-impervious) are cleaned to
100 mg/100 cm2
- Soil contaminated by the spill is cleaned to 25 ppm PCBs by weight
- Post-cleanup sampling is done
Verify that spills in nonrestricted access locations are decontaminated as follows
- Furnishings, toys, and other easily replaceable household items are disposed of and
replaced
- Indoor solid surfaces and high-contact outdoor solid surfaces are cleaned to 10 mg/
100 cm2 (as measured by standard wipe tests)
- Indoor vault areas and low-contact, outdoor, impervious solid surfaces are
decontaminated to 10 mg/100 cm2
- At the option of the facility, low-contact, outdoor, nonimpervious solid surfaces are
cleaned to either 10 or 100 mg/100 cm2 and encapsulated
- Soil is decontaminated to 10 ppm PCBs by weight provided that the soil is
excavated to a minimum depth of 10 in (25 cm) and replaced with clean soil
- Post-cleanup sampling is done
Phase 1 - Section 13
PCB Management
13-18
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Compliance Category;
PCB Management
Regulatory Retirements;
Reviewer Checks:
PCB 20 Continued
Verify that records documenting all cleanup and decontamination are maintained for
five years
(NOTE The occurrence/discovery of the spill on the weekend or overtime costs are
not considered acceptable reasons to delay response )
(NOTE The final numerical cleanup standards do not apply to spills directly into
surface waters, drinking water, sewers, grazing lands, and vegetable gardens)
(NOTE The EPA may impose more stringent or less stringent cleanup requirements
on a case by case basis depending on conditions such as possibility of groundwater
contamination)
PCB Items
PCB 21 PCBs may be used in
heat transfer and hydraulic
systems m a manner other than a
totally enclosed manner at
concentrations less than 50 ppm
if specific requirements are met
(40 CFR 761 30(d) through
761 30(e))
Determine if testing has been conducted to demonstrate that heat transfer or hydraulic
systems that formerly contained PCBs at a concentration greater than 50 ppm now
contain less than 50 ppm PCB
Verify that no fluid containing greater than 50 ppm PCB is added to heat transfer or
hydraulic systems.
Verify that results from analyses which are performed to demonstrate presence of less
than 50 ppm PCB, are retained for confirmation for at least five years
Verify that heat transfer or hydraulic systems are free from leaks of dielectric PCBs
PCB 22 Electromagnets,
switches, and voltage regulators
may contain PCBs at any
concentration if certain
requirements are met (40 CFR
761 30(h))
Verify that no electromagnets are used or stored at the facility that contain greater
than 500 ppm PCB and pose an exposure risk to food or feed
Verify that electromagnets that contain greater than 500 ppm PCB and which pose an
exposure risk to food or feed are inspected at least weekly to determine if they are
leaking
Verify that electromagnets, switches, and voltage regulators that contain 500 ppm or
greater PCB are not rebuilt and no removal or reworking of internal components is
done during servicing
Verify that electromagnets, switches, and voltage regulators which contain between
50 and 500 ppm PCB (PCB contaminated electrical equipment) are only serviced with
dielectric fluid which that less than 500 ppm PCB
Verify that PCBs removed or captured are either reused as dielectric fluid or disposed
of properly
Verify that dielectric fluid containing a mixture of fluids with less than 500 ppm
PCBs are not used as dielectric fluid in any electrical equipment
PCB 23 Capacitors may
contain PCBs at any
concentration subject to certain
requirements (40 CFR
761 30(1)).
Verify that all PCB large, high- and low-voltage capacitors that pose an exposure risk
to food and feed have been removed
Verify that all PCB large, high- and low-voltage capacitors are in use only in
restricted-access electrical substations, or in a contained and restricted-access indoor
area
Verify that capacitors are free from leaks of dielectric PCBs
Phase 1 - Section 13
PCB Management
13-19
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Cowplla&ce Category:
PCB Management
Regulatory {tegairenrefttt;
; Reviewer C&ecJw
PCB 24 Circuit breakers,
reclosers, and cable may contain
PCBs at any concentration for
remainder of their useful lives
subject to certain conditions (40
CFR 761 3(m))
Verify that any circuit breakers, reclosers, and cables used at the facility are serviced
using only dielectric fluid which contains less than 50 ppm PCB and have been free
from leaks
PCBs in Research
PCB 25 The use of pigments
containing PCBs in research or
microscopy or in miscellaneous
items is subject to certain
conditions (40 CFR 761 30(g),
761.300), and 761 30(k)).
Verify that pigments used at the facility contain PCBs in concentrations less than 50
ppm
Verify that pigments are handled in enclosed conditions
PCB Storage
PCB.26. PCBs and PCB items
at concentrations greater than 50
ppm that are to be stored before
disposal must be stored in a
facility that will assure the
containment of PCBs (40 CFR
761 65(a) through 761 65(b) and
761.65(c)(8))
Verify that the following provisions are present by inspecting the PCB storage area.
- The roof and walls of the building in which the PCBs are stored are constructed so
as to exclude rainfall from contacting PCBs and PCB items
- A 6 in (15 24 cm) tall containment curb circumscribes the entire area in which any
PCBs or PCB items are stored Such curbing shall effectively provide containment
for twice the internal volume of the largest PCB Article or 25 percent of the total
internal volume of all PCB articles or containers stored, whichever is greater
- Drains, valves, floor drains, expansion joints, sewer lines or other openings that
would allow liquids to flow from the curbed area are not present
- Floors and curbing are constructed of continuous, smooth, and impervious material
- Location is not below a 100-year flood water elevation
Verify that PCB articles or PCB containers are removed from storage and disposed of
within one year from the date they were placed in storage
PCB 27 PCB items may also be
stored in other areas that do not
comply with the storage area
requirements when such storage
is for a period of less than 30
days and when any such PCB
items are marked with the date
of removal from service (40
CFR 761.65(c)(1))
Verify that only the following items are stored and are properly marked in areas used
as a 30 day storage area
- Nonleaking PCB articles and PCB equipment
- Leaking PCB articles and PCB equipment placed in a non-leaking PCB container
which contains sufficient sorbent material to absorb liquid contained on the PCB
Article or equipment
- PCB containers in which nonliquid PCBs have been placed
- PCB containers in which liquid PCBs at a concentration between 50-500 ppm have
been placed when containers are marked to indicate less than 500 ppm PCB
Verify that area has been included in the facility Spill, Prevention, Control, and
Countermeasure (SPCC) Plan
PCB 28 Nonleaking and
structurally undamaged PCB
large, high-voltage capacitors
and PCB contaminated electric
equipment that have not been
drained of freeflowing dielectric
fluid may be stored on pallets
next to a storage area that
complies with the storage area
Determine if available unfilled storage space in the storage area is equal to at least 10
percent of the volume of capacitors and electrical equipment stored outside
Verify that capacitors and equipment stored outside the storage facility are on pallets
and inspected at least weekly
Phase 1 - Section 13
PCB Management
13-20
-------
Compllaace Category;
PCB Management
Regutetory Retirements;
Bevtewer Cbeefcs;
PCB.29 Specific operational
procedures are required at PCB
storage areas (40 CFR
761 65(c)(4), 761 65(c)(5), and
761 65(c)(8))
Verify that the following practices are conducted at any area where PCBs or PCB
items are stored
- Movable equipment used for handling PCBs and PCB items that directly contact
PCBs is not removed from storage area unless decontaminated
- Inspections for leaks of all PCB articles and PCB containers in storage are done at
least once every 30 days
- Any leaked PCBs are immediately cleaned up and any spill absorbent material
properly disposed
- PCB articles and containers are marked with the date when placed into storage
- PCB articles and PCB containers are positioned so that they can be located by the
date they were placed into storage
- Containers in which PCBs are accumulated have a record that includes quantity and
date of each batch
PCB 30 Containers used for the
storage of PCBs must comply
with the shipping container
specification of the DOT (40
CFR 761 65(c)(6) and
761 65(c)(7))
Verify that DOT specifications are on drums/containers Typical specifications are 5,
5B,17C
(NOTE Containers larger than those specified in DOT specifications 5, 5B, or 17C
may be used for nonliquid PCBs when such containers will provide as much
protection against leaking and exposure to the environment as the DOT specified
containers)
Verify that containers used for storage of liquid PCBs are containers without
removable heads
Verify that if the facility uses containers larger than DOT approved containers it has
prepared a SPCC Plan covering its containers storing PCBs
PCB 31 Commercial storers of
PCB Waste must have final
storage approval (40 CFR
761 65(d))
Determine if the facility is a commercial storer of PCB or has a commercial storer of
PCB waste at the facility
Verify that the commercial storer has final storage approval from the EPA Regional
Administrator for PCB waste
(NOTE Commercial storers were required to file for final storage approval by 2
August 1990. After filing for final approval, they will operate under interim approval
until the a final decision is made on approval)
(NOTE The following storage facilities may be exempt from this requirements for
storage approval
- Storage areas at transfer facilities unless the PCB waste is stored at the transfer
facility for more than 10 consecutive days between destinations
- Storage areas at RCRA-permitted facilities if the facility proves to the Regional
Administrator that the facility's existing RCRA closure plan substantially meets the
requirements for a TSCA closure plan
- Storage areas ancillary to a TSCA approved disposal facility if the disposal
approval contain an expiration date and the current disposal approval's closure and
financial responsibility conditions specifically extend to storage areas ancillary to
disposal)
Phase 1 - Section 13
PCB Management
13-21
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CompJtawe Category:
PCB Management
Regulatory Reqairetneirrtsi
Reviewer Cbecks;
PCB Transportation
PCB 32 A generator who
offers a PCB waste for transport
for commercial offsite storage or
offsite disposal must prepare a
manifest (40 CFR 761 207
through 761 210)
(NOTE This applies to PCB wastes as defined \n 40 CFR 761 3, and that contain
greater than 50 ppm PCB unless the concentration was reduced below 500 ppm by
dilution)
Verify that a manifest has been prepared when needed and that it contains (use EPA
Form 8700-22).
- The identity of PCB waste, the earliest date of removal from service for disposal
and the weight in kg of the waste for bulk load of PCBs
- The unique identifying number of each PCB article container or PCB container, the
date of removal from service, type of waste, and the weight of PCB waste contained
- The serial number if available or other identification for each PCB article not in a
PCB container or PCB article Container, the date of removal from service for
disposal, and weight in kg of the PCB waste in each PCB article
Verify that sufficient copies are prepared to supply the generator, the initial
transporter, each subsequent transporter, and the owner or operator of the disposal
facility with one legible copy each for their records, and one additional copy to be
signed and returned to the generator by the owner or operator of the disposal facility
Verify that the generator maintains a copy of the signed manifest for at least three
years after receipt of waste by the initial transporter
PCB.33. If the generator does
not receive a signed copy of the
manifest within 35 days of the
date the waste was accepted by
the initial transporter, the
generator is required to
immediately contact the
transporter and/or owner or
operator of the designated
facility to determine the status of
the PCB waste (40 CFR
761.215(a) and 761 215(b)).
Verify that a procedure is in place so that if the generator does not receive a copy
within 35 days of the date the waste was accepted by the initial transporter, an
Exception Report is filed with the EPA containing the following information.
- A legible copy of the manifest for which the generator does not have confirmation
of delivery
- A cover letter signed by the generator or his authorized representative explaining
the efforts taken to locate the PCB waste and the results of those efforts
PCB Disposal
PCB.34. For each shipment of
manifested PCB waste that a
disposal facility accepts, the
owner or operator of the
disposal facility must prepare a
COD (40 CFR 761 218).
Verify that a COD has been prepared containing the following information
- The identity of the disposal facility by name, address, and EPA identification
number
- The identity of the PCB waste affected by the COD including reference to the
manifest number for the shipment
- A certification as defined in 40 CFR 761 3
Verify that a copy of the COD was:
- Sent to the generator identified on the manifest within 30 days of the date that
disposal of the PCB waste was completed
- Retained at the facility with the annual report
Phase 1 - Section 13
PCB Management
13-22
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Compltettce Category:
PCB Management
Regulatory Retirements;
Reviewer Checks;
PCB 35 PCB contaminated
fluids other than mineral oil
dielectric fluid of concentrations
greater than 50 ppm but less
than 500 ppm are required to be
disposed of according to specific
requirements (40 CFR
761 60(a)(3))
Determine if any PCB fluids meeting these criteria were processed for disposal in the
last year
Verify that disposal was done at
- A EPA-approved incinerator
- A EPA-approved chemical waste landfill
- A high efficiency boiler
Verify that if the fluid is burned in an high efficiency boiler
- The boiler is rated at a minimum of 50 MBtu/h (14 65 MW)
- The CO concentration in the stack is 50 ppm or less and the excess 02 is at least
three percent when PCBs are being burned and the boiler uses natural gas or oil as
the primary fuel
- The CO concentration in the stack is 100 ppm or less and the 02 content is at least
three percent when PCBs are being burned and the boiler uses coal as the primary
fuel
- The waste does not compromise more than 10 percent (on a volume basis), of the
total fuel feed rate
- The waste is not fed into the boiler unless the boiler is operating at its normal
operating temperature the operator of the boiler does one of the following
-- continuously monitors and records the CO concentrations and excess 02
percentages in the stack gas while burning the waste fluid
-- measure and records the CO concentration and excess 02 percentage in the stack
gas at regular intervals of no longer than 60 minutes if boiler will burn less than
30,000 gal/yr (113,562 36 L/yr) of waste fluid
-- measures and records the primary fuel feed rates, the waste fluid feed rates, and
total quantities of both primary fuel and waste fluid fed to the boiler at regular
intervals of no longer than 15 minutes
-- checks the CO concentration and the excess 02 percentage at least once every
hour and if either measurement falls below the specified levels, the flow of the
waste fluid to the boiler stops immediately.
Verify that before burning waste fluid, approval has been obtained from the EPA
Regional Administrator.
Verify that the following information is obtained by persons burning waste fluid in a
boiler and kept at the boiler location for five years
- Emissions data
- The quantity of waste fluid burned in the boiler each month
- A waste analysis
Verify that such PCB fluids were disposed of by an approved method at a properly
licensed facility
PCB.36. PCB liquids greater
than 50 ppm must be disposed
of in an incinerator which is
approved by EPA to incinerate
PCBs (40 CFR 761 60(a)(1))
Verify that all shipments were made to EPA licensed PCB incinerators by reviewing
manifests for a PCB shipments over the past three years.
(NOTE: Other disposal provisions apply to
- Mineral oil dielectric fluid from PCB-Contaminated Electrical Equipment with a
concentration greater than 50 ppm but less than 500 ppm
- Liquids, other than mineral oil dielectric fluids, with PCB concentrations between
50 and 500 ppm
- Rags, solids, and other debris contaminated with PCB at concentrations greater than
50 ppm
- PCB articles)
Phase 1 - Section 13
PCB Management
13-23
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Compliance Category:
PCB Management
Regulatory Heq&iremerrts:
Reviewer dedau
PCB 37 Mineral oil dielectric
fluid from PCB-contaminated
electrical equipment containing
a PCB concentration greater
than SO ppm but less than 500
ppm is required to be disposed
of according to specific methods
(40 CFR 761 60(a)(2))
Verify that mineral oil dielectric fluid as described is disposed of in one of the
following ways
An EPA approved incinerator
- An approved chemical waste landfill if written information proves that the fluid is
not contaminated at greater than 500 ppm and is not an ignitable waste
- An approved high efficiency boiler that is rated at a minimum of 50 MBtu/h (14 65
MW)
Verify that if the fluid is burned in an high efficiency boiler
- The boiler is rated at a minimum of 50 MBtu/h (14 65 MW)
- The CO concentration in the stack is 10 ppm or less and the excess 02 is at least
three percent when PCBs are being burned and the boiler uses natural gas or oil as
the primary fuel
- The CO concentration in the stack is 100 ppm or less and the 02 content is at least
three percent when PCBs are being burned and the boiler uses coal as the primary
fuel
- The mineral oil dielectric fluid does not compromise more than 10 percent (on a
volume basis), of the total fuel feed rate
- The mineral oil dielectric fluid is not fed into the boiler unless the boiler is
operating at its normal operating temperature
- The operator of the boiler does one of the following
— continuously monitors and records the CO concentrations and excess 02
percentages in the stack gas while burning mineral oil dielectric fluid
-- measure and records the CO concentration and excess 02 percentage in the stack
gas at regular intervals of no longer than 60 minutes if boiler will burn less than
30,000 gal (113,562 36 L) of mineral oil dielectric fluid per year
- measure and record the primary fuel feed rates, the mineral oil dielectric fluid
feed rates, and total quantities of both primary fuel and mineral oil dielectric
fluid fed to the boiler at regular intervals of no longer than 15 min
-- checks the CO concentration and the excess 02 percentage at least once every
hour and if either measurement falls below the specified levels, the flow of the
mineral oil dielectric fluid to the boiler stops immediately
Verify that 30 days before burning mineral oil dielectric fluid, a written notice of the
burning is given the to EPA Regional Administrator
Verify that the following information is obtained by persons burning mineral oil
dielectric fluid in a boiler and kept at the boiler location for five years
- Emissions data
- The quantity of mineral oil dielectric fluid burned in the boiler each month
PCB.38. Rags, soils, and other
debris contaminated with PCBs
at concentrations greater than
50 ppm must be disposed of in a
PCB incinerator or in a chemical
waste landfill
(40 CFR 761 60(a)(4))
Determine if any contaminated soil or debris has been disposed of, and verify that
disposal was conducted at a properly licensed facility
PCB 39 PCB transformers with
PCB concentrations of 500 ppm
or greater shall be disposed of in
either a EPA approved
incinerator or a chemical waste
landfill (40 CFR 761 60(b)(1))
Determine if the PCB transformers are being disposed of at a EPA-approved
incinerator or a chemical waste landfill
Verify that if disposal is being done at a chemical waste landfill the transformer is
drained of all free-flowing liquids, filled with solvent, allowed to stand for at least 18
hours, and than drained thoroughly
Phase 1 - Section 13
PCB Management
13-24
-------
Compliance Category:
PCB Management
Regulatory Reqtrtrementr,
Reviewer Cfcecta
PCB 40 PCB capacitors must
be disposed of in accordance
with certain requirements (40
CFR761 60(b)(2))
Verify that disposal of PCB capacitors was done as follows
- PCB small capacitors (less than 1 36 kg (3 lb) of PCBs) are disposed of in a solid
waste landfill
- PCB large, high- or low-voltage capacitors (greater than 1 36 kg (3 lb) of PCBs)
containing more than 500 ppm are incinerated in a EPA approved incinerator
(NOTE The large, high, or low-voltage capacitors may be disposed of in a chemical
waste landfill upon approval of the EPA )
Verify that capacitors in storage are placed in DOT containers with absorbent
material
PCB 41 PCB hydraulic
machines containing PCBs at
concentrations greater than 50
ppm may be disposed of as
municipal solid waste if specific
conditions are met (40 CFR
761 60(b)(3))
Verify that the machines are drained of all free-flowing liquid
Verify that if the machine contained PCB liquid of 1000 ppm PCB or greater, it is
flushed prior to disposal with a solvent containing less than 50 ppm PCB
PCB 42 PCB contaminated
electrical equipment (50 500
ppm PCB), except capacitors,
shall be disposed of by draining
off the free-flowing liquid (40
CFR 761 60(b)(4))
Verify that the free-flowing liquid is drained from electrical equipment prior to
disposal
PCB 43 PCB articles shall be
disposed of properly (40 CFR
761 60(b)(5))
Verify that PCB articles with concentrations at 500 ppm or greater are disposed of in
either
- A EPA-approved incinerator
- A chemical waste landfill if all free-flowing liquids have been removed
Verify that PCB articles with PCB concentration between 50 and 500 ppm are drained
of all free-flowing liquid
PCB 44 PCB containers shall
be disposed of properly (40 CFR
761 60(c))
Verify that PCB containers with concentrations of 500 ppm or greater are disposed of
in one of the following ways
- In a EPA-approved incinerator
- In a chemical waste landfill if first the container is drained of any liquid PCBs
Verify that PCB containers used to contain only PCBs at concentrations less than 500
ppm are drained of PCB liquid prior to disposal as municipal solid waste
PCB 45 PCB contaminated
fluids other than mineral oil
dielectric fluid of concentrations
greater than 50 ppm but less
than 500 ppm shall be disposed
of properly (40 CFR
761 60(a)(3))
Determine if any PCB fluids meeting these criteria were processed for disposal in the
last year
Verify that disposal was done at
- A EPA-approved incinerator
- A EPA-approved chemical waste landfill
- A high efficiency boiler, if
-- the boiler is rated at a minimum of 50 MBtu/h
-- the boiler uses natural gas or oil
Verify that such PCB fluids were disposed of by an approved method at a properly
licensed facility
Phase 1 - Section 13
PCB Management
13-25
-------
Section 13
PCB Management
Appendices
-------
Appendix 13-1
PCB Label Format
Caution
Contains
PCBs
(Polychlorinated Biphenyls)
A toxic environmental contaminant requiring special
handling and disposal in accordance with the U.S.
Environmental Protection Agency Regulations
40 CFR 761.
For disposal information, contact the nearest U.S. EPA
office.
In case of accident or spill, call toll free the U.S. Coast
Guard National response Center: 800-424-8802.
Also contact:
Tel. no. i
A13-1
-------
Appendix 13-2
Dielectric Fluid Trend Names and Manufacturers
s s S
" --- v .... .jr -
Mpofatmm" t - "",,4 .1. ^
1 US Manufactured Dielectrics
Aroclor
Monsanto
Aroclor B
Mallory
Sbestol
American Corporation
Askarel Hevi-Duty
Hevi-Duty Corporation
Askarel *
Ferranti-Packard, Ltd
Askarel
Universal Mfg Co
Chlorextol
Allis-Chalmers
Chlorinol
Sparagoe Electric
Chlorphen
Jard Company
Diaclor
Sangamo Electric
Dykanol
Cornell Dubilier
Elemex
McGraw Edison
Eucarel
Electric Utilities Co
Hyvol
Aerovox
Inerteen
Westinghouse Electric
No-Flamol
Wagner Electric
Pyranol
General Electric
Saf-T-Kuhl
Kuhlman Electric
* Generic name used for insulating liquids in capacitors and transformers.
2 Foreign Manufactured Dielectrics
Clophen
Bayer (Germany)
Fenclo
Caffaro (Italy)
Kennechlor
Mitsubishi (Japan)
Phenoclor
Prodelec (France)
DK
Caffaro (Italy)
Pyralene
Prodelec (France)
Solvol
USSR
Santotherm
Mitsubishi (Japan)
3 Transformers that list other dielectrics or do not bear a manufacturer's identification or service plate on the
transformer: if the transformer contains any of the dielectrics (commonly referred to as askarels), it is to be
certified as a PCB transformer containing in excess of 500 ppm PCB and no laboratory testing is necessary
A13-2
-------
Phase 1
Section 14
Pesticide Management
-------
Phase 1
Section 14
Table of Contents
Pesticide
A. Applicability 14-1
B. Federal Legislation 14-1
C. State/Local Regulations 14-1
D. Key Compliance Requirements 14-2
E. Key Compliance Definitions 14-3
F. Records to Review 14-5
G. Physical Features to Inspect 14-5
H. Guidance for Checklist Users 14-6
Appendix
A14-1. Restricted Use Pesticides A14-1
-------
A. Applicability
This section applies to facilities which use, store or handle pesticides. Pesticides are
regulated on the Federal and state levels.
Assessors are required to review agency, Federal, state, and local regulations in order to
perform a comprehensive assessment.
It must be noted that pesticides by nature are hazardous materials and are subject to
hazardous materials management regulations. Please see Section 8, Hazardous Materials
Management. In this manual, the term pesticides includes herbicides and fungicides.
B. Federal Legislation
1. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
This Act, as last amended in December 1991 (7 U.S. Code (USC) 136-136(y)), deals with
the sale, distribution, transportation, storage, and use of pesticides It requires the registration of
new pesticides and, when pesticides are preregistered, requires that they will not present any
unreasonable risks to human health or the environment if used according to label directions.
2. Executive Order (EO) 12088, Federal Compliance with Pollution Standards
This EO, dated 13 October 1978, requires federally owned and operated facilities to comply
with applicable Federal, state, and local pollution control standards. It makes the head of each
executive agency responsible for seeing to it that the agencies, facilities, programs, and activities
it funds meet applicable Federal, state, and local environmental requirements or to correct
situations that are not in compliance with such requirements. In addition, the EO requires that
each agency ensure that sufficient funds for environmental compliance are included in the agency
budget.
C. State/Local Requirements
State pesticide regulatory programs are to be at least as stringent as FIFRA State and local
programs typically contain regulations which are tailored to an industry or activity which is
prevalent or particularly sensitive in a state. State and local pesticide regulations in many cases
provide more stringent standards or specifically identify a requirement which may be
qualitatively regulated under the Federal program. State and local pesticide programs generally
include regulations which address the following topics:
1. Restrictions or requirements for the sale, distribution, or use of selected pesticides;
2. Disposal requirements for excess pesticides and pesticide wastes such as pesticide
containers;
3. Restrictions on the control of specific animal or insect species;
Operational requirements for selected application methods; and
Phase 1 - Section 14
Pesticide Management
14-1
-------
4. Recordkeeping and applicator certification requirements. This may require that applicators
practice Integrated Pest Management (IPM) techniques.
D. Key Compliance Requirements
1. Pesticide Application
People applying restricted use pesticides must be certified to purchase and apply restricted
use pesticides. Contractors used for pest management must have current certification for the
types of applications to be performed. The application of pesticides must not jeopardize the
existence of threatened or endangered species. (40 CFR 171.9 and 50 CFR 402).
2. Pesticide Storage, Mixing, and Preparation Facilities
Pesticide storage, mixing, and preparation activities must provide facilities and procedures
to ensure safety of personnel. Facilities such as a ventilation system for all indoor pesticide
mixing/preparation areas and an emergency deluge shower and eyewash station located to
provide immediate access to all personnel performing mixing. Personal protective clothing and
equipment need to be provided and used by pest management personnel. Pesticides, pesticide
container, and/or pesticide residues are to be stored such that it is not inconsistent with labeling
(40 CFR 165.7).
3. Highly Toxic and Moderately Toxic Pesticide Storage and Use
Storage facilities for pesticides and excess pesticides classed as highly toxic or moderately
toxic that are labeled DANGER, POISON, or with the skull and crossbones symbol, must meet
specific structural, operational (e.g., ventilation) and storage requirements. These include
pesticides being kept in a dry, separate room (building) with fire protection and not near food or
feed, and in containers in good condition with plainly visible labels. There should be a
decontamination facility, the area must be placarded and the local fire department, hospitals,
public health officials, and police departments should be notified in writing that the pesticides are
being stored (MP).
4. Pesticide and Container Disposal
Facilities are required to dispose of any excess pesticide, pesticide container, or pesticide
residue in a manner consistent with labeling, not including open dumping or burning. Organic
pesticides other than organic mercury, lead, cadmium, and arsenic compounds, must be disposed
according to specific procedures. Options include incineration at an incinerator that meets air
quality standards for gaseous emissions. Metallo-organic pesticides must be disposed of in a
manner that facilities the recovery of heavy metals (40 CFR 165.7, 165.8 and 165.9).
5. Recordkeeping
Regardless of the regulatory requirements concerning the length of time which records must
be kept, it is advisable to maintain application and disposal records beyond the regulated periods
of time in order to support facility compliance.
Phase 1 • Section 14
Pesticide Management
14-2
-------
E. Key Compliance Definitions
1. Acute LDjo
A statistically derived estimate of the concentration of a substance that would cause 50
percent mortality to the test population under specified conditions (40 CFR 152.3).
2. Caution
The human hazard signal word required on the front panel of a pesticide container
determined by the Toxicity Category of the pesticide. All pesticide products meeting the criteria
of Toxicity Category III or IV must bear on the front panel the signal word CAUTION (see
Toxicity Category (40 CFR 156.10(h)).
3. Commercial Applicator
A certified applicator, other than a private applicator, who uses or supervises the use of any
pesticide, for any purpose, on any property, or performs other pest control related activities (40
CFR 171.2).
4. Crisis Exemption
This is utilized in an emergency condition when the time from discover)' of the emergency
to the time when the pesticide use is needed is insufficient to allow for the authorization of a
specific quarantine exemption or public health exemption (40 CFR 166.2)
5. Danger
The human hazard signal word required on the front panel of a pesticide container
determined by the Toxicity Category of the pesticide. All pesticide products meeting the criteria
of Toxicity Category I must bear on the front panel the signal word DANGER (see Toxicity
Category) (40 CFR 156.10(h)).
6. Imminent Hazard
A situation that exists when the continued use of a pesticide during the time required for
cancellation proceedings would be likely to result in unreasonably adverse effects on the
environment or will involve unreasonable hazard to the survival of a species declared endangered
by the Secretary of the Interior (SOI) under PL 91-135 (40 CFR 165.1).
7. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
8. Pesticide
Any substance or mixture of substances intended for preventing, destroying, repelling, or
mitigating any pest, or intended for use as a plant regulator, defoliant, or disinfectant; and is
further categorized into the following (40 CFR 165.1)-
Phase 1 - Section 14
Pesticide Management
14-3
-------
a. Excess pesticides means all pesticides that cannot be legally sold pursuant to the Act or
that are to be discarded;
b. Organic pesticides means carbon-containing substances used as pesticides, excluding
metallo-organic compounds;
c. Inorganic pesticides means noncarbon-containing substances used as pesticides;
d. Metallo-organic pesticides means a class of organic pesticides containing one or more
metal or metalloid atoms in the structure.
9. Pesticide Product
A pesticide in the particular form (including composition, packaging, and labeling) in which
the pesticide is, or is intended to-be,-distributed or sold. This includes any physical apparatus
used to deliver or apply the pesticide if distributed or sold with the pesticide (40 CFR 152.3).
10. Public Health Exemption
This may be authorized in an emergency condition to control a pest that will cause a
significant risk to human health (40 CFR 166.2).
11. Quarantine Exemption
This may be authorized in an emergency condition to control the introduction or spread of
any pest new to or not theretofore known to be widely prevalent or distributed within and
throughout the United States and its territories (40 CFR 166.2).
12. Restricted Use Pesticides
Pesticides designated for restricted use under the provisions of Section 3(d)(1)(c) of FIFRA
(40 CFR 171.2)
13. Specific Exemption
This exemption may be authorized in an emergency condition to avert (40 CFR 166.2):
a. A significant economic loss;
b. A significant risk to endangered species, threatened species, beneficial organisms, or the
environment.
14. Toxicity Category
Required warnings and precautionary statements are based on the Toxicity Category of the
pesticide. The category is assigned on the basis of the highest hazard shown in the table listed in
40 CFR 156.10 (40 CFR 156.10(h)).
15. Warning
Phase 1 - Section 14
Pesticide Management
14-4
-------
The human hazard signal word required on the front panel of a pesticide container
determined by the Toxicity Category of the pesticide. All pesticide products meeting the criteria
of Toxicity Category II shall bear on the front panel the signal word WARNING (see 40 CFR
156.10 for listing of indicators necessary to meet specific criteria of toxicity categories) (40 CFR
156 10(h)).
F. Records to Review
• Records of pesticides purchased by the facility (purchase orders, inventory),
• Pesticide application records and annual reports,
• Description of the management of the facility's pest control program;
• Certification status of pesticide applicators;
• Pesticide disposal manifests and records,
• Contract files;
• Respiratory protection program (qualification, medical monitoring and respirator
maintenance/cartridge replacement);
• Any emergency exemption granted to the Federal agency by the EPA;
• Disposal of pesticide containers; and
• Monitoring of applicator's health status.
G. Physical Features to Inspect
• Personnel protection equipment;
• Pesticide application equipment;
• Pesticide storage areas, including storage containers;
• Observation of pesticide applications, procedures and protective equipment; and
• Disposal of used containers and pesticide waste (if any)
Phase 1 - Section 14
Pesticide Management
14-5
-------
H. Guidance for Checklist Users
Refer To
Checklist Items
Page Numbers
All facilities
PM 1 through PM 3
PM 4 through PM 5
14-7
14-8
Pesticide application
PM 6 through PM 10
PM. 11 through PM 12
14-9
14-10
Storage, mixing, or preparation areas
PM 13 through PM 14
PM 13 through PM 15
14-10
Highly and moderately toxic pesticides
PM 19
PM 20 through PM.22
PM 23
PM 24 through PM 25
PM 26
14-11
14-12
14-13
14-14
14-15
Mixing/formulation facilities
PM 27
14-15
Disposal
PM 28 through PM 29
PM 30 through PM 31
PM 32 through PM 33
14-15
14-16
14-17
Agricultural pesticides
PM.34 through PM 35
14-18
Phase 1 - Section 14
Pesticide Management
14-6
-------
Compliance Category:
Pesticide Maoagemea t
Regulatory Iteqtiiremeats;
Reviewer Checks:
All Facilities
PM 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
actionyidentifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, interagency
agreements or equivalent state enforcement actions For those open items, indicate
what corrective action is planned and milestones established to correct problems
PM 2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of
the applied regulation as a basis
of finding)
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist
Verify that the facility is in compliance with all applicable and newly issued
regulations
PM 3 Facilities are required to
comply with state and local
pesticide regulations concerning
pesticide management (EO
12088, Section 1-1)
Verify that the facility is abiding by state and local requirements
Verify that the facility is operating according to permits issued by the state or local
agencies
(NOTE Issues typically regulated by state and local agencies include
- Applicator certification
- Restricted use pesticides
- Application procedures
- Banned pesticides
- Disposal methods
- Emergency application of pesticides due to public health threats
- Annual reporting of usages
- Application health monitoring
- Record of each application including target pest)
Phase 1 - Section 14
Pesticide Management
14-7
-------
Compliant Category:
PesOcideMatmgewettt
Regulatory Requirements;
: fteviewer Cfcecfcst,
PM.4 All pesticides present on
the facility must be registered or
ruled exempt from the
registration requirements (40
CFR152 15 through 152 30)
Verify that pesticide products at the facility are registered unless the facility or
product is considered exempt, such as the following.
- Certain biological control agents
- Certain human drugs
- Treated articles or substances such as paint treated with a pesticide
- Pheromones and pheromone traps
- Preservatives for biological specimens
- Vitamin hormone products
- Pesticide transferred between registered establishments operated by the same
producer
- A pesticide distributed or sold under an experimental use permit
- A pesticide transferred solely for export
- A pesticide distributed or sold under an emergency exemption
PM 5 All facilities must
comply with pesticide use
requirements unless an
emergency exemption has been
granted by the EPA (40 CFR
166 1, 166.2, 166 20, 166 28,
166 32, 166 45, 166 50).
Verify that pesticide use requirements are followed unless one or more of the
following emergency conditions exist
- Specific exemptions may be authorized to avoid conditions of
- Significant economic loss
- Significant risk to threatened or endangered species
- Significant risk to beneficial organisms
- Significant risk to the environment
- Quarantine exemptions may be authorized to control the introduction or spread of
any pest new to or unknown to be widespread throughout the United States and its
territories
- Public health exemptions may be authorized to control a pest that imposes
significant risk to human health
- Crisis exemptions may be utilized when the time constraint between discovery, and
implementation of pesticide use will not allow a specific, quarantine, or public
health exemption to be issued
Verify that applications for exemptions are submitted to the Regional Administrator in
writing and include'
- A description of the pesticide
- The proposed use
- Target organism
- Any alternative means of control and why those means are not feasible
Verify that exemptions are issued for a specific length of time, as follows
- No more than one year for specific and public health exemptions
- For no longer than three years for a quarantine permit, but it may be renewed
- No longer than 15 days (unless an application for another type of exemption has
been submitted) for an crisis exemption.
Verify that any unexpected adverse affects from the use of a pesticide under
exemption conditions are be reported to the EPA
Verify that a report summarizing the use of a pesticide under an exemption was
submitted within six months after the expiration of the exemption to the agency (three
months for a crisis exemption).
Phase 1 - Section 14
Pesticide Management
14-8
-------
Compliance Category:
Pesticide Management
Regulatory Requirements;
| Reviewer Checks:
Pesticide Application
PM 6 Persons applying
restricted use pesticides must be
certified to apply restricted use
pesticides (40 CFR 1719)
Determine if facility personnel apply restricted use pesticides (see Appendix 14-1).
Determine if pesticide applicators are trained and/or certified
Verify that training recertification is scheduled and performed as required to maintain
certification and that certification is relevant to the pest management activities
undertaken
Verify the certification status of contractors used for pest management through
interviews or contract review
PM.7. Personnel routinely
applying any pesticides should
be trained in safety procedures
and application procedures
(MP)
Determine if personnel at the facility routinely apply pesticides
Verify that personnel are trained in appropriate handling and use procedures.
PM 8 Health monitoring
should be provided for
government personnel applying
restricted use pesticides (MP)
Verify that all pest management personnel have received baseline physical
examinations within 30 days of starting pest management work
Verify that pest management personnel receive additional physical examinations once
each year
Verify that chohnesterase tests are given to pest management personnel working
regularly with pesticides which contain organophosphates or N-alkyl-carbamates
PM 9 Public safety should be
ensured when applying or using
pesticides (MP)
Verify the elimination of hazardous exposure to the general public by checking for the
following
- Appropriate signs for treatment area are posted
- Scheduling for low use periods or restricted usage for a number of days
- Water use restrictions and reentry times are followed according to the pesticide
labels
PM 10 Records should be
maintained of each application
of a pesticide, whether
performed by facility staff or
contract labor, and retained at
the facility (MP)
Verify that records are kept on file for a minimum of three years
Verify that the record of each application includes information (e g, target organism,
compound applied, dilution, quantity applied, notification/posting done, etc), based
on individual state requirements
Phase 1 - Section 14
Pesticide Management
14-9
-------
Compliance Category: !
Pesticide Management
Regulatory Requirements:
Reviewer Checks:
PMll. Facilities must ensure
that the use of pesticides does
not jeopardize the existence of
threatened or endangered
species (50 CFR 402 01)
Determine if surveys have been conducted to identify the presence of threatened or
endangered species in areas where pesticides are used
Determine what measures are taken to ensure that threatened or endangered species
are not impacted
Verify that applications are made according to label instructions regarding the
protection of endangered species
(NOTE Refer to the checklist items on endangered species in Natural Resources
Management)
PM 12 Dining facilities should
be notified at least 24 hours in
advance of a pesticide
application (MP)
Verify that food services personnel are notified of scheduled applications and that
only compounds and procedures labelled for food service are used by applications
certified in the food processing category
Storage/Mixing/Preparation Areas
(NOTE. Storage areas must also meet the general requirements for the storage of hazardous materials found in 29 CFR
1910 106, see Hazardous Materials Management protocol)
PM 13 Facilities are required
to store any pesticide, pesticide
container, or pesticide residue
according to specific
restrictions (40 CFR 165 7)
Verify that pesticides, pesticide containers, and/or pesticide residues are stored such
that they are consistent with labeling
PM 14 Pesticide storage,
mixing and preparation
facilities must provide
structures and procedures to
ensure safety of personnel (29
CFR 1910 133).
Determine if a ventilation system is specifically provided for all indoor pesticide
mixing/preparation areas
Verify that an emergency deluge shower and eyewash station are located to provide
immediate access to all personnel performing mixing
Verify that personal protective clothing and equipment is provided and used by pest
management personnel The following equipment depends upon magnitude and type
of operations
- Respirators
- Masks
- Gloves (appropriate kinds)
- Safety shoes
- Coveralls
- Barrier aprons
- Specialized personal protective equipment for fumigation.
Verify that operations include health and safety procedures emphasizing good work
habits, reduction or elimination of hazards (through the use of engineering controls),
and use of personal protective equipment
Phase 1 - Section 14
Pesticide Management
14-10
-------
Compliance Category:
PesticideMaaageraeBt
Regulatory Requirements;
Reviewer Checks:
PM 15 A spill containment
system constructed of
impervious materials should
provide containment for
pesticide storage, mixing,
preparation and management
areas (MP).
Verify that there is curbing around the required areas
Determine if there are drains or cracks in floors
Determine if pest management shop personnel are familiar with spill response
procedures
Verify that spill response procedures are written and understood by staff
PM 16 Storage facilities for
pesticides should have
ventilation at a rate of 10 air
changes/hour (MP)
Verify that storage facilities for pesticides have ventilation at a rate of 10 air changes/
hour
PM 17. Storage facilities for
pesticides should have separate
drainage systems and fire
suppression/extinguishers (MP).
Verify that fire extinguishers are installed near the door of pesticide storage room or
an automatic fire suppression system is in place and working
Verify that the drainage systems are separated from the regular systems
PM. 18 Pesticide storage areas
should be inspected quarterly
by certified applicator
ersonnel (MP)
Verify that pesticide storage areas are inspected
Highly and Moderately Toxic Pesticides
PM 19 Storage facilities for
pesticides classified as highly
toxic or moderately toxic which
are required to be labeled with
DANGER, POISON,
WARNING, or the skull and
crossbones symbol should meet
specific structural requirements
(MP)
Verify that storage is in a dry, separate room, building, or covered area where fire
protection is provided and that the building is clearly placarded on the exterior
Verify that when relevant and practicable, the entire storage facility is secured by a
climb-proof fence and the doors and gates are kept locked
Verify that pesticides are not stored near food or feed
(NOTE: These MPs are based on recommendations found in 40 CFR 165 10(c)(1))
Phase 1 - Section 14
Pesticide Management
14-11
-------
Compliance Category:
Pesticide Management
Regulatory Requirements:
Reviewer Cheeks;
PM 20 The storage of
pesticides classified as highly
toxic or moderately toxic which
are required to be labeled with
DANGER, POISON,
WARNING, or the skull and
crossbones symbol should meet
specific operational
requirements (MP)
Verify that pesticide containers are stored with the label plainly visible
Verify that all containers are in good condition
Verify that the lids and bungs on metal or rigid plastic containers are tight
Verify that the pesticides are segregated
Verify that a complete inventory is kept indicating the number and identity of
containers in a storage unit (See PM 25 for posting requirements )
Verify that containers are regularly inspected for corrosion and leaks and that
absorbent material is available for spill cleanup
Verify that diluted oil based pesticides are stored separately from other materials since
they are flammable
Verify that excess pesticides and containers are segregated
(NOTE These MPs are based on recommendations found in 40 CFR 165.10(d))
PM 21 Pest management
programs which use pesticides
classified as highly toxic or
moderately toxic and are
required to bear the signal
words DANGER, POISON,
WARNING, or the skull and
crossbones symbol on the label
should have decontamination
facilities (MP)
Determine if facilities are available for personnel decontamination and where they are
located.
Determine if facilities are available for the decontamination of equipment, including
vehicles which have been used for pesticide applications
Verify that berms, curbing, surfaces, and catchment drains used to impound
washwater resulting from decontamination are impervious
Verify that drains impound washwater and are not connected to sanitary sewer or
stormwater systems
Verify that the procedure for disposal of washwater resulting from decontamination
activities is the same as for excess pesticides
(NOTE These MPs are based on recommendations found in 40 CFR 165 10(c)(3)
and 165 10(c)(4))
PM 22 Equipment used for
pesticides applications may not
be removed from a
decontamination site unless
thoroughly decontaminated
(MP)
Verify that prior to removal from a site, vehicles are decontaminated
(NOTE This MP is based on recommendations found in 40 CFR 165 10(c)(2) and
165 10(e)(l)(v))
Phase 1 - Section 14
Pesticide Management
14-12
-------
Compliance Category:
Pesticide Maoageraeat
Regulatory Requirements:
Reviewer CheefcM
PM 23 Storage of pesticides
and excess pesticides that are
classified as highly toxic or
moderately toxic and are
required to be labeled
DANGER, POISON,
WARNING, or the skull and
crossbones should meet specific
requirements (MP)
Verify that the site location, where possible, is in an area where flooding is unlikely
and where hydrogeologic conditions prevents contamination of any water system by
runoff or percolation by
- Inspecting area surrounding facilities and determining proximity to surface water
- Noting location relative to floodplains, depth of groundwater, and general soil types
and typical permeabilities
- Verifying that the spill management system is in existence
Verify that an environmental monitoring system exists for facilities which do not have
spill management system when the facility handles large quantities of pesticides and is
located near sensitive environmental receptors The reviewer should
- Note approximate quantity of pesticides and location of sensitive environmental
receptors
- Check whether groundwater, or surface water, or air monitoring program exists to
determine any effects caused by pesticide storage, mixing and preparation
- Inspect facility operations and layout to determine if operations are likely to allow
runoff of water which may have contacted pesticides
(NOTE- The Clean Water Act specifies certain pesticides which may trigger
additional monitoring/reporting requirements (Aldrin/Dieldrin, DDT, Endrin,
Toxaphene) (40 CFR 129).)
Verify that, when needed, drainage from the site is contained by natural or artificial
barriers or dikes
(NOTE- These MPs are based on recommendations found in 40 CFR 165 10(b))
Phase 1 - Section 14
Pesticide Management
14-13
-------
Compliance Category:
Pesticide Management
Regulatory Requirements;
Reviewer Checks
PM 24 Facilities which
store/use pesticides that are
classified as highly toxic or
moderately toxic and are
required to bear the signal
words DANGER, POISON,
WARNING, or the skull and
crossbones symbol should
provide facilities and
procedures to ensure the safety
of personnel (MP)
Verify that no food consumption, drinking, smoking, or tobacco use is undertaken in
any area where pesticides are present
Verify that the following practices are performed in pest management operations
- Persons handling pesticides keep hands away from mouths and eyes and wear
rubber gloves during all pesticide handling
- Persons handling pesticides wash hands immediately upon completion of working
with pesticides and always prior to eating, smoking or using toilet facilities
- Persons handling concentrated pesticides wear protective clothing which is
removed if found to be contaminated
- A stock of clean protective clothing and respirators is available
- Self-contained breathing apparatus and impermeable suits are available when
handling pesticides which present the potential of being absorbed through the skin
- Inspections are made once a month to determine if any pesticide containers are
leaking
- Pesticide containers are inspected for leakage prior to handling
- Unauthorized persons are not allowed in storage areas
Verify that the following accident prevention measures are done
- Containers are not manhandled
- Unauthorized persons are not allowed in the storage area
- Pesticides are not stored next to food or feed or other articles intended for
consumption by humans or animals
- All vehicles are inspected prior to departure
(NOTE These MPs are based on recommendations found in 40 CFR 165 10(e) and
165 10(f))
PM 25 Pesticide storage
facilities and equipment which
contain or use pesticides
classified as highly toxic or
moderately toxic and are
labeled DANGER, POISON,
WARNING, or the skull and
crossbones symbol should have
signs and safety procedures
posted (MP)
Verify that signs which read DANGER POISON, PESTICIDE STORAGE, are placed
on or near entries to storage facilities
Verify that safety precautions and accident prevention measures are posted
Verify that an inventory of pesticides is displayed outside of the storage facility
identifying all chemicals in storage.
Verify that mobile equipment used for pesticide applications is labeled
CONTAMINATED WITH PESTICIDES
(NOTE These MPs are based on recommendations found in 40 CFR 165 10(c)(2)
through 165 10(c)(3), 165 10(e), and 165 10(g)(2))
Phase 1 - Section 14
Pesticide Management
14-14
-------
Compliance Category:
l Pesticide Management
Regulatory D&guiireatattt;
Reviewer Cfeecfe:
PM 26 Where large quantities
of pesticides classified as highly
toxic or moderately toxic and
are labeled DANGER,
POISON, WARNING, or the
skull and crossbones symbol are
being stored, or other
conditions warrant, the local
fire department, hospitals,
public health officials, and
police department should be
notified in writing that
pesticides are being stored in
the event of a fire (MP)
Verify that notification has been submitted and includes a statement of the hazards
that pesticides may present during a fire
Verify that a floor plan of the storage facility indicating the location of the different
pesticide classifications has been submitted to the fire department
Verify that the fire chief has the home telephone numbers of the person(s) responsible
for the pesticide storage facility
(NOTE These MPs are based on recommendations found in 40 CFR 165 10(g)( 1))
Mixing/Formulation Facilities
PM 27 Mixing/formulation
areas should meet specific
standards (MP)
Determine if the facility has any mixing/formulation areas
Verify that enclosed mixing areas have a local exhaust ventilation with a minimum
face velocity of 100 linear feet per minute to control toxic vapors
Verify that drainage systems are separate from the regular system
Disposal
PM 28 Facilities are required
to dispose of any pesticide,
pesticide container, or pesticide
residue according to specific
restrictions (40 CFR 165 7)
Verify that pesticides, empty pesticide containers, and/or pesticide residues are
disposed of such that
- Disposal is not inconsistent with labeling
- Open dumping of pesticides or pesticide containers is not done
- Open burning is not done except when allowed by state and local regulation
- Water dumping or ocean dumping does not occur
PM 29 Organic pesticides,
except organic mercury, lead,
cadmium, and arsenic
compounds should be disposed
of according to specific
procedures (MP)
Determine if the facility uses organic pesticides
Verify that the organic pesticides are disposed of through incineration at an
incinerator which meets the air quality standards for gaseous emissions, or in a
specially designated landfill if incineration is not available, or by another approved
method
(NOTES
- Municipal solid waste incinerators may be allowed to be used to incinerate
pesticides and pesticide containers if they meet criteria of the state
- These MPs are based on guidelines found m 40 CFR 165.8 and 165 9 )
Phase 1 - Section 14
Pesticide Management
14-15
-------
Compliance Category:
Pesticide Management
Regulatory Rtquiremeats:
3Kevie*er Checks:
PM.30 Metallo-organic
pesticides, except organic
mercury, lead, cadmium, or
arsenic compounds should be
disposed of according to
specific procedures (MP)
Determine if the facility uses metallo-organic pesticides
Verify that metallo-organic pesticides are subjected to an appropriate chemical or
physical treatment to recover the heavy metals from the hydrocarbon structure prior to
disposal.
Verify that metallo-organic pesticides are disposed of through incineration at an
approved incinerator, or in a specially designated landfill, or by another approved
method
(NOTE- These MPs are based on guidelines found in 40 CFR 165.8 and 165 9 )
PM 31 Organic mercury, lead,
cadmium, arsenic, and all
inorganic pesticides should be
disposed of according to
specific procedures (MP)
Determine if the facility uses organic mercury, lead, cadmium, arsenic, or any
inorganic pesticides
Verify that these pesticides are converted to a nonhazardous compound and the heavy
metal resources are recovered
Verify that, if chemical deactivation facilities are not available, these pesticides are
encapsulated and buried in a specially designated landfill and records sufficient to
permit location and retrieval are maintained
Determine if an alternate method of disposal has been approved
(NOTE- These MPs are based on guidelines found in 40 CFR 165 8 and 165 9)
Phase 1 - Section 14
Pesticide Management
14-16
-------
Compliance Category:
PesticideMaaagetaeot
Regulatory Requirements;
Jtevletver Checits:
PM 32 Containers should be
disposed of according to their
classification as either a Group
I, Group II, or Group III
container (MP)
Determine which of the following types of containers the facility has onsite
- Group 1 Containers combustible containers which formerly contained organic or
metallo-organic pesticides
- Group II Containers noncombustible containers which formerly held organic or
metallo-organic pesticides
- Group III Containers containers (both combustible and noncombustible) which
formerly held organic mercury, lead, cadmium, or arsenic or inorganic pesticides
Verify that Group I containers are disposed of in an incinerator or buried in a
specially designated landfill
(NOTE Small quantities of Group I containers may be burned in open fields by the
user of the pesticide when allowed by the state)
Verify that Group II containers are triple rinsed
Verify that Group II containers in good condition are returned to the manufacturer,
formulator, or drum reconditioner to reuse with the same chemical class of pesticides
Verify that Group II containers which are going to be transported to a facility for
recycling as scrap metal or for disposal are punctured
Determine if rinsed Group II containers are crushed and disposed of in a landfill
according to state or local requirements
Verify that unnnsed Group II containers are disposed of in a specially designated
landfill or incinerated
Verify that Group III containers which are not rinsed are encapsulated and disposed of
in a specially designated landfill
(NOTE
- Group III containers which are rinsed may be disposed of in a sanitary landfill
- These MPs are based on guidelines found in 40 CFR 165.8 and 165 9.)
PM.33 Pesticide residues and
rinse liquids should be added to
spray mixtures or disposed of
according to their pesticide type
(MP)
Verify that pesticide residues or rinse liquids are reused.
Verify that if they are not reused they are disposed of according to their pesticide
type
(NOTE These MPs are based on guidelines found in 40 CFR 165 8 and 165 9 )
Phase 1 - Section 14
Pesticide Management
14-17
-------
Compliance Category:
Pesticide Management
Regulatory Requirement;
Reviewer Checks
Agricultural Pesticides
PM 34 Agricultural pesticides
must be applied in a manner
that workers or other persons,
except those knowingly
involved in the application, are
not exposed either directly or
through drift (40 CFR 170.3(a)
and 170.4(c))
Determine if the facility applies agricultural pesticides
Verify that the area being treated is vacated by unprotected persons
(NOTE- These requirements do not pertain to
- Mosquito abatement treatment and related public pest control programs
- Greenhouse treatments which are applied in accordance with labeling directions and
restrictions
- Livestock and other animal treatments which are applied in accordance with
labeling directions and restrictions
- Treatment of golf courses and similar non-agricultural areas which are applied in
accordance with labeling directions and restrictions )
Verify that workers are warned when a field is to be treated and when a field has been
treated
PM.35 Workers not wearing
protective clothing shall not be
allowed to enter a field treated
with sprays until specific
conditions are met (40 CFR
170.3(b) and 170 4(c))
Verify that workers without protective clothing do not enter fields that have been
sprayed until the labelled reentry times have elapsed
Verify that if the following pesticides are used, the indicated reentry times are
observed
- Ethyl parathion: 48 hours
- Methyl parathion- 48 hours
- Guthion- 24 hours
- Demeton: 48 hours
- Azodrin- 48 hours
- Phosalone 24 hours
- Carbophenothion. 48 hours
- Metasystox-R 48 hours
- EPN 24 hours
- Bidrin 48 hours
- Endnn 48 hours
- Ethion 24 hours
(NOTE. Check labels to verify these reentry times have not changed.)
(NOTE. These requirements do not pertain to.
- Mosquito abatement treatment and related public pest control programs
- Greenhouse treatments which are applied in accordance with labeling directions and
restrictions
- Livestock and other animal treatments which are applied in accordance with
labeling directions and restrictions
- Treatment of golf courses and similar non-agricultural areas which are applied in
accordance with labeling directions and restrictions.)
Phase 1 - Section 14
Pesticide Management
14-18
-------
Section 14
Pesticide Management
Appendices
-------
Appendix 14-1
Restricted Use Pesticides
(40 CFR 152.175)
The following uses of pesticide products containing the active ingredients specified below have been
classified for restricted use and are limited to use by or under the direct supervision of a certified
applicator
NOTE These may vary from state to state. The auditor must check each state, some compounds are not
permitted and for others, the trigger concentrations may be lower.
NOTE- Any applications made by a certified applicator must be recorded and done in accordance with
the labelled instructions, even if the compounds are not restricted use pesticides
••v s "•
Sfownufetfem ....
s s s ¦* %
s <
Critarta Mlae»cJag
Acrolein
As sole active ingredient No
mixtures registered
All uses
Restricted
Inhalation hazard to humans
Residue effects on avian
species and aquatic organisms
Acrylonitrile
In combination with carbon
tetrachloride No registrations
as the sole active ingredient
~do
do
Other hazards-accident history
of acrylonitrile and carbon
tetrachloride products
Aldicarb
As sole active ingredient No
mixtures registered
Ornamental uses
(indoor and outdoor)
Agricultural crop uses
do
Under further
evaluation
Other hazards-accident
history
Allyl alcohol
All formulations
All uses
Restricted
Acute dermal toxicity
Aluminum
phosphide
As sole active ingredient No
mixtures registered
do
do
Inhalation hazard to humans
Azinphosmethyl
All liquids with a
concentration greater than
13 5%
do
do
do
All other formulations
do
Under further
evaluation
Calcium cyanide
As sole active ingredient No
mixture registered
do
Restricted
do
Carbofiiran
All concrete suspensions and
wettable powders 40% and
greater
do
do
Acute inhalation toxicity
All granular formulations
Rice
Under evaluation
All granular and fertilizer
formulations
All uses except rice
do
Chlorfenvinphos
All concentrate solutions or
emulsifiable or concentrates
21% and greater
All uses (domestic and
non-domestic)
Restricted
Acute dermal toxicity
A14-1
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
.. <• %¦. J
^ ' tw !*.-¦ ?.i.t
^ V * V-.. !•
\£b|3
y"'"^
¦¦ ¦¦ - ¦
? •> S . >¦.. N < \ ^ '
Chloropicnn
All formulations greater than
2%
All uses
Restricted-'
Acute inhalation toxicity
All formulations
Rodent control
Restricted
Hazard to non-
target organisms
All formulations 2% and less
Outdoor uses
(other than
rodent control)
Unclassified
Clonitralid
All wettable powders 70% and
greater
All uses
do
Acute inhalation toxicity
All granulars and wettable
powders
Molluscide uses
do
Effects on aquatic organisms
Pressurized sprays 0 55% and
less
Hospital antiseptics
Unclassified
Cycloheximide
All formulations greater than
4%
All uses
Restricted
Acute dermal toxicity
All formulations 0 027% to
4%
All uses
Under evaluation
All formulations 0 027% and
less
Domestic uses
Unclassified
Demeton
1% fertilizer formulation,
1 985% granular
All uses including
domestic uses
Restricted
Domestic uses
Acute oral toxicity Acute
dermal toxicity Nondomestic
outdoor uses Residue effects
on avian and mammalian
species
All granular formulations
emulsifiable concentrates and
concentrated solutions
All uses
do
Acute dermal toxicity
Residue effects on mammalian
and avian species
Dicrotophos
All liquid formulations 8% and
greater
All uses
Restncted
Acute dermal toxicity, residue
effects on avian species
(except for tree injections)
A14-2
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
"i-.
Dioxathion
All concentrate solutions or
emulsiflable concentrates2
greater than 30%
All uses
Restricted
Acute dermal toxicity
Concentrate solutions or
emulsion concentrates2 30%
and less and wettable powders
25% and less
Livestock and
agricultural uses
(nondomestic uses
only)
Unclassified
All solutions2 3% and greater
Domestic
Restricted
do
3% and greater 2 5%
solutions2 with toxaphene and
malathion
All uses
Under evaluation
Disulfoton
All emulsifiable concentrates
65% and greater, all
emulsiflable concentrates and
concentrate solutions 21 % and
greater with fensulfothion 43%
and greater, all emulsiflable
concentrates 32% and greater
in combination with 32%
fensulfothion and greater
do
Restricted
do
Acute inhalation toxicity
Non-aqueous solution 95 % and
greater
Commercial
seed treatment
Restricted
Acute dermal
toxicity
Granular formulations 10%
and greater
Indoor uses
(greenhouse)
do
Acute inhalation
toxicity
Endrin
All emulsions, dusts, wettable
powders, pastes, and granular
formulations 2% and above
All uses
Restricted
Acute dermal toxicity
Hazard to nontarget
organisms
All concentrations less than
2%
do
do
Hazard to non-target
organisms
EPN
All liquid and dry formulations
greater than 4%
Aquatic uses
All uses
Restricted
Acute dermal toxicity, acute
inhalation toxicity, residue
effects on avian species
Restricted
Effects on aquatic
organisms
Ethoprop
Emulsifiable concentrates
40% and greater
do
do
Acute dermal toxicity
All granular and fertilizer
formulations
do
Under evaluation
A14-3
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
<4|t
Ethyl parathion
All granular and dust
formulations greater than 2%
fertilizer formulations,
wettable powders, emulsifiable
concentrates, concentrated
suspensions, concentrated
solutions
do
Restricted
Inhalation hazard to humans
Acute dermal toxicity
Residue effects or
mammalian, aquatic, avian
species Inhalation hazard to
humans
Smoke fumigants
do
do
Other hazards-accident
history
Dust and granular formulations
2% and below
do
do
Fenamiphos
Emulsifiable concentrates 35%
and greater
do
do
Acute dermal toxicity
Fensulfothion
Concentrate solutions 63% and
greater, all emulsifiable
concentrates and concentrate
solutions 43% and greater with
disulfoton 21 % arid greater all
emulsifiable concentrates 32%
and greater in combination
with disulfoton 32% and
greater
do
Restricted
do
Granular formulations 10%
and greater
Indoor uses
(greenhouse)
do
Acute inhalation toxicity
Fluoroacetamide/1
081
As sole active ingredient in
baits No mixtures registered
All uses
Restricted
Acute oral toxicity
Fonofos
Emulsifiable concentrates 44%
and greater
All uses
do
Emulsifiable concentrates
12 6% and less with pebulate
50 3% and less
Tobacco
Unclassified
Acute dermal toxicity
Hydrocyanic acid
As sole active ingredient No
mixtures registered
do
do
Inhalation hazard to humans
Methamidophos
Liquid formulations 40% and
greater
All uses
Restricted
Acute dermal toxicity, residue
effects on avian species
Dust formulations 2 5% and
greater
All uses
Restricted
Residual effects on avian
species
A14-4
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
S
A *•
-IttejMtm
Methidathion
All formulations
All uses except stock
safflower and
sunflower
Restricted
Residue effects on avian
species
All formulations
Nursery stock,
safflower, and
sunflower
Unclassified
Residue effects on avian
species
Methomyl
As sole active ingredient in
1 % to 2 5 baits (except 1 % fly
bait)
Nondomestic outdoor
agricultural crops,
ornamental and turf
All other registered
uses
Restricted
Residue effects on mammalian
species
All concentrated solution
formulations
do
do
Other hazards-accident
history
90% wettable powder
formulations (not in water
soluble bags)
do
do
Other hazards-accident
history
90% wettable powder
formulation in water soluble
bags
do
Unclassified
do
All granular formulations
do
do
25 % wettable powder
formulations
do
do
In 1 24% to 2 5% dusts as
sole active ingredient and in
mixtures with
fungicides and chlorinated
hydrocarbon, inorganic
phosphate and biological
insecticides
do
do
Methylbromide
All formulations in containers
greater than 1 5 lb
All uses
Restricted
Other hazards-accident
history
Containers with not more than
1 5 lb of methyl bromide with
0 25 % to chloropicrin as an
indicator
Single applications
(nondomestic use) for
soil treatment in closed
systems
Unclassified
Containers with not more than
1 5 lb having no indicator
All uses
Restricted
do
A14-5
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
CK&fteiW \
<
itestridfoft''
Methyl parathion
All dust and granular
formulations less than 5%
do
do
Other hazards-accident
history All foliar applications
restricted based on residue
effects on mammalian and
avian species
Microencapsulated All dust
and granular formulations 5%
and greater and all wettable
powders and liquids
do
do
Residue effects on avian
species Hazard to bees
Acute dermal toxicity
Residue effects on mammalian
and avian species
Mevinphos
All emulsifiable concentrates
and liquid concentrates
do
do
do
Psycodid filter fly liquid
formulations
do
do
Acute dermal toxicity
2% dusts
do
do
Residue effects on mammalian
and avian species
Monocrotophos
Liquid formulations 19% and
greater
do
do
Residue effects on avian
species Residue effects on
mammalian species.
Liquid formulations 55% and
greater
do
do
Acute dermal toxicity
Residue effects on avian
species. Residue effects on
mammalian species
Nicotine (alkaloid)
Liquid and dry formulations
14% and above.
Indoor (greenhouse)
Restricted
Acute inhalation toxicity
All formulations
Applications to
cranberries
Restricted
Effects on aquatic organisms
Liquid and dry formulations
1 5% and less
All uses (domestic and
non-domestic)
Unclassified
A14-6
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
: 'j" x
^ ¦¦ .. \ ..
, rv,::W::
::
s X* s s O-X-O 1
Paraquat
(dichlonde) and
paraquat
bis(methylsulfate)
All formulations and
concentrations except those
listed below
All uses
Restricted
Other hazards Use and
accident history, human
toxicological data
Pressurized spray formulations
containing 0 44% Paraquat
bis(methyl sulfate) and 15%
petroleum distillates as active
ingredients
Spot weed and grass
control
do
Liquid fertilizers containing
concentrations of 0 025%
paraquat dichlonde and 0 03%
atrazine, 0 03% paraquat
dichlonde and 0 37% atrazine,
0 04% paraquat dichlonde and
0 49% atrazine
All uses
Unclassified
Phorate
Liquid formulations 65% and
greater
do
Restricted
Acute dermal toxicity
Residue effects on avian
species (applies to foliar
applications only) Residue
effects on mammalian species
(applies to foliar application
only)
All granular formulations
Rice
Restricted
Effects on aquatic organisms
Phosacetim
Baits 0 1 % and greater
All uses
Restricted
Hazard to non-target species
Residues effects on
mammalian species Residue
effects on avian species
Phosphamidon
Liquid formulations 75% and
greater
do
do
Acute dermal toxicity
Residue effects on mammalian
species Residue effects on
avian species
Dust formulations 15% and
greater
do
do
Residue effects on mammalian
species
Picloram
All formulations and
concentrations except tordon
101R
do
do
Hazard to non-target
organisms (specifically
nontarget plants both crop and
noncrop)
Tordon 101 R forestry
herbicide containing 5 4%
picloram and 20 9% 2, 4-D
Control of unwanted
trees by cut surface
treatment
Unclassified
Sodium cyanide3
All capsules and ball
formulations
All uses
Restricted
Inhalation hazard to humans
A14-7
-------
Appendix 14-1 (continued)
Restricted Use Pesticides
(40 CFR 152.175)
v. v" •• %
' tomtit:
RestrMoa '' i * -
Sodiumfluoro-
acetate
All solutions and dry baits
do
do
Acute oral toxicity Hazard to
nontarget organisms Use and
accident history
Strychnine
All dry baits pellets and
powder formulations greater
than 0 5%
do
do
Acute oral toxicity Hazard to
non-target avain species Use
and accident history
All dry baits pellets and
powder formulations
All uses calling for
burrow builders
do
Hazard to non-target
organisms
All dry baits, and pellets, and
powder formulations 0 5% and
below
All uses except
subsoil
do
do
do
All subsoil uses
Unclassified
do
Sulfotepp
Sprays and smoke generators
All uses
Restricted
Inhalation hazard to humans
Tepp
Emulsifiable concentrate
formulations
do
do
Inhalation hazard to humans
Dermal hazard to humans
Residue effects on mammalian
and avian species
Zinc Phosphide
All formulations 2% and less
All domestic uses and
non-domestic uses in
and around buildings
Unclassified
All dry formulations 60% and
greater
All uses
Restricted
Acute inhalation toxicity
All bait formulations
Nondomestic outdoor
uses (other than around
buildings)
Restricted
Hazard to nontarget
organisms
All dry formulation 10% and
greater
Domestic uses
Restricted
Acute oral toxicity
1 "Under evaluation" means no classification decision has been made and the use/formulation is still under active review within
EPA
2 Percentages given are the total of dioxathion plus related compounds
3 (NOTE M-44 sodium cyanide capsules may only be used by certified applicators who have also taken the required additional
training )
A14-8
-------
Phase 1
Section 15
Groundwater Protection
-------
Phase 1
Section 15
Table of Contents
Groundwater Protection
A. Applicability 15-1
B. Federal Legislation 15-1
C. State/Local Regulations 15-1
D. Key Compliance Requirements 15-2
E. Key Compliance Definitions 15-6
F. Records to Review 15-10
G. Physical Features to Inspect 15-11
H. Guidance for Checklist Users 15-11
Appendices
15-1. Inventory of Neighboring Facilities A15-1
15-2. Inventory of Groundwater Wells A15-2
15-3. Inventory of Existing and Former Aboveground Storage Tanks A15-3
15-4 Inventory of Prior Operations A15-4
15-5. Inventory of Spills and Leaks or Suspected Areas of Contamination A15-5
15-6. Inventory of Aquifers A15-6
15-7. Inventory of Lithologies A15-7
15-8. Inventory of On-Site Disposal A15-8
15-9. Inventory of Water Discharges A15-9
15-10. Inventory of Existing and Former Underground Storage Tanks A15-10
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A. Applicability
This section applies to facilities that have Solid Waste Management Units (SWMUs), and/or
hazardous waste Treatment, Storage, or Disposal Facilities (TSDFs), and/or Underground
Injection Control (UIC) activities. It includes a discussion of the relevant statutes, regulations,
and procedures for determining applicability of groundwater protection and UIC requirements
and it includes reviewing procedures for determining the facilities' compliance status with
respect to these requirements.
B. Federal Legislation
1. Resource Conservation and Recovery Act (RCRA), Subtitle C and D
This Act, Public Law (PL) 98-616,42 U.S. Code (USC) 6921 -2939(b), establishes standards
for groundwater protection and monitoring at hazardous waste treatment, storage, and disposal
facilities, and solid waste disposal facilities.
Under the Underground Storage Tank (UST) rules of RCRA, USTs containing petroleum
products or hazardous substances must have a release detection program That program can
include a shallow groundwater monitoring program. The UST shallow groundwater monitoring
program for USTs is only appropriate for tanks storing materials, immiscible in and with a
density less than water, located where the water table is less than 20 feet below ground surface,
backfill soils are similar to natural soils and monitoring wells are properly constructed, placed,
marked and secured.
2. The Safe Drinking Water Act (SDWA)
This Act, Public Law (PL) 99-339, 42 U.S. Code (USC) 201,300(f)-300(j)-25, 6939(b),
6979(a), 6979(b), 7401-742, etc., is the Federal legislation which regulates the safety of drinking
water in the country.
The SDWA also established a program to ensure that underground injection will not
endanger drinking water sources and empowers each state to develop a UIC program.
Under the SDWA, regulations were promulgated concerning the use of underground injection
as a means of disposing wastes. The regulations require an Underground Injection Control
Program permit and establishment of an Underground Injection Control Program. The program
must contain procedures for sampling, recordkeeping, reporting, well construction, well plugging
and abandonment, and outline financial assurances for the underground injection control
program.
C. State/Local Regulations and Other State Regulations
The UIC program within each state is administered directly by the state (Primary Program) or
EPA (where states do not administer the program), or a combination of the state and EPA. The
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overall Wellhead Protection Program for a state is administered by the state but is developed and
implemented on a local (e.g., municipal, water district) level.
D. Key Compliance Requirements
1. Classification of Wells
There are five classes of UIC wells:
Class I.
a. Wells used by generators of hazardous waste or owners or operators of hazardous waste
management facilities to inject hazardous waste beneath the lowermost formation containing,
within one-quarter mile of the well bore, an underground source of drinking water.
b. Other industrial and municipal disposal wells which inject fluids beneath the lowermost
formation containing, within one-quarter mile of the well bore, an underground source of
drinking water.
Class II. Wells which inject fluids:
a. Which are brought to the surface in connection with natural gas storage operations, or
conventional oil or natural gas production and may be commingled with waste waters from
gas plants which are an integral part of production operations, unless those waters are
classified as a hazardous waste at the time of injection.
b. For enhanced recovery of oil or natural gas.
c. For storage of hydrocarbons which are liquid at standard temperature and pressure.
Class III. Wells which inject for extraction of minerals including:
a. Mining of sulfur by the Frasch process.
b. In-situ production of uranium or other metals; this category includes only in-situ production
from ore bodies which have not been conventionally mined. Solution mining of conventional
mines such as stopes leaching is included in Class V.
c. Solution mining of salts or potash.
Class IV.
a. Wells used by generators of hazardous waste or of radioactive waste, by owners or operators
of hazardous waste management facilities, or by owners or operators of radioactive waste
disposal sites to dispose of hazardous waste or radioactive waste into a formation which
within one-quarter mile of the well contains an underground source of drinking water.
b. Wells used by generators of hazardous waste or of radioactive waste, by owners or operators
of hazardous waste management facilities, or by owners or operators of radioactive waste
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disposal sites to dispose of hazardous waste or radioactive waste above a formation which
within one-quarter mile of the well contains an underground source of drinking water.
c. Wells used by generators of hazardous waste or owners or operators of hazardous waste
management facilities to dispose of hazardous waste, which cannot be classified under 1 .a or
4 a and b above (e.g., wells used to dispose of hazardous waste into or above a formation
which contains an aquifer which has been exempted pursuant to 40 CFR 146.04).
Class V. Injection wells not included in Classes I, II, III, or IV.
2. Exempted Aquifers
Under 40 CFR 144.7(b), EPA has identified "exempted aquifers" which cannot be used as
sources of drinking water because they:
a. Contain minerals, hydrocarbons, or geothermal energy expected to be commercially
producible;
b. Are situated at a depth or location which makes recovery for drinking water purposes
economically or technologically impractical;
c. Are contaminated;
d. Are located over a Class III well or mining area subject to subsidence or catastrophic
collapse; or
e. contain between 3,000 and 10,000 mg/1 of total dissolved solids. These aquifers are
exempted from the protection afforded by the UIC regulations (40 CFR 144.7)
3. Indian Lands
EPA may promulgate an alternative UIC program for Class II wells on any Indian reservation
or Indian lands (40 CFR 144.2).
4. Prohibition of Unauthorized Discharge
Any underground injection, except as authorized by permit or rule issued under the UIC
program is prohibited (40 CFR 144.11).
§. Prohibition of Class IV Wells
The following activities relating to Class IV wells are prohibited, unless the conditions in 40
CFR 144.13(c) are met (40 CFR 144.13):
• The construction of any Class IV well;
• The operation or maintenance of any Class IV well not in operation prior to July 18, 1980;
• The operation or maintenance of any Class IV well that was in operation prior to July 18,
1980, after six months following the effective date of a UIC program approved or
promulgated for the state;
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• Any increase in the amount of hazardous waste or change in the type of hazardous waste
injected into a Class IV well.
6. Prohibition of Movement
The construction, operation, maintenance, conversion, plugging, abandonment, or conduct of
other injection activities must not cause movement of fluid containing contamination into
underground sources of drinking water if the presence of that contaminant may cause a violation
of any primary drinking water regulation or otherwise adversely affect the health of persons (40
CFR 144 12).
7. Injection of Hazardous Waste Under the UIC Program
Each facility using any class of well to inject hazardous waste must comply with (40 CFR
144.14):
• The notification requirements of Section 3010 of RCRA;
• The identification number requirements of 40 CFR 264.11;
• The recordkeeping, reporting, and manifest requirements in 40 CFR 264.71-264.72;
• The operation record requirements in 40 CFR 264.73(a), (b)(1), and (b)(2);
• The annual report requirements of 40 CFR 264.75;
• The unmanifested waste report requirements in 40 CFR 264.75;
• The applicable training requirements of 40 CFR 264.16;
• The closure certification requirements of 40 CFR 144.52(a)(6).
8. Inventory Requirements
Owners/operators of all injection wells authorized by rule must submit an inventory to the
Director (40 CFR 144.26).
9. Financial Responsibility
Owners/operators of Class I hazardous waste injection wells must establish financial
assurance. A written estimate, in current dollars, of the cost of plugging and abandoning each
injection well is required. Owners/operators of each facility must establish financial assurance
for the plugging and abandonment of each existing and new Class I hazardous waste injection
well, choosing from the following options:
• Plugging and abandonment trust fund; surety bond guaranteeing payment into a plugging and
abandonment trust fund;
• Surety bond guaranteeing performance of plugging and abandonment; plugging and
abandonment letter of credit;
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• Plugging and abandonment insurance; or
• Financial test and corporate guarantee for plugging and abandonment (40 CFR 144(f)).
Owners/operators of hazardous and solid waste landfills have similar responsibilities defined
in Subpart H of 40 CFR 258, 264 and 265. A written estimate of costs for closure, post-closure
care, liability and sudden and non-sudden occurrences is required. The options for establishing
financial assurance are the same as those for the UIC program. These estimates are to be updated
annually; some states may require a more frequent update.
10. RCRA Permit Programs
RCRA regulations under 40 CFR 258.50-258.58 outline the requirements of a groundwater
monitoring and corrective action program. RCRA regulations under 40 CFR 264 and 265 require
that any facility that treats, stores or disposes of hazardous waste must apply to the state for an
operating permit If the state has not yet given final approval or denial of the permit application,
then the facility is considered an "interim status" facility, and the temporary permit issued by the
state is called a "Part A permit." If a final permit, called a "Part B permit" has been issued, then
the facility is considered a Treatment, sStorage, and Disposal Facility (TSDF) The facility
RCRA permit, whether it is Part A or B, will have requirements in it for groundwater programs
and those requirement tend to differ from state to state.
In the Federal regulations, there are basic requirements for both interim status facilities and
TSDFs including the development and maintenance of a groundwater monitoring program. The
programs generally have different levels of requirements depending on the potential level of
groundwater contamination at the facility, and proximity to sensitive receptors.
11. Imminent and Substantial Endangerment
Federal environmental laws, including CERCLA, RCRA, the SDWA, the Clean Air Act
(CAA) and, to some extent, the Clean Water Act (CWA), rely on the concept of immediate
response action when an actual or threatened release poses an imminent and substantial
endangerment to public health, welfare or the environment. Site inspectors must have a full
understanding of this concept to properly interpret and take immediate and appropriate action if
situations that present an imminent and substantial endangerment to human health, welfare, or
the environment are encountered. The following definitions provide clarification-
"Actual or threatened release" applies not only to actual releases or discharges, but also to
potential releases or discharges as well. However, the release or discharge must be actual or
probable not merely speculative.
"Imminent" is defined as existing now or likely to exist in the near future. "Imminent" refers
to endangerment, it does not require that actual harm be imminent.
"Substantial" is defined both in relation to the potential for risk (that is, harm is very likely to
occur) and the degree of harm that may occur (that is, the harm will be very serious).
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"Endangerment" is defined broadly as the risk of harm to human health, welfare, or the
environment. Risk of harm to human health includes the potential for acute/chronic illness or
injury caused by exposure to hazardous substances, wastes, contaminants, or pollutants
including contaminated public or private water supplies Risk of harm to welfare includes the
potential for economic loss due to damage to property, livestock, crops, resources, fish, or
other harm to livelihood. Risk of harm to the environment includes the direct physical
destruction or alteration of an ecosystem, (e.g., harm to flora and fauna). The harm need not
have already occurred for the endangerment to exist.
Consideration of these terms simultaneously suggests a complex interaction between the
material released or threatened to be released, the amount of material released, the potential
pathways of migration, the proximity of such pathways, the potential for human, animal, or
environmental exposure, the nature of harm caused by exposure, and the severity of harm.
12. Clean Water Act - Discharges to Groundwater
Frequently, state NPDES equivalent programs will contain regulations controlling the
discharge of pollutants to groundwater. These programs generally require permitting, monitoring,
and reporting activities.
E. Key Compliance Definitions
1. Approved State Program
a. UIC program administered by the state or Indian Tribe that has been approved by EPA
according to SDWA Sections 1422 and/or 1425 (40 CFR 144.3).
b. A RCRA program administered by the state or Indian Tribe that has been approved by
EPA according to 40 CFR 271.
2. Aquifer
Geological "formation," group of formations, or part of a formation that is capable of
yielding a significant amount of water to a well or spring (40 CFR 144.3,40 CFR 260.10).
3. Area of Review
The area surrounding an injection well described according to the criteria set forth in 40 CFR
146.06 or in the case of an area permit, the project area plus a circumscribing area the width of
which is either 1/4 of a mile or a number calculated according to the criteria set forth in 40 CFR
146 06 (40 CFR 144.3).
4. Contaminant/Pollutant
a. Any physical, chemical, biological, or radiological substance or matter in water (40 CFR
144 3).
b. As defined by section 101(33) of CERCLA, this term includes, but is not limited to, any
element, substance, compound or mixture, including disease-causing agents, which after
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release into the environment and upon exposure, ingestion, inhalation, or assimilation
into any organism, either directly from the environment or indirectly by ingestion
through food chains, will cause death, disease, behavioral abnormalities, cancer, genetic
mutation, physiological malfunctions, or physical deformations, in such organisms or
their offspring The term does not include petroleum, including crude oil or any fraction
thereof which is not otherwise specifically listed or designated as a hazardous substance
under section 101(14)(A) through (F) of CERCLA (40 CFR 300 5)
5. Corrective Action Management Unit (CAMU)
An area within a facility that is designated by the Regional Administrator under 40 CFR 264
Subpart S, for the purpose of implementing corrective action requirements under 40 CFR
264 101 and RCRA section 3008(h) A CAMU shall only be used for the management of
remediation wastes pursuant to implementing such corrective action requirements at the facility
6. Discharge
As defined by section 311(a)(2) of the CWA, includes, but is not limited to, any spilling,
leaking, pumping, pouring emitting, emptying, or dumping of oil but excludes discharges in
compliance with a permit under section 402 of the CWA. For purposes of the NCP, discharge
also means threat of discharge.
7. Drilling Mud
A heavy suspension used in drilling an "injection well," introduced down the drill pipe and
through the drill bit (40 CFR 144.3).
8. Exempted Aquifer
An "aquifer" or its portion that meets the criteria in the definition of "underground source of
drinking water" but which has been exempted according to the procedures in 40 CFR 144.7 (40
CFR 144 3)
9. Facility or Activity
a Any UIC "injection well," or another facility or activity that is subject to regulation
under the UIC program (40 CFR 144.3).
b. Any building, structure, installation, equipment, pipe or pipeline (including any pipe into
a sewer or publicly owned treatment works), well, pit pond, lagoon, impoundment,
ditch, landfill, storage container, motor vehicle, rolling stock or aircraft, or any site or
area where a hazardous substance has been deposited, stored, disposed of, or placed, or
otherwise come to be located; but does not include any consumer product in consumer
use or any vessel.
10. Fluid
Any material or substance which flows or moves whether in a semisolid, liquid, sludge, gas,
or any other form or state (40 CFR 144.3).
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11. Formation
A body of consolidated or unconsolidated rock characterized by a degree of lithologic
homogeneity which is prevailingly, but not necessarily, tabular and is mappable on the earth's
surface or traceable in the subsurface (40 CFR 144.3).
12. Formation Fluid
"Fluid" present in a "formation" under natural conditions as opposed to introduced fluids,
such as "drilling mud" (40 CFR 144.3).
13. Generator
Any person, by site location, whose act or process produces hazardous waste identified or
listed in 40 CFR Part 261 (40 CFR 144.3).
14. Groundwater
Water below the land surface in a zone of saturation (40 CFR 260.10, 144.3).
15. Hazardous Waste
Hazardous waste as defined in 40 CFR 261.3 (40 CFR 144.3).
16. Hazardous Waste Management Facility
"HWM facility" means all contiguous land, and structures, other appurtenances, and
improvements on the land used for treating, storing, or disposing of hazardous waste. A facility
may consist of several treatment, storage, or disposal operational units (for example, one or more
landfills, surface impoundments, or combination of them) (40 CFR 144.3).
17. Indian Lands
"Indian country" as defined in 18 U.S.C. 1151. That section defines Indian country as (40
CFR 144.3):
a. All land within the limits of any Indian reservation under the jurisdiction of the United States
government, notwithstanding the issuance of any patent, and, including rights-of-way
running through the reservation.
b. All dependent Indian communities within the borders of the United States whether within the
original or subsequently acquired territory thereof, and whether within or without the limits
of a state.
c. All Indian allotments, the Indian titles to which have not been extinguished, including rights-
of-way running through the same.
18. Indian Tribe
Any Indian Tribe having a federally recognized governing body carrying out substantial
governmental duties and powers over a defined area (40 CFR 144.3).
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19. Injection Well
A "well" into which "fluids" are being injected (40 CFR 144.3).
20. Injection Zone
Geological "formation" group of formations, or part of a formation receiving fluids through a
"well" (40 CFR 144.3).
20. Landfill
A disposal facility or part of a facility where hazardous waste is placed in or on land and
which is not a pile, a land treatment facility, a surface impoundment, an underground injection
well, a salt dome formation, a salt bed formation, an underground mine, a cave, or a corrective
action management unit (40 CFR 260.10).
21. Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating
procedures.
22. Owner or Operator
The owner or operator of any "facility or activity" subject to regulation under the UIC
program (40 CFR 144.3).
23. Permit
An authorization, license, or equivalent control document issued by EPA or an approved state
to implement the requirements of 40 CFR Parts 144, 145,146 and 124. "Permit" includes an
area permit (40 CFR 144.33) and an emergency permit (40 CFR 144.34). Permit does not
include UIC authorization by rule (40 CFR 144.21), or any permit which has not yet been the
subject of final agency action, such as a "draft permit" (40 CFR 144.3)
24. Person
An individual, association, partnership, corporation, municipality, state, Federal, or Tribal
agency, or an agency or employee thereof (40 CFR 144.3).
25. Plugging
The act or process of stopping the flow of water, oil or gas into or out of a formation through
a borehole or well penetrating that formation (40 CFR 144.3).
26. Project
A group of wells in a single operation (40 CFR 144.3).
27. Radioactive Waste
Any waste which contains radioactive material in concentrations which exceed those listed in
10 CFR Part 10, Appendix B, table II, Column 2 (40 CFR 144 3).
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28. 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 (40 CFR 144.3).
29. Underground Injection Control (UIC)
Underground Injection Control program under Part C of the Safe Drinking Water Act,
including an "approved state program" (40 CFR 144.3).
30. Underground Source of Drinking Water (USDW)
An aquifer or its portion (40 CFR 144.3):
a. Which supplies any public water system; or
b. Which contains a sufficient quantity of ground water to supply a public water system; and
c. Currently supplies drinking water for human consumption; or
d. Contains fewer than 10,000 mg/1 total dissolved solids; and
e. Which is not an exempted aquifer.
31. Uppermost Aquifer
The geologic formation nearest the natural ground surface that is an aquifer, as well as lower
aquifers that are hydraulically interconnected with this aquifer within the facility's property
boundary (40 CFR 144.3).
32. Well
A bored, drilled or driven shaft, or a dug hole, whose depth is greater than the largest surface
dimension (40 CFR 144.3)
33. Well Injection
The subsurface emplacement of "fluids" through a bored, drilled, or driven "well;" or through
a dug well, where the depth of the dug well is greater than the largest surface dimension (40 CFR
144.3).
F. Records to Review
• Approved underground injection well permits;
• Injection well planning and constction records;
• Injection well monitoring results;
• Facility records, or petitions for review records, for projects that may potentially cause
contamination of a sole source aquifer through its recharge zone;
• State waivers; and
• Groundwater monitoring results, reports (for more detail, see checklist).
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G. Physical Features to Inspect
• Underground injection wells;
• Groundwater monitoring well system; and
• Surrounding environment for signs of stress.
H. Guidance for Checklist User
Refer To
Checklist Items
; F#ge Numbers
All Facilities
GW.l through GW 2
15-12
Site Reconnaissance and Inspections
GW 3
15-12
Records Review
GW 4
15-13
State-Specific Regulatory
Requirements
GW 5
15-13
Groundwater Pollution and
Hydrogeology
GW 6
15-14
Groundwater Protection Program
GW.7
15-15
Hazardous Waste Site Groundwater
Monitoring - Permitted Facilities
GW.8 through GW 9
GW. 10 through GW 11
GW 12 through GW 13
15-15
15-16
15-17
Hazardous Waste Site Groundwater
Monitoring - Interim Status Facilities
GW.l4 through GW.l5
GW 16
15-18
15-19
Sampling and Analytical Practices
GW 17 through GW.l8
15-20
Underground Injection
GW 19 through GW 22
GW.23 through GW 25
GW.26 through GW 29
15-21
15-22
15-23
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15-11
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Compliance Category:
Groundwater Protection
Regulatory Requirements:
Reviewer Checks
All Facilities
GW 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions must be
examined (A finding under this
checklist item will have the
enforcement action/identifying
information as the citation )
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions
For those open items, indicate what corrective actions are planned and milestones
established to correct problems
GW.2 Facilities are required to
comply with all applicable
Federal regulatory requirements
not contained in this checklist
(A finding under this checklist
item will have the citation of the
applied regulation as a basis of
finding.)
Determine if any new regulations have been issued since the finalization of the guide
If so, annotate checklist to include new standards
Determine if the facility has activities or facilities which are federally regulated, but
not addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued
regulations.
Site Reconnaissance and Inspections
GW 3 The facility must review
all of its operations in an effort
to identify any possible areas of
concern with respect to
groundwater protection
Creating inventories of potential
sources of groundwater
contamination (e g, USTs,
ASTs, past spills and leaks,
etc ), allows the facility to
determine its compliance status
(MP)
Determine whether the facility has developed an inventory of potential sources of
groundwater contamination
Determine whether the following potential contaminant sources are present at the
facility.
- Petroleum products, hazardous material, and non-RCRA wastes stored in
underground storage tanks which could negatively affect groundwater If yes,
complete Appendix 15-3, Inventory of Existing and Former Underground Storage
Tanks
- Petroleum products and oil-filled dielectric transformers stored in aboveground
storage tanks which could negatively affect groundwater If yes, complete
Appendix 15-3, Inventory of Existing and Former Aboveground Storage Tanks
- Facility operations (e.g., soil column discharges, SWMUs) that caused on-site soil
or groundwater contamination If yes, complete Appendix 15-5, Inventory of Spills
and Leaks or Suspected Areas of Contamination
- Operation of any offsite locations (e g, warehouses, garages, storage units,
specialty experiments shops, etc) that could negatively affect groundwater
monitoring or supply wells, etc If yes, complete Appendix 15-2, Inventory of
Groundwater Wells, Appendix 15-6, Inventory of Aquifers, and Appendix 15-7,
Inventory of Lithologies
- Any known or suspected spill events with the potential for causing soil or
groundwater contamination If yes, complete Appendix 15-5, Inventory of Spills
and Leaks or Suspected Areas of Contamination
- Property abettors capable of causing groundwater contamination. If yes, complete
Appendix 15-1, Inventory of Neighboring Facilities
- Tne facility discharges pollutants into water bodies If yes, complete Appendix 15-
9, Inventory of Water Discharges
- Operation of wastewater treatment facilities
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Compliance Category
irouadwater Protection.
Kegulatory Requirements:
i Reviewer <%eck$
Records Review
GW 4 The facility must keep
records of all past groundwater
problems and all facility
programs and procedures in
place to prevent groundwater
pollution This will help the
facility compare the types of
problems they may be
susceptible to with the control
techniques they use to prevent
and remediate those problems to
ensure there is a contingency for
all potential problems (MP).
Evaluate whether the facility been subject to any regulatory action (e g , lawsuits,
consent decrees, investigations, etc ) during the period of review
Determine if the facility documented any internal audits, appraisals, or reviews during
the period of review.
Determine if the facility evaluated the potential effect past operations may have had
on groundwater
Determine if the facility has been the subject of groundwater complaints or lawsuits
by third parties (e.g., neighbors, environmental organizations, etc) during the period
of review.
Identify and evaluate any formal groundwater protection programs in place
State Specific Regulatory Requirements
GW 5 Groundwater is
normally considered "waters of
the state" and is regulated by
dividual states The specialist
>uld obtain and review state
groundwater related regulations
and laws Below are some state
regulated issues the specialist
should keep in mind (MP)
Determine if the state has any groundwater regulations covering the following
- Groundwater well plugging and abandonment procedures
- Groundwater discharge permits
- Monitoring well security requirements
- Wellhead protection (often regulated and implemented at the local level)
- Groundwater contamination reporting requirements and cleanup standards
- Other state regulatory requirements
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Compliance Category:
Groundwater Protection
Regulatory Requirements;
Reviewer Checks
Groundwater Pollution and Hydrogeology
GW 6 The facility must
consistently monitor the
groundwater at the site for
evidence of contamination It is
imperative to understand how
the contaminants are discharged,
how they would react if
discharged to the groundwater,
as well as the hydrologic regime
at the site to properly evaluate
the groundwater monitoring
system
Verify that facility programs are adequate to detect leaks from underground storage
tanks before groundwater resources are degraded
Determine if there is groundwater contamination on-site. (NOTE Primary types of
contamination include volatile organic compounds, inorganic compounds and
radiological compounds) (If groundwater contamination exists, if possible, determine
its state (e g , non-aqueous phase, dissolved)
Determine if soil gas studies and/or other programs for contamination within the
unsaturated zone or vadose zone have been conducted to characterize volatile organic
compounds and/or radiological contaminants
Verify that facility formal site assessment procedures exist to address groundwater
contamination if it is identified Determine that applicable state environmental
regulations and/or CERCLA requirements are met
Determine if there is groundwater contamination at the site. If contamination is
present, has the facility
- Identified and removed the source
- Characterized the nature and extent (e g , determined the types of contamination
present, the state (dissolved/non-aqueous) the contamination is in, and the limits of
the contaminant plume)
- Taken necessary steps with the regulators to determine if cleanup is necessary?
Determine if soil base studies and/or other investigations have been performed to
identify and characterize contamination in the unsaturated zone
Verify that the facility has characterized the groundwater system and determined the
aquifer properties that control groundwater flow, and that the facility has
characterized groundwater quality, flow direction and rate Methods for assessing
aquifer properties include slug tests, aquifer pump tests, geophysical methods, tracer
testing, and laboratory soil/sediment property measurements The aquifer
characteristics of importance include transmissivity, storage coefficient, anisotropy,
infiltration rates, organic carbon content, fracture spacing and aperture, degree of
interconnection between aquifer and other water bearing units and surface water,
leakage rates, groundwater velocity, porosity, gradients, and dispersion
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Compliance Category:
Groundwater Protection
Regulatory Re
-------
Compliance Category:
Groundwater Protection
Regulatory Requirements;
Reviewer Checks
GW 10 Facilities must comply
with the requirements in 40 CFR
264 97 for any groundwater
monitoring program developed
to satisfy 40 CFR 264 98,
264 99, or 264 100(40 CFR
264.97)
If there is a possibility of hazardous constituents in the groundwater, ensure that the
following activities are added to the groundwater monitoring plan
- For each hazardous constituent in each well, one of the statistical methods described
in 40 CFR 264 97(h) for evaluating monitoring data has been chosen by the facility,
approved by the Regional Administrator, and complies with the performance
standards in 40 CFR 264.97(i)
- All groundwater monitoring data collected is maintained in the facility operating
record and submitted for review as required by the Regional Administrator
- The program includes sampling and analytical procedures that are appropriate and
accurately measure hazardous constituents in groundwater samples
- An appropriate method for determining background water quality has been selected
and background groundwater quality has been determined
GW 11 Facilities required to
establish a detection monitoring
program under 40 CFR 264
Subpart F must, at a minimum,
comply with 40 CFR 264 98 (40
CFR 264 98)
If the facility is required by the Regional Administrator to establish a detection
monitoring program, ensure that the following activities are included in the
groundwater monitoring plan
- Monitoring for indicator parameters (e g, specific conductance, total organic
carbon, or total organic halogen), waste constituents, or reaction products that
provide a reliable indication of the presence of hazardous constituents in the
groundwater
(NOTE' The Regional Administrator will specify the parameters or constituents to
be monitored and their frequency for collection and statistical analysis in the facility
permit (40 CFR 264 98(d))
- Determination of the groundwater flow Tate and direction in the uppermost aquifer,
at least annually
- Determination of whether statistically significant evidence of contamination exists
and if it does exist, the following steps are taken
(NOTE. If statistically significant evidence of contamination exists but, may have
been caused by contamination from another source or by an error in sampling, then
the facility must demonstrate that to the Regional Administrator)
the Regional Administrator is notified in writing within seven days
the groundwater is immediately sampled in all monitoring wells to determine
if any constituents in Appendix IX of 40 CFR 264 are present, and if so, in
what concentration
(NOTE: If Appendix IX constituents are present in the sample then the following
activities are required
- An application for a permit modification to establish a compliance monitoring
program is submitted within 90 days to the Regional Administrator
- An engineering feasibility plan for corrective action and all data necessary to justify
any alternative concentration limits are submitted to the Regional Administrator
within 180 days.)
Phase 1 - Section IS
Groundwater Protection
15-16
-------
CwopIfeJMS Category;
Groundwater Protection
Regulatory Requirements;
¦Reviewer Cfcecks
GW 12 Facilities required to
establish a compliance
monitoring program under CFR
264 Subpart F must, at a
minimum, comply with 40 CFR
264 99 (40 CFR 264 99).
If the facility is required to establish a compliance monitoring plan, verify that the
plan contains procedures for the following activities to be done in conjunction with
the groundwater monitoring plan
- Determination of whether any significant evidence of increased contamination
exists and if it does exist, the following steps are taken
the Regional Administrator is notified in writing which limits are exceeded
within seven days
an application for a permit modification to establish a corrective action
program is submitted to the Regional Administrator within 180 days
(NOTE If statistically significant evidence of increased contamination exists but, may
have been caused by contamination from another source or by an error in sampling,
then the facility must demonstrate that to the Regional Administrator)
GW 13 Facilities required to
establish a corrective action
program under 40 CFR 264
Subpart F must, at a minimum,
comply with 40 CFR 264 100
(40 CFR 264 100)
If the facility is required to establish a corrective action program, determine whether
the following procedures are in place in addition to the groundwater monitoring plan
- The facility either removes hazardous waste constituents or treats them in place to
prevent the constituents from exceeding their respective concentration limits The
permit will specify the specific measures that will be taken
- The facility establishes a groundwater monitoring program to evaluate the
effectiveness of the corrective action program and submits the results of the
evaluation semi-annually in a written report to the Regional Administrator
Hazardous Waste Site Groundwater Monitoring - Interim Status Facilities
(NOTE GW 14 through GW 16 describe the requirements for groundwater programs pursuant to 40 CFR 265 Subpart F,
Interim Status for Owners and Operators of Treatment, Storage, and Disposal Facilities (40 CFR 265 90))
Phase 1 - Section 15
Groundwater Protection
15-17
-------
Compliance Category:
Groundwater Protection
Regulatory Requlrenwafej
B«svj|ew*rC&ecfc$
GW. 14. The facility must have
a groundwater monitoring
program capable of determining
the facility's impact on the
uppermost aquifer unless they
have demonstrated and certified
that a program is not necessary
(40 CFR 265.90(c)(e)).
The program must include a
groundwater monitoring system
consistent with the requirements
of 40 CFR 265.91 and a
sampling and analysis plan
consistent with 40 CFR 265.92
Verify that the facility has developed a groundwater sampling and analysis plan
Review the plan and verify that it includes procedures and techniques for
- Sample collection
- Sample preservation and shipment
- Analytical procedures
- Cham of custody control.
Verify that the facility determines the background concentration or value of the
following parameters in the groundwater samples at least annually:
- Parameters characterizing the suitability of groundwater as a drinking water supply,
as specified in 40 CFR 265 Appendix III
- The following parameters establishing groundwater quality
Chloride
Iron
Manganese
Phenols
Sodium
Sulfate.
- The following parameters used as indicators of groundwater contamination.
- pH
specific conductance
total organic carbon
total organic halogen
Verify that the facility maintains records of all borings advanced and well
construction details for all wells installed Review records to determine if wells are
capable of determining the facility's impact on the uppermost aquifer.
GW.15 The facility must
resample and provide notice if a
downgradient monitoring well
sample shows a significant
increase (or pH decrease) in
constituent concentration (40
CFR 265.93(c)).
If the facility determines that a monitoring well sample shows a significant increase
(or pH decrease) in constituent concentration, confirm that the facility conducts the
following activities:
- Duplicate resampling of the well(s) that showed the difference and separate analysis
of the two sets of samples to determine whether the difference was a result of
sampling or laboratory error
- If it is determined that the difference was not a result of sampling or laboratory
error, the facility must prepare:
written notice for the Regional Administrator within seven days
a groundwater quality assessment plan that has been approved by a qualified
geologist or geotechnical engineer for the Regional Administrator within 15
days
an assessment report for the Regional Administrator within 15 days of its
completion.
Phase 1 - Section IS
Groundwater Protection
15-18
-------
Compliance Category;
Groundwater Protection
Regulatory ite
Reviewer decks
GW 16 Groundwater
monitoring program records
must be maintained (40 CFR
265 94)
Unless the groundwater is monitored to satisfy 40 CFR 265 93(d)(4), verify that the
facility
- Maintains records of the analyses required in 40 CFR 265 92(c) and (d), the
associated groundwater surface elevations required in 40 CFR 265 92(e), and the
evaluations required in 40 CFR 265 93(b)
(NOTE These records must be kept throughout the active life of the facility, and, for
disposal facilities, throughout the post-closure care period as well)
- Reports information specified in 40 CFR 265 94(a)(2) to the Regional
Administrator
If the groundwater is maintained to satisfy the requirements of 40 CFR 265 93(d)(4),
verify that the facility
- Maintains records of the analyses and evaluations specified in the plan
(NOTE These records must be kept throughout the active life of the facility, and, for
disposal facilities, throughout the post-closure care period as well)
- Annually submits a report to the Regional Administrator containing the results of
the groundwater quality assessment program
(NOTE This report is required annually until final closure of the facility )
Review facility recordkeeping and reporting procedures to ensure that they include
the following with respect to groundwater monitoring
- Procedures to keep all analyses and evaluations of groundwater throughout the
active life of the facility, and, for disposal facilities, throughout the post-closure
care period as well
- Procedures to submit (no later than 1 March each year) to the Regional
Administrator, a report containing the results of the groundwater quality
assessment
Phase 1 - Section 15
Groundwater Protection
15-19
-------
Compliaoce Category:
Groundwater Protection
Regulatory Requiremefltst
; Bevlewer C&eeks
Sampling and Analytical Practices
GW 17 Sampling and analysis
requirements are largely
regulated by the individual
states and will be described in
the facility's permit A review of
the permit requirements and the
groundwater protection program
is necessary to complete this
section The following steps are
general requirements which
should be coordinated with the
permit requirements when
conducting sampling and
analysis procedures (MP)
Verify that groundwater sampling technicians are properly trained and certified
Verify that all sampling activities are conducted in accordance with an approved
health and safety plan
Verify that all sampling and analysis is conducted in accordance with an approved
Quality Assurance Plan.
Verify that samples are submitted to approved laboratories where required
GW 18 The groundwater
monitoring system must be
capable of yielding
representative groundwater
samples (40 CFR 265 91)
Obtain and review the facility's written groundwater monitoring program and/or
procedures Test the adequacy of the facility's monitoring system and sampling and
analytical procedures by performing the following
- Verify compliance with applicable sampling and analytical procedures and
requirements by completing the following-
verify that the appropriate and up-to-date state certification has been obtained
verify that representative samples are obtained and that the sampling
frequency and analytical program complies with prescribed requirements
- Note whether or not the monitoring frequency is consistent with regulatory
provisions and good management practices
review the procedures used in calibrating and maintaining analytical
equipment and review maintenance logs and determine whether the equipment
is routinely maintained and calibrated in conformance with good management
practices
review the analytical procedures used by the facility to verify compliance with
best management practices or approved test procedures (e.g., confirm that
proper preservation techniques, holding times, and quality control procedures
are used and correct)
- If samples are analyzed by an outside laboratory:
confirm that the lab is certified or approved to perform the work
note any provisions for cross-checking or verification by independent analysis
as well as other quality control/assurance procedures
Phase 1 - Section IS
Groundwater Protection
1S-20
-------
Compliant! Category:
Groundwater Protection
Regulatory Requirements;
¦Reviewer Checks
Underground Injection
GW 19 Injection wells are
classified into five classes of
wells Class I, Class II, Class
III, Class IV, and Class IV (40
CFR 144 6)
Determine by reviewing engineering records or other documentation if
- the injection well is properly classified according to EPA requirements
- any injection wells have been installed since 20 July 1984
Confirm by comparing engineering data to regulatory provisions that the design and
construction of those wells meet EPA standards
GW20 Owners/operators of
Class I injection wells are
required to establish financial
assurance for the plugging and
abandonment of the wells using
one of the options specified in
40 CFR 144 63(a)-(f) (40 CFR
144 62 and 144 63)
For any class I injection well, determine whether the facility has established financial
assurance by
- establishing and keeping current a cost estimate for its plugging and abandonment
plan (P&A)
(NOTE The cost estimate must be in current dollars, equal to the cost of plugging
and abandonment at the point in the facility's operating life when the extent and
manner of its operation would make plugging and abandonment the most expensive,
and adjusted for inflation annually)
- keeping financial assurance for its plugging and abandonment plan using at least
one of the specified forms
P&A trust
surety bond guaranteeing payment into a P&A trust fund
surety bond guaranteeing performance of P&A
P&A letter of credit
P&A insurance
financial test and corporate guarantee for P&A
GW21. Underground injection
activities must be authorized by
permit All permit applications
must be complete before the
Director of the UIC program
will issue a permit (40 CFR
144 31-14441)
Obtain and review the permit application for the underground injection control
program
Confirm that the permit application reflects current operations (complete and
accurate) and has the proper signatories
Confirm that the facility's permits are up to date and reflect current operations
GW 22 The permittee must
comply with all conditions of
the permit Any permit
noncompliance is a violation of
the SDWA and is grounds for
enforcement action, for permit
termination, revocation and
reissuance, or modification, or
for denial of a permit renewal
application (40 CFR 144 51)
Prepare a schedule that includes a representative sample of permit conditions and
regulatory requirements
Verify that the facility has meet these obligations by observing operations, reviewing
facility records, and interviewing facility personnel
Note any discrepancies
Phase 1 - Section 15
Groundwater Protection
15-21
-------
Compliance Category;
Groundwater Protection
Regulatory Requirements;
Reviewer Checks
GW 23. The permittee must at
all times properly operate and
maintain all facilities and
systems of treatment and control
(and related appurtenances)
necessary to achieve
compliance Proper operation
and maintenance includes
effective performance, adequate
funding, adequate operator
staffing and training, and
adequate laboratory and process
controls, including appropriate
quality assurance procedures (40
CFR 144 51(e))
Review the facility's maintenance and calibration records and observe operations to
verify that automatic monitoring systems are functioning properly.
Evaluate the facility's injection well operation by performing the following
- Review a representative sample of location monitoring data to verify that permitted
operating limitations (injection pressure, temperature, pH) are being met
- Verify by interviewing personnel and inspection records that other operating
requirements (receipt control, inspections, etc.) are addressed by the facility and that
they are being met
GW.24. The permittee is
required to retain all monitoring
information as specified in 40
CFR 144 510))
Verify that samples and measurements taken are representative of the monitored
activity
Verify by reviewing facility files that the following records have been maintained for
a minimum of three years (or longer if requested by the Director)
- Calibration and maintenance records
- Original strip chart recordings for continuous monitoring instrumentation
- Monitoring reports
- Permit application data
- Nature and composition of all injected fluids
Review monitoring information to verify that it includes
- The date, exact place, and time of sampling or measurements
- The mdividual(s) who performed the sampling or measurements
- The date(s) analyses were performed
- The mdividual(s) who performed the analyses
• The analytical techniques or methods used
- The results of such analyses
Determine by interviewing key personnel how the facility will maintain inventory
records of plugged wells for three years after they are taken out of service to ensure
the facility will meet the requirements of 40 CFR 144.51.
GW 25 All applications,
reports, or information
submitted to the Administrator
must be signed and certified (40
CFR 144 32 and 144 51 (k))
Review all permit applications, reports, and other information to verify that the proper
signature and certification is included.
Phase 1 - Section IS
Groundwater Protection
15-22
-------
Compliance Category:
Croond water Protection
Regulatory ftequirejiwattsi
Bevievrer Checks
GW 26 The permittee must
notify the Director of any
planned physical alterations or
additions to the facility, any
anticipated noncompliance,
compliance schedules, and
permit transfers. In addition,
monitoring reports must be
reported as specified in the
permit (see 40 CFR 144 51(j)),
and 24-hour reporting is
required for any noncompliance
which may endanger health or
the environment (40 CFR
144 51(1))
Confirm that the facility conducts required reporting activities such as
- Planned changes, anticipated non-compliance, transfers, or compliance schedules
- Monitoring reports
- 24-hour reporting of any non-compliance which may endanger health or the
environment, including
any monitoring or other information which indicates that any contaminant
may cause an endangerment to an Underground Source of Drinking Water
(USDW) or
any noncompliance with a permit condition or malfunction of the injection
system which may cause fluid migration into or between USDWs
(NOTE Information must be provided orally within 24-hours and written submission
must follow within five days)
GW 27. New injection wells
may not commence injection
until construction is complete
and the permittee has submitted
notice of completion of
construction to the Director, and
the Director has inspected or
reviewed the new injection well
an finds it in compliance with
permit conditions (40 CFR
144 51(m))
Determine if any new injection wells have commenced construction or injection since
the last audit
Verify that for each new injection well
- A notice of completion of construction was submitted to the Director
- The Director has inspected/reviewed the injection well for permit compliance
GW 28 The permittee must
notify the Director before
conversion or abandonment of
the well or before closure of the
project (40 CFR 144 51(n))
Determine if any injection wells have been
- Converted,
- Abandoned, or
- Closed
Verify that the Director was notified of such activity as specified in the permit
GW 29 A plugging and
abandonment report must be
submitted to the Regional
Administrator for EPA-
administered programs (40 CFR
144 51 (o))
Determine if any plugging and abandonment activities have occurred since the last
audit
Determine if the facility is located in an EPA-administered program state
Verify that a plugging and abandonment report was submitted to the Regional
Administrator
- Written 60 days after plugging a well, or
- At the time of the next quarterly report, whichever is less
(NOTE: If the quarterly report is due less than 15 days before completion of plugging,
the report must be submitted within 60 days )
Verify that the report is certified as accurate by the person who performed the
plugging operation
Phase 1 - Section 15
Groundwater Protection
15-23
-------
Section 15
Groundwater Protection
Appendices
-------
Appendix 15-1: Inventory of Neighboring Facilities
Name
Location and
Distance
Operations
Known or Suspected Contamination
Name Name and owner of facility
Location Proximity to reviewed location
Operations Nature of operations capable of causing soil or groundwater contamination
Known or Suspected Groundwater Contamination. Nature of groundwater contamination at the neighboring facility and the extent
of any migration
"Neighboring Facility" Facility within 1/2 mile of the reviewed location with a potential for causing groundwater contamination
Location Prepared by Date
A15-1
-------
Appendix 15-2: Inventory of Groundwater Wells
Well
Number
Type
Location
Pumping
Rate
Geologic
Materia] to
Screened
Area
Depth of
Screen
Hydraulic
Conductivity
Water
Table
Depth
Average
Date of
Measurement
Contamination
Present Y or N.
If Y type e.g.,
VOC, BNA,
PTB
Type e g , monitoring, observation, potable water supply, cooling water, injection wells
Hydraulic Conductivity Indicate value and methods, e g , based on pump, rising head, or falling head tests
Location On-site - indicate area of site, Off-site - indicate distance and direction from site
Location Prepared by Date
A15-2
-------
Appendix 15-3: Inventory of Existing and Former Aboveground Storage Tanks
Tank
Identification
Contents
Capacity
(gallons)
Age
Materials of
Construction
Frequency of Integrity
Inspection
Tank Identification
Daily
Inspection
Type of Overfill
Protection
Inventory
Frequency
Leak Detection
Secondary
Containment
Secondary Containment Nature and adequacy of dikes, berms, etc
"Tanks": Tank, drum, or barrel
Location Prepared by Date
AI5-3
-------
Appendix 15-4: Inventory of Prior Operations
Owner
Operations
Hazardous Materials
Used
Dates
Comments
Owner Include all past owners of the site
Operations Nature of operations capable of causing soil or groundwater contamination
Hazardous Materials Used Nature and quantities of hazardous materials used
Comments e g , known or potential soil or groundwater contamination and nature of any remedial activities undertaken
Location Prepared by Date
A15-4
-------
Appendix 15-5: Inventory of Spills and Leaks or Suspected Areas of Contamination
Location
Number of
Gallons
Leaked/
Soilled
Material
Spilled/Leaked
Date
Area/Volume of
Contamination
Comments
Comments e g , nature of any cleanup or remediation undertaken, cost estimates, verification from regulators that area is "clean"
Location Prepared by Date
A15-5
-------
Appendix 15-6: Inventory of Aquifers
Name
Type
Depth
Discharge to
Recharge From
Gradient
and
Direction
Comments
Comments e g , nature of any cleanup or remediation undertaken, cost estimates, verification from regulators that area is "clean"
Location Prepared by Date
A15-6
-------
Appendix 15-7: Inventory of Lithologies
Name
Depth of Top and
Bottom Unit
Composition
Comments
Comments e g , grain size, fracturing, faulting, jointing
Location Prepared by Date
A15-7
-------
Appendix 15-8: Inventory of On-Site Disposal
Unit Type
Location
Waste/
Hazardous
Constituents
Method of
Disposal
Date of
Disposal/ Total
Amount
Regulatory
Status
Comments
Unit T^pe: e g., impoundment, landfill, sump, drain, pit, tank, drum, storage area, treatment unit, incinerator, etc.
Waste: Nature, amount, and ownership of waste disposal
Regulatory Status: e g , conformance with applicable permits, compliance orders/agreements, regulations, etc , likely future
conformance
Comments: e g , visible leakage/spillage, nature of spill protection, condition of unit and usable life, potential for mixing of
incompatibles
Disposal: Treatment, storage, or disposal
Location Prepared by. Date-
A15-8
-------
Appendix 15-9: Inventory of Water Discharges
Source
Type
Receptor
Daily
Discharge
Pollutants
Length of
Discharge
Pi Dine
Conformance with Applicable
Limitations/ Standards
Source: Point of generation
Type: Direct (D) or Indirect (I) discharge, Point Source (P) or Nonpoint Source (N)
Receptor: e g , surface water body, POTW, deep well, French drain, retention/settling pond
Applicable Limitations/Standards: e g , nature of permits, compliance orders/agreements, POTW regulations, sewer use
ordinances, pre-treatment standards, etc
Length of Piping: Length of facility-maintained piping from source to receptor
Conformance with Applicable Limitations/Standards: During preceding twelve-month period and likely future conformance
Location Prepared by Date
A15-9
-------
Appendix 15-10: Inventory of Existing and Former Underground Storage Tanks
Tank
Identification
Type
Contents
Capacity
Age
Materials of
Construction
Date Last
Leak
Tested and
Method
Secondary
Containment
Type of
Leak
Detection
Tank
Piping
Type: e g , product storage tank, sump, pipe, oil/water separator, process tanks, septic tanks, if more than 10% of volume is below
the surface
Location Prepared by Date
A15-10
-------
Phase 1
Section 16
Environmental Radiation Protection
-------
Phase 1
Section 16
Table of Contents
Environmental Radiation Protection
A. Applicability 16-1
B. Federal Legislation 16-1
C. State/Local Regulations 16-2
D Key Compliance Requirements 16-2
E. Key Compliance Definitions . 16-3
F Records to Review 16-6
G Physical Features to Inspect . 16-6
H. Guidance for Checklist Users 16-6
-------
A. Applicability
This section applies to Federal facilities that use, possess, store, and dispose of
radioactive materials. This section and its associated checklists address activities associated with
Federal research and development laboratories, hospitals, and other facilities where radioactive
material is used, stored, and disposed. Not all checklist items will be applicable to a facility.
Guidance is provided on the checklists to direct the assessor to the regulations concerning the
radioactive material use, storage, and disposal activities at the facility. Information regarding
radioactive waste that also contains a hazardous waste subject to the requirements of the
Resource Conservation and Recovery Act (RCRA), Subtitle C, are included in the Hazardous
Waste Management checklist.
Assessors are required to review the Federal facility's Radiation Protection Program,
Radioactive Material License and license application, and state and local regulations in order to
perform a comprehensive assessment.
B. Federal Legislation
1. The Atomic Energy Act of 1954, as Amended
This Act established the Nuclear Regulatory Commission (NRC) and empowered the NRC
to regulate the use, possession, storage and disposal of source material, byproduct material and
special nuclear material. Also under the authority of the Atomic Energy Act of 1954, the NRC
has promulgated regulations regarding the packaging of radioactive material for transport.
2. The Low-Level Radioactive Waste Policy Amendments Act of 1985
This Act required states to establish their own capability for disposal of low-level
radioactive waste generated within their borders
3. The Federal Water Pollution Control Act
Commonly known as the Clean Water Act (CWA), this is the primary Federal statute
designed to "restore and maintain the chemical, physical, and biological integrity" of the
Nation's navigable waterways. The EPA and authorized states regulate point sources of
pollutants through the National Pollutant Discharge Elimination System (NPDES) Permit
Program.
4. The Radon Program Development Act of 1987
This Act requires studies to be conducted to determine the extent of radon contamination in
buildings owned by the Department of the Interior, the Department of Agriculture, the General
Services Administration, and the Veterans' Administration, including radon contamination of
water for Federal buildings using a nonpublic water source (such as a well or other groundwater).
Radon checklist items can be found in the protocol, "Air Pollution Control" - Section 1.
Phase 1 - Section 16
Environmental Radiation Protection
16-1
-------
5. The Safe Drinking Water Act
This Act establishes requirements for sampling drinking water sources for radioactivity.
6. Hazardous Substance Release Reporting
Under CERCLA Section 103, facilities are required to notify the National Response Center
(NRC) immediately if it releases hazardous substances in excess of or equal to reportable
quantities. Facilities with continuous and stable releases have limited notification requirements
(40 CFR 302.1 through 302.6, and 302.8).
7. The National Environmental Policy Act (NEPA)
The purpose of this Act (42 U.S. Code (USC) 4321-4370(c)), as last amended in November
1990, is to declare and implement a national policy to prevent or eliminate damage to the
environment and biosphere, and stimulate the health and welfare of man (42 USC 4321). Its
underlying intent is to encourage productive and enjoyable harmony between man and his
environment. Under NEPA, the continuing policy of the Federal government is to use all
practicable planning, policy, and regulatory means and measures in a manner calculated to foster
and promote the general welfare, and to create and maintain conditions under which man and
nature can exist in productive harmony, and fulfill the social, economic, and other needs of
present and future generations of Americans (42 USC 4331(a)). Under NEPA and related laws,
it is the continuing responsibility of the Federal government to manage, monitor, and preserve
the important historic, cultural, and natural aspects of our national heritage (42 USC 4331(b)(4)).
C. State/Local Regulations
Many states have met the U.S. Nuclear Regulatory Commission's requirements for
establishing a state agency and management system to regulate users of radioactive material, and
have been granted Agreement State status. Agreement States have promulgated regulations
identical to the NRC, and in some instances, have promulgated regulations that are more
restrictive than those of the NRC. Since differences might exist between regulations of an
Agreement State and the NRC, the assessor must review the regulations of the Agreement State
to ensure that additional restrictions are included in the scope of the assessment and added to this
checklist.
D. Key Compliance Requirements
1. License Requirements
In order for Federal facilities to possess, use, store, and dispose of radioactive materials, the
facility must obtain a license from the NRC. As part of the licensing process, the facility must
submit an application describing the contents of a Radiation Protection Program designed to
ensure that activities meet the regulations of the NRC or Agreement State. Specific conditions
stated in the license imposed by the NRC, and information presented in the application for the
license are enforceable.
Phase 1 - Section 16
Environmental Radiation Protection
16-2
-------
2. Radioactivity in Liquid Discbarge Requirements
Under the Clean Water Act, discharges of radioactive material cannot exceed specific
quantities specified in a NPDES Permit. In addition, radionuclide discharges to the sanitary
sewer must meet certain discharge limitations presented in Appendix B, Table II of 10 CFR Part
20.
3. Air Effluent Discharge Requirements
Under the Clean Air Act, the National Emission Standards for Hazardous Air Pollutants
(NESHAPS) requirements specify that discharges of radioactivity in airborne effluents must not
result in an annual effective dose equivalent exceeding 10 millirem to the public for the airborne
pathway. Additionally, airborne effluents containing radioactivity measured at the point of
discharge cannot exceed specific concentrations presented in 10 CFR Part 20 Appendix B, Table
II.
4. Radioactive Waste Management Requirements
Radioactive wastes must be segregated, stored and disposed of according to specific
requirements of the NRC and the state.
5. Decommissioning Funding Plan
Facilities that use, possess, store, and dispose of radioactive materials must establish a
financial instrument to ensure the decontamination and decommissioning of affected facilities.
The facility can establish a bond by either developing a detailed cost estimate for the
decontamination and decommissioning of affected facilities and submitting to the NRC for
approval, or by establishing a bond of predetermined value based on the possession limits stated
in the facility's NRC license.
6. Dose to the Public Requirements
The facility must demonstrate that the radiological dose to the public from activities and
releases to the environment of radioactive materials does not exceed specific values.
E. Key Compliance Definitions
(NOTE: Definitions taken from "The Health Physics and Radiological Health Handbook",
Revised Edition, Scinta, Inc., 1992.)
1. Agreement State
Any state with which the U.S. Nuclear Regulatory Commission or the U.S. Atomic Energy
Commission has entered into an effective agreement under subsection 274b. of the Atomic
Energy Act of 1954, as amended (73 Stat. 689).
2. ALARA
Acronym for "As Low As is Reasonably Achievable." Making every reasonable effort to
maintain exposures to radiation as far below the dose limits as is practical consistent with the
Phase 1 - Section 16
Environmental Radiation Protection
16-3
-------
purpose for which the licensed activity is undertaken, taking into account the state of technology,
the economics of improvements in relation to state of technology, the economics of
improvements in relation to benefits to the public health and safety, and other societal and
socioeconomic considerations, and in relation to utilization of nuclear energy and licensed
materials in the public interest.
3. Annual Limit on Intake (ALI)
The derived limit for the amount of radioactive material taken into the body of an adult
worker by inhalation or ingestion in a year. ALI is the smaller value of intake of a given
radionuclide in a year by the reference man that would result in a committed effective dose
equivalent of 5 rems (0.05 Sv) or a committed dose equivalent of 50 rems (0.5 Sv) to any
individual organ or tissue.
4. Background Radiation
Radiation from cosmic sources; naturally occurring radioactive materials, including radon
(except as a decay product of source or special nuclear material) and global fallout as it exists in
the environment from the testing of nuclear explosive devices. Background radiation does not
include radiation from source, byproduct, or special nuclear materials.
5. Becquerel
A unit, in the International System of Units (SI) of measurement, of radioactivity equal to
one transformation per second.
6. Byproduct Material
a. Any radioactive material (except special nuclear material) yielded in, or made
radioactive by, exposure to the radiation incident to the process of producing or utilizing
special nuclear material; and
b. The tailings or wastes produced by the extraction or concentration of uranium or
thorium from ore processed primarily for its source material content, including discrete
surface wastes resulting from uranium solution extraction processes. Underground ore
bodies depleted by these solution extraction operations do not constitute byproduct
material within this definition.
7. Curie
The basic unit used to describe the intensity of radioactivity in a sample of material. The
curie is equal to 37 billion disintegrations per second, which is approximately the rate of decay of
1 gram of radium A curie is also a quantity of any radionuclide that decays at a rate of 37 billion
disintegrations per second.
8. Decontamination
The reduction or removal of contaminating radioactive material from a structure, area,
object, or person. Decontamination may be accomplished by:
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a. Treating the surface to remove or decrease the contamination;
b. Letting the material stand so that the radioactivity is decreased as a result of natural
decay; and
c. Covering the contamination to shield or attenuate the radiation emitted
9. Dose Equivalent
The product of the absorbed dose in tissue, quality factor, and all other necessary modifying
factors at the location of interest. The units of dose equivalent are the rem and Sievert (Sv). The
ICRP defines this as the equivalent dose.
10. Effective Dose Equivalent
The sum of the products of the dose equivalent to the organ or tissue (HT) and the weighing
factors (WT) applicable to each of the body organs or tissues that are irradiated (HE = £WXHX)
The ICRP defines this as the effective dose.
11. Half-life
The time in which half the atoms of a particular radioactive substance disintegrate to another
nuclear form. Measured half-lives vary from millionths of a second to billions of years. Also
called physical half-life.
12. High-Level Radioactive Waste
a. Irradiated reactor fuel,
b. Liquid wastes resulting from the operation of the first cycle solvent extraction system,
or equivalent, and the concentrated wastes from subsequent extraction cycles, or
equivalent, in a facility for reprocessing irradiated reactor fuel, and
c Solids into which such liquid wastes have been converted.
13. Low-Level Radioactive Waste
Radioactive waste not classified as high-level radioactive waste, transuranic waste, spent
nuclear fuel, or byproduct material.
14. Member of the Public
An individual in a controlled or unrestricted area. However, an individual is not a member
of the public during any period in which the individual receives an occupational dose
15. Occupational Dose
The dose received by an individual in a restricted area or in the course of employment in
which the individual's assigned duties involve exposure to radiation and to radioactive material
from licensed and unlicensed sources of radiation, whether in the possession of the licensee or
other person. Occupational dose does not include dose received from background radiation, as a
patient from medical practices, from voluntary participation in medical research programs, or as
a member of the general public.
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16. Transuranic Waste
Material contaminated with elements that have an atomic number greater than 92, including
neptunium, plutonium, americium, and curium, and that are in concentrations greater than 10
nanocuries per gram, or in such other concentrations as the Nuclear Regulatory Commission may
prescribe to protect the public health and safety.
F. Records to Review
• NRC License;
• License application,
• Radioactive material inventory;
• Records of radioactive material quantities discharged via the sanitary sewer;
• Radioactive material receiving procedures;
• NESHAP compliance documentation;
• Radioactive waste shipping manifests;
• Decommissioning funding plan; and
• Previous audits and inspections.
G. Physical Features to Inspect
• Laboratories;
• Radioactive waste storage areas; and
• Radioactive material storage areas.
H. Guidance for Checklist Users
Refer To / ; £ ,
Checklist Items
' Paf^uraW *€ "
V"** - "OS- " v
All facilities
ER 1 through ER 3
16-7
ER 4 through ER 6
16-8
ER 7 through ER 10
16-9
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Compliance Category:
Environmental Radiattoh Protection
Regulatory Requirements:
[ Reviewer Checks:
All Facilities
ER 1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOV), Interagency
Agreements, or equivalent state
enforcement actions is required
to be examined (A finding
under this checklist item will
have the enforcement
action/identifying information
as the citation)
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
Agreements or equivalent state enforcement actions
For those items, indicate what corrective actions are planned and milestones
established to correct problems
ER 2 Federal facilities are
required to comply with all
applicable Federal regulatory
requirements not contained in
this checklist. (A finding under
this checklist item will have the
citation of the applied
regulation as the citation )
Determine if any new regulations have been issued since the finalizatton of this
checklist If so, annotate checklist to include new standards
Determine if the Federal facility has activities or facilities which are Federally
regulated, but not addressed in this checklist
Verify that the Federal facility is in compliance with all applicable and newly issued
regulations
ER 3 Federal facilities must
meet the requirements provided
in a NRC or Agreement State
issued license for the use,
possession, storage, and
disposal of by-product
materials Radionuclides,
quantities, and activities
requiring a license are presented
in 10 CFR Part 30 through 35,
and 39 or the equivalent
Agreement State regulations
Verify that the Federal facility possesses or is operating under a license issued by the
NRC or Agreement State where licensable quantities of by-product materials are used,
stored, or disposed
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Compliance Category:
Edviroa mental Radiation Protection
Regulatory Requirements;
Jteviewer Cheeks*
ER 4 The NPDES program as
contained in 40 CFR 122 1
requires permits for the
discharge of "pollutants" from
any "point source" into "waters
of the Untied States " The
terms "pollutant," "point
source," and "waters of the
United States" are defined in 40
CFR 122 2 Requirements for
NPDES permits for storm water
discharges associated with
industrial activity are contained
in 40 CFR 122 26
Determine whether radionuclide discharge limitations are specified by the Federal
facility's discharge permit
Verify whether radionuclide discharge limitations, if any, are met
(Specific requirements regarding implementation of the NPDES program are
addressed in the Water Pollution Control checklist)
ER 5 Federal facilities
releasing radionuclides into the
sanitary sewer must ensure that
discharge limitations are not
exceeded, and must maintain
records of such releases (10
CFR 20 2003, 20 2103(b)(4))
Determine whether the Federal facility releases radionuclides into the sanitary sewer
for disposal
Verify that the facility only disposes of material that is readily soluble, or is readily
disposable biological material, in water
Verify that the facility maintains records of radionuclides disposed by releasing into
the sanitary sewer
Verify that the quantity of licensed or other radioactive material released by the
Federal facility into the sanitary sewer in one month divided by the average monthly
volume of water released into the sewer by the facility by the facility does not exceed
the concentration listed in Table 3 of Appendix B to 10 CFR Part 20
Verify that the total quantity of licensed and other radioactive material released into
the sanitary sewer in a year does not exceed 5 Ci of H-3, 1 Ci of C-14, and 1 Ci of all
others combined
ER 6 Federal facilities must
evaluate the potential for
radionuclide emissions in
airborne effluents, and
demonstrate that the annual
effective dose equivalent for
members of the public does not
exceed 10 million for the
airborne pathway (40 CFR 61
Subpart F)
Verify that the Federal facility has evaluated the potential for releases of radionuclides
via airborne effluents using the COMPLY code.
Verify, if necessary, that the Federal facility has used the A1RDOS-PC or similar EPA
approved computer code to demonstrate that the annual effective dose equivalent to
the public does not exceed 10 million, and submitted the required reports
Verify that the facility has documented the AIRDOS-PC input parameters, with
justification for those used
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Compliance Category:
Eaviroawfefttai Ksditttton Protect loo
Regulatory Requirements:
Reviewer Checks:
ER 7 Federal facilities must
ensure that the annual average
concentration of radioactive
materials released in gaseous
effluents at the boundary of an
unrestricted area do not exceed
the values specified in Table 2
of Appendix B in 10 CFR Part
20
Verify whether the Federal facility has evaluated releases of radioactive materials and
demonstrated that the concentration does not exceed specified values at the boundary
to unrestricted areas
Verify whether the techniques used to estimate releases and calculate concentrations
at the boundary to unrestricted areas are appropriate
Verify whether effluent air sampling techniques used to demonstrate compliance with
the specified limits are performed in accordance with appropriate methodologies (e g ,
ANSI N42 18, ANSI N13 1, Regulatory Guide 8 25)
ER 8 Federal facilities that
generate radioactive waste must
dispose of licensed material
only by transfer to an
authorized recipient, by decay-
in-storage, or by release in
effluents (10 CFR Part 20
Subpart K)
Verify whether the Federal facility has identified all radioactive waste streams and
that all liquid wastes disposed of by the sanitary sewer meet the requirements
specified in ER 5 , and gaseous effluents meet the requirements specified in ER 7
Verify whether the Federal facility is licensed to perform decay-in-storage as a means
of disposing of radioactive waste and that all conditions specified in the license
regarding decay-in-storage are met
Verify that the Federal facility transfers all other radioactive wastes regarding land
disposal to an authorized recipient, and follows all of the recipient's manifesting and
labeling requirements
ER 9 Federal facilities are
required to develop a
Decommissioning Funding Plan
and file a Statement of Intent
with the NRC or Agreement
State to ensure for
decontamination and
decommissioning of facilities
(10 CFR 30 35, 40 36, 70 25).
Verify the Federal facility has developed a decommissioning cost estimate based on
their Radioactive Material License's possession limits and the extent of the use of
their facilities
Verify that the Federal facilities have filed a Statement of Intent with the NRC or
Agreement State which states that the funds will be budgeted as needed
Verify that the decommissioning cost estimate is reviewed and updated, as significant
changes occur (e g, change in extent of facility use or addition of radionuclides, to
the Radioactive Material License) or at least every five years upon renewal
ER 10 Federal facilities that
possess radioactive material
must conduct operations such
that the annual total effective
dose equivalent to a member of
the public does not exceed 100
mitlirem, and conduct surveys
of radiation levels and
radioactive materials in
effluents to demonstrate
compliance with the dose limit
to the public (10 CFR Part 20,
Subpart D)
Verify that the Federal facility has demonstrated that areas where radioactive
materials are used, stored, received, and held for disposal, the radiation levels in
unrestricted areas do not exceed 2 millirem per hour and/or 50 millirem per year
Verify that the Federal facility has measured or has a system in place to determine the
concentration of radioactive materials disposed of in gaseous and liquid effluents and
that they do not exceed the values listed in 10 CFR Part 20, Appendix B, Table 3 at
the boundary to unrestricted areas (See ER 2 )
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4U.S. OOVERWENI PRWITUJ OrTICE. 1998-51S-003--60619
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