NEIC
7
multi-media compliance
audit procedures
July 1985
National Enforcement Investigations Center, Denver
U.S. Environmental Protection Agency
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
MULTI-MEDIA COMPLIANCE
AUDIT PROCEDURES
July 1985
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
INTRODUCTION 1
PURPOSE 1
OBJECTIVES I
SCOPE 2
PLANNING THE AUDIT 3
THE AUDIT TEAM 5
SKILLS REQUIRED 5
INSPECTOR RESPONSIBILITIES . . 5
AUDIT PREPARATION 7
COMPILATION ANO REVIEW OF BACKGROUND INFORMATION 7
NOTIFYING THE FACILITY 11
CONOUCTING THE AUDIT 14
ENTRY 14
OPENING CONFERENCE 18
GENERAL AUOIT PROCEDURES 19
MEDIA SPECIFIC AUOIT PROCEDURES 24
CLOSING CONFERENCE 43
THE AUDIT REPORT AND FOLLOWUP 45
REFERENCES 46
ACRONYMS 48
APPENDICES
A SUMMARY OF POLLUTON CONTROL LEGISLATION
B SAFETY PLAN
C EVIOENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G CERCLA CHECKLIST
H TSCA ANO PCS CHECKLIST
I TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
J PESTICIDE CHECKLIST
K WATER SUPPLY CHECKLIST
TABLES
1 Federal Statutes/Regulations for Multi-Media Compliance
Audits 10
2 Background Review Information Sources 12
3 Audit Authority Under the Major Environmental Acts 15
4 Summary of Federal Environmental Acts Regarding Right of
Entry, Inspecting, Sampling, Testing, Etc 16
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INTRODUCTION
PURPOSE
This manual is a guide to aid inspectors who conduct multi-media
compliance audits of facilities that discharge, emit, handle or dispose of
pollutants controlled by Federal, State or local environmental laws and
regulations. Investigative methods are presented which integrate the
enforcement programs in air, water, solid waste and toxic substances. The
manual includes general activities and functions while focusing on special
features of the specific media.
The purposes of a multi-media compliance audit are to review a facil-
ity's pollution control practices, inspect waste handling equipment, evalu-
ate waste handling procedures, and determine status of compliance with
applicable laws and regulations. Appendix A summarizes the environmental
laws which EPA enforces. Emphasis is given to identifying violations of
regulations, permits, approvals, consent decrees, etc. and the underlying
causes of the violations. Given the number of environmental laws and regu-
lations which may apply to the facility, an in-depth review cannot always
be made. The inspectors, though, are to conduct as thorough a review as
possible so that violations and problems that have an existing or potential
effect on the environment are identified.
Pollution sources vary in complexity depending on facility size, pro-
cess operations and the number of pollution programs involved (e.g., air,
water, solid waste, toxic substances). The time and personnel resources
required, therefore, vary accordingly. For example, a large industrial
facility with multiple process operations may require consideration under
several environmental laws, such as the Clean Water Act (CWA), Clean Air
Act (CAA), Resource Conservation and Recovery Act (RCRA) and Toxic Sub-
stances Control Act (TSCA), Comprehensive Environmental Resource, Compensa-
tion and Liability Act (CERCLA) and Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA). A multi-media compliance audit of this magnitude
requires an audit team with sufficient combined experience to effectively
audit the pollution potential of the facility.
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2
OBJECTIVES
This guide is to provide clear and uniform procedures for multi-media
compliance audits. Specific objectives of such audits are to:
Document facility compliance with environmental laws, regulations,
permits, consent decrees and approvals.
Determine ability of a facility to maintain "continuous compliance"
across all environmental areas.
Identify need for remedial and/or enforcement action to correct
the causes of violations.
SCOPE
The multi-media compliance audit approach effectively uses investiga-
tory personnel to reduce multiple visits to the same facility. This manual
discusses the information that audit teams should obtain prior to the actual
compliance audit field procedures, the audit itself, report writing and
followup procedures.
In performing compliance audits, inspectors shall follow established
Agency policies and procedures for chain-of-custody and document control;
receipt and handling of confidential information; employee conduct, respon-
sibilities and ethics; quality assurance and quality control; and appli-
cable safety rules. When established policies and procedures do not exist,
common sense guided by experience must be used. The inspectors shall col-
lect factual and valid information and data which are supportable and admis-
sible for use in subsequent enforcement action.
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3
PLANNING THE AUDIT
The successful accomplishment of any project requires, extensive,
up-front planning. Coordination with all interested parties (e.g., Region,
State, audit team members, NEIC supervisory staff) is essential to assure a
smooth operation. All of the individuals concerned should be identified as
soon as possible and the necessary coordination initiated.
A project plan assures an effective compliance audit and that all
involved parties are aware of the upcoming activites. A comprehensive plan
is prepared to describe the project objectives and tasks required to fulfill
the objectives, procedures to be followed, required resources and schedules.
A project plan will generally address the following:
Objectives - The plan defines what the audit is to accomplish (e.g.,
". . .to assess environmental compliance with the regulations that
apply to the source—water, air, etc."). This involves evaluation of
process operations, pollution control/treatment and disposal practices,
operation and maintenance procedures, self-monitoring and self-
reporting practices and pollution abatement/control needs.
Tasks - The plan clearly lays out tasks for accomplishing the objec-
tives and spells out procedures for obtaining necessary information
and evaluating facility compliance.
Procedures - The plan gives policies and procedures for document con-
trol, chain-of-custody, quality assurance, handling and processing of
confidential information, and safety which must be followed by EPA
audit teams. Appendix B provides guidance for developing a safety
plan. Specific instructions for the particular audit are also provided.
Resources - Personnel needs and equipment requirements are described.
Experienced personnel, knowledgeable of pollution control activities,
shall comprise the compliance audit team.
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4
Schedules - A schedule of project activities is necessary for smooth
project operations. The schedule is important to the participants as
well as those Regional and/or Headquarters officials who requested the
project. Start and finish dates of the field activities, dates for
analytical work and dates for draft and final project reports should
be firmly established and understood at the beginning.
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5
THE AUDIT TEAM
SKILLS REQUIRED
The audit team should consist of individuals who possess a good working
knowledge of the various environmental pollution control statutes and under-
stand the rules, regulations and other provisions, including permits, regi-
strations, authorizations, limitations, monitoring requirements, etc., as
they pertain to a specific facility. The inspectors should have knowledge
of manufacturing and production processes, applicable pollution control
technology, and the nature of pollution problems and possible solutions,
including available treatment and controls.
Individual inspectors may have more specific knowledge of a process,
control equipment, regulation, etc. than others. The team, as a whole,
however, should have the knowledge and background to be able to conduct all
aspects of the audits.
The inspectors should be familiar with agency policies and procedures,
know their authority to conduct the inspection, know techniques for evidence
gathering and possess skill in collecting information and obtaining state-
ments from interviewees.
INSPECTOR RESPONSIBILITIES
Inspectors represent the Agency in their dealings with the regulated
community and the public. They must conduct themselves in a professional
manner and maintain their composure at all times. Cooperation and good
working relations with facility personnel should be established, whenever
possible, and maintained. EPA inspectors must adhere to the regulations
described in the EPA handbook "Responsibilities and Conduct for EPA
Employees"
Applicable safety provisions and precautions are to be followed
throughout the audit. Inspectors will dress appropriately, including wear-
ing protective clothing or equipment. It is important that inspectors
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6
identify and obtain necessary safety equipment before the audit so that the
audit will not be hindered or precluded. Inspectors should provide their
own safety equipment and not rely on the facility to do so. All required
FIT testing and certifications must be done in advance.
Inspectors must properly handle information for which confidentiality
is claimed or requested to prevent disclosure to unauthorized persons.
Inspectors must have specific authorization for accessing and handling Con-
fidential Business Information under TSCA rules. They must be familiar
with the confidentiality regulations to ensure that information is handled
properly and to prevent disclosure to unauthorized persons.
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7
AUDIT PREPARATION
COMPILATION AND REVIEW OF BACKGROUND INFORMATION
Collection and analysis of background information on the facility to
be inspected are essential to the effective planning and overall success of
a compliance audit. Materials can be obtained from files of Federal, State
and local agencies, technical libraries, EPA databases and other information
sources. This review will enable inspectors to become familiar with facility
operations, clarify technical and legal issues before entry, and develop a
sound, factual audit report.
A properly conducted background review should consider both the tech-
nical and legal information needed and the available information sources.
The following discusses the types of information which may be acquired and
reviewed.
Technical Information
Facility Background
Maps showing facility location and environmental (stacks, dis-
charge pipes,, solid waste disposal sites, etc.) and geographic
features
Names, titles, phone numbers of responsible facility officials
Process description, process flow charts and major production
areas
Production levels - past, present and future
Geology/hydrogeology of the area
Changes in facility conditions since previous audit/permit
application
Available aerial photographs
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8
Audit Reports, Records, and Files
Federal and State compliance files
Correspondence between the facility and the local, State and
Federal agencies
Citizens' complaints and reports, followup studies, findings
Previous audit records, reports, correspondence on past incidents
or violations
Emissions inventory
Self-monitoring data and reports
Previous EPA, State and consultant studies and reports
Annual reports by the facility (e.g., PCB Annual Documents and
inventories, §10K reports)
Data including records, applications, reports, manifest files,
etc. (e.g., RCRA reports, CERCLA submittals)
Laboratory audit reports, QA/QC activities
Reports of previous hazardous substances spills
Pollutant and Waste Generation, Control, Treatment and Disposal Systems
Description and design data for each appropriate pollution control
system and process operation
Sources and characterization of wastewater discharges, hazardous
wastes, emissions, types of treatment and disposal operations
Type and amount of waste generated which is discharged, emitted,
stored, treated and disposed of
Waste storage, treatment and disposal areas
Waste/spill contingency plans
Available bypasses or diversions and spill containment facilities
Industrial process, pollution control, treatment and disposal
methods, monitoring systems
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9
Legal Information
Requirements, Regulations and Limitations
Copies of permit applications, draft or existing permits,
registrations, approvals and applicable Federal, State and local
regulations and requirements
Copies of draft permits or information on draft permit terms which
are different from current terms
Special exemptions and waivers
Receiving stream water quality standards, ambient air standards,
SIPs, protected uses
RCRA notification and Part A and Part B application data
Grant applications for publicly owned treatment works, R&D demon-
stration projects and progress reports.on these projects
Official classification of facility (e.g., Interim Status, Small
Quantity Generator, etc.)
Enforcement History
Status of current and pending litigation against the facility*
Deficiency notices issued to facility and responses by the
faci1ity
Status of administrative orders, consent decrees or other regula-
tory corrective actions, if any, and compliance by the facility
Penalties imposed against the Company
Information Sources
Laws and Regulations - Federal laws and regulations establish proce-
dures, controls and other requirements applicable to a facility [Table 1].
In addition, State laws and regulations and sometimes even local ordinances
may be applicable to the same facility.
Coordination should occur prior to the audit (in conjunction with the
Regional office) with the local Assistant United States Attorney or
Justice Department attorney responsible for the civil case and any
consent decree.
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Table I
FEDERAL STATUTES/REGULATIONS FOR MULTI-MEDIA COMPLIANCE AUDITS
Ai r
CAA
Water
CWA
Super fund
CERCLA
Pesticides
FtFRA
Sal id Waste
RCRA
Drinking Water
SOWA
Toxics
TSCA
Inspection
Authority
Recordkeeping
Authority
Confidential
Information
Emergency
Authori ty
ErapIoyee
Protection
114 , 211
[80, 86°]
114, Z08 [51, 57,
58. 60, 61, 79,
85. 86]
208, 307, 12 201-
2.215, 2.301, S3,
57, BOJ
308, 402
[122.41]
308,402
[122 41,
122.48]
12.201-2. 215,
2 302. 122.7]
104
[160.15]
103
104
[2.201-2.215]
303
322
504
507
104, 106
[300.53, 300.65]
110
8. 9
[169.3]
4. 8
[160.63. 169,
160.185-195]
7. 10
[2,201-2.215,
2.307j
2?
[164. 166]
3007, 9005
[270.30]
3002, 3003, 3004,
9003
[262.40, 263.22,
264.74, 264.279,
264.309, 265.74,
265.94, 265.279,
264.309, 270.30]
9005
[2.201-?. 21b,
2.305, 260.2,
270.12]
7003
1445
[142.34, 144.51]
1445
[141.31-33, 144.51.
144.54]
[2.201-2.215,
2.304, 144.5]
7001
1431
1450
11 [717.17,
792.15]
8 [704, 710,
717.15, 720.78,
761.180,
762.60, 763.114,
792.185-195]
14 [2.201-
2.215, 2.306,
704.7, 707.75,
710.7, 712.15,
71 J.19, 720.80-
95, 750.16,
750.36, 762.60.
763.74]
23
Permits
Basic requirements
include applica-
tions, standard
permit conditions,
monitoring,
reporting
EPA procedures for
permit issuance
Technical
requirements
[122, 125]
[270]
[144, 147]
[124]
[52]
[124]
[136, 302]
BMP [125]
SPCC® [112]
Waivers [125,
230]
[124]
[260-266]
[124]
[146, 264]
Specific Source NSPS" £60]
Category - Controls - NESHAP™ [61]
Liaitations - CEH. [60],
Standards - Rules SlPi [52]
PSD* [50]
Effluent guide-
lines [400-460]
BMP [125], SPCC
[112], Pretreatment
[125, 403], Toxic
pollutants [129]
Generators [262], Trans- PCBs [761]
porters [263], TSO Dioxin [775]
[265], Stds for TSD,
Permits [264], Interim
Stds [265], Storage
<90 days [262],
Exemptions [261]
Statute (e.g., Clean Air Act, Section Hi or 2J1)
[BO, 86) - 40 CFR, Parts BO and 86; CFK refers to Code of Federal Peculations
Reportable quantities
BMP • Best Management Practices
SPCC - SpiJ} Prevention Control and Counter-measures Plan
USPS - New Source Performance standards
NESHAP - National Enission Standards for Hazardous Air Poiiutants'
7SO - Treatment, Storage and Disposal
C£* - Continuous Emission Monitoring
SIP - State /upleoentation PJan
PSD - Prevention of Significant Deterioration
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11
Permits and Permit Applications - Permits provide information on the
limitations, requirements and restrictions applicable to discharges, emis-
sions and disposal practices; compliance schedules; and monitoring, analy-
tical and reporting requirements. Applications provide technical informa-
tion on facility size, layout and location of pollution sources; waste or
pollutant generation, treatment, control and disposal practices; contin-
gency plans and emergency procedures; and pollutant characterization--types,
amounts, and locations of discharge, emissions or disposal.
Regional and State Files - These files often contain grant records,
applications, facility self-monitoring data and audit reports, as well as
permits and permit applications pertaining to individual facilities. These
information sources can provide compliance, enforcement and litigation
history; special exemptions and waivers applied for and granted or denied;
citizen complaints and action taken; process operational problems/solutions;
pollution problems/solutions; and laboratory capabilities. Consultant
reports can provide design and operating data and recommendations for pro-
cesses; pollutant sources; treatment, control and disposal systems; and
remedial measures.
Technical Reports, Documents and References - These sources provide
information on industrial process operations, pertinent specific data on
available treatment, control and disposal techniques, such as their advant-
ages or drawbacks, limits of application, etc. Such sources include Effluent
Guideline and New Source Performance Standard development documents and
EPA's Treatability Manual. Similar guidance documents or hazardous waste
generation, treatment/disposal are also becoming available.
Background review information sources for all program areas and those
that apply specifically to the water, air, solid waste and toxic substances
programs are listed in Table 2.
NOTIFYING THE FACILITY
Notification is not required when illegal activity, such as illegal
discharges and/or emissions or improper recordkeeping, are suspected.
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Table 2
BACKGROUND REVIEW INFORMATION SOURCES
All Program Areas
Water Pollution
CWA
Air Pollution
CAA
Solid Wastes Pollution
RCRA
Toxic Substances Pollution
TSCA
NEIC Information Retrieval
System data on corporate
structure, financial condi-
tions, pollution control
history, environmental and
health impacts of pollutants
of interest
EPA grants (R&O, construct-
ing, planning)
Information available on
process operations; pol-
lutants of interest; exist-
ing treatment, control and
disposal practices; raw
materials; etc.
Administrative Orders.issued
for environmental noncom-
pliance
Applicable local ordinances
on environmental control
Compliance history and
present compliance status
Available correspondence
between regulating officer
and facility officials
Available contractor/
consultant report on
facility environmental
control matters
Environmental compliance
schedules and present
status
Available aerial photography
NPDES permits/permit
applications/draft permits
Applicable effluent
guidelines
Compliance inspection
reports (Federal/State/
local)
Laboratory performance
reports
Self-monitoring require-
ments and self-reporting
data
Best Management Practices
Plan
Spill Prevention Control
and Countermeasure Plan
Pretreatment requi rements
if facility discharges to
POTW
Applicable Federal/State
regulations related to
water pollution control
at facility
Technical manuals and
references on pollution
treatment/control tech-
nology, process operation,
monitoring inspection
procedures, etc.
Interstate Commission water
quality date (Ohio River
Sanitary Commission, Dela-
ware River 6asin Commission,
Interstate Commission on
the Potomac River, etc.)
PDS permits and present
status
Self-monitoring requirements
and self-reported data
Compliance inspection reports
(Federal/State/local)
Applicable NESHAP
Applicable NSPS
Applicable air quality
standards
State Implementation Plan
Ambient air quality reports
for AQCR
Air pollutants emission
inventories
Continuous monitoring prac-
tices and facility and
applicable performance
inspections
Available contractor/
consultant reports
Technical manuals and
references on applicable
pollution treatment/control
technology, process oper-
ators, air pollution
monitoring, inspection
procedures, etc.
Part A of permit application
(TSDs only) to designate type
and volume of wastes handled,
type and design capacity of
treatment, storage and/or
disposal processes
Part B of permit application,
i f available
Draft/final RCRA permit
Applicable regulations for
source designations
Groundwater monitoring
plans/data
UIC permit and present status
Hydrogeologic reports on local
area relative to UIC permit
Self-monitoring requirements
and self-reported data
Applicable regulation on
manifest requirements
Inspection reports (Federal/
State/local)
Technical manual and references
on applicable treatment/control
and disposal technology, inspec-
tion and monitoring procedures
and techniques, etc.
Available information on
chemical substances
produced by facility
Applicable regulations
regarding manufacture,
identification, self-
reporting requirements,
concerning toxic mater-
ials (e.g., PCB rules)
Inspection reports
(Federal/State/local)
Technical manuals and
references on applicable
treatment/control and
disposal technology,
inspection and monitoring
procedures and techniques,
etc.
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13
The concern that physical conditions may be altered prior to the audit or
that records may be destroyed justifies an unannounced audit. Normally,
compliance audits are announced; that is, facility officials are contacted
prior to the audit. The initial contact is usually by phone with followup
written confirmation of the anticipated audit period. The notification
1etter,specifies the authority for the audit and provides an outline of the
areas that will be covered by the audit and the information to be provided.
This approach improves the chances that responsible facility officials will
be present and that necessary information will be made available.
Typical information requested by a notification letter may include the
following:
Raw materials, products, byproducts, production levels
Facility maps identifying process areas, discharge and emission
points, waste disposal sites
Flow diagrams for processes and waste control, treatment and dis-
posal systems showing where wastewater, air emission and solid
waste sources are located
Description and design of pollution control and treatment systems
and normal operating parameters
O&M problems that may be causing violation of applicable regula-
tions and limitations
Recent self-monitoring reports and inventories of discharges and
emissions
Self-monitoring equipment in use, normal operating levels and
available data
Required records
Information already available in regulatory files should not be
requested if the facility is handling any TSCA regulated substances (e.g.,
PCBs).
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14
CONDUCTING THE AUDIT
The compliance audit will consist of the following phases:
Entry
Opening conference
The onsite inspection
Closing conference
ENTRf
Arrival at the facility should be made during normal working hours,
unless special circumstances, such as suspected illegal activity at night,
etc. are being investigated. The inspectors shall identify themselves to
the owner, agent in charge or other responsible facility official 5 present
their official Agency credentials to the facility official, whether requested
or not; and explain the purpose of the audit. Tables 3 and 4 outline the
various Federal environmental statutes which give Agency inspectors the
authority to enter facilities, review records and collect environmental
samples. The inspector should not discuss their authority to conduct the
audit unless requested by facility personnel.
If the audit is of a Federal facility that has national security,
restricted areas or classified areas, special procedures may be required
for entry. For example, a military installation regulation may stipulate
that "inspectors shall be required to show proof of appropriate security
clearance before entry is approved into restricted areas". Inspectors
should refer such special cases to their appropriate legal staff (e.g.,
Office of Regional Counsel).
When the facility provides a blank sign-in sheet, log or visitor reg-
ister, it is acceptable for inspectors to sign it. Note, however, that EPA
employees will not sign any type of "waiver" or "visitor release" that would
relieve the facility of responsibility for injury or which would limit the
rights of the Agency to use data obtained from the facility. The inspector
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Table 3
INSPECTION AUTHORITY UNDER THE MAJOR ENVIRONMENTAL ACTS
15
CAA - § 114(a)(2)
.. .the Administrator or his authorized representative, upon presentation of his credentials - shall have a right of
entry to, upon, or through any premises of such person or in which any records required to be maintained. . .are located,
and may at reasonable times have access to and copy any records, inspect any monitoring equipment and method. . .arid
sample any emissions. .
CWA - § 308(a)(4)(B)
". . .the Administrator or his authorized representative, upon presentation of his credentials - shall have a right of
entry to, upon, or through any premises in which an effluent source is located or in which any records required to be
maintained. . .are located, and may at reasonable times have access to and copy any records, inspect any monitoring
equipment or method. . .and sample any effluents which the owner or operator of such source is required to sample. . .".
RCRA - § 3007(a)
". . .any person who generates, stores, treats, transports, disposes of or otherwise handles or has handled hazardous
wastes shall upon request of any. . .employee or representative of the Environmental Protection Agency. . .furnish
information relating to such wastes and permit such person at all reasonable times to have access to, and to copy all
records relating to such wastes."
". . .such employees or representatives are authorized. . .to enter at reasonable times any establishment or other place
where hazardous wastes are or have been generated, stored, treated or disposed of or transported from; to inspect and
obtain samples from any person of any such wastes and samples of any containers or labeling for such wastes."
TSCA - § ll(a)(b)
". . .any duly designated representative of the Administrator, may inspect any establishment. . .in which chemical sub-
stances or mixtures are manufactured, processed, stored or held before or after their distribution in commerce and any
conveyance being used to transport chemical substances, mixtures or such articles in connection with distribution in
commerce. Such an inspection may only be made upon the presentation of appropriate credentials and of a written notice
to the owner, operator or agent in charge of the premises or conveyance to be inspected."
FIFRA - § 8 and 9
". . .officers or employees duly designated by the Administrator are authorized to enter at reasonable times, any estab-
lishment or other place where pesticides or devices are held for distribution or sale for the purpose of inspecting and
obtaining samples of any pesticides or devices, packaged, labeled and released for shipment and samples of any containers
or labeling for such pesticides or devices."
". . .any person who sells or offers for sale, delivers or offers for delivery any pesticide. . .shall, upon request
of any officer or employee of the Environmental Protection Agency. . .furnish or permit such person at all reasonable
times to have access to, and to copy: (1) all records showing the delivery, movement or holding of such pesticide or
device, including the quantity, the date of shipment and receipt, and the name of the consignor and consignee. .
"Before undertaking such inspection, the officers or employees must present to the owner, operator or agent in charge
of the establishment. . .appropriate credentials and a written statement as to the reason for the inspection, including
a statement as to whether a violation of the law is suspected."
". . .employees duly designated by the Administrator are empowered to obtain and to execute warrants authorizing entry
. . .inspection and reproduction of all records. . .and the seizure of any pesticide or device which is in violation of
this Act."
SDWA - § 1445
. .the Administrator, or representatives of the Administrator. . .upon presenting appropriate credentials and a
written notice to any. . .person subject to. . .any requirement. . .is authorized to enter any establishment, facility
or other property. . .in order to determine. . .compliance with this title, including for this purpose, inspection, at
reasonable times, of records, files, papers, processes, controls and facilities or in order to test any feature of a
public water system, including its raw water source."
CERCLA (Superfund) - § 104(3)(I)
.any person who stores, treats or disposes of. . .where such hazardous substances are located, who generates,
transports or otherwise handles or has handled hazardous substances shall. . .furnish information relating to such sub-
stances and permit such person at all reasonable times to have access to, and to copy all records relating to such
substances."
". . .such officers, employees, or representatives are authorized. . .to enter at reasonable times any establishment or
other places where such hazardous substances are or have been generated, stored, treated or disposed of, or transported
from."
". . .to inspect and obtain samples from any person of any such substance and samples of any containers or labeling for
such substances."
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Table 1
SUMMARY OF FEDERAL ENVIRONMENTAL ACTS
REGARDING RIGHT OF ENTRY, INSPECTIONS, SAMPLING, TESTING, ETC.
Receipt
Return of
Designated
Presentation
Notice of
Sampling
Inspection
Sample
for Agency's
Analytical
Act/Section
Representative
of Credentials
Inspection
Perm i tted
of Records
Splits
Samp 1es
Results
Clean Water 5308(a)
Yes, auth. ty
Required
Not required
Yes (effluents
Yes
Not required
Not required
Not required
Act
Administrator
which the owner
is required to
sample)
FIFRA
58(b)
Yes, designated
Required
Written notice
No
Yes
N/A
N/A
N/A
(Books &
by Administrator
required with
Records)
reason and sus-
pected violation
note
59(a)
Yes, designated
Required
Written notice
Yes
See §8
Required,
Required
Required,
(Inspec-
by Administrator
required with
if requested
promptly
tions of
reasons for
estab-
inspection
1 ishments
Clean Air
5114(a)
Yes, auth. by
Required
Not required
Yes
Yes
Not required
Not required
Not required
Act
Administrator
except notify
State for SIP
sources
RCRA
53007(a)
Yes, designated
Not required
Not required
Yes
Yes
Requi red,
Required
Required,
9005(a)
by Administrator
i f requested
promptly
SOMA
51445(b)
Yes, designated
Required
Written notice
Yes
Yes
Not required
Not required
Not required
by Administrator
required, must
also notify
State with
reasons for
entry if State
has primary
enforcement
responsibi1ity
TSCA
SH(a.b)
Yes, designated
Requi red
Written notice
(The Act.
Yes
N/A
N/A
N/A
by Administrator
requi red
does not men-
tion samples
or sampling in
this section.
It does state an
inspection shall
extend to all
things within
the premise of
conveyance.)
CERCLA
§104(3)
Yes, designated
Not required
Not required
Yes
Yes
Required,
Required
Requi red,
by President
if requested
promptly
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17
must not agree to any such unwarranted restrictive conditions. If such a
waiver or release is presented, the inspectors should politely explain they
cannot sign and request a blank sign-in sheet. If the inspectors are
refused entry because they do not sign such a release, they should leave
and immediately report all pertinent facts to the appropriate supervisory
and/or legal staff (e.g., Office of Regional Counsel). All events surround-
ing the refused entry should be fully documented, including the name of the
person refusing entry. Problems should be discussed courteously and pro-
fessionally. Facility officials must not be subjected to intimidation by
emphasizing the Government's right to inspect.
Various Federal environmental statutes give Agency inspectors the
authority to enter facilities, review records and collect environmental
samples [Tables 3 and 4], The audit should be made with the consent of the
facility owner and/or authorized person, unless the audit is conducted under
a warrant. As long as the inspector is allowed to enter, entry is consid-
ered voluntary and consensual by the facility operator or owner, unless the
inspector is expressly told to leave the premises. Consent to enter can,
however, be revoked at any time during the audit. If this occurs, all
information collected during the consensual phase remains in possession of
the inspectors. When withdrawal of consent takes place, the same procedures
apply as for denial of entry.
Because audits may be considered adversary proceedings, inspectors may
be challenged as to their legal authority, techniques and competency.
Facility personnel may also display antagonism to Agency personnel. In all
cases, the inspectors must courteously explain the authorities and the
reasons for the protocols followed. If explanations are not satisfactory
or disagreements cannot be resolved, the inspectors should leave and obtain
further direction from the appropriate Agency supervisory or legal staff.
Professionalism must prevail at all times.
Under certain circumstances, audits will be conducted under authority
of search warrants. A warrant is a judicial authorization for appropriate
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18
persons to enter specifically described locations and to perform particular
audit functions. It is possible that a pre-audit warrant could be obtained
where there is reason to believe that entry will be denied when the inspector
arrives at the site or when violations are expected which could be hidden
during the time a search warrant was obtained. Administrative search war-
rants can be served by an inspection team member. Other search warrants,
once obtained, are to be served by designated Federal law enforcement offi-
cials (e.g., U.S. Marshal, EPA criminal investigators) and not by an inspec-
tion team member.
OPENING CONFERENCE
At the opening conference with facility officials, the inspector pre-
sents credentials; provides names of the inspectors, purpose of the audit
and laws under which the audit is being conducted; and outlines procedures
to be followed. Any required notices should also be presented to facility
representatives at this time, if not previously done.* The Agency encour-
ages cooperation between the inspectors and the facility officials; this
will simplify assignments and contribute to the success of the compliance
audit.
Major topics at the opening conference should include: audit objec-
tives, processes and areas to be inspected, anticipated audit schedules to
various areas of the facility, basic types of records to be inspected,
safety requirements, the handling of confidential data (which should be
obtained only if absolutely necessary), how questions will be handled during
the course of the audit and the closing conference. Facility officials
should be informed of their right, under RCRA, CERCLA/Superfund and FIFRA,
to receive duplicates, splits or any samples taken and receive the results
of analyses. • If inspectors desire to take photographs or copies of records
during the audit, this should also be discussed.
Under FIFRA, TSCA and SDWA, written notification is required before
entry. For "unannounced audits", this notification can be provided at
the time of entry. Under TSCA, the inspector presents a TSCA Inspec-
tion Confidentiality Notice which informs the facility of their right
to claim certain materials as Confidential Business Information (CBI).
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19
Photographs may be used to prepare a more thorough and accurate
inspection report, as evidence in enforcement proceedings and to better
explain conditions found at the plant. The facility, however, may object
to the use of cameras in their facility and on their property. If a mutually
acceptable solution cannot be reached and photographs are considered essen-
tial to the audit, Agency supervisory and legal staff should be contacted
for advice.
Facility personnel may also request that any photographs taken during
the visitation be considered confidential, with which the Agency is obliged
to comply, pending further legal determination. Self-developing film,
although of lower quality, is useful in these situations. A facility may
refuse permission to take photographs unless they can see the finished print.
Duplicate photographs (one for the inspector and the other for the facility)
should satisfy this need. When taking pictures under TSCA authority, self-
developing film eliminates processing problems, because the film processing
facility must also have TSCA clearance. Note, however, that self-developing
film may contain disposable negatives which must also be handled in accord-
ance with the TSCA requirements. Giving the facility the option of having
the film developed may resolve problems when self-developing film is not
satisfactory.
Photographs must be fully documented, following procedures for handling
evidentiary materials [Appendix C].
GENERAL AUDIT PROCEDURES
This section describes general elements that are common to all environ-
mental program areas—process operations, pollution control, treatment and
disposal, and operation and maintenance. Specific elements that complement
the general elements and that can be used when deemed appropriate are con-
tained in the following section, organized by program area--air, water,
solid/hazardous wastes, and toxic substances; additional checklists are
provided in the appendices.
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20
Activities include reviewing records; observing and evaluating equipment,
monitors, devices or activities directly; and interviewing facility person-
nel. It is, therefore, important to have a knowledgeable facility represen-
tative accompany the inspectors during this segment of the audit and/or to
be available for questions.
If the audit includes determining consent decree compliance, the fol-
lowing procedures are recommended:
Inspectors should ascertain the names and functions of the facil-
ity individuals familiar with, and responsible for, compliance
with the terms of the consent decree.
Inspectors should be thoroughly aware of contents of the decree,
interim and final deadlines and any modifications of the decree
that have occurred prior to the audit.
Process Operations
The inspectors must have a basic understanding of the physical plant
under investigation and the processes in use at the facility. This knowledge
is necessary to aid in the determination of substances (e.g., raw materials,
products, byproducts, including waste materials) present at the facility
and where these may be released as pollutants into the environment. It is
not necessary that a compliance audit team have an in-depth understanding
of all the intricacies of the industrial processes but inspectors should
have sufficient understanding to conduct a thorough, efficient audit.
The compliance audit team may perform the following:
Determine if changes have been made since the last audit, permit
issuance, etc. to process units, their operation and flow diagrams
by comparing to available information. Determine the present
production level and rate of products, byproducts and waste gener-
ation. Determine the rate of raw material usage. Determine pro-
duction process unit mode (e.g., continuous or batch). Infor-
mation on.production is essential if pollution control limits are
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21
based on production rates or products. Process modifications may
have changed the types and loads of pollutants emitted, discharged
or disposed of. Different production levels could cause higher
emission mass loadings or gas flow rates. Varying operating con-
ditions may mean pollutant collection and control problems.
Identify those processes or physical elements of the facility
which contribute to sources of pollution (air, water, solid/
hazardous waste). Identify the sources, characterization, flow
rates, etc. at points where wastewater, gaseous emissions and
solid wastes are generated. Determine fate of byproducts (e.g.,
do they discharge or emit directly to the environment or to stor-
age facilities or to a treatment facility). Determine types and
amounts of pollutants being discharged.
Determine the variability of process controls and production rates
and their relationship to pollutant emission discharges, etc.
Determine if production upsets are tied to pollution incidents,
exceedences, etc. and the facility response to these upsets.
Determine if process or facility modifications are proposed or
planned. Obtain specifics on these modifications, including
schedules, and certainty of the modifications (e.g., is the change
proposed or planned, is money set aside). Obtain facility esti-
mates on wastes generated and/or discharged.
Pollution Control, Treatment and Disposal
After inspectors have determined what wastes are generated by each
process, they should determine how the materials are handled and ultimately
released, treated or otherwise disposed of. This will include tracking the
waste from generation to final disposition, using process flow diagrams,
physical audits, facility records and other means.
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22
The compliance audit team may perform the following:
Determine which waste streams are regulated by Federal, State
and/or local regulations, licenses and approvals. In doing so,
the inspectors will be able to tailor their audit activities to
the handling, disposal and treatment requirements of the appropri-
ate regulations. Identification of the various items regulated
under the established Federal regulations were shown in Table 1.
Although it is desirable to obtain information on all waste -
streams generated (both those that are and those that are not
specifically regulated), the emphasis must be placed on the han-
dling of regulated wastes. This will ensure that the audit team
accomplishes the major objective of determining compliance with
applicable regulations in a reasonable period.
Obtain updated descriptions and schematics of major pollution
control equipment and waste storage/treatment/disposal areas.
Visually inspect equipment and storage/treatment/disposal areas.
Locate points of pollutant emission or discharge and waste dis-
posal or storage, including alternative locations, such as diver-
sions, bypasses and overflows.
Obtain design data and startup dates for pollution control/
treatment devices and waste disposal areas. Observe equipment or
. disposal areas. Observe equipment or disposal practices during
operation. Locate and observe indicating and recording instrumen-
tation for monitoring control/treatment devices; compare operating
levels to design specifications to determine if devices are oper-
ating normally or abnormally. Identify any operating problems
and their causes.
Evaluate sampling techniques, equipment and locations to be used
for collection of representative samples. Identify recycle or
dilution streams and other flow disturbances and reference to
these sampling locations. Determine if samples are being collected
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23
consistent with permit/regulation requirements (e.g., grab vs
composite) and frequency of sample collection. Observe monitoring
procedures such as flow measurement, sample collection and preser-
vation, calibration procedures, in-stack monitors, etc. Determine
if proper parameters are being monitored, if the records are con-
sistent with permits and regulations, and if results are properly
calculated and reported. Evaluate quality assurance/quality con-
trol procedure followed by the Company.
Determine facility plans to expand existing treatment facilities
and install new treatment units. Obtain copies of design cri-
teria, consultants' reports, etc. Based on these data and first-
hand observations, determine what additional treatment may be
required to meet existing permit limits, regulations and other
requirements.
Evaluate compliance with schedules, including status of engineer-
ing plans and equipment design, procurement, fabrication, instal-
lation and testing and startup of equipment. Determine if the
final requirements can be achieved on time; verify if structures
are in place. Determine any delays associated with particular
construction schedule and possible violations. If schedules are
not being met, determine if the facility has rescheduled activi-
ties; for example, corporate resolutions, financing agreements,
contracts, equipment orders and engineering services documents.
Verify dates when documents were completed. These documents may
be procured through a formal written request so they can be
studied in depth. Determine if recruitment and training of new
personnel for new pollution control activities have been initiated.
Review laboratory analytical methods and procedures and quality
control measures. Determine if the methods conform to permit or
regulatory requirements. Determine if quality control is suffi-
cient to generate valid data (e.g., proper and timely calibration,
fresh chemical reagents, scheduled equipment maintenance, etc.).
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24
Operation and Maintenance (O&M)
Knowledge of operation and maintenance of process and control
facilities provides the inspector insight into plant management and prob-
lems including frequency of breakdowns, malfunctions, upsets, outages,
diversions, spills and leaks, bypasses and waste variability. It is impor-
tant to determine the causes of these incidents and if they can be corrected.
O&M review includes preventive, routine, and remedial maintenance programs;
spare parts inventory; emergency operating and response programs; training
and certification of plant personnel; alarm systems for power and equipment
failures; backup systems; and regularity of housekeeping throughout the
plant. It also includes review of facility protocol and schedules for such
items as reading and calibrating instrumentation, examining recording charts
and logs, and updating O&M manuals, engineering drawings and specifications,
supplier manuals, and data cards on equipment.
The compliance audit team may determine major factors which affect
process discharge, emissions, disposal, controls and changes in operation.
O&M practices should be evaluated as to whether they are adequate for the
proper management of pollution control equipment. Abnormal releases can be
due to progressive equipment deterioration or lack of repair. Also, as
equipment ages, efficiency drops and original removal rates cannot be
achieved. Startup and shutdown of process and control facilities can create
problems of surge waste releases which may be alleviated by improved plant
management.
MEDIA-SPECIFIC AUDIT PROCEDURES
Air
Air pollution audit items are divided into four groups: (1) operating
conditions, (2) control systems, (3) continuous monitoring and (4) compli-
ance records and testing. Inspectors should be prepared to observe and
document these audit items so that factual information can later be evalu-
ated and compliance determined. Prior to the audit, review of the check-
lists in Appendix D is encouraged.
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25
Operating Conditions
Determine if construction and operating permits are updated.
Determine if emission inventories are updated.
Review records of abnormal operations, shutdowns, malfunctions.
Determine if any operational changes (feedstock, fuel flow rate,
temperature changes, etc.) have been made that could affect
emissions.
Observe evidence of air pollution effects on premises but espe-
cially over surrounding areas (e.g., odors, dusting, deposits on
cars, vegetation damage). Fugitive emissions may require special
attention. Odor problems are best characterized outside the plant
because of olfactory fatigue inside the plant.
Control Systems
Compare observed operating conditions with baseline values obtained
from compliance stack tests or from manufacturer's specifications.
Conduct control system evaluation. Review instrumentation, design
and operational flow rates, temperatures, pressure drops and emis-
sion monitors. From these data, the inspector should know if the
plant can achieve compliance under normal circumstances.
Check control equipment maintenance procedures, malfunctions and
corrective action taken.
Check number of emissions violations and any complaints since the
last audit.
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26
Continuous Monitoring
Check equipment and records on continuous monitoring, as required
by NSPS, of specific pollutants by certain industries.
Correlate the readings of opacity monitors with VEOs.
Compliance Records and Testing
Check source records for compliance with applicable regulations,
including NESHAP, NSPS.
Determine if an onsite visible emission audit is warranted; an
inspector doing CAA audits must be certified for visible emissions
reading or the information developed may require duplication.
Check results of compliance tests. The Company should be able to
provide proof that emissions have been within desired limits by
means of a compliance test using a specified or reference test
method. The test is usually witnessed by control agency officials.
Process and emission parameters must have been adequately docu-
mented during test.
Water
Water pollution audit items are categorized as control and treatment
systems; self-monitoring systems, including both field and laboratory areas;
operation and maintenance and the Best Management Practices (BMP) plan.
Before the audit, the inspectors are encouraged to review the checklists in
Appendix E. The checklists also includes the Spill Prevention Control and
Countermeasure (SPCC) plan which companies are required to have to prevent
or control spills of petroleum products. Note that spills of hazardous
substances are covered by 40. CFR 117.
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27
Control and Treatment Systems
Assess ability of the wastewater treatment plant to withstand shock
loads, low temperature, excess stormflows, peak process flows and shock
organic loads by reviewing past operating data. Assess impact of storm-
flows, inflow and infiltration on system operation. Determine if SPCC plan
meets §311 requirements of the CWA (see 40 CFR 112).
Self-monitoring Systems
Self-monitoring consists of sampling and flow measurement by the
facility and its laboratory which analyzes water samples required for devel-
oping necessary data under the NPDES permit program.
Field - Confirm that acceptable sampling and flow measurement, as
specified by the NPDES permit, are carried out at the correct loca-
tions and with the proper frequency, and that all necessary calibra-
tions and 0&M are performed. Representative samples must be collected
at prescribed locations. Flow rating and calibration must use stand-
ardized techniques. Clean and properly prepared containers must be
used in sampling. Adequate procedures are to be used in the handling,
preserving and transporting of samples [Appendix E].
Laboratory - Evaluate analytical procedures including: (1) preserva-
tion methods and holding times of samples, (2) use of approved analyses
(40 CFR 136 or approved alternatives), (3) adequacy of instrument cali-
bration and state of repair, (4) adequacy of QA/QC program for all
analyses, and (5) recordkeeping and calculations in the lab. Other
important areas include cleaning and use of glassware, condition of
laboratory instrumentation, reagent quality control, and, media prepara-
tion and sterilization techniques.
Evaluate how the data are entered into lab notebooks; the sign-off
procedures used; analysis of spikes, blanks and reference samples; how the
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28
lab data are transposed onto the official, self-monitoring report forms
going to the enforcement agency; and the' extent and capability of outside
contract laboratories, if used.
Operation and Maintenance
Observe if vital treatment units are out of service and causes of non-
service; there is excess accumulation of solids, scum, grease and floating
materials in the treatment units; or there is a presence of odors, excessive
weed growth, etc. Assess handling, treatment and disposal of sludges and
other residues generated from processes and wastewater treatment system.
Best Management Practices (BMP) Plan
Check for BMP plan if the facility handles toxic pollutants. A BMP
plan is indicated if toxics are contributed from ancillary operations and
reasonable opportunity exists for discharge. BMP and SPCC plans, documents
and facilities should be reviewed.
Solid/Hazardous Waste
The first step in evaluating compliance with solid/hazardous waste
requirements is to identify all waste streams and determine which are regu-
lated by Federal*, State** and/or local regulations, licenses and approvals.
Preferably, this determination is initiated during background document
review prior to the onsite facility audit and supplemented/modified using
information obtained during an onsite process evaluation. All waste streams
generated (even those that the generator claims are not regulated) must be
evaluated for regulatory inclusion. This will allow the inspector to deter-
mine whether or not the generator has properly identified all of the regu-
lated waste streams.
Definition, identification and listing of federally regulated waste
are given in 40 CFR 260 and 261.
Solid (nonhazardous) waste is usually regulated by State regulations
and these regulations must be obtained to evaluate applicable facility
activity.
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29
Once the regulated waste is identified, the inspector can track the
material from generation to final onsite disposition (onsite treatment/
disposal) or storage and/or transport to offsite disposal and determine
compliance with applicable regulations. Throughout the audit, the inspector
must keep in mind that both past and present activities need to be evaluated
for compliance with applicable regulations.
In general, the compliance evaluation for solid/hazardous wastes han-
dled at a facility includes obtaining, reviewing and evaluating information
from Federal, State and local regulatory agency files; interviews with
facility personnel regarding management activity; examination of facility
records, including any internal waste.tracking/storage/disposal logs, audit
records and offsite shipment records ("bills of lading" and manifests); and
visual audit of waste management units. An integral part of any evaluation
is the compilation of facility background information including facility
size, physical description of operating units (area, depth, volume, etc.)
and construction methods (presence/absence of liners, special compacting,
etc.). Prior to or during the onsite audit, the inspector will have to
determine how extensive a records review will be necessary to meet the com-
pliance evaluation objectives of the audit. Factors such as number of doc-
uments available, available resources and time constraints determine whether
the objectives are realistic and can be achieved. However, in all cases,
the records review must be sufficient to show patterns of facility compliance
or noncompliance. Often, because of time constraints, it may be necessary
to obtain copies of documents (either microfilm or photocopies) for future
review and evaluation.
Inspectors are encouraged to use the various RCRA evaluation check-
lists in Appendix F, during the audit, to supplement their knowledge of the
RCRA regulations and to ensure that all items under each activity are ade-
quately addressed. The inspector should also be aware of the requirements
of CERCLA, including a facility's responsibilities to notify the proper
regulatory authorities of former hazardous substance releases and sites
(non-interim status) where hazardous substances have been stored, treated
or disposed of [CERCLA, Section 103(a)]. Military installations also have
the responsibility to conduct site assessment through remedial action
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30
programs to identify past hazardous substance releases and handling
facilities [40 CFR 300.64-68]. The inspector should determine, through
records review, interviews, etc. [Appendix G], whether or not all CERCLA
sites have been reported to the proper authorities. The inspector should
also evaluate assessment and response programs at a facility, if this
objective is within the scope of the audit.
The facility should also be evaluated concerning -State and local
requirements controlling past and current disposal of municipal waste, non-
hazardous industrial waste and construction debris. The information con-
cerning such past disposal activities may lead to unreported CERCLA sites.
All of the information obtained during the audit inspection will be
used, with the applicable regulations, licenses, approvals, etc., to eval-
uate the facility's waste handling activities and determine compliance/
non-compliance as outlined in the following sections.
General Facility RCRA Status
Determine if the facility has notified EPA of its hazardous waste han-
dling activity (waste generation, transport, treatment, storage and/or dis-
posal) and has a required EPA identification number (40 CFR 262.12).
For treatment, storage or disposal (TSD) facilities, as per Section
2010(e) of RCRA, determine if a RCRA Part A application has been submitted
(40 CFR 270). Determine the permit status of the facility. Has the RCRA
Part B permit application been called for, submitted (if so, when), or
reviewed by EPA; does the facility have a Part B permit in place? If a
permit has been issued, the facility is subject to the specific permit pro-
visions and requirements of 40 CFR 264. If no RCRA Part B permit is in
place, the facility is subject to the interim status provisions of 40 CFR
265. In both cases, the facility may also be subject to requirements of
State/local regulations, licenses and approvals. The inspector should deter
mine, prior to the audit, if State/local regulations apply. The inspector
should have a copy of the current Part A application (with amendments), the
Part B application (if available) and the RCRA permit (if issued in draft)
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31
during the audit so that the accuracy of the Part A and B applications can
be verified or compliance with the permit determined.
Hazardous Waste Generating Facilities
Generators, as defined in 40 CFR 260.10, are subject to the require-
ments of 40 CFR 262 and any additional State/local regulations, licenses
and approvals. In general, determine if the waste is properly identified
and the waste containers are properly marked, including the date when waste
accumulation was initiated. Also ensure the generator has obtained an EPA
identification number (40 CFR 262.12). Because generators are only author-
ized to accumulate waste for less than 90 days (40 CFR 262.34), it is impor-
tant to determine length of accumulation of all waste in storage.* Determine
if the generator has maintained signed hazardous waste shipping manifests
for waste shipped offsite for the last 3 years and evaluate if these
manifests were completed/handled properly (40 CFR 262, Subpart B). The
facility's "Contingency Plan and Emergency Procedures," "Preparedness and
Prevention Plans," and "Personnel Training Program" should also be evaluated
(40 CFR 265, Subparts C and D and CFR 265.16).
The inspector should determine whether the facility is properly manag-
ing containers and tanks (40 CFR 265, Subparts I and J). All containers
onsite during the audit should be inspected for general condition (leaks,
corrosion, etc.).and proper packaging, labeling and marking (40 CFR 262,
Subpart C). The inspector should determine if all storage area audits are
performed regularly and documented.
Hazardous Waste Transporters
Hazardous waste transporters, as defined in 40 CFR 260.10, are required
to comply with the Federal requirements of 40 CFR 263 and any State/local
regulations, licenses and approvals. The transporter must also meet applic-
able requirements of 49 CFR 171-179.
If a generator has stored waste for more than 90 days, it is subject
to the Federal requirements of 40 CFR 265 and 40 CFR 270 or the compar-
able State -requirements in authorized states.
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32
The inspector must ensure that the transporter has obtained an EPA
identification number (40 CFR 263.11) and is completing and handling the
waste shipping manifests properly, including maintaining a copy of each one
for at least 3 years. If a transporter stores waste in a transfer facility
(40 CFR 263.12), determine length of storage of waste at the facility.*
Any containers of waste in a storage facility should be inspected for proper
condition and proper marking and labeling. If loaded trucks are present,
proper placarding should be checked.
Treatment, Storage and Disposal Facilities
The inspector must determine if present facility operations and types
and quantities of waste handled are the same as those authorized by the
original Part A permit application (and approved amendments) or the final
RCRA permit, as applicable. Ensure that the TSD has obtained an EPA identi-
fication number (40 CFR 265.11/264.11). Operations at all TSD facilities
must be evaluated for compliance with the general requirements of Subparts A
through H of either 40 CFR 265 or 40 CFR 264. The inspector should deter-
mine which of these subparts are applicable to each facility. Compliance
evaluation of a facility includes, but is not limited to, evaluation of:
Waste Analysis Procedures (40 CFR 265/264.13, Subpart B)
written waste analysis plan
analytical/sampling procedures
recordkeeping
Facility Security (40 CFR 265.14)
access to the facility
display of warning signs
Under Federal regulations, transporters can oniy store waste at a
transfer facility for less than 10 days.
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General Facility Audit Requirements (40 CFR 265.15/264)
written audit plan
remedial action
recordkeeping
Personnel Training (40 CFR 265.16/264)
written training plan
recordkeeping
Facility Preparedness and Prevention (40 CFR 265/264, Subpart C)
general maintenance
communications/alarm system
fire control equipment
arrangements with local authorities
Contingency Plan and Emergency Procedures (40 CFR 265/264, Subpart 0)
written contingency plan
availability of emergency coordinator
Manifest System, Recordkeeping (40 CFR 265/264, Subpart E)
use, handling and maintenance of shipping manifests
facility operating record (including waste characterization/
quantity, waste tracking, disposal and treatment location)
Groundwater Protection (40 CFR 265/264, Subpart F)
monitoring system (well location, design, operation)
sampling and analysis
data recordkeeping
characterization of site hydrogeology
preparation, evaluation and response
waiver request (if any)
detection vs. assessment monitoring
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34
Closure and Post-Closure (40 CFR 255/264, Subpart G)
written closure/post-closure plans
Financial Requirements (40 CFR 265/264, Subpart H)
financial assurance
closure costs
When evaluating facility compliance with regulations requiring written
plans (waste analysis, facility audits, contingency, training, closure), it
is usually necessary to obtain copies of the plans for an in-depth analysis
of their adequacy. The inspector, by observing actual facility.operations,
should determine whether or not the facility is actually following the speci-
fics of these plans. In many cases, a facility may have used several modi-
fications of these plans, all with different effective dates. All current
plans must be evaluated. It is suggested that out-of-date plans also be
reviewed for compliance with applicable regulations in effect at the time
the plans were in place.
The inspector must also evaluate facility records required to be main-
tained by the regulations (manifests, waste analysis results, operating
record, audit records, etc.). The extent of this records review must be
sufficient to determine patterns of compliance/noncompliance with the
recordkeeping requirements. Although it may be desirable to review all
available records (from the time the regulations became effective), in the
best comprehensive audit, this is not always possible due to the number of
documents. In these cases, the inspectors must decide on the minimum number
of records necessary to identify patterns of compliance/noncompliance. In
situations where a relatively large number of documents must be reviewed
and immediate time or resource allocations do not allow for adequate eval-
uation, it may be beneficial to obtain copies (either microfilm or photo-
copies) to be reviewed at a later date.
In addition to the general requirements specified above, the inspectors
must evaluate the facility for compliance with the specific requirements
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for each type of hazardous waste management activity. This includes,
is not limited to, an evaluation of:
Use and Management of Containers (40 CFR 265/264, Subpart I)
general operation procedures
condition of containers (leaks, corrosion, etc.)
compatabi1ity of waste with containers
management of containers
audit records
Tanks (40 CFR 265/264, Subpart J)
general operating procedures
compatabi1ity of waste with tank construction material
integrity of tanks
corrosion rate of tank materials
compatabi1ity between waste treated/stored in tanks
audit records
closure procedures
Surface Impoundments (40 CFR 265/264, Subpart K)
general operating procedures
freeboard levels
protective coverings of dikes
audit records
closure/post-closure provisions
Waste Piles (40 CFR 265/264, Subpart L)
general operating procedures
protection from wind dispersal of waste
compatability between various wastes within the pile
run-on protection
runoff characteristics, containment and handling
closure/post-closure provisions.
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36
Land Treatment (40 CFR 265/264, Subpart M)
general operating procedures
runoff/runon control provisions
waste analysis
waste loading
protection of food chain crops
Unsaturated zone (zone of aeration) monitoring
recordkeeping
closure/post-closure provisions
Landfills (40 CFR 265/264, Subpart N)
general operating procedures
runon/runoff control and management
protection from wind dispersal
recordkeeping
required treatment of ignitable/reactive waste and liquid material
(prior to landfilling)
leachate collection/handling procedures
closure/post-closure provisions
Incinerators (40 CFR 265/264, Subpart 0)
general operating procedures
waste analysis
startup/shutdown procedures
monitoring/control equipment and provisions (combustion and emis-
sion control)
audits
closure procedures
Thermal Treatment (40 CFR 265, Subpart P)
general operating conditions
waste analysis
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37
monitoring/control equipment and procedures (combustion and
emission controls)
open burning/waste explosives procedures
audits
closure
Other Chemical/Physical Treatment (40 CFR 265/264, Subpart Q)
general operating procedures
waste analysis
monitoring/control equipment
audits
closure
Toxic Substances
Various "toxic substances" are regulated by the Federal Toxic Sub-
stances Control Act (TSCA). Although the controlled substance most fre-
quently encountered during multi-media investigations is polychlorinated
biphenyls (PCBs), the inspector should determine if other regulated toxic
substances are present at the facility. Currently these include fully halo-
genated chlorofluoroalkanes (40 CFR 762), asbestos (40 CFR 763) and dioxin
(40 CFR 775); additional toxic substances may be regulated in the future.
Because the probability of finding PCBs and PCB items at a facility is
greater.than finding other TSCA-regulated substances, the following discus-
sion is directed toward an evaluation of compliance with proper PCB and PCB
item handling procedures. Should other TSCA-regulated substances be present,
the inspector must consult the regulations for specific requirements.
Management of PCBs/PCB items is regulated under 40 CFR 761. In general,
these regulations address recordkeeping, marking and labeling, audits, stor-
age and disposal. The inspector is encouraged to use TSCA audit checklists,
such as the ones provided in Appendix H, to ensure that a complete audit is
performed.
Facilities which store and/or dispose of PCBs and PCB items often have
EPA-issued Letters of Approval which contain facility operating and/or
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38
recordkeeping requirements in addition to those specified in 40 CFR 761.
The inspector must obtain a copy of these approvals and any subsequent noti-
fications to evaluate facility compliance.
In general, the compliance evaluation includes obtaining and reviewing
information from Federal, State and local regulatory agency files; inter-
viewing facility personnel regarding material handling activity; examining
of facility records and visual audit of material handling units.
Prior to discussing TSCA activities* at a facility, the inspector must
complete and present appropriate facility personnel with copies of the fol-
lowing three TSCA audit forms [Appendix I):
Notice of inspection - Shows purpose, nature and extent of TSCA audit
TSCA Inspection Confidentiality Notice - Explains a facility's rights
to claim that some or all of the information regarding toxic substance
handling at the facility is to be considered as TSCA Confidential Busi-
ness Information (CBI)
Declaration of CBI** - Itemizes the information that the facility
claims to be TSCA CBI
A fourth form, Receipt for Samples and Documents, is presented to the
facility at the close of the audit. It itemizes all documents, photos,
and samples received by the inspector during the audit.
Recordkeeping (40 CFR 761, Subpart J)
Every facility using or otherwise handling PCBs/PCB items is required
to maintain specific records. Records regarding use, storage, transport
and disposal must be reviewed for accuracy, completeness and compliance
All personnel handling material claimed as Confidential Business Infor-
mation under TSCA must be cleared for access to that material in accord-
ance with Agency procedures. An annual update is required.
Although this form is presented at the initiation of the audit, it is
generally completed after the audit has been conducted.
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39
with applicable regulations. This includes a determination of the accuracy
of the PCB inventory and annual document (40 CFR 761.180). An inventory
checklist is provided in Appendix H. In general, the inspector must visu-
ally inspect all PCB items in service and in storage to verify completeness/
accuracy of the records. Also, current records should be compared with
past records to ensure that all items have been adequately accounted for.
Marking/Labe1ing (40 CFR 761, Subpart C)
Observe PCB units in service and in storage and determine if items are
properly marked/labeled.
Audits (Items in Use or in Storage for Reuse) [40 CFR 761.30(a)(1)]
Review records to determine if items in use or stored for reuse have
been inspected, as required. Determine whether or not all audit and
maintenance records are being maintained, as required. Review these
records to determine if problems identified during the audit are being
addressed properly. PCB items should.be inspected to verify that they are
.in non-leaking condition.
Servicing and Use of Various PCB Items (40 CFR 761.30)
Determine if the facility is servicing PCB items and/or using PCBs in
the following manner: heat transfer systems, hydraulic systems, research
purposes, in capacitors, or in any other special authorized use category
listed in 40 CFR 761.30. If PCBs are used in these services, determine if
their use complies with the special requirements for each use category.
Storage for Disposal (40 CFR 761.65)
Identify all areas where PCBs/PCB items are stored for disposal.
Determine the adequacy of these storage facilities, including proper mark-
ing, walls, roof, continuous floor with containment (ensure that contain-
ment is adequate) and location (above/below 100-year floodplain). Visually
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40
inspect all items in storage to determine if they are being stored properly
(i.e., non-leaking, marked/labeled and dated with storage date). Review
storage area records (including the required PCB annual document) for accur-
acy and adequacy. Determine whether or not the storage area is being
inspected and that remedial action is conducted, as required.
If PCBs/PCB items are stored outside of the designated storage facil-
ities (i.e., temporary storage); determine if items are stored properly,
including if: (1) items are leaking, concentration of liquids stored in
containers [liquids with PCB concentrations greater than 500 ppm cannot be
stored in temporary areas (except for transformers)] and (2) items are prop-
erly marked and labeled and show dates removed from service and placed into
storage (determine length of time items have been in temporary storage).
If liquids with PCBs. have been or are being stored in temporary storage,
evaluate the required Spill Prevention Control and Countermeasure (SPCC)
plan as described in 40 CFR 112, for adequacy and accuracy. If the facility
stores, in any permanent or temporary storage areas, liquid PCBs in any
containers larger than those described in 40 CFR 761.65(c)(6), the facility
SPCC plan must also be reviewed/evaluated.
Disposal
Incineration (40 CFR 761.70)
If the facility incinerates PCBs/PCB items, determine if the facility
has applied for and received the required EPA approval. Determine if the
facility meets required monitoring, control and recordkeeping requirements
of the approval and of 40 CFR 761. Observe monitoring and control equip-
ment and review the required records (including the PCB annual document)
for adequacy and accuracy and to ensure that the incinerator meets the
specified feed rate, combustion criteria and combustion efficiency. Eval-
uate the required annual document for completion and accuracy.
Landfillinp (40 CFR 761.75)
If the facility landfills PCBs/PCB items, determine if the facility
has applied for and received the required EPA approval. Determine if the
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facility meets the specified siting, liner and geological conditions.
Determine if the landfill is in the 100-year floodplain. If so, inspect
for proper water diversion structures. Evaluate general landfill operating
conditions to determine if waste is being handled properly (as stated in
the EPA Approval Letter and/or 40 CFR 761). This includes, but is not
limited to, evaluation if: incompatables are being landfilled with the
PCBs/PCB items, the facility is maintaining required records (including
concentration of liquids disposed of and three-dimensional burial coordi-
nates of waste), site security is accurate, liquids are solidified prior to
disposal, and transformers and other PCB items are being properly prepared
(drained/rinsed, etc.) prior to disposal. Evaluate the required PCB annual
document for adequacy and accuracy.
Determine if the facility is monitoring surface and groundwater, as
required by 40 CFR 761.75(b)(6). This includes identifying, locating and
evaluating operation of groundwater monitoring wells, and reviewing ground-
water sampling and analysis procedures and sample analysis results (for
adequacy of monitoring frequency and proper chemical constituents). Deter-
mine, by audit and records review, if the facility has an operating leachate
collection system. Review laboratory data on leachate characterization to
determine if leachate is being adequately monitored and disposed of properly.
Pesticides (Algaecides, Insecticides, Fungicides, Herbicides,
Rodenticides, etc.)
Pesticides are regulated by the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA).
The following list of pesticide audit items is for use in conjunction
with the checklist in Appendix J and specific storage/use/disposal require-
ments found on pesticide labels. Label directions are enforceable and vary
widely. FIFRA requires a written notice of inspection and written receipt
for samples collected.
Determine types of pesticides used at the facility. Ask if any
restricted use pesticides are used or stored at the facility.
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Determine use of pesticides.
Determine certification status of facility/handlers
Check who certifies facility/pesticide handlers (EPA, State,
DOD).
If restricted-use pesticides are used, check if pesticide
handlers are authorized to use these pesticides.
Check expiration dates on licenses/certificates.
Review applicable records.
Check previous audit records and complaints.
Check application records.
Check restricted-use pesticide records.(must be kept at least
2 years).
Check inventory records.
Check training records.
Check equipment repair records.
Inspect storage, mixing/loading and container disposal areas.
Check location, ventilation, segregation, fire protection,
security, shelter, warning signs and housekeeping of pesti-
cide storage/handling areas.
Check mixing equipment/procedures for reducing handlers
exposures to pesticides.
Check for safety equipment/procedures/use.
Check container cleanup and disposal procedures.
Pesticide liquid waste disposal
Check to see that liquid pesticides are disposed of in
accordance with applicable RCRA requirements.
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Water Supply
Public drinking water supply systems (i.e., serve at least 25 people)
are regulated by the Safe Drinking Water Act (SDWA).
The water supply checklist in Appendix K should be reviewed for those
items of information necessary to determine monitoring requirements for
water supply systems and whether or not the system can be reasonably
expected to routinely provide safe potable water. Many facilities purchase
their potable water supply from a nearby municipality. If no further treat-
ment is provided (e.g., chlorination by the facility), the facility may not
be directly covered by the SDWA. Nevertheless, the facility does have a
responsibility to assure that their actions do not result in contamination
of the municipal water supply (e.g., through cross-connection). The audit
team should be alert to these possibilities. The SDWA requires a written
notice of inspection.
CLOSING CONFERENCE
A post-audit or wrap-up conference should be held with the facility.
This should be limited to specific findings of the audit (e.g., factual
observations and measurements). The audit team's main function is to
observe and evaluate compliance. It must be noted that overall compliance
is determined by the Regional or State office upon final review of the
report and other pertinent findings. Therefore, statements on compliance
status, legal effects or enforcement consequences of noncompliance should
not be discussed with the facility or its operating personnel. It is unac-
ceptable to recommend a particular consulting firm, if asked, but it is
proper to advise that professional societies be contacted.
During the closing conference, there can be a discussion of the audit
team's preliminary findings. This discussion may include observed devia-
tions from prescribed or recommended procedures. Facility officials should
be informed of any leaks, spills or other problems that require immediate
attenton; however, no instructions or orders that repairs be undertaken
should be issued. At this meeting, the inspectors may request
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44
additional data, questions may be asked and answered, requested permit
changes and process modifications are noted, and necessary receipts are
given. The inspectors should make a final review of checklists and field
notes before the conclusion of the visit. Field notes taken by the
inspectors.at the time of the field investigation should not be turned over
to the Company officials. However, the inspectors are free to let Company
officials know that they may request a copy of the final audit report
through the EPA office which requested the audit.
For TSCA, FIFRA, RCRA and CERCLA activities, written receipts are
given for samples and documents taken. A Declaration of Confidential
Business Information (TSCA-CBI) shall include a list of items declared con-
fidential by an authorized facility official, and procedures should be
explained if the Company desires to make any subsequent declaration.
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THE AUDIT REPORT AND FOLLOWUP
The audit report organizes and coordinates all evidence gathered during
the audit in a usable manner. It is the compilation of factual information
and professional judgment resulting from the compliance audit. Information
in the report must be accurate, relevant, complete, coordinated, objective,
clear and legible. The report serves to record the procedures used in gath-
ering the data and gives factual observations, and evaluations from the audit
This report is the basis for any followup activities/enforcement that might
occur.
Many different formats are possible for the audit report. A typical
report could be structured in two main sections, the Executive Summary and
the Technical Analysis. The Executive Summary establishes the objectives
of the audit and presents succinct conclusions which are supported by rele-
vant findings; recommendations are made if appropriate. Topics in the sum-
mary may include: overall environmental compliance, adequacy of pollution
control and treatment systems, adequacy of operation and maintenance prac-
tices, multi-media waste abatement needs, and followup action.
The Technical Analysis section comprehensively describes the inspec-
tion by discussing such topics as facility history, discussions with Com-
pany representatives, records reviewed, recordkeeping procedures, sampling
programs, and specific problem areas. The Technical Analysis section cor-
relates audit findings with the conclusions contained in the Executive
Summary.
Where significant cases of noncompliance with a consent decree are
discovered during the audit, the audit team and Regional office should coor-
dinate at the earliest possible date with the appropriate field office of
the Criminal Enforcement Division to discuss the potential for criminal
charges - including criminal contempt - stemming from this noncompliance.
Administrative/civil enforcement (including informal negotiations with the
Company) should be held in abeyance, pending a decision on the appropriate-
ness of a criminal referral or additional field investigation.
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2
3
4
5
6
7
8,
9
10,
11,
12.
46
REFERENCES
National Enforcement Investigations Center, May 1978 (revised June
1985). NEIC Policies and Procedures Manual. Denver, Colorado: Envi-
ronmental Protection Agency, EPA-330/9-78-001-R.
Pesticides and Toxic Substances Enforcement Division, January 1980.
Toxic Substances Control Act Inspection Manual, Volume One: TSCA Base
Manual, Washington, D.C., Environmental Protection Agency.
Pesticides and Toxic Substances Enforcement Division, March 1981, Toxic
Substances Control Act Inspection Manual, Volume Two: PCS Inspection
Manual, Washington, D.C. , Environmental Protection Agency.
Office of Water Enforcement, Enforcement Division, January 1981. NPDES
Compliance Evaluation Inspection Manual, WCD-75, Washington, D.C. ,
Environmental Protection Agency.
Government Institutes, Inc., September 1982, Resource Conservation and
Recovery Act Inspection Manual, Washington, D.C. Environmental
Protection Agency.
National Enforcement Investigations Center, August 1979. Enforcement
Considerations for Evaluation of Uncontrolled Hazardous Waste Disposal
Sites by Contractors, Draft Report, Denver, Colorado, Environmental
Protection Agency.
National Enforcement Investigations Center, August 1979. Performance
Audit Inspections of Wastewaster Sources, Denver, Colorado, Environ-
mental Protection Agency, EPA-3Q0/1-79-004.
National Enforcement Investigations Center, July 1981. A Step-by-Step
Approach to Development of NPDES and RCRA Permits, Denver, Colorado,
Environmental Protection Agency, EPA-330/1-81-004.
Office of Water Enforcement, Enforcement Division, 1977. NPDES Com-
pliance Sampling Inspection Manual, Washington, D.C., Environmental
Protection Agency.
PEDCO Environmental, Inc., 1980. Standards of Performance for New Sta-
tionary Sources - A Compilation as of January 1, 1980. Cincinnati,
Ohio, Environmental Protection Agency, EPA-340/1-77-015, EPA-340/
1-79-001, EPA-340/1-79-001a, EPA"340/1-80-001.
Office of General Enforcement, February 1979. Inspection Procedures
for Evaluation of Electrostatic Precipitator Control System Performance,
Washington, D.C., Environmental Protection Agency, EPA-304/1-79-007.
Office of General Enforcement, February 1979. Enforcement Workshop on
Plant Inspection and Evaluation - Volume II, Inspection Procedures and
Performance Evaluation, Washington, D.C., Environmental Protection
Agency.
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13. Office of General Enforcement, February 1979. Enforcement Workshop on
Plant Inspection and Evaluation - Volume III, Process and Control
Equipment Flow Charting Techniques, Washington, D. C. ,. Environmental
Protection Agency.
14. Technology Transfer, 1978. Handbook, Industrial Guide for Air Pollu-
tion Control, Environmental Protection Agency, EPA-625/6-78-004.
15. Thomas H. Truitt, et al., 1971. Environmental Audit Handbook - Basic
Principles of Environmental Compliance Auditing, Washington, D.C.,
Wald, Harkrader & Ross and Resource Planning Corp.
16. G. William Frick, October 1981. Conducting an Environmental Audit,
Washington, D.C., Van Ness, Feldman, Sutcliffe, Curtis and Levenberg.
17. Industrial Environmental Research Laboratory, August 1979. A Handbook
of Key Federal Regulations and Criteria for Multimedia Environmental
Control. Interagency Energy/Environment R&D Program Report, Research
Triangle Park, North Carolina, Environmental Protection Agency,
EPA-600/7-79-175.
18. State of Oregon, Oregon State Health Division, Department of Human
Resources, Small Public Water Supply Sanitary Survey Report, 33-5
(revised January 1985).
19
National Enforcement Investigations Center, March 1981. NEIC
Pesticide Sampling Guide, EPA 330/9-81-001.
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48
ACRONYMS
AQCR - Air Quality Control Region
BAT - Best Available Technology Economically Achievable
BCT - Best Conventional Pollution Control Technology
BMP - Best Management Practices
BOD - Biochemical Oxygen Demand
BPT - Best Practicable Control Technology Currently Available
Btu - British thermal units
CAA - Clean Air Act [aka: Federal Water Pollution Control Act (FWPCA)]
CBI - Confidential Business Information
CEM - Continuous Emission Monitoring
CERCLA - Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (Superfund)
CFR - Code of Federal Regulations
COD - Chemical Oxygen Demand
CWA - Clean Water Act [aka: Federal Water Pollution Control Act (FWPCA)]
DCO - Document Control Officer
DO - Dissolved Oxygen
DOT - Department of Transportation (Federal)
EPA - Environmental Protection Agency (Federal)
ESP - Electrostatic Precipitators
FIFRA - Federal Insecticide, Fungicide and Rodenticide Act
FIP - Final Implementation Plan
F/M - Food to Microorganism Ratio
HW-FW - Half Wave/Full Wave (electrical distribution)
LAER - Lowest Achievable Emission Rate
MLVSS - Mixed Liquor Volatile Suspended Solids
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49
N/A - Not Applicable
NAA - Non-Attainment Areas
NAAQS - National Ambient Air Quality Standards
NEIC - National Enforcement Investigations Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NPDES - National Pollutant Discharge Elimination System
NSPS - New Source Performance Standards
OE - Office of Enforcement (now Office of Enforcement and Compliance
Monitoring
Q&M - Operation and Maintenance
ORM - Other Regulated Material
OSHA - Occupational Safety and Health Act
PC8 - Polychlorinated Biphenyls
PMN - Premanufacture Notice
PQTW - Publically-Qwned Treatment Works
PSD - Prevention of Significant Deterioration
QA/QC - Quality Assurance/Quality Control
RCRA - Resource Conservation and Recovery Act (enacted as amendment to the
Solid Waste Disposal Act)
R&D - Research and Development
SDWA - Safe Drinking Water Act (enacted as amendment to the Public Health
Service Act)
SIP - State Implementation Plan
SPCC - Spill, Prevention, Containment and Countermeasures
SSE - Stationary Source Enforcement
TOC - Total Organic Carbon
T-R - Transformer-Rectifier
fSCA - Toxic Substances Control Act
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TSD - Treatment, Storage and Disposal
TSDF - Treatment, Storage and Disposal Facilities (hazardous waste)
TSS - Total Suspended Solids
UIC - Underground Injection Control
U.S.C. - United States Code
USDW - Underground Source of Drinking Water
VEO - Visible Emissions Observation
WLA/TMDL - Wasteload Allocation/Total Maximum Daily Load
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APPENDICES
A SUMMARY OF POLLUTION CONTROL LEGISLATION
B SAFETY PLAN
C EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G CERCLA CHECKLIST
H TSCA AND PCB CHECKLIST
I TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
J PESTICIDE CHECKLIST
K WATER SUPPLY CHECKLIST
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APPENDIX A
SUMMARY OF POLLUTION CONTROL LEGISLATION
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SUMMARY OF POLLUTION CONTROL LEGISLATION
This appendix is a synopsis of the Federal approach to environmental
regulation, EPA enforcement remedies and a summary of each of the major
pollution control acts: the Clean Air Act (CAA), the Clean Water Act (CWA),
the Resource Conservation and Recovery Act (RCRA), the Comprehensive Envi-
ronmental Response, Compensation and Liability Act (CERCLA/Superfund), the
Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA), and the Safe Drinking Water Act (SDWA).
GENERAL FEDERAL APPROACH TO ENVIRONMENTAL REGULATION
National standards are established to control the handling, emission,
discharge and disposal of harmful substances. Waste sources must comply
with these national standards whether the programs are implemented directly
by the EPA or delegated to the States. In most cases, the national stand-
ards are applied to sources througn permit -programs which control the
release of pollutants into the environment. The EPA establishes the Federal
standards and requirements and approves State programs for permit issuance.
The States can set stricter standards than those required by Federal
law. Some of the larger programs which have been delegated by the EPA to
qualifying States are the National Emissions Standards for Hazardous Air
Pollutants (NESHAP), and the Prevention of Significant Deterioration (PSD)
permits under the CAA, the Water Quality Standards and the National Pollution
Discharge Elimination System (NPDES) programs under the CWA, the Hazardous
Waste Program under RCRA, and the Drinking Water and Underground Injection
Control (UIC) programs under the SDWA. Conversely, TSCA is administered
entirely by the Federal government.
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EPA ENFORCEMENT OPTIONS
1. Issuance of an Administrative Compliance Order, sometimes preceded
by a Notice of Violation*. A Compliance Order will specify the
nature of the violation and give a reasonable time for compliance.
The order, if violated, can lead to civil or, in some cases, crim-
inal action.
2. EPA may go directly to court seeking injunctive relief or civil
penalty without using administrative procedures.
3. EPA may go directly to court seeking criminal sanctions without
using administrative procedures. Criminal penalties are avail-
able for "knowing" or for "willful or negligent" violations.
4. EPA can attempt to obtain an emergency restraining order halting
activity alleged to cause "an imminent and substantial endanger-
ment" to the health of persons.
5. Emergency authority may be used until judicial authority is granted.
Additionally, the EPA can assess administrative penalties. These pen-
alties will generally attempt to eliminate the economic advantage that may
be enjoyed by a firm as a result of delaying installation of control equip-
ment. The penalty calculation may involve comparing the cash flow which
the source would have incurred if it had complied on time with the cash
flow that will result if it does not comply. The EPA can also "blacklist"
a company or party from entering into Federal contracts, loans and grants.
*
A concise written statement with factual basis for alleging a viola-
tion and a specific reference to each regulation, act, provision or
permit term allegedly violated
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A-3
CLEAN AIR ACT
The Clean Air Act (CAA) calls for the EPA to establish national
ambient air standards. These standards are expressed as concentrations of
designated hazardous pollutants called National Ambient Air Quality Stand-
ards (NAAQS). These standards are to be achieved by the States through
State Implementation Plans (SIPs). EPA also sets two types of national
air emission standards: New Source Performance Standards (NSPS) and
National Emissions Standards for Hazardous Air Pollutants (NESHAP). Special
programs have also been developed for prevention of significant deteriora-
tion (PSD) in clean air areas and for stringent controls in non-attainment
areas (NAAs).
The SIP provides emission limitations, schedules and timetables for
compliance by stationary sources. The act focuses upon "major" stationary
sources or major modifications of existing sources. Major sources are
defined as sources which generally emit more than 100 tons/year of a desig-
nated pollutant. The Clean Air Act emphasizes five areas:
National Ambient Air Quality Standards/State Implementation Plans
EPA designates harmful pollutants and publishes criteria documents
which discuss potential harmful effects of those pollutants. The EPA then
sets primary and secondary ambient air standards (CAA, Section 109). Pri-
mary standards are intended to protect the health of the population,
whereas secondary standards are meant to protect the esthetic values of the
envi ronment.
Seven pollutants have been established as harmful and standards estab-
lished. These pollutants include: sulfur dioxides, particulates, carbon
monoxide, ozone, hydrocarbons, nitrogen oxides and lead. These standards
are implemented through SIPs (CAA, Section 110).
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EPA has designated 247 Air Quality Control Regions (AQCRs). These
have been rated as either "clean" or "non-attainment" for each of the cri-
teria pollutants. SIPs must assure attainment of NAAQS by prescribed
dates. SIPs must meet Federal requirements, but each State may choose its
own mix of emissions for stationary and mobile sources to meet the NAAQS.
Control procedures may include stationary source emission limits, transpor-
tation plans, preconstruction review of new sources, NAA and PSD permits
for construction of new sources, monitoring, and inspection and testing of
vehicles. Other measures may include emissions charges, closing and relo-
cation of plants, changes in operations, and ways to reduce vehicular
traffic including taxes, staggered work hours, and mass transportation.
The CAA prescribes that no SIP will be adopted without a public hearing,
and sources affected by the SIP are expected to participate.
New Source Performance Standards
NSPS are established for specific pollutants in industrial categories
based upon adequately demonstrated control technology. Many States have
been delegated the authority to enforce NSPS. When a State does not have
the authority, EPA enforces NSPS in that state. Waivers from NSPS for up
to 7 years may be obtained, the purpose of which is to encourage use of
innovative technological systems (CAA, Section 111).
National Emissions Standards for Hazardous Air Pollutants
Section 112 of the CAA defines hazardous air pollutants as those for
which no air quality standard is applicable but which are judged to increase
mortality or serious irreversible or incapacitating illness. NESHAP stand-
ards are based on health effects with strong reliance on technological capa-
bilities. They apply to both existing and new stationary sources. The
five substances on the NESHAP list for which there are effective regula-
tions currently are: benzene, beryllium, asbestos, mercury and vinyl
chloride. The NESHAP program can be delegated to any qualifying State
(CAA, Section 112).
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A-5
Prevention of Significant Deterioration
The purpose of PSD is to avoid significant future degradation of the
nation's clean air areas. A clean air area is one where the air quality is
better than the ambient primary or secondary standard. Designation is
pollutant specific so that an area can be non-attainment for one pollutant
but clean for another. PSD applies only to new and modified sources in
clean air areas. Clean air areas are divided into three categories: Class
I - only minor air quality degradation allowed; Class II - moderate degra-
dation; and Class III - substantial degradation. In no case would PSD
allow air quality to deteriorate below secondary air quality standards.
"Baseline" is the existing air quality for the area at the time the
first PSD is applied for. "Increments" are the maximum amount of deteri-
oration that can occur in a clean air area over baseline. Increments
in Class I areas are smaller than for Class II and Class II increments
are smaller than Class III areas. For purposes of PSD, a major emitting
source is one of 26 designated categories which emits or has the poten-
tial to emit 100 tons/year of the designated air pollutant. A source
that is not within the 26 designated categories is a major source if it
emits more than 250 tons/year.
New sources are required to obtain permits before construction. The
permit describes the level of control to be applied and what portion of the
increment may be made available to that source by the State (CAA, Part C).
Non-Attainment Areas (NAA)
Non-attainment/areas are those which are not in compliance with
national air quality standards. New construction in an NAA is prohibited
unless the SIP has been amended and approved by EPA to reflect the follow-
ing conditions:
1. Total allowable emissions for the area will be less than emis-
sions from existing sources.
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A-6
2. The new source must comply with the lowest achievable emission
rate (LAER).
3. All other sources within the State owned by the subject Company
are in compliance.
4. The SIP is being carried out for the area.
The applying source in an NAA must, therefore, obtain a greater than
1:1 reduction of the pollutant or pollutants for which the area has been
designated non-attainment. The source must undergo a relatively stringent
pre-construction review.
Emission offsets from existing sources may need to be obtained,
especially if the new source will have emissions that would exceed the
allowance for the NAA. In these situations, the source would need to obtain
enforceable agreements from other sources in the NAA or from its own plants
in the NAA.
Emission reductions can also be "banked" by an existing source to per-
mit future new source growth. Banked offsets may be sold or traded to other
sources. Rules are yet to be established by the States governing the sale
or trade of these banked offsets (CAA, Part 0).
CLEAN WATER ACT
Through the 1950s and 1960s, emphasis was on the States setting ambient
water quality standards and developing plans to achieve these standards.
In 1972, the Federal Water Pollution Control Act was significantly amended.
These changes emphasized a new approach combining water quality standards
and effluent limitations (i.e., technology-based standards). The amendments
called for compliance by all point-source discharges with the technology-
based standards. A strong Federal enforcement program was created and sub-
stantial monies were made available for construction of sewage treatment
plants. The Federal Water Pollution Control Act was amended in 1977 and
renamed the Clean Water Act.
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State Water Quality Standards and Water Quality Management Plans
Section 303 of the CWA authorized the States to establish ambient water
quality standards and water quality management plans. If national technol-
ogy standards are not sufficient to attain desired stream water quality,
the State shall set maximum daily allowable pollutant loads for these waters
and, accordingly, determine effluent limits and compliance schedules for
point sources to meet the maximum daily allowable loads.
The National Pollutant Discharge Elimination (NPDES) Program
This program was established by Section 402 of the CWA and, under it,
EPA and approved States have issued more than 50,000 NPDES permits. Permits
are required for all point sources from which pollutants are discharged to
navigable waters. An NPDES permit is required for any direct discharge
from new or existing sources. Indirect discharges through POTWs are regu-
lated under a separate program. In 1979 and 1980, the permit program was
revised and one of the new features was the use of Best Management Prac-
tices (BMPs) on a case-by-case basis to minimize the introduction of toxic
and hazardous substances into surface waters. BMPs are industry practices
used to reduce secondary pollution (e.g., raw material storage piles shall
be covered and protected against rain and runoff). BMPs do not have numer-
ical limits and, therefore, are different from effluent limits.
Section 304 of the CWA sets restrictions on the amount of pollutants
discharged at industrial plant outfalls. Amounts are usually expressed as
weight per unit of product (i.e., 0.5 lb/1,000 lb product manufactured).
The standards are different for each industry. Effluent guidelines are
applied to individual plants through the NPDES permit program.
There are three levels of technology for existing industrial sources:
Best Practicable Control Technology (BPT), Best Conventional Technology
(BCT), and Best Available Technology Economically Achievable (BAT). BPT
was previously intended to be in place by industry in 1977 and BAT in 1983.
Amendments to the CWA modified this schedule whereby a very limited BPT
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extension was granted to 1979 and the BAT deadline was extended to between
1984 and 1987. The amendments divided all pollutants into three categories-
"Conventional" pollutants shall meet BCT limitations by July 1984. "Toxic
pollutants"* shall achieve BAT criteria by July 1987. Limitations on other
pollutants shall be achieved no later than 3 years after limitations are
established but not later than July 1987.
New Source Performance Standards (NSPS) are closely related to BAT for
existing sources but are not quite the same. NSPS are different for each
industrial category. These standards must be achieved when the new indus-
trial source begins to discharge. NSPS permits will be effective for a
period of 10 years vs 5 years or less for the BPT and BAT-type permits.
This 10-year protection insulates against change in BCT or BAT requirements
but does not hold against Section 307(a) toxic pollutant standards or
against "surrogate" pollutants that are used to control hazardous or toxic
pollutants.
A permit application must be made. Adequate information must be sub-
mitted including basic facility descriptions, SIC codes, regulated activ-
ities, lists of current environmental permits, descriptions of all outfalls,
drawings, flows, treatment, production, compliance schedules, effluent char-
acteristics, use of toxics, potential discharges and bio-assay toxicity
tests performed.
Applicants must conduct analytical testing for pollutants for BOD,
COD, TOC, TSS, ammonia, temperature and pH. The applicant, if included
within any of the 34 "primary industry" categories, must sample for all
toxic metals, cyanide and phenols given in EPA Application Form 2C and for
specified organic toxic pollutant fractions.
The applicant must list hazardous substances believed to be present at
the industrial plant. Testing is not required but analytical results must
be provided, if available.
The 1977 amendments to the CWA define 129 pollutants as toxic.
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NPDES Permit
The NPDES permit, issued by EPA or the State, enforces Federal effluent
limitations promulgated for individual industrial categories; NSPS; toxic
effluent standards; State water quality standards under Section 303 of the
CWA, if any are applicable; and hazardous substances otherwise regulated
under Section 311 of the CWA, but which may instead be incorporated under
the NPDES permit. Permit elements include the amount of pollutants to be
discharged expressed in terms of average monthly and maximum daily loads;
compliance schedules, if applicable standards cannot be met now; and moni-
toring, testing and reporting requirements.
goutine It on-compliance Reports - The Discharge Monitoring Form
The Discharge Monitoring Report (DMR) gives a summary of the dis-
charger's records on a monthly or quarterly basis for flow measurement,
sample collection and laboratory analyses. Noncompliance reports must be
submitted quarterly on the cause of noncomplying discharges, period of non-
compliance, expected return to compliance and plans to minimize or eliminate
recurrence of incident.
Emergency Reporting
Health: The EPA shall be notified within 24 hours of noncompli-
ance involving discharge of toxic pollutants, threat to drinking
water, or injury to human health.
Bypass; Noncompliance due to intentional diversion of waste shall
be reported promptly to the permitting agency and may be permis-
sable if essential to prevent loss of life or serious property
damage.
Upset: Temporary noncompliance due to factors beyond the reason-
able control of the permittee shall be promptly reported to the
agency.
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Pretreatment Standards for Indirect Discharges to
Publ i cly-Owned Treatment Works
Coverage
New and existing industrial users who discharge to POTWs are subject
to general and categorical pretreatment standards. The categorical stand-
ards are primarily directed to control of toxic pollutants in specific
industries.
Requirements
General Pretreatment Standards
Prohibit fire or explosion hazards, corrosi vi ty, solid or viscous
obstructions, "slug" discharges, and heat sufficient to inhibit
biological activity at POTWs
Categorical Standards
Standards to be expressed as concentration limits or mass
weight per unit of production.
Source must be in compliance 3 years after promulgation of
standards.
Variances can be obtained for fundamentally different factors
or if industrial pollutants are consistently being removed
by POTW.
Reports
Users must provide appropriate agency (EPA, State or POTWs having
approved pretreatment programs) with basic information, SIC code,
average and maximum daily discharge, characteristics or pollu-
tants, applicable standards, and certification whether standards
are being met and, if not, what pretreatment is necessary and a
compliance schedule.
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Monitoring, Sampling and Analysis
Users shall submit sampling data for each regulated pollutant in
di scharge.
Progress Reports
Reports and information shall be submitted at 6-month intervals.
Non-point Source Pollution Control
Section 208 of the CWA provides for control of non-point source pollu-
tion and directs States to establish planning bodies to formulate area-wide
pollution control plans. NPDES permits cannot be issued where the permit
may conflict with an approved Section 208 plan.
Dredge or Fill Discharge Permit Program
Section 404 of the CWA regulates the discharge of dredged or fill mate-
rial into waters of the United States. Dredged material is excavated or
dredged from a water body. Fill material is that used to replace water
with dry land. The Section 404 permit program is administered by the U.S.
Army Corps of Engineers. EPA provides guidelines for the issuance of
permits by the Corps of Engineers. States may assume responsibility for
portions of the program.
Discharge of Oil and Hazardous Substances
Section 311 of the CWA prohibits discharges of oil or hazardous sub-
stances in quantities that may be harmful to waters of the United States.
The appropriate Federal agency must be immediately notified of any spill of
a "reportable quantity". Section 311 provides for cleanup of spills and
requires plans for preparation of Spill Prevention, Control and Counter-
measures (SPCC) plans.
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Over 300 substances have been defined as hazardous under Section 311
and each of these substances has a "reportable quantity" (4-0 CFR, Parts 116
and 117, 1980).
A person or corporation who properly notifies the Agency of the dis-
charge of a reportable quantity of oil or hazardous substance is immune
from criminal prosecution but is liable for civil penalties. Additionally,
those who cause the spill are liable for the costs of cleanup and removal.
If the Federal government must clean up the spill, the discharger of the
spill is liable for cleanup costs. There are maximum liability limits,
depending upon the type of facility and spill. These limits do not apply
if the discharge resulted from willful negligence or willful misconduct of
the owner.
Certain discharges of oil and hazardous material that flows from a
point source may be excluded from Section 311 liability if, during prepara-
tion of the NPDES permit covering that facility, conditions are added to
the permit to avoid the occurrence of a spill.
RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA)*
RCRA was signed on October 21, 1976 and subsequently amended in 1980
and 1984. The 1984 amendments to RCRA brought about dramatic changes in
the coverage required by the act. Regulations are still to be promulgated
which will include expanded coverage in such areas as waste oil, underground
tanks, etc. The act primarily deals with waste activities now and in the
future. However, one section of the act (Section 7003), addresses problems
which may have arisen prior to 1976. The 7003 provision allows EPA to take
action against persons conducting past and current activities that may pre-
sent "an imminent or substantial endangerment to health or to the environ-
ment". The 1984 amendments also provide for corrective actions against
contamination resulting from past releases of hazardous waste even without
imminent hazard. A review of the act and effective regulations by the
inspector is imperative before the start of the inspection because of all
these changes.
43 U.S.C. §§6902 et seq. and Solid Waste Disposal Act amendents of
1980, P.L. 96-482, 94 Stat. 2334.
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Solid wastes, if land disposed, are regulated through State programs
under Subtitle D of RCRA. Hazardous solid wastes are subject to regulation
in their generation, transport, treatment, storage and disposal under Sub-
title C of RCRA. Subtitle C of the statute authorizes a comprehensive
Federal program to regulate hazardous wastes from generation to ultimate
disposal. A waste is hazardous under Subtitle C if it is listed by EPA as
hazardous, if it exhibits hazardous characteristics (corrosivity, reacti-
vity, ignitability and extraction procedure toxicity), and if not delisted
or excluded from regulation. There are special management provisions for
hazardous wastes created by small generators and hazardous wastes that are
intended to be reused or recycled.
Solid waste includes garbage, refuse and sludge, other solid, liquid,
semi-solid or contained gaseous material which is discarded, has served its
intended purpose, or is a mining or manufacturing byproduct. Most indus-
trial and commercial byproducts can qualify as a solid waste. Exclusions
from solid waste include domestic sewage, irrigation return flows, mater-
ials defined by the Atomic Energy Act, in situ mining waste and NPDES point
sources.
Solid wastes excluded from regulation as hazardous solid wastes are
household waste; crop or animal waste; mining overburden and wastes from
processing and benefication of ores and minerals; flyash, bottom ash waste,
slag waste and flue gas emission control waste; and drilling fluids from
energy development. A waste can be "delisted" from the hazardous waste
listing or excluded for other reasons. Materials intended to be reused or
recycled have to meet tougher requirements in order to be regulated as haz-
ardous wastes.
Statutory Restricti ons/Prohi bi ti ons
November 8, 1984 - The placement of any bulk liquid hazardous
waste in salt domes, salt bed formations, underground mines or
caves is prohibited until the facility receives a permit.
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A-14
May 8, 1985 - The landfilling of bulk or noncontainerized liquid
hazardous waste or free liquids contained in hazardous waste is
prohibited.
November 8, 1985 - The placement of any nonhazardous waste liquid
in a landfill operating under interim status or a permit is pro-
hibited unless the only reasonable alternative is a landfill or
unlined surface impoundment which will not endanger groundwater
drinking sources [see Section 3004(b)(3) for full graphics],
November 8, 1986 - The land disposal of solvents (codes FC01
through F005) and dioxins (codes F020 through F023) is prohibited
unless human health and the environment will not be endangered.
(Wastes generated by Superfund and RCRA enforcement actions are
not affected until November 8, 1988.)
July 8, 1987 - Land disposal of wastes listed in Section 3004(d)(2)
is prohibited unless human health or the environment is not
endangered (Wastes generated by Superfund and RCRA enforcement
actions not affected until November 8, 1988.)
May 8, 1985 - New units, lateral expansions and replacement of
existing units at interim status waste piles are to have single
liners and leachate collection systems.
New units, lateral expansions and replacement of existing units
at interim status landfills and surface impoundments are to have
double liners and leachate collection systems.
August 8, 1988 - Deep well injection of certain wastes is prohib-
ited unless deemed safe by EPA [see Section 3004(d)(2) and (e)(2)
for wastes].
List of Hazardous Wastes
Hazardous waste streams from specific major industry groups and some
generic sources (40 CFR, Part 261, Subpart D, §261.31 and 261.32) and
toxic commercial chemical wastes [261.33(e)] comprise a list of over 200
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A-15
commercial chemical products and chemical intermediates by generic name.
Substances become hazardous wastes when discarded. If a commercial chemical
substance is on the list, its off-spec species and spill residues are also
considered hazardous [40 CFR, Section 261.33(f)],
The overall listing further includes acutely toxic commercial chemical
wastes, which are commercial chemical products and manufacturing chemical
intermediates by generic name which are classified as hazardous wastes when
discarded. If a substance is on this list, its off-spec species, spill
residues and containers and inner liners (unless triple rinsed and effec-
tively cleaned) are also considered hazardous [40 CFR, Section 261.33(e)].
Special Management Provisions
Small Generators
Small generators are defined as producing less than:
1,000 kg/month of hazardous waste but greater than 100 kg/month
Or in the case of acutely toxic wastes:
1 kg/month of waste
10 kg/month inner liners
100 kg/month spill residues
It is noted that the cut-off applies to the generator, not to
each waste. Small generators must, however, still comply with
two requirements:
Identify hazardous waste by list, testing or experience
Dispose of their hazardous waste in a RCRA-authorized TSDF
either offsite or onsite
Reuse or Recycling - See above
Special Waste Class - A new class has been created: greater than
100 kg per month but less than 1,000 kg per month. By March 31,
1986, regulations are to be promulgated to cover this new class.
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Beginning November 8, 1984, wastes fitting this class are to be
sent to a TSDF which has a permit or interim status or are to be
disposed of in a facility licensed, permitted or registered by a
State.
By no later than August 4, 1985, wastes fitting the new class are
to be manifested when shipped offsite (see checklist for new
requirements).
Requirements for Generators*
Identification - Hazardous wastes must be identified by list,
testing or experience and assigned waste identification numbers.
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State. An EPA identification
number must be received.
Manifest System - Implement the manifest system and follow proce-
dures for tracking and reporting shipments. Beginning Septem-
ber 1, 1985, a waste minimization statement is to be signed by
the generator [see RCRA Section 3002(b)].
Packing - Implement packaging, labeling, marking and placarding
requirements prescribed by DOT regulations (40 CFR, Parts 172,
173, 178 and 179).
Annual Report - Submittal required March 1 using EPA Form 8700-13.
Exception Reports - When generator does not receive signed copy
of manifest from designated TSDF within 45 days, the generator
sends Exception Report to EPA including copy of manifest and
letter describing efforts made to locate waste and findings.
40 CFR Part 262
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Accumulation - When waste is accumulated for less than 90 days,
generator shall comply with special requirements including con-
tingency plan, prevention plan and staff training (40 CFR, Part
265, Subparts C, D, J and 265.16).
Permit for Storage More Than 90 Days - If hazardous wastes are
retained onsite more than 90 days, generator is subject to all
requirements of TSDFs including need for RCRA permit.
Requirements for Transporters*
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State. Receive EPA identification
number.
Manifest System - The transporter must fully implement the mani-
fest system. The transporter signs and dates manifest, returns
one copy to generator, assures that manifest accompanies waste,
obtains date and signature of TSDF or next receiver, and retains
one copy of the manifest for himself.
Delivery to TSDF - The waste is delivered only to designated TSDF
or alternate.
Record Retention - Transporter retains copies of manifest signed
by generator, himself and accepting TSDF or receiver, and keeps
these records for a minimum of 3 years.
Discharges - If discharges occur, notice shall be given to National
Response Center. Appropriate immediate action shall be taken to
protect health and the environment and a written report shall be
made to the DOT.
* 40 CFR Part 263
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A-18
Requirements for Treatment, Storage or Disposal Facilities (TSDFs)*
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be
filed with EPA or an authorized State.
Interim Status - These faciities include TSDFs; onsite hazardous
waste disposal; onsite storage for more than 90 days; in transit
storage for greater than 10 days and the storage of hazardous
sludges, listed wastes, or mixtures containing listed wastes
intended for reuse. Interim status is achieved by:
Notification (see above)
Being in existence on November 19, 1980 or on the date of statu-
tory or regulatory changes which require the facility to have a
permit
Filing a Part A by the date specified in the regulation
covering the facility (40 CFR, Parts 261, 264 or 265)
Interim Status Facility Standards - The following standards and
requirements shall be met.
General information (Subpart B)
Waste analysis plan
Security
Inspection plan
Personnel training
Handling requirements
Preparedness and prevention
Contingency planning and emergency procedures (Subparts C
and D)
Records and reports
Manifest system
Operating logs
Annual and other reports (Subpart E)
40 CFR Parts 264 and 265
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A-19
Groundwater Monitoring (Subpart F)
Closure and post-closure plans (Subpart G)
Financial requirements (Subpart H)
Containers, tanks, surface impoundments, piles (Subparts I,
0, K' L)
Land treatment, landfills, incinerators, thermal treatment,
chemical, physical and biological treatment (Subparts M, N,
0, P' «
Underground injection (Subpart R)
Permit - In order to obtain a permit:
Facilities with interim status must file a Part B.RCRA permit
application when directed to do so by EPA or an authorized
State and final facility standards must be met or the facil-
ity must be on an approved schedule to meet those standards.
The EPA-authorized States are to issue permits or deny the application
by November 8, 1988 for land disposal facilities; by November 8, 1989 for
incinerators; and by November 8, 1992 for other facilities. The following
is a statutory schedule for termination of interim status.
Interim Status
Unless Part B
Facility
Terminates
Submitted
Land Disposal
November 1985
November 1985
Inci nerators
November 1989
November 1986
Other facilities
November 1992
November 1988
New facilities and facilities which do not qualify for interim
status are to receive a RCRA permit before construction can
begin or a hazardous waste can be handled.
Used/Recycled Oil - Both used and recycled oil are to come under
regulation by RCRA. EPA is to promulgate standards for recycled
oil by November 8, 1985 and to decide by that same date if used
oil is to be listed as a hazardous waste. Subsequent regulations
are to be developed for its handling if the material is listed as
a hazardous waste.
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Underground Storage Tanks - The 1984 amendments also will cause
certain underground storage tanks to be regulated. By May 8,
1986, all owners of underground tanks are to notify the designated
State or local agency of the existence of the tank and specify
the following:
Age
Size
Type
Location
Uses
For tanks taken out of operation after January 1, 1974, the owner
is to also notify the designated State or local agency of the
existence of the tank and specify the following:
Date the tank was taken out of operation
Age at that time
Size
Type
Location
Type and quantity of substance left in the tank
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT OF
1980 (SUPERFUND)
The Superfund Act was enacted December 11, 1980. The Federal govern-
ment is authorized to clean up toxic or hazardous contaminants at closed
and abandoned hazardous waste dumps and the government is permitted to
recover cost of this cleanup and associated damages by suing the responsible
parties involved. Cleanup monies will come out of a "superfund" created by
taxes on chemicals and hazardous wastes.
The act provides that, when there is a release of hazardous substance,
either real or threatened, the parties who operated the vessel or facility
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which created the release are liable for the containment, removal, remedial
action, response and injury damages to natural resources under Section 107(a),
The act also establishes limitations on liability.
If claims are presented to the liable parties but are not satisfied,
the act then allows claims to be reimbursed from the Superfund.
Regulatory provisions under Sections 102 and 103 of the act require
that release of hazardous substances into the environment be reported unless
the release is in accordance with an established permit. A spill from 1
pound or any "reportable quantity" established pursuant to Section 311(b)(4)
of the CWA must be reported. It is expected that this reportable quantity
will be changed in the future.
All owners or operators of any facility handling and disposing of haz-
ardous substances or that has handled hazardous substances in the past
(including previous owners and operators) were required to inform the EPA
Administrator by June 1981 of their facility activities unless they have a
RCRA permit or have been accorded "interim status". Failure of notifica-
tion is a crime and, if the party knowingly fails to provide these data,
they are not entitled to the prescribed limits and defenses of liability.
TOXIC SUBSTANCES CONTROL ACT (TSCA)
TSCA regulates existing and new chemical substances. TSCA applies
primarily to manufacturers, distributors, processors and importers of chem-
icals. TSCA can be divided into five parts as follows:
Inventory and Pre-manufacture Notification
EPA has published an inventory of existing chemicals. A substance
that is not on this list is considered "new" and requires Pre-manufacture
Notification (PMN) to EPA at least 90 days before the chemical can be manu-
factured, shipped or sold (TSCA, Section 5). If the EPA does not make a
declaration within 90 days to restrict the product, then full marketing can
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begin and the chemical is added to the inventory. Conversely, EPA, in
response, may reject PMN for insufficient data, negotiate for suitable data,
prohibit manufacture or distribution until risk data are available or pend-
ing development of a Section 6 rule, completely ban the product from the
market, or review the product data for an additional 90 days.
Testing
Under TSCA, Section 4, EPA can require product testing of any substance
which "may present an unreasonable risk of injury to health or to the envi-
ronment". Some testing standards are proposed, but no test requirements
for specific chemicals are yet in effect.
Reporting and Recordkeeping
TSCA, Section 8(a) deals with general reporting. The "first tier"
rule now in effect is a short form seeking production and exposure data on
over 2,300 existing chemicals. A "second tier" rule is expected to obtain
more detailed data on a relatively small group of chemicals that may become
priority candidates for regulation.
Section 8(c) calls for records of significant adverse effects of toxic
substances on human health and the environment. It requires that records
of alleged adverse reaction be kept for a minimum of 5 years.
Section 8(d) allows EPA to require that manufacturers, processors and
distributors of certain listed chemicals (designated under 40 CFR 716.13)
submit to the EPA lists of health and safety studies conducted by, known
to, or ascertainable by them. Studies include individual files, medical
records, daily monitoring reports, etc.
Section 8(e) requires action upon discovery of certain data. Any per-
son who manufacturers, processes or distributes a chemical substance or
mixture, or who obtains data which reasonably supports the conclusion that
their chemical presents a substantial risk of injury to health or to the
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environment, is required to notify EPA immediately. Personal liability can
only be limited if the Company has a response plan in effect.
Regulation Under Section 6
EPA can impose a Section 6 rule if there is reason to believe that the
manufacture, processing, distribution, or use or disposal of a chemical
substance or mixture causes, or may cause, an unreasonable risk of injury
to health or to the environment. Regulatory action can range from labeling
requirements to complete prohibition of the product. Section 6 rules are
currently in effect for several chemicals including PCBs. A Section 6 rule
requires informal rulemaking, a hearing, and a cost-benefit analysis.
Imminent Hazard
This is defined as a chemical substance or mixture causing an imminent
and unreasonable risk of serious or widespread injury to health or ttie envi-
ronment. When such a condition prevails, EPA is authorized by TSCA, Sec-
tion 7, to bring action in U.S. District Court. Remedies include seizure
of the chemical or other relief including notice of risk to the affected
population or recall, replacement or repurchase of the substance.
FEDERAL INSECTICIDE, FUNGICIDE AND RQDENTICIDE ACT (FIFRA)
A pesticide is defined as any substance intended to prevent, destroy,
repel or mitigate pests. FIFRA requires registration of all pesticides,
restricts use of certain pesticides, authorizes experimental use permits,
and recommends standards for pesticide applicators and the disposal and
transportation of pesticides.
Pesticides are registered for 5 years and classified for either general
or restricted usage. Restricted means that they are to be applied either
by or under the direct supervision of a certified applicator. Pesticides
must be labeled and specify ingredients, uses, warnings, registration number
and any special use restrictions. Regulations also specify tolerance levels
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for certain pesticide chemicals in or on agricultural commodities. These
limits apply to 310 different compounds and residue tolerances range from 0
to 100 ppm. A few pesticides are also regulated as toxic pollutants under
Section 307(a) of the CWA and by Primary Drinking Water Standards under the
SDWA.
SAFE DRINKING WATER ACT
The SDWA of 1974 was established to provide safe drinking water to the
public. Both primary and secondary drinking water standards have been set
by EPA regulations which apply to water after treatment by public drinking
water systems. National Interim Primary Drinking Water Regulations were
adopted in 1975 to protect public health (40 CFR, Part 141). Regulations
covering radionuclides were added in 1976. Regulations for trihalomethanes
were prepared in 1977. Secondary regulations were established in 1979 as
guidelines to States to protect the non-health-related qualities of drink-
ing water.
The SDWA also provides for protection of underground sources of drink-
ing water. Final regulations have been issued whereby States are to estab-
lish Underground Injection Control (UIC) waste disposal programs to ensure
that contaminants in water supplies do not exceed National Drinking Water
Standards and to prevent endangerment of any underground source of drinking
water. Injection wells are divided into five classes for regulatory handling
Construction and disposal standards are established for the permitting of
Class I to III wells. Class I and Class IV wells are subject to RCRA
requirements. Class IV wells are those used by generators of hazardous or
radioactive wastes to dispose of hazardous wastes into formations within h
mile of an underground source of drinking water. New Class IV wells are
prohibited and existing Class IV wells must be phased out within 6 months
after approval or promulgation of a UIC program in the state. There are
numerous State regulatory requirements affecting groundwater which should
be consulted by multi-media compliance inspectors.
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APPENDIX B
SAFETY PLAN
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NEIC - SAFETY PLAN
PROJECT: NO._
APPROVAL OHS Designee: Date
Project Coordinator: . Date
Branch Chief: Date
On Scene Coordinator: Date
ACTIVITIES:
HAZARDS ANTICIPATED:*
Toxic Vapors: Yes
If yes, List: 1.
3.
TLV 1.
4.
Explosivity: Yes
Radioactivity: Yes
O2 Depletion: Yes
Buried Utilities: Yes
LEVEL OF PROTECTION RECOMMENDED
Level A
Level B
Level C
Level D
Enhancement
No
2. __
4. 5.
2. 3.
5.
No
No
No
No ^ If yes, Specify^
Type SCBA
Type Cartridge
* If unknown, mark UK
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B-2 •
NEIC - SAFETY PLAN (Cont'd)
Page 2
CONTRACTOR EQUIPMENT REQUIRED:
CONTRACTOR PERSONNEL:
Number and Skills
Medical Monitoring:
Yes , No
Respirator/SCBA Qualified (if required for activity)
Yes , No
SITE MDNITORING PROCEDURES (Equipment to be used):
DECONTAMINATION/DISPOSAL PROCEDURES:
COMMENTS:
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NEIC - SAFETY PLAN (Cont'd)
Page 3
EMERGENCY CONTACTS*
MEDICAL:
Loeation:_
Phone No.
Phone No.:
FIRE:
Phone No.
POLICE:
Phone No.:
PROJECT NO.
(Hospital)
(EMT)
* POST AT SITE
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APPENDIX C
EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
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PHOTOGRAPHS
When movies, slides or photographs are taken which visually show the
effluent or emission source and/or any monitoring locations, they are num-
bered to correspond to logbook entries. The name of the photographer, date,
time, site location and site description are entered sequentially in the
logbook as photos are taken. A series entry may be used for rapid sequence
photographs. The photographer is not required to record the aperture set-
tings and shutter speeds for photographs taken within the normal automatic
exposure range. Special lenses, films, filters or other image enhancement
techniques must be noted in the logbook. Chain-of-custody procedures
depend upon the subject matter, type of film and the processing it requires.
Film used for aerial photography, confidential information or criminal
investigations require chain-of-custody procedures. Adequate logbook nota-
tions and receipts may be used to account for routine film processing.
Once developed, the slides or photographic prints shall be serially numbered
corresponding to the logbook descriptions and labeled.
MICROFILM
Microfilm is often used to copy documents that are or may later become
TSCA Confidential Business Information (CBI). This microfilm must be
handled in accordance with the TSCA CBI procedures (see Appendix I for
additional information and forms). Table C-l is the NEIC procedure for
processing microfilm containing TSCA CBI documents.
-------
C-2
Table C-l
NEIC PROCEDURE FOR MICROFILM
PROCESSING OF TSCA CBI DOCUMENTS
1. Kodak Infocapture AHt/ 1454 microfilm shall be usecf for filming aT7
TSCA CBI documents.
2. Obtain packaging materials and instructions from the NEIC Document
Control Officer or Assistant, including:
Preprinted shipping labels
Chain-of-custody records
Custody seals
Double envelopes
Green TSCA cover sheets
TSCA loan receipt
3. Prepare each roll of microfilm for shipment to the processor.
Enclose the film in double-wrapped packages
Place a green TSCA cover sheet in the inner package
Place a TSCA loan receipt in the inner package
Complete a Chain-of-Custody Record, place the white copy in the
inner package and keep the pink copy for the field files
Seal inner package with a custody seal and sign and date it
Mark the inner package:
"TO BE OPENED BY ADDRESSEE ONLY
TSCA CONFIDENTIAL BUSINESS INFORMATION"
4. Ship the film via Federal Express to the Springfield, Virginia Federal
Express office and instruct that it is to be held for pickup. USE
SIGNATURE SECURITY SERVICE ONLY.
This practice requires the courier to sign, the station personnel to
sign and the delivery courier to sign.
Instruct the Springfield Federal Express office to hold the shipment
for pickup and to notify:
Mr. Vern Webb
U.S. EPA/EPIC
Vint Hill Farms Station
Warrenton, Virginia 22186
(730) 557-3110
5. Telephone Mr. Webb and inform him of the date shipped, the number of
rolls of film, the air bill number and your phone number.
6. Telephone the NEIC Document Control Officer or Assistant and inform
them.
7. Telephone Mr. Webb the following day and verify film quality to deter-
mine if repeat microfilming is necessary.
8. The pink copy of the Federal Express form, with the shipment cost and
project number indicated, must be turned in to the Assistant Director,
Planning and Management. If you are in the field for an extended
period of time (3 weeks or more), the pink copies must be mailed to
NEIC.
-------
APPENDIX D
AIR POLLUTION CHECKLISTS
-------
NEW SOURCE PERFORMANCE STANDARDS (NSPS)*
Sources Covered
NSPS includes new and modified stationary sources in 42 industrial
categories for which construction was started after the standard was pro-
posed. The categories are listed in Table D-l.
Requi rements
Notification to Agency
Agency notified before construction Yes No
before startup Yes No
before testing Yes No
Emissions Testing
Performance tests of emission control equip-
ment conducted using prescribed reference
methods Yes No
Within 180 days of startup Yes No
Written results sent to Agency Yes No
Monitoring
Continuous emission monitoring to be conducted for 10 categories
[Table D-2]
Recordkeeping kept in permanent form suitable
for inspection Yes No
Records of continuous monitoring system
maintained, including actual data
Yes
No
performance specification test reports
Yes
. No
calibration checks
Yes
No
adjustments and maintenance
Yes
No
Quarterly Reports
Reports on data, time and magnitude of
excess emissions Yes No
Identification of excess emission periods
associated with startup, shutdown and
malfunction Yes No
Date and time when control equipment was
repaired, adjusted or inoperative Yes No
Date and time when CEM was inoperative,
nature of ,repairs Yes No
40 CFR, Part 60, 1980
-------
D-2
Table D-l
SOURCES SUBPART (40 CFR Part 60)
EFFECTIVE DATE OF STANDARD AND POLLUTANTS SUBJECT TO HSPS
Source
Subpart
Effective Date
Pollutant
Fossil-fuel-fired steam generators
0
August 17, 1971
Particulate matter,
sulfur dioxide,
Da
September 18, 1978
nitrogen oxides
Municipal incinerators
E
August 17, 1971
Particulate matter
Portland cement plants
F
August 17, 1971
Particulate matter
Nitric acid plants
€
August 17, 1971
Nitrocen oxides
¦Sul furic acid plants
H
August 17, 1971
Sulfur dioxide, acid mist (sulfuric acid)
Asphalt concrete plants
I
June 11, 1973
Particulate matter
Petroleum refineries
J
June 11, 1973
Particulate matter,
carbon monoxide,- sulfur
dioxide
Storage vessels for petroleum liquids
K
June 11, 1973
VOC
Ka
May 18, 1978
Secondary lead smelters
L
June 11, 1973
Particulate matter
Secondary brass and bronze ingot
M
June 11, 1973
Particulate matter
production plants
Iron and steel plants (basic
N
June 11, 1973
Particulate matter
oxygen furnace)
Sewage treatment plants (incinerators)
0
June 11, 1973
Particulate matter
Primary copper smelters
P
October 16, 1974
Particulate matter,
sulfur dioxide
Primary zinc smelters
Q
October 16, 1974
Particulate matter,
sulfur dioxide
Primary lead smelters
R
October 16, 1974
Particulate matter,
sulfur dioxide
Primary aluminum reduction plants
S
October 23, 1974
Fluorides
Phosphate fertilizer industry
T
October 22, 1974
Fluorides
(listed as five separate
U
categories)
V W X
Coal preparation plants
V
October 24, 1974
Particulate matter
Ferro-alloy production facilities
z
October 21, 1974
Particulate matter, carbon monoxide
Steel plants (electric arc furnaces)
AA
October 21, 1974
Particulate matter
Kraft pulp mil Is
BB
September 24, 1976
Particulate matter,
TRS
Glass plants
cc
June 15, 1979
Particulate matter
Grain elevators
DD
August 3, 1978
Particulate matter
Metal furniture surface coating
EE
November 28, 1980
VOC
Stationary gas turbines
EE GG
September 24, 1976
Nitrogen oxides, sulfur dioxide
Lime plants
HH
May 3, 1977
Particulate matter
Lead acid battery plants
KK
January 14, 1980
Lead
Metallic mineral processing plants
LL
August 24, 1982
Particulate matter
Auto and light-duty truck, surface
KM
October 5, 1979
VOC
coating operation
Phosphate rock plants
NN
September 21, 1979
Particulate matter
Ammonium sulfate plants
PP
February 4, 1980
Particulate matter
Graphic arts industry
qq
October 28, 1980
VOC
Pressure sensitive tape manufacturing
RR
December 30, 1980
VOC
Appliance surface coating
SS
December 24, 1980
VOC
Metal coil surface coating
TT
January 5, 1981
VOC
Asphalt roofing plants
uu
November 18, 1980;
Particulate matter
May 26, 1981
Synthetic organic chemicals
w
January 5, 1981
Performance standards
Beverage can surface coating
WW
November 26, 1980
VOC
Eulk gasoline terminal
XX
December 17, 1980
VOC
Vinyl/urethane coating
FFF
January 18, 1983
VOC
Synthetic fiber plants
HHH
November 23, 1982
VOC
Petroleum refineries
GGG
January 4, 1983
Performance standards
-------
0-3
Table D-2
NSPS SOURCES REQUIRING CEM
Source Subpart Effective Date Monitor
FFFSG
D
8/17/71
opacity, S02t
N0x, 02 or C02
Fossil-fuel-fired electric
uti1ities
Da
9/18/78
opacity, S02,
N0x, 02 or C02
Nitric acid plants
G
8/17/71
NOx
Sulfuric acid plants
H
8/17/71
S02
Petroleum refineries (FBCCU)
J
6/11/73
opacity, CO,
so2( h2s
Claus sulfur recovery unit
J
10/4/76
opacity, CO,
S02j H2S
Primary copper smelters
P
10/16/74
opacity, S02
Primary zinc smelters
Q
10/16/74
opacity, S02
Primary lead smelters
R
10/16/74
opacity, S02
Ferroalloy production
facilities
Z
10/21/74
opacity
Electric arc furnaces
AA
10/21/74
opacity
Kraft pulp mills
BB
9/24/76
opacity, TRS
Lime manufacturing plants
HH
5/3/77
opacity
Phosphate rock plants
NN
9/21/79
opacity
Flexible vinyl and urethane
coating and printing
FFF
1/18/83
VOC
-------
0-4
NATIONAL EMISSIONS STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP)*
Sources Covered
NESHAP includes new and existing stationary sources that emit or have
the potential to emit any one of six hazardous air pollutants. The pollu-
tants and sources covered are listed in Table D-3.
Existing sources must comply within 90 days but can obtain waivers for
up to 2 years for installation of controls. New sources or modified sources
coming online after the publication of standards must achieve immediate
compliance.
Requi rements
Compliance Status
Submit to Agency within 90 days of publication
of standard adequate information on design,
method of operation, weight/month of hazardous
material and control devices Yes No
Agency Notification
Proper notice before startup and before
emissions testing Yes No
Emissions Testing
Emission testing conducted using prescribed
reference methods Yes No
Written results sent to Agency Yes No
Monitoring and Reporting
Required monitoring being performed Yes No
Reporting to Agency Yes No
40 CFR, Part 61, 1980
-------
0-5
Table D-3
SOURCES SUBJECT TO TITLE 40 CFR PART 61
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
Pol 1utant
Subpart
Source
Asbestos
Beryl 1i urn
Beryl 1ium
Mercury
ViryJ chloride
Benzene (leaks)
M Asbestos mills
Manufacturi ng
Demolition and renovation
Spraying
Fabrication
Waste disposal
C Extraction plants
Ceramic plants
Foundries
Incinerators
Machine shops
D Rocket motor firing
E Ore processing plants
Chlor-alkali plants
Sludge incinerators
Sludge drying plants
F Ethylene dichloride pJants
Vinyl chloride plants
Polyvinyl chloride plants
J Equipment in.benzene service
(plants designed to produce
more than 1,000 megagrams of
benzene per year)
Volatile Hazardous
Air Pollutant (VHAP)
V
Equipment in VHAP service
-------
D-6
Table D-4
EXAMPLE OF INSPECTION CHECKLIST*
I. GENERAL INFORMATION
A. Plant Location (mail address)
B. Chief Corporate Officer (name/phone)
C. Plant Manager (name/phone)
D. Environmental Contact (name/phone)
E. Sources Inspected Production Status
Reasons for Inspection (check appropriate items)
Routine Inspection Compliance Progress
Complaint Investigation Permit Review/Renewal
Stack Testing Observed Tax Certification
Special Studies Emergency Episode"
Other__ Equipment Malfunction
G. Plant Representative Contacted (name and title)
H. Inspection Procedures and Conditions
Prior Notice (check one) Yes No
Time/Date Duration Onsite
Type Inspection (check one) Counterflow Followup_
Other
Weather Wind Direction
II. PRE-INSPECTION INTERVIEW
A. Production Status: Normal Abnormal
B. Control Equipment: Normal Abnormal_
C. Permit/Compliance Schedule Changes Needed: Yes__ No_
D. Comments
Revised from Enforcement Workshop on Plant Inspection and Evaluation,
Volume II, Draft, EPA, OE, SSE, February 1979
-------
D-7
Table D-4 (contd)
III. INSPECTION RESULTS
A. Preliminary Conclusions
All sources in compliance with
Mass Emission Regulations
Yes
No
N/A
Visible Emission Regulations
Yes
No
N/A
Fuel Quality Regulations
Yes
No
N/A
Continuous Monitoring Regulations
Yes
No
N/A
Sampling/Testing Requirements
Yes
No
N/A
Recordkeeping Requirements
Yes
No
N/A
Permit Stipulations
Yes
No
N/A
Special Orders
Yes
No
N/A
O&M Practices Good Average Poor
Housekeeping Good Average Poor
B. Specific Conclusions
Compliance questionable due to:
Changes in raw materials and/or fuels
Production rate increases
Operational changes in process
Deterioration of process equipment
Operational Problems in Control Equipment (check appropriate items below)
Electrostatic
Precipitators
Resistivity
TR Sets
Insulators
Discharge Wires
High Velocity
Gas Distribution
Rappers
Solids Handling
Plate Warpage
Mass Overload
Other
Fabric
FiIters
Tears/pinholes
B1inding
Bleeding
Cleaning System
Hopper Overflow
Corrosion
Wet
Scrubbers
Low Liquor Flow
Gas Flow Rate Low
Bed Plugging
Nozzle Erosion
Demisters
Throat Adjustment
Tray Collapse
Corrosion
C. Samples Taken (Describe)
D. Comments/Recommended Action
Inspector
Date
-------
D-8
Figure D-l
Cahric Filter Insnection Flowsheet
[From Enforcement Workshop on Plant Inspection & Evaluation, Volume II,
Draft, EPA, OE, SSE, February 1979].
-------
D-9
Jaschadula '-Tsoaciian
for a tlx* whan utiic la
op«racional
Check puaa$ on lar^e,
aake-uo, ar.d recircuii-
clon lines.
Xead Eiov naears tt ivai
aole. Check Usuar ;j:3
qb taieca and juclaca.
T
Oaefc pressure jau;as a.is
t.-.spact ir.tsTT.ai parts:
differencial
pressura
.^ozri.« csndicisa
=oni:ars across cha fol-
?resen5» of jorrssion
lowing:
Preser.sa ac erosicr.
Spriy oouias
Prssar.ci os seaiia?
Scrubber aeJs
Vancuri cswjc
"aaisiar*
y
Chaeii t!\c«?Tiv; -sf 3'r.ell
Cheefc c::ri3 ar.4 recircu-
recencio.i jriij, aftc ec.-.a:
lation canica
pares.
-Liquor ta-peracura
-Liquor pH
1
1
f
CH«clc «].urTv handling
Cliaek iniec
:2nd i:icns:
•ysc«s.
-r,*s- :a=?e
racure
-?resatura
cor vac*r
flow rata
•::3 ;cu*3ssr :?o?ectiqm
Figure D-2
Scrubber InsDection.Flowsheet
[From enforcement Workshop on Plant Insoection & Evaluation, Volume
Draft, EPA, OE, SSE, February 1979].
-------
D-10
Ate
:'*ers ar.y In-
dies cic
of non-
:snpllance opv
j; rat ion?
CNT iSP INCTCTIOS.
Figure d_3
Electrostatic Precipitator Inspection Flowsheet
[From Enforcement l.'orkshop On Plant Inspection & Evaluation,
Volume II, Draft, EPA, OE, SSE, Washington, O.C., February 1979].
-------
APPENDIX E
WATER POLLUTION CHECKLISTS
-------
Table E-l
NPDES Compliance Inspection Report (Form 3560-3) f »m,
OM8 No. ISt • R007J
NPOES COMPLIANCE INSPECTION REPORT (Coding Instruction* on bock of loit
TRANSACTION INSPEC- fac
COOE NPOES VR MO OA TYPE TO« TYPE
II 151 1 M M 1 1 1 1 1 1 1 1 It 1 1
1 1 a 11 12 17 m 14 JO
TIME
*.m, lo.m.
REMARKS
1 1 1 1 1 1 1 1 1 1 1 II II 1 II II 1 1 II 1 II 1 1 1 II 1 II 1 1 1 1 1 1 II
•51 64
i M II
70
AOOlTIONAL
SECTION A ¦ Permit Summary
NAME ano AOOA6SS OP facility ffnchtdt County, Stare and ZfP cauei
EXPIRATION OATE
ISSUANCE OATE
RESPONSIBLE OFFICIAL
TITLE
PHONE
FACILITY REPRESENTATIVE J TITLE
PHONE
serTIOM B . Milan) Chir»eTariitie< fAdditinnal thrett encckrti I
PARAMETER/
outfall
MINIMUM
average
maximum
AOOlTIQNAL
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
>
SAMPLE
MEASUREMENT
PERMIT
REOUI REMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
sample
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
I
SECTION C • Facility Evaluation IS * Satisfactory. 1 - i'nsaus;sctory. St A * .-Vor applicable)
leFFLUEVT WITHIN PERMIT REQUIREMENTS
OPERATION ANO MAINTENANCE
I SAMPLING PROCEDURES
(RECORDS ANO REPORTS
COMPLIANCE SCWEOULE
I LABORATORY PRACTICES
[PERMIT VERlPiCATION
FLOW MEASUREMENTS
]OTHER:
SECTION 0 - Commtnu
SECTION E ¦ Intpaetien/Rtvitw
ENPORCBUKftfT
SIGNATURES
AGENCY
OATE
: DIVISION
UMOMtY
INSPECTED BY
COMPUAMCK STATUS
OC0M»UAMCI
Qnomcqmw^ci
INSPECTS0 8Y
REVIEWED BY
,V t
EPA FORM 1560-3 (9-771 REPLACES EP A FORM T-S1 19 76) WHICH IS OBSOLETE.
-------
E-2
Form Approved
Sections F thru L: Complete on all inspections, as.appropriate. N/A
3 Not Applicable
PERMIT NO.
SECTION f - Facility *"d Ptrmit ••ekaround
ADORESS OP PERMITTEE IF OlFMRBNT MOM FACILITY
(Inctudinf City. County and ZIP CO&J
DATE Of LAST PREVIOUS INVESTIGATION BY EPA/STATE
PINOINOS
SECTION C ¦ Record* tnd fl«ons
RECORDS ANO REPORTS MAINTAINED AS REQUIRED BY PERMIT.
3£TA!LS:
~ yes U NO On/a (Further explanation attached -
i
r»i aoequare hecoros maintained op:
(il sampling OATE. TIMS. SXACT LOCATION
~ YES
Q
2
0
1
~ n/a
(il) ANALYSES DATES. TIMES
~ YES
Q NO
~ N/A
am iNOivtouAt analysis
~
YES
~ NO
On/a
Civ> ANALYTICAL methods/techniques USEO
~ YES
~ NO
On/a
(v> analytical RESULTS (t,f., continent with self-monitoring report dalaj
~
YtS
~ NO
Gn/a
tot MONiTOff«NS recoros fe.f.r/low, DO.. etc.j maintaineo pcr a mwmom of three yeaas
INCLUDING ALL original STRIP CHART RECORDINGS [i f. continuous monitoring instrumentation,
cstibnition sna nwir uwicr rtcarti).
~ YES
~ NO
~ n/a
(c> LA9 EQUIPMENT calibration ANO MAINTENANCE RSCOflOS KEPT.
O re s
~ NO
~ n/a
(a) FACILITY OPERATING RE COR OS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT UNTT. ~ YES
~ NO
~ n/a
(•I QUALITY ASSURANCE RECORDS KEPT.
~
YES
~
*
O
~ n/a
-------
¦E-3
Form Approved ^ •
OMB 1V0. I SB - R0073
PERMIT NO.
SECTION J ¦ CerteHinc* SchadtiM
[PERMITTEE IS MEETING COMPLIANCE SCHEDULE. O vES OnO Dn/a [Further explanationattached
' CHECK APPROPRIATE PMAM131:
~ (d THE PERMITTEE HAS 08TAIN80 the NECESSARY APPROVALS FROM THE APPROPRIATE
authorities TO BEGIN CONSTRUCTION.
~ (bi proper arrangement has BEEN MADE FOR pinancing [mortgage commitment:, grants, iff./.
~ (o CONTRACTS fOR ENGINEERING SERVICES HAVE BEEN EXECUTED.
~ Id) OESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED.
~ (*i CONSTRUCTION HAS COMMENCED.
~ <»l CONSTRUCTION ANO/OR EQUIPMENT ACQUISITION IS ON SCHEOULE.
C
.'ml FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED 3Y PERVIT
n
YES
~ NO
~ N/A
tivi sample HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3
C
YES
~ NO
~ N/A
Hi MONITORING AND ANALYSES 3E1NG PERFORMED MORE FREQUENTLY THAN REQUiREO 0Y
PERMIT.
YES
~ NO
~ N/A
Ill IF (•) IS YES. RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONiTOR'NG REPORT.
YES
~ NO
~ N/A
Part 3 — Laboratory /Further explanation attarhrd 1
PERMITTEE LABORATORY PROCEDURES MEET THE REQUI REMENTS ANO INTENT OF THE PERMIT,
DETAI LS:
i—
YES ¦
~ NO
~ n/a
(t) EPA APPROVED ANALYTICALT6STING PROCEDURES USED. [40 CFR ! 26.3)
~
YES
~ NO
~ n/a
(01 I F ALTERNATE ANALYTICAL PROCEDURES ARE USEO. PROPER APPROVAL HAS BEEN OBTAINED.
~
YES
~ NO
~ n/a
(cl PARAMETERS other THAN THOSE REQui«EO BY THE PERMIT ARE ANALYZED.
~
YES
~ NO
~ N/A
(0) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS ANO EQUIPMENT.
r™!
YES
~ NO
.~n/a
(•I QUALITY CONTROL PROCEDURES USEO.
i
YES
~ NO
~ N/A
Cl DUPLICATE SAMPLES ARE ANALYZED. S OF TIME.
~
v»
Ul
>-
~ NO
Q N/A
!S1 SPl KcO SAMPLES ARE USED _ ».HF TIMf
Lj
YES
~ NO
~ N/A
INi COMMERCIAL LABORATORY USED.
'—i
YES
~ NO
Q N/A
C. COMMERCIAL LABORATORY STATE CERTIFIED
YES
~ NO
Qn/a
LAB MAMF , _
LA# Aonnns
1
-------
E-4
Form Approval
OMB Wo. ISS-R0073
PBKMIT NO.
SECTION L ¦ EHiu«nt/Hec«mm Wew Oheervefaara (Further explanation attached J
OUTFALL NO.
OIL SHEEN
GREASE
TURBIDITY
VISIBLE
FOAM
VISIBLE
FLOAT SOL
COLOR
OTHER
1
I
1
I
1
(Sections M and N: Complete u appropriate for sampling inspections)
SECTION M • Sampling Inspection Procedures and Obturations /Further explanation attached )
~ CRA3 SAMPLES OSTAINEO
~ COMPOSITE OBTAINED
~ FLOW PROPORTIONED SAMPLE
~ automatic sampler useo
~ sample split with permittee
~ CHAIN OF CUSTODY EMPLOYED
~ sample OBTAINED from facility sampling device
compositing frequency PRESERVATION
SAMPLE REFRIGSRATsO OURING COMPOSITING: DyES ~ NO
SAMPLE REPRESENTATIVE OF volume and nature of OISCHARGE
SECTION N • Analytical Rnulti lAttjch report if rtecetsary)
-------
SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN
(SPCC) CHECKLIST
1. Does this facility have:
a. More than 1,320 gallons of above-ground
oil storage capacity or a single container
with a capacity of more than 660 gallons? Yes No
b. More than 42,000 gallons of underground
oil storage capacity? Yes No
2. Does this facility have a Spill Prevention
Control and Countermeasure (SPCC) plan? Yes No
a. Has the SPCC plan been certified by a
registered professional engineer? Yes No
b. Date the SPCC plan was last certified:
c. Original date SPCC plan was prepared:
3. Are there other State or local requirements
for hazardous materials spill prevention and
control plan? Yes No
a. Is this hazardous materials SPCC plan
available? Yes No
4. Have any reportable spills of petroleum products
or hazardous materials occurred at this facility
within the last review period? Yes No
Li st:
a.
Were these spills reported to the proper
.authorities?
Yes
No
b.
Were these spills cleaned up properly?
Yes
No
c.
Were measures, taken to prevent future spills?
Yes
No
d.
Is there evidence of these reported spills
or other spills at the facility?
Yes
No
-------
E-6
5. Does the SPCC plan include:
a. Notification procedures?
b. Inspection procedures?
c. A facility drawing which includes storage
tanks and containment areas?
d. Oil spill prevention designee?
6. Does the facility have:
a. Secondary containment or diversionary
structures at oil storage areas?
b. Spill cleanup materials available or infor-
mation on where these materials are available?
c. Security?
COMMENTS:
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
-------
APPENDIX F
RCRA CHECKLISTS
-------
INSPECTION PROCEDURES FOR NON-NOTIFIERS
Inspections may be conducted to determine whether handlers of hazardous
waste who have not notified under §3010 of RCRA should have done so. Steps
that should be taken by the inspector to make this determination include:
Request proof of a nonhazardous determination (this applies to
generators) via written notice or site visit.
If the generator is unable to satisfactorily demonstrate how such
a determination was made, ask the generator to present data or
records indicating:
Materials used and their quantity
Processes used
Product output and quantity of output
Waste stream produced and quantity
Byproducts created and quantity
Evaluate the data to determine whether or not the generator pro-
duces hazardous waste in quantities regulated by the Act.
If doubt still exists concerning the nature of the waste stream,
take a representative sample of the waste stream and submit it for
analysi s.
-------
F-2
Table F-l
RCRA INSPECTION CHECKLISTS*
RCRA COMPLIANCE INSPECTION REPORT
GENERATORS CHECKLIST
Note: On multiple part questions, circle those not in compliance.
Section A - EPA Identification No.
1. Does Generator have EPA ID No. (262.12 - EPA ID No.)? Yes No
a. If yes, EPA ID No.
Section B - Hazardous Waste Determination
1. Does generator generate hazardous waste(s) listed
in Subpart D (261.30 - 261.33 - List of Hazardous
Waste)? Yes No
a. If yes, list wastes and quantities on attachment. (Include EPA
Hazardous Waste No. Provide waste name and description.)
2. Does generator generate solid waste(s) that exhibit
hazardous character!sties (corrosivity, ignit-
ability, reactivity, EP toxicity) (261.20 - 251.24 -
Characteristics of Hazardous Waste)? Yes No
a. If yes, list wastes and quantities on attachment.
(Include EPA Hazardous Waste No. Provide waste
name and description.)
b. Does generator determine characteristics by
testing or by applying knowledge of processes? Yes No
(1) If determined by testing, did generator
use test methods in Part 261, Subpart C
(or equivalent)? Yes No
(2) If equivalent test methods used, attach copy of equivalent
methods used.
3. Are there any other solid wastes deemed nonhazardous
generated by generators (i.e., process waste streams,
collected matter from air pollution control equipment,
water treatment sludge, etc.)? Yes No
The checklists are to be used only as a guide and references should be
made to both RCRA and the regulations (40 CFR Parts 260 through 256)
for recent changes.
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F-3
a. If yes, did generator determine non-
hazardous characteristics by testing
or knowledge of process? Yes No
(1) If determined by testing, did generator
use test methods in Part 261, Subpart C
(or equivalent)? Yes No
(2) If equivalent test methods used, attach copy of equivalent
methods used.
b. List wastes and quantities deemed nonhazardous or processes from
which nonhazardous wastes were produced. Use narrative explanations
sheet.
Section C - Manifest
1. Does generator ship hazardous waste offsite
(Subpart B - The Manifest)? Yes No
a. If no, do not fill out Sections C and D.
b. If yes, identify primary offsite facility(ies). Use narrative
explanations sheet.
2. Has generator shipped hazardous waste offsite since
November 19, 1980? Yes No
3. Is generator exempted from regulation because of:
Small quantity generator (261.5 - Special
requirements) Yes No
OR
Produces nonhazardous waste at this time
(261.4 - Exclusions) Yes No
4. Is waste generated >100 kg/month, <1000 kg/month Yes No
a. Is waste shipped offsite in any quantity? Yes No
b. If yes, is waste manifested and does it include the following
information (required by no later than August 4, 1985)?*
(1) Name and address of generator Yes No
(2) DOT waste description, including proper
shipping name, hazard class and identi-
fication number or EPA identification
number, generic waste description or
hazardous waste characteristics? Yes No
Further information to be effective March 31, 1986.
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F-4
(3) Number and type of containers Yes No
(4) Quantity of waste transported Yes Mo
(5) Name and address of facility designated
to receive the waste Yes No
c. Does facility designated to receive the waste have:
(1) RCRA permit? Yes No
(2) Interim Status? Yes No
(3) Permitted, licensed or registered
by a State to manage municipal or
industrial solid waste? Yes No
5. If not exempted, does generator use manifest
(262.20 - General Requirements)? Yes No
a. If yes, is manifest EPA Form 8700-22 and, if
necessary, EPA form 8700-22A (Uniform Hazardous
Manifest) properly filled out (appendix to
40 CFR 262)? Yes No
b. Is the following certification on each manifest
form (effective September 1, 1985)? Yes No
The generator of the hazardous waste has a program in place to
reduce the volume or quantity and toxicity of such waste to the
degree determined by the generator to be economically practicable
and the proposed method of treatment, storage or disposal is that
practicable method currently available to the generator which
minimizes the present and future threat to human health and the
environment.
6. Does generator retain copies of manifests? Yes No
(Check completed manifests at random. Indicate how many manifests were
inspected, how many violations were noted and the type of violation.)
If yes, complete a through e. If questions contain more than one
item, circle those not in compliance (263.23 - Use of the Manifest).
a. Did generator sign and date all manifests
inspected? Yes No
Who signed for generator?
Name Title
Did generator obtain handwritten signature and
date of acceptance from initial transporter? Yes No
Who signed and dated for transporter?
Name Title
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F-5
c. Does generator retain one copy of manifest
signed by generator and transporter? Yes No
d. Do returned copies of manifest include facility
owner/operator signature and date of acceptance? Yes No
e. If copy of manifest from facility was not
returned within 45 days, did generator file an
exception report (262.42 - Exception
Reporting)? Yes No
1. If yes, did it contain the following information?
Legible copy of manifest Yes No
AND
Cover letter explaining generator's efforts
to locate waste. Yes No
f. Does (will) generator retain copies for 3
years? Yes No
Section D - Pre-Transport Requirements
1. Does generator package waste? Yes No
If no, skip the rest of Section D.
If yes, complete the following questions.
2. Does generator package waste in accordance with
49 CFR 173, 178 and 179 (DOT requirements, 262.30 -
Packaging)? Yes No
3. Inspect containers to be shipped.
a. Are containers to be shipped leaking,
corroding or bulging? Yes No
b. Use narrative explanations sheet to describe containers and
condition.
c. Is there evidence of heat generation from
incompatible wastes in the containers? Yes No
4. Does the generator use DOT labeling requirements in
accordance with 49 CFR 172 (262.31 - Labeling)? Yes No
5. Does the generator mark each package in accordance
with 49 CFR 172 (262.32 - Marking)? Yes No
6. Is each container of 100 gallons or less marked
with the following label (262.32 - Marking)? Yes No
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F-6
Label saying: 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
7. If there are any vehicles present cnsite loading or unloading hazardous
waste, inspect for presence of placards. Note this instance on narra-
tive explanation sheet.
8. Accumulation time (262.34 - Accumulation Time)
a. Is facility a permitted storage facility? Yes No
If yes, skip to question 9. If no, answer rest of question 8.
b. Is hazardous waste shipped offsite within
90 days? Yes Mo
c. Are containers used to store waste? Yes No
(1) Is the beginning date of accumulation time
clearly indicated? Yes No
c. (1) Does generator inspect containers for
leakage or corrosion? (265.174 -
Inspections)? Yes No
d. (1) Does generator handle ignitable or reactive
waste? Yes No
(2) If yes, does generator locate containers
holding ignitable or reactive waste at
least 15 meters (50 feet) inside facility's
property line? (265.176 - Special Require-
ments for Ignitable or Reactive Wastes)? Yes No
NOTE: If generator accumulates waste onsite for less than 90 days, fill
out Facilities Checklist, Section A-9, Personnel Training; Section
B - Preparedness and Prevention; and Section C - Contingency Plan
and Emergency Procedures.
9. Describe storage area. Use photos and narrative explanation sheet.
Section E - Recordkeeping and Records
1. Is generator keeping the following reports? (262.40 - Recordkeeping)
(NOTE: The following must be kept for a minimum of three (3) years.)
a. Manifests and signed copies from designated
faci1ities?
Yes No
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F-7
b. Annual reports (not applicable until March 1982)? Yes No
c. Exception reports? Yes No
D. Test results, where applicable? Yes No
2. Where are records kept (at facility or elsewhere)?
3. Who is in charge of keeping the records? Name:
Title:
Section F - Special Conditions
1. Has generator received from or transported to a
foreign source any hazardous waste (262.50 -
International Shipments)? Yes No
If yes,
a. Has he filed a notice with the R.A.? Yes No
b. Is this waste manifested and signed by foreign
consignee? Yes No
c. If generator transported wastes out of the
country, has he received confirmation of
delivered shipment? Yes No
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F-8
Table F-2
RCRA COMPLIANCE INSPECTION REPORT
TRANSPORTER(S) AND VEHICLE CHECKLIST
A. General Transporter Information
1. Does transporter have EPA Identification Number? Yes No
a. If yes, EPA No.
2. Does more than one location use this identification
number? Yes No
a. If yes, how many?
3. Identify the mode(s) of transportation used by transporter.
Air Rail Highway Water Other (specify)
Speci fication:
4. Does transporter have all necessary permits? Yes No
If yes, identify State permit number:
identify Federal permit number:
5. Does transporter ship hazardous waste out of the
U.S.? Yes No
6. Does transporter ship hazardous waste into the U.S.? Yes No
7. Does transporter mix hazardous wastes of different
DOT shipping descriptions by placing them into a
single container? Yes No
a. If yes, complete "Generator Check?ist" for these mixtures.
8. Transfer Facilities
1. Does the transporter store manifested shipments of
hazardous waste in containers meeting the requirements
of §262.30 at a transfer facility? Yes No
2. Is all manifested hazardous waste, temporarily
stored by the transporter, shipped offsite within
10 days? Yes No
a. If not, complete "RCRA Facility Checklist".
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F-9
C. Manifest and Recordkeeping Requirements
1. Are all shipments of hazardous wastes accompanied by
an approved manifest (EPA Form 8700-22 and EPA Form
8700-22A)? Yes No
2. Does all required information appear on the manifest? Yes No
3. Identify number of manifests inspected and give narrative explanation
of deficiencies.
4. If transporter, has shipped hazardous waste(s) out of
the United States, is the date of exit and the name
and address of receiving facility indicated on
manifest? Yes . No
5. Special Conditions
a. If transportation occurs by water (bulk shipment),
does the transporter:
(1) Ship to the designated facility? Yes No
(2) Maintain shipping papers with information
contained on manifest? Yes No
(3) Obtain designated facility signature and
date of receipt? Yes No
(4) Retain copies of shipping papers for
3 years? Yes No
b. If transportation occurs by rail, does the
transporter:
(1) Sign and date manifest acknowledging
acceptance? Yes No
(2) Return signed copy to nonrail transporter? Yes No
(3) Forward at least three copies of the
manifest to the next appropriate
destination? Yes No
(4) Retain one copy of manifest and rail
shipping papers? Yes No
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F-10
(5) Assure shipping papers accompany the
waste(s)? Yes No
(6) On delivery, obtain name, date and
signature of designated facility or
transporter? Yes No
6. Does transporter keep copies of manifests and shipping
papers for the required 3-year period? Yes No
0. Manifest Compliance
1. Does the transporter ship all waste to either the
designated facility listed on the manifest or the
alternate facility (when applicable) or the next
designated transporter? Yes No
2. Does the transporter assure delivery to the
designated facility outside the U.S.? Yes No
3. What procedures does the transporter follow when delivery of hazardous
wastes to designated facility is prevented? (Use narrative
explanation sheets.)
E. Pre-transport Review
1. Does the transporter check to assure that the generator
has complied with the following requirements?
a. Has the generator packaged wastes in accordance
with DOT requirements? Yes No
b. Has the generator packaged wastes in repacks? Yes No
c. Has the generator labeled wastes in accordance
with DOT requirements? Yes No
d. Has the generator marked wastes in.accordance
with DOT requirements? Yes No
e. Has generator marked each container of 110
gallons or less used in such transportation
with the following words and information dis-
played in accordance with the requirements of
49 CFR 172.304? Yes No
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:
-------
F-ll
f. Did generator placard or offer the initial
transporter the appropriate placards according
to DOT (49 CFR 172, Subpart F)?
F. Emergency Action
1. Has transporter ever been involved in a dis-
charge of hazardous wastes?
a. If yes, was the National Response Center
(800-424-8802 or 202-426-2675), U.S.
Coast Guard, the State and the principal
office of transporter notified?
b. Was a written report submitted to DOT
within 10 days following the discharge
Attach copy of report (if available).
2. Has the transporter obtained an Emergency
Identification Number from EPA for the
cleanup operation?
a. If yes, identify the number(s):
G. Transport Vehicle Inspection
1. Company/name/designation of vehicle:
2. Truck driver's name:
3. What hazardous wastes are listed on manifest? List in narrative
explanation.
4. Form of containerization of hazardous wastes:
drums, size: gallons (ea), amount (i.e., 30 drums)
portable tanks - number volume (ea)
gondola
tanker-type volume (ea)
5. Narrative explanation of condition of containerization (leaking,
corroded, fuming, damaged, improperly sealed, poor condition,
improper 1ining, etc.)
Yes No
Yes No
Yes No
Yes No
Yes No
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F-12
6. Is truck properly placarded and marked? Yes No
7. Complete portions on A, B arid C parts as apply? Yes No
8. Did generator have to repackage wastes by
truck driver's request? Yes No
9. Is truck driver aware of any special handling
of materials? Yes No
10. Does truck driver have the National Response
Center phone number accessible? Yes No
COMMENTS:
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F -13
Table F-3
RCRA COMPLIANCE INSPECTION REPORT
TSD FACILITIES CHECKLIST FOR INTERIM STATUS FACILITIES
Section A - General Facility Standards
1. Does facility have EPA identification number
(265.11 - Identification Number)? Yes No
a. If yes, EPA identification number:
If no, explain:
2. Has facility received hazardous waste from a foreign
source (265.12 - Required Notices)? Yes No
a. If yes, has he filed a notice with the
Regional Administrator? Yes No
Waste Analysis
3. Does the facility have a written waste analysis plan
(265.13 - General Waste Analysis)? Yes No
a. If yes, is a copy maintained at the facility? Yes No
If no, question 4 not applicable.
4. If yes, does it include:
a: Parameters for which each waste will be analyzed? Yes No
b. Test methods used to test for these parameters? Yes No
c. Sampling method used to obtain sample? Yes No
d. Frequency with which the initial analysis will
be reviewed or repeated? Yes No
(1) If yes, does it include requirements to
re-test when the process or operation
generating the waste has changed? Yes No
e. (For offsite facilities) Waste analyses, that
generators have agreed to supply? Yes No
f. (For offsite facilities) Procedures which are
used to inspect and analyze each movement of
hazardous waste including:
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F-14
(1) Procedures to be used to determine the
identity of each movement of waste? Yes No
(2) Sampling method to be used to obtain
representative sample of the waste to
be identified? Yes No
5. Does the facility provide adequate security to mini-
mize the possibility for the unauthorized entry of
persons or livestock onto the active portions of the
facility (265.14 - Security)? Yes No
If no, describe inadequacies. (Use narrative explanation sheet.)
If yes, is security provided through:
a. 24-hour surveillance system (e.g., television
monitoring or guards)? Yes No
OR
b. (1) Artificial or natural barrier around
facility (e.g., fence or fence and cliff)? Yes No
Describe type of security:
AND
(2) Means to control entry through entrances
(e.g., attendant, television monitors,
locked entrance, controlled roadway
access)? Yes . No
Describe type of security:
Include a drawing indicating any inadequacies in the facility's
security system.
6. Is a sign with the legend, "Danger-Unauthorized
Personnel Keep Out", posted at the entrance to the
active portion of the facility? Yes No
Is it written in English and legible from at least
25 feet? Yes No
NOTE: The sign must be written in any other language predominant in the
area surrounding the facility (e.g., in New Mexico and Texas
areas bordering Mexico, the sign must be in Spanish).
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F -15
If a sign exists with a legend other than "Danger-Unauthorized
Personnel Keep Out", what does that legend say?
General Inspection Requirements
7. a. Does the owner/operator maintain a written
schedule for inspecting (265.25 - General
Inspection Requirements)? Yes No
(1) Monitoring equipment, if applicable? Yes No
(2) Safety and emergency equipment? Yes No
(3) Security devices? Yes No
(4) Operating and structural equipment, if
applicable? Yes No
(5) Does the schedule or plan identify the
types of problems to be looked for during
inspection? Yes No
(a) Malfunction or deterioration (e.g.,
inoperative sump pump, leaking fitting,
eroding dike, corroded pipes or tanks,
etc.)? Yes No
(b) Operator error? Yes No
(c) Discharges (e.g., leaks from valves
or pipes, joint breaks, etc.)? Yes No
b. Is a written schedule for these inspections
maintained at the facility? Yes No
(1) Are these inspections conducted? Yes No
(a) Is a record of these inspections
maintained in the inspection log? Yes No
8. Does the owner/operator have an inspection log
(265.15 - General Inspection Requirements)? Yes No
a. If yes, does it include:
(1) Date and time of inspection? Yes No
(2) Name of inspector? Yes No
(3) Notation of observations? Yes No
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F-16
(4) Date and nature of repairs or remedial
action?
B. Are there any malfunctions or other defi-
ciencies noted in the inspection log that
remain uncorrected? Use narrative
explanation sheet.
C. Are records of the inspection log main-
tained at the facility for 3 years?
Personnel Training
9. Does the owner/operator maintain a personnel
training program (266.16 - Personnel Training)
a. If yes,
(1) Is the program directed by a person
trained in hazardous waste manage-
ment procedures?
(2) Is the program designed to prepare
employees to respond effectively to
hazardous waste emergencies?
(3) Is a training review given annually?
B. Does the owner/operator keep the following
records:
(1) Job title and written job description
of each position?
(2) Description of the type arid amount of
introductory and continuing training?
(3) Documentation that training has been
given to employees?
c. Are these records maintained at the
faci1?ty?
Requirements for Ignitable, Reactive or Incompatible Waste
10. Does facility handle ignitable or reactive
waste (265.17 - Ignitable, Reactive,
Incompatible Wastes)?
a. If yes, is waste separated and confined
from sources if ignition or reaction
(open flames, smoking, cutting and welding,
hot surfaces, frictional heat), sparks
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F-17
(static, electrical or mechanical), spon-
taneous ignition (e.g., from heat producing
chemical reactions) and radiant heat? Yes No
b. Are smoking and open flames confined to
specifically designated locations? Yes No
c. Are "No Smoking" signs posted in hazardous
areas where ignitable or reactive wastes
are handled? Yes No
11. Check containers (265.17 - Ignitable, Reactive,
Incompatible Wastes).
a. Are containers leaking, corroding or
bulging? Yes No
Use narrative explanation sheet to explain containers in
this condition.
b. Has the facility ever placed incompatible
wastes together? Yes No
If yes, what were the results? Use narrative explanation
sheet. Look for signs of mixing of incompatible wastes
(e.g., fire, toxic mist, heat generation, bulging con-
tainers, etc.).
Section B - Preparedness and Prevention
1. Is there evidence of fire, explosion of contamination
of the environment (265.31 - Maintenance and operation
of facility)? Yes No
If yes, use narrative explanation sheet to explain.
2. Is the facility equipped with (265.32 - Required
Equipment)?
a; Internal communications or alarm system? Yes No
(1) Is it easily accessible in case of
emergency? Yes No
b. Telephone or two-way radio to call emergency
response personnel? Yes No
c. Portable fire extinguishers, fire control
equipment, spill control equipment and
decontamination equipment? Yes No
(1) Is this equipment tested to assure its
proper operation? Yes No
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F-18
d. Water of adequate volume for hoses, sprinklers
or water spray system? Yes No
(1) Describe source of water
(2) Indicate flow rate and/or pressure and storage capacity,
if applicable.
3. Is there sufficient aisle space to allow unobstructed
movement of personnel and equipment (e.g., adequate
aisle space in between barrels to check, for leakage,
corrosion and proper labeling, etc.) (265.35 -
Required Aisle Space)? Yes No
4. Has the owner/operator made arrangements with the
local authorities to familiarize them with charac-
teristics of the facility (layout of facility,
properties of hazardous waste handled and assoc-
iated hazards, places where facility personnel
would normally be working, entrances to roads
inside facility, possible evacuation routes)
(265.37 - Arrangements with Local Authorities)? Yes No
If no, has the owner/operator attempted to make
such arrangements? Yes No
5. In the case that more than one police or fire
department might respond, is there a designated
primary authority (265.37 - Arrangements with
Local Authorities)? Yes No
If yes, indicate primary authority:
A. Is the fire department a city or volunteer fire department?
6. Does the owner/operator have phone numbers of and
agreements with State emergency response teams,
emergency response contractors and equipment
suppliers? Yes No
Are they readily available to the emergency
coordinator (265.37 - Arrangements with Local
Authorities)? Yes No
7. Has the owner/operator arranged to familiarize
local hospitals with the properties of hazardous
waste handled and typed of injuries that could
result from fires, explosions or releases at the
facility? Yes No
If no, has the owner/operator attempted to do this
(265.37 - Arrangements with Local Authorities)? Yes No
-------
8. If the State or local authorities decline to.enter
into the above-referenced agreements, has this
situation been entered in the operating record
(265.37 - Arrangements with Local Authorities)?
Section C - Contingency Plan and Emergency Procedures
1. Does the facility have a contingency plan (265.52 -
Content of Contingency Plan)?
a. If yes, does it contain:
(1) Actions to be taken in response to
emergenci es?
(2) Description of arrangements with police,
fire and hospital officials?
(3) List of names, addresses, phone numbers
of personnel qualified to act as emergency
coordi nator?
(4) List of all emergency equipment at the
facility?
(5) Evacuation plan for facility personnel?
2. Is a copy of the contingency plan maintained at the
facility (265.53 - Copies of Contingency Plan)?
3. Has a copy been supplied to local police and fire
departments (265.53 - Copies of Contingency Plan)?
4. Is the plan a revised SPCC plan (265.52 - Contents
of Contingency Plan)?
5. Is there an emergency coordinator onsite or within
short driving distance of the plant at all times?
If yes, list primary emergency coordinator:
Section D - Manifest System, Recordkeeping and Reporting
1. Has facility received hazardous waste from offsite
since November 19, 1980 (255.71 - Use of Manifest.
System)?
a. If no, questions 1, 2 and 3 not applicable.
b. If yes, does the facility retain copies of all
mani fests?
(1) Is the uniform manifest used?
-------
F-20
(2) Are the manifests signed, dated and
returned to the generator? Yes No
(3) Is a signed copy given to the transporter? Yes No
2. Has the facility received any hazardous waste from
a rail or water (bulk shipment) transporter since
November 19, 1980 (265.71 - Use of Manifest System)? Yes No
a. If yes, is it accompanied by a shipping paper? Yes No
(1) Does the owner/operator sign and date the
shipping paper and return a copy to the
generator? Yes No
(2) Is a signed copy given to the transporter? Yes No
3. Has the facility received any shipments of hazardous
waste since November 19, 1980, which were inconsistent
with the manifest (265.72 - Manifest Discrepancies)? Yes No
a. If yes, has he resolved the discrepancy with
the generator and transporter? Yes No
b. If no, has Regional Administrator been
notified? Yes No
4. Has the facility received any waste (that does
not come under the small generator exclusion)
not accompanied by a manifest (265.76 - Unmani-
fested Waste Report)? Yes No
a. If yes, has he submitted an unmanifested
waste report to the Regional Administrator? Yes No
5. Does the facility have a written operating record
(265.73 - Operations Record)? Yes No
a. Is a copy maintained at the facility? Yes No
b. Does the record include:
(1) Description and quantity of each hazardous
waste and the methods and dates of its
treatment, storage or disposal at the
facility? Yes No
(2) Location and quantity of each hazardous
waste at each location? Yes No
(a) Is this information cross-referenced
with specific manifest document
numbers, if applicable? Yes No
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F - 21
(3) (For disposal facilities only) Is the
location and quantity of each hazardous
waste recorded on a map or diagram of
each cell or disposal area? Yes No
(4) Record and results of waste analyses? Yes No
(5) Reports of incidents involving imple-
mentation of the contingency plan (if
applicable)? Yes No
(6) Records and results of required
inspections? Yes No
(7) Monitoring, testing or analytical data
where required? Yes No
(8) Closure cost estimates and, for disposal
facilities, post-closure cost estimates? Yes No
Section E - Plans and Reports
1. Have all plans and reports been visually inspected
and/or been made available for inspection (265.74 -
Availability, Retention and Disposition of Records)? Yes No
List plans and/or reports not made available for inspection.
2. Did operator provide inspector with a drawing of
the facility? Yes No
a. If yes, indicate which are hazardous waste facilities on the
drawing.
3. Indicate types of hazardous waste facilities.
Groundwater Monitoring Program (Subpart F)
Containers (Subpart I)
Tanks (Subpart J)
Surface Impoundments (Subpart K)
Waste Piles (Subpart L)
Land Treatment (Subpart M)
Landfill (Subpart N)
Incinerator (Subpart 0)
Thermal Treatment (Subpart P)
Chemical, Physical and Biological Treatment (Subpart Q)
Underground Injection (Subpart R)
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Table F-4
GROUNDWATER MONITORING FOR PRE-JULY 26, 1982 SITES
Has the facility implemented a groundwater monitoring
program? Yes
Has a waiver demonstration been prepared? Yes
a. Does it describe the potential for migration
of waste from the unit to the uppermost
aquifer? Yes
b. Does it describe the potential for waste
movement to a water supply or surface water? Yes
c. Is it certified by a qualified geologist or
geotechnical engineer? Yes
Has an alternate groundwater monitoring system
been designed? Yes
a. Is it certified by a qualified geologist or
geotechrical engineer? Yes
b. Does it determine the rate and extent of waste
migration? Yes
c. Does it determine the combinations of waste in
the groundwater? Yes
d. Has a groundwater quality assessment report
been submitted? Yes
e. Are groundwater determinations (b) and (c) above
made quarterly? Yes
f. Are records retained showing results of analyses
and evaluations? Yes
g. Is an annual report submitted March 1? Yes
Obtain or review available geclogic/hydrogeologic information.
Obtain a site map identifying the following:
a. Location of regulated- unit(s)
b. Groundwater contours
c. Groundwater flow rate and direction
d. Monitoring well locations, depths and size
e. Location of compliance point(s)
f. Geology of the area
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F-?3
g. Proximity of unit(s) to surface waters
h. Areas of groundwater recharge and discharge
6. Review well construction.
a. Well(s) properly screened Yes No
b. Well(s) properly packed Yes No
c. Well(s) properly sealed Yes No
d. Wei 1Cs) in uppermost aquifer Yes No
7. Review compliance point location.
a. Well downgradient of regulated unit Yes No
b. Well in uppermost aquifer Yes No
c. Well under hydraulic influence of regulated
unit Yes No
8. Review upgradient wells.
a. Well(s) under hydraulic influence of regulated
unit Yes No
b. Three or more in place Yes No
c. Wells in uppermost aquifer Yes No
d. Well locations will characterize background Yes No
9. Review sampling and analysis procedures plan.
10.
a.
Sample collection adequately described
Yes
No
b.
Sample preservation adequately described
Yes
No
c.
Sample shipping adequately described
Yes
No
d.
Analytical procedures described or identified
Yes
No
e.
Approved procedures used
Yes
No
f.
Sample chain-of-custody adequate
Yes
No
q-
Quality assurance/control program outlined
Yes
No
h.
Detection levels identified for each parameter
Yes
No
i.
Sampling performed quarterly
Yes
No
J-
Are parameters to be analyzed those found in
40 CFR 265.92(b)?
Yes
No
Is
each well sampled quarterly for 1 year?
Yes
No
11. Are a minimum of four samples used to determine
background? Yes No
12. Have background levels been established for each
parameter? Yes No
13. Is groundwater surface elevation determined at each
sampling? Yes No
14. Is background based on quarterly sampling for a year? Yes No
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F-24
15. Is the approved statistical test used? Yes No
16. Has a groundwater assessment program been prepared? Yes No
a. Can it determine if waste has entered the
groundwater? . Yes No
b. Can it determine the rate and extent of
migration? - Yes No
c. Can it determine the concentrations of waste in
the groundwater? Yes No
17. Have any statistical increases (decreases for pH)
appeared in background? Yes No
a. Was a report submitted showing difference? Yes No
b. Are annual reports submitted each March 1? Yes Ho
18. Have any statistical increases (decreases for pH)
appeared downgradient? Yes No
a. Was statistical difference verified by sampling? Yes No
b. Was RA or State notified of the statistical
difference? Yes No
c. Was an assessment plan submitted? Yes No
d. Was the assessment plan submitted within 15
days of (b)? Yes No
e. Does the assessment action plan follow the
requirements of 40 CFR 265.93(d)(3)? Yes No
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F-25
Table F-5
GROUNDWATER MONITORING CHECKLIST FOR
FACILITIES RECEIVING WASTE AFTER JULY 26, 1982
1. Obtain or review available geologic/hydrogeologic information.
2. Obtain a site map identifying the following:
a. Location of regulated unit(s)
b. Groundwater contours
c. Groundwater flow rate and direction
d. Monitoring well locations, depths and size
e. Location of compliance point(s)
f. Geology of the area
g. Proximity of unft(s) to surface waters
h. Areas of groundwater recharge and discharge
3. Review well construction.
a.
Well(s) properly screened
Yes
No
b.
Well(s) properly packed
Yes
No
c.
Well(s) properly sealed
Yes
No
d.
Well(s) in uppermost aquifer
Yes
No
Review compliance point location.
a.
Well downgradient of regulated unit
Yes
No
b.
Well in uppermost aquifer
Yes
No
c.
Well under hydraulic influence of regulated
unit
Yes
No
Review upgradient wells.
a.
Well(s under hydraulic influence of regulated
unit
Yes
No
b.
Three or more in place
Yes
No
c.
Wells in uppermost aquifer
Yes
No
d.
Well locations will characterize background
Yes
No
Review sampling and analysis procedures plan.
a.
Sample collection adequately described
Yes
No
b.
Sample preservation adequately described
Yes
No
c.
Sample shipping adequately described
Yes
No
d.
Analytical procedures described or identified
Yes
No
e.
Approved procedures used
Yes
No
f.
Sample chain-of-custody adequate
Yes
No
g-
Quality assurance/control program outlined
Yes
No
h.
Detection levels identified for each parameter
Yes
No
i.
Sampling performed quarterly
Yes
No
J-
Are parameters to be analyzed those formulas
found in 40 CFR 265.92(b)?
Yes
No
-------
F-26
7. Is each well sampled quarterly? Yes No
8. Are a minimum of four samples used to determine
background? Yes No
9. Have background levels been established for each
parameter? Yes No
10. Is groundwater surface elevation determined at each
sampling? Yes No
11. Is background based on quarterly sampling for a year? Yes No
12. Is the approved statistical test used? Yes No
13. Has a groundwater assessment program been prepared? Yes No
a. Can it determine if waste has entered the
groundwater? ___ Yes No
b. Can it determine the rate and extent of
migration? Yes No
c. Can it determine the concentrations of waste in
the groundwater? Yes No
14. Have any statistical increases (decreases for pH)
appeared in background? Yes No
a. Was a report submitted showing differences? Yes No
b. Are annual reports submitted each March 1? Yes No
15. Have any statistical increases (decreases for pH)
appeared downgradient? Yes No
a. Was statistical difference verified by sampling? Yes No
b. Was RA or State notified of the statistical
difference? Yes No
c. Was corrective action plan submitted? Yes No
d. Was corrective action plan submitted within 15
days of (b)? Yes No
e. Does the corrective action plan follow the
requirements of 40 CFR 264.100? Yes No
16. Are the following records kept at the facility?
a. Analysis of all well sampling Yes No
b. Well groundwater elevations Yes No
c. The statistical evaluation for each well Yes No
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F - 27
17. Is the following information reported?
a".
The quarterly analysis for background wells
during first year
Yes
No
b.
The annual analyses for all wells and the
evaluation
Yes
No
c.
Results of groundwater surface elevation
evaluations
Yes
No
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F-28
Table F-6
CONTAINER STORAGE CHECKLIST
(Subpart I - Use and Management of Containers 265.170)
1. Does the facility store hazardous waste in containers? Yes No
2. Are the containers in good condition (check for
leaks, corrosion, bulges, etc.)? Yes No
If no, explain in narrative and document with photograph.
3. If a container is found to be leaking, does the
operator transfer the hazardous waste from the
"leaking container? Yes No
4. Is the waste compatible with the containers and/or
its liner? Yes No
If no, explain in narrative.
5. Are the stored containers closed? Yes No
If no, explain in narrative.
6. Are containers holding hazardous waste opened, handled
or stored in such a manner as to cause the container
to rupture or leak? Yes No
7. Are each of the containers inspected at least weekly? Yes No
If no, explain in the narrative the frequency of inspection.
8. Are containers holding ignitible or reactive wastes
located at least 15 meters (50 feet) from the
facility property line? Yes No
If no, explain in narrative and document with photograph.
9. Are incompatible wastes stored in the same containers? Yes No
10. Are containers holding incompatible wastes kept apart
by physical barrier or sufficient distance? Yes No
If no, explain in narrative.
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F - 29
Table F-7
TANKS CHECKLIST
(Subpart J - Tanks, 265.190)
NOTE: If multiple tanks exist, list each tank and specify compliance or
noncompliance. Complete an individual checklist for each tank
not in compliance and a collective checklist for those in
compliance.
1. Are there any tanks which are not being used which
the facility no longer plans to use? Yes No
a. If yes, has all hazardous waste and hazardous
waste residue been removed from these tanks,
discharge control equipment, and discharge
confinement structures? Yes No
2. Are tanks presently used to treat or store waste? Yes No
a. If no, do not complete rest of form.
b. If yes, check tanks.
3. Is there evidence that wastes placed in the tank
are incompatible with the tank or liner? Yes No
Note any evidence of ruptures, leaks or corrosion. Use narrative
explanations sheet.
4. Are there any uncovered tanks? Yes No
a. If no, do not complete 4b thru e.
b. If yes, do they have 2 feet (60 cm) freeboard? Yes No
OR
c. A containment structure (e.g., dike or trench)? Yes No
OR
d. A drainage control system? Yes No
OR
e. A diversion structure (e.g., standby tank)? Yes No
NOTE: The structure in c, d or e must have a capacity that equals or
exceeds the volume of the top 2 feet (60 cm) of the tank.
If the answers to 4b thru e are "no", explain current conditions using
narrative sheets.
-------
F-30
5. Are any of the tanks continuous feed?
a. If yes, is it equipped with a means to stop
flow (e.g., waste feed cutoff or bypass to
a standby tank)?
Waste Analysis
6. Is the tank used to store one waste exclusively?
a. If no, what are the different wastes stored in
the tank? Use narrative explanation sheet.
(1) Are waste analyses and trail tests con-
ducted on these wastes? Yes No
OR
Does the owner/operator have written docu-
mented information on similar treatment of
similar wastes under similar operating
conditions? Yes No
(2) Is this information retained in the
operating record? Yes No
Inspections (NOTE: This section does not exclude underground tanks.)
7. Does the owner/operator inspect the following at
least daily, where present: (Indicate which items
are present in 7 and 8.)
a. Discharge control equipment (e.g.,waste feed
cutoff, bypass and/or drainage systems)?
b. Monitoring equipment (e.g., pressure and
temperature gages)?
c. Level of waste in each uncovered tank?
8. Does the owner/operator inspect the following at
least weekly:
a. Construction materials of tanks for corrosion
or leaks?
b. Construction materials of and area surrounding
discharge confinement structures for erosion
or signs of leakage? Yes No
9. What is the procedure for assessing the condition of the tank(s)?
Explain in narrative (e.g., how does the procedure allow for detection
of cracks, leaks or corrosion or procedures for emptying the tank to
allow entrance, etc.).
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
-------
F-31
10. Does the facility have a closure plan?
a. Does the plan address the closure of each
tank?
If no, explain in narrative,
b. Is the plan maintained at the facility?
11. Are ignitable or reactive wastes placed in tanks?
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
tank so it no longer meets the definition of
ignitable or reactive?
OR
b. Is the waste protected from sources of ignition
or reaction? Yes No
(1) If yes, use narrative explanations sheet to describe
separation and confinement procedures.
(2) If no, use narrative explanations sheet to describe sources
of ignition or reaction.
OR
c. Is the tank used solely for emergencies? Yes No
12. Has the facility ever placed incompatible wastes
in the tank? Yes No
a. If yes, what were the results. Use narrative explanations sheet.
Look for signs of mixing of incompatible wastes (e.g., fire,
toxic mist, heat generation, bulging containers, etc.).
13. If a waste is to be placed in a tank that previously
held an incompatible waste, was that tank washed? Yes No
a. If yes, describe washing procedures. Use narrative explanation
sheet.
Describe how it is possible for incompatible wastes to be placed
in the same tank. Use narrative explanations sheet.
Yes No
Yes No
Yes No
Yes No
Yes No
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F-32
Table F-8
SURFACE IMPOUNDMENTS CHECKLIST
SUBPART K - SURFACE IMPOUNDMENTS 265.220
NOTE: Check all surface impoundments. Fill out one checklist for
any impoundment in violation. Fill out one checklist for all
other impoundments in compliance. Indicate number of surface
impoundments at the facility.
1. Are there any surface impoundments which are not
being used which the facility does not plan to
use in the future?
a. If yes, has all hazardous waste and hazardous
waste residue been removed from the
impoundment?
2. Are impoundments presently used to treat or store
waste?
3. Does the impoundment appear to maintain at least
2 feet (60 cm) of freeboard?
a. If no, what was the freeboard?
4. Is.there evidence of overtopping of the dike? Yes No
If yes, please describe.
Ves No
Yes No
Yes No
Yes No
5. Does the impoundment have a containment system? Yes No
a. Does the earthen dike have adequate protective
cover (e.g., grass, shale, rock) to minimize
wind and water erosion? Use narrative
explanation sheet to explain deficiencies. Yes No
b. Provide description of containment.
6. What wastes are treated or stored in the impoundment? Use narrative
explanations sheet.
7. Are hazardous wastes chemically treated in the
impoundment? Yes No
a. If yes:
(1) Are waste analyses and trial tests
conducted on these wastes? Yes No
-------
F-33
(2) Does the owner/operator have written
documented information on similar treatment
of similar wastes under similar operating
conditions? Yes No
b. Is this information retained in the operating
record? Yes No
8. Is the impoundment inspected daily to check freeboard
level? Yes No
9. Is the impoundment, dike and vegetation surrounding
the dike inspected to detect, leaks, deterioration or
failures at least once a week (265.226 -
Inspections)? Yes No
10. Does the facility maintain a record of the closure
plan on site? Yes No
11. Are ignitable or reactive wastes placed in the
impoundment? Yes No
a. If no, do not complete b and c.
b. If yes, are they treated, rendered or mixed
before or immediately after placement in the
impoundment so it no longer meets the definition
of ignitable or reactive? Yes No
OR
c. Is the impoundment used solely for emergencies? ; Yes No
(1) If yes, has further treatment, storage or disposal been
conducted'on.these wastes? Describe this situation.
12. Has the facility ever placed incompatible wastes in
the impoundment? Yes No
a. If yes, what were the results. Use narrative explanation sheet.
Look for signs of mixing of incompatible wastes (e.g., fire, toxic
mist, heat generation, bulging containers, etc.).
13. What is the impoundment lined with?
14. Does the impoundment solely neutralize corrosive
waste or waste listed in Subpart I solely
because of corrosivity? Yes No
15. Did the impoundment receive waste after July 26,
1982? Yes No
If yes, fill out Groundwater Monitoring Checklist B.
-------
F- 34
a. If yes, is no other hazardous waste in the
impoundment? Yes No
b. Has a demonstration been made that the waste is
neutralized so that no corrosive waste migrates
from the impoundment? Yes No
c. Has the demonstration been certified by a
qualified professional? Yes No
If any of the above are answered no, the groundwater monitoring
program cannot be waived.
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F - 35
Table F-9
WASTE PILES CHECKLIST
(Subpart L - Waste Piles, 265.250)
NOTE: Waste piles may also be managed as a landfill.
1. Did the unit receive hazardous waste after July 26,
1982? Yes No
If yes, fill out Groundwater Monitoring Checklist B.
2. Is the pile containing hazardous waste protection
from wind? Yes No
3. For offsite facilities, is a representative sample of
waste from each incoming shipment analyzed before
the waste is added to the pile to determine the
compatibility of the wastes? Yes No
a. For offsite facilities, does the analysis include
a visual comparison of color and texture? Yes No
4. Is the leachate or runoff from the pile considered
a hazardous waste? Yes No
a. If yes, is the pile managed with following?
(1) An impermeable base compatible with the
waste? Yes No
(2) Runon diversion? Yes No
(3) Leachate and runoff collection? Yes No
OR
b. Is the pile protected from precipitation and
runon by some other means? Yes No
OR
c. Are liquids or wastes containing free liquids
placed in the pile? Yes No
5. Are ignitable or reactive wastes placed in the pile? Yes No
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
pile so it no longer meets the definition of
ignitable or reactive? Use narrative sheet
to describe procedure. Yes No
OR
b. Is the waste protected from sources of ignition
or reaction? Yes No
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F-36
(1) If yes, use narrative explanations sheet to describe
separation and confinement procedures.
(2) If no, use narrative explanations sheet to describe source
of ignition or reaction.
6. Is there evidence of fire, explosion, gaseous
emissions, leaching or other discharge from the
hazardous waste pile? Use narrative explanation
sheet. Yes No
a. Does the waste pile have a leachate detection,
collection and removal system? Yes No
b. If no, does the inspection plan include a
schedule of inspection of the devices for
controlling precipitation and runon and
runoff? Yes No
c. Is the waste pile periodically removed for
inspection of the base? Yes No
7. Have incompatible wastes ever been placed together
in the waste pile? Yes No
If yes, what was the result?
8. Have there been other wastes previously stored at
the site of the present waste pile? Yes No
a. Have hazardous wastes been piled in the same
area where incompatible wastes or materials
were previously piled? Yes No
b. If yes, was the area decontaminated? Use
narrative explanation sheet. Yes No
9. Is a closure plan available? Yes No
a. Will all waste residues, system components,
subsoils, etc., be decontaminated and/or
removed? Yes No
b. If the above cannot be decontaminated, will
the facility be closed as a landfill? Yes No
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F-37
Table F-10
LAND TREATMENT CHECKLIST
(Subpart M - Land Treatment 265.270)
1. Did the unit receive hazardous waste after July 26,
1982? Yes No
If yes, fill out Groundwater Monitoring Checklist B.
2. Is runon diverted away from the land treatment
facility? Yes No
3. Is runoff from the land treatment facility collected? Yes No
4. Is the runoff analyzed to see if it is a hazardous
waste? Yes No
a. If the runoff is considered hazardous, how is
it handled? Use narrative explanation sheet. Yes No
b. If it is not a hazardous waste, is it
discharged through a point source to
surface waters? . Yes No
(1) If yes, list NPDES Permit No.
5. Is wind dispersal controlled? Yes No
6. What hazardous wastes are treated at the land treatment facility?
Use narrative explanation sheet.
Subpart D Listed Wastes Characteristic Wastes
a. For those listed wastes, were analyses done
to determine the concentrations of those
constituents which caused the waste to be
listed? Yes No
(1) If yes, what are these concentrations? Use narrative
explanation sheet.
b. For those characteristic wastes designated toxic because of the
extraction procedure, what are the concentrations of the
following?
Concentration Waste
Arsenic
Bari um
Cadmium
Chromium
Lead
-------
F-38
Concentration Waste
Mercury
Selenium
Si 1ver
Endrin
Li ndane
Methoxychlor
Toxaphene
2,4 D
2,4,5-TP Si 1 vex
7. Obtain a copy of the land treatment process and include it with the
report.
8. Are food chain crops grown? Yes No
a. If yes, can the owner/operator demonstrate
from field testing that arsenic, lead, mercury
or other toxic waste constituents:
(1) Will not be transferred to the food
portion of the crop or ingested by
food chain animals Yes No
OR
(2) Will not occur in greater concentrations
in the crops on the facility than in the
same crops on untreated soils in the
same region? Yes No
b. Is the following information used for making
this above demonstration and is it kept at
the facility?
(1)
Tests for specific wastes and application
rates being used at the facility
Yes
No
(2)
Crop characteristics
Yes
No
(3)
Soil characteristics
Yes
No
(4)
Sample selection criteria
Yes
No
(5)
Sample size determination
Yes
No
(6)
Analytical methods used
Yes
No
(7)
Statistical procedures
Yes
No
-------
F-39
9. Was the Regional Administrator notified by January 19,
1981 that food chain crops h.ad been or would be grown
at the facility? Yes No
10. Does the facility treat wastes that contain cadmium? Yes No
a. If no, go to question 11.
b. If yes, list these wastes. Use narrative explanation sheet.
c. Was the pH of the soil and waste mixture 6.5 or
greater at the time of each waste application? Yes No
(1) If the pH was less than 6.5, did the waste
contain cadmium concentrations of 2 mg/kg
or less? Yes No
d. Is the annual application rate of cadmium less
than .15 kg/ha (hilograms per hectare) for the
following: tobacco, leafy vegetables, or root
crops grown for human consumption? Yes No
(1) For all other food chain crops, is the
annual cadmium application rate less than
2.0 kg/ha (until June 30, 1984)? Yes No
11. Does the plan include:
a. Soil monitoring? Yes No
b. Soil pore water monitoring (water above the
saturated zone)? Yes No
c. Sample depths below waste incorporation? Yes No
d. Number of samples to be taken? Yes No
e. Frequency and time of sampling? Yes No
f. Analysis of samples? Yes No
Continue to g if facility received waste after
July 26, 1982.
g. Analysis for all parameters identified by 40 CFR
265.273 (a) and (b)? Yes No
h. Sample locations and depths? Yes No
12. Does implementation of the plan yield:
a. Background soil-pore liquid quality and chemical
makeup of soil not affected by treatment zone
leakage? Yes No
b. The quality of soil-pore liquid and chemical
makeup of soil below the treatment zone? Yes No
-------
F-40
13. Have background levels been established? Yes No
14. Is monitoring occurring in the soil-pore zone
immediately below the treatment zone? Yes No
15. Has a sampling and analysis plan been prepared and
does it include:
a. Sample collection techniques? Yes No
b. Sample preservation and shipment? Yes No
c. Analytical procedures? Yes No
d. Chain-of-custody control? Yes No
16. Has a statistically significant change over back-
ground been found? Yes No
a. Has the RA or State been notified if yes ? Yes No
b. Have operating practices been modified? Yes No
17. Is the following information (for each hazardous
waste) kept at the facility?
a. Application dates Yes No
b. Application rates Yes No
c. Quantities Yes No
d. Waste location Yes No
18. Does the facility have a closure/post-closure plan? Yes No
a. If yes, where is it kept?
19. Are ignitable or reactive wastes treated at the
facility? (circle appropriate waste) Yes No
a. If yes, are the wastes immediately incorporated
into the soil so that they are no longer
reactive or ignitable? Yes No
b. Describe or attach a copy of treatment.
20. Are incompatible wastes placed in the facility? Yes No
a, Are the incompatible wastes placed in different
locations in the facility? Yes No
(1) If no, look for signs of fire, heat generation, toxic mists,
etc. (use narrative explanation sheet).
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F - 41
Table F-ll
LANDFILLS CHECKLIST
(Subpart N - Landfills, 265.300)
1. Did the unit receive waste after July 26, 1982? Yes No
2. Is runoff from the landfill collected? Yes No
a. Is the waste from the collected runoff analyzed
to determine if it is a hazardous waste? Yes No
(1) If it is a hazardous waste, how is it
managed? (Use narrative explanation sheet.)
(2) Is the collected runoff discharged through
a point source to surface waters? Yes No
(a) If yes, list NPDES permit number
3. Is the landfill managed so that wind dispersal is
controlled? (Note blowing debris.) Yes No
4. Is the following information maintained in the
operating record? Yes No
a. On a map, the exact location and dimensions,
including depth of each cell with respect to
permanently surveyed benchmarks? Yes No
AND
b. Contents of each cell and the approximate
location of each hazardous waste type
within each cell? Yes No
5. Are reactive or ignitable wastes placed in the
landfill? Yes No
a. If yes, is it treated, rendered or mixed before
or immediately after placement in the landfill
so it is no longer reactive or ignitable? Yes No
b. Describe treatment, etc..or attach a copy of treatment.
6. Are incompatible wastes placed in the same landfill
cell? Yes No
a. If yes, what were the results? (Use narrative
explanation sheet.) (Look for signs of mixing
of incompatible wastes, e.g., fire, toxic mist,
heat generation, etc.)
-------
F-42
Describe how it is possible for incompatible wastes
to be placed in the same landfill cell. (Use
narrative explanation sheet.)
7. Are bulk or non-containerized liquid wastes or wastes
containing free liquids placed in the landfill? Yes No
a. If yes, does the landfill have:
(1) A liner which is chemically and physically
resistant to the added liquid? Yes No
(2) A functioning leachate collection and
adequate removal system? Yes No
OR
b. Is the liquid waste treated chemically or
physically so that free liquids are no longer
present? Yes No
8. Are containers holding liquid wastes placed in the
landfill? Yes No
If yes,
a. Has all free-standing liquid been removed? Yes No
OR
D. Has waste been mixed with absorbent or solidified
so that free-standing liquid is no longer
observed? Yes No
OR
c. Is the container very small, such as an ampule? Yes No
OR
d. Is the container designed to hold free liquids
for use other than storage, such as a battery
or capacitor? Yes No
OR
e. Is the container a lab pack? Yes No
9. Are empty containers placed in the landfill? Yes No
a. If yes, are they reduced in volume (e.g.,
shredded, crushed)? Yes No
-------
F - 43
10. Is there evidence of site instability (e.g.,
erosion, settling)? (Use narrative explanation
sheet.) Yes No
11. Is there evidence of ponding of water onsite?
(Use narrative explanation sheet.) Yes No
12. Is there any indication of improper or inadequate
drainage? (Use narrative explanation sheet.) Yes No
13. Does the facility have closure/post-closure plans? Yes No
a. If yes, where are they maintained?
b. Do the plans address the following items?
(1) Control of pollutant migration? Yes No
(2) Control of surface water infiltration? Yes No
(3) Prevention of erosion? Yes No
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F-44
Table F-12
INCINERATORS CHECKLIST
(Subpart 0: 265.340 - 265.369)
1. Is the incinerator operating at steady State condi-
tions (temperature and air flow) before adding
hazardous waste? Yes No
If no, explain in narrative.
2. Is a waste analysis performed on hazardous waste not
previously incinerated at facility? Yes No
3. Does it include analysis for the following?
a.
Heating value
Yes
No
b.
Halogen content
Yes
No
c.
Sulfur content
Yes
No
d.
Concentration of lead
Yes
No
e.
Concentration of mercury
Yes
No
f.
Is the above information documented in the
operating record?
Yes
No
(NOTE: D and e are not required if the facility has written documented
data that show the elements are not present.)
4. Does the owner/operator monitor the following when
incinerating hazardous waste? Are any of the following
instruments existing on the incinerator? Check under
applicable column.
a. Does the owner/operator monitor the following
at least every 15 minutes?
Existing Monitored
1.
Waste feed
Yes
No
Yes
No
2.
Auxiliary fuel feed
Yes
No
Yes
No
3.
Air flow
Yes
No
Yes
No
4.
Incinerator temperature
Yes
No
Yes
No
5.
Scrubber flow
Yes
No
Yes
. No
6.
Scrubber pH
Yes
No
Yes
No
7.
Relevant level controls
Yes
No
Yes
No
(NOTE: EEg., afterburner and temperature, 02, and CO meters are
examples of relevant level controls.)
b. Does the owner/operator monitor the stack plume
(emissions) at least hourly for:
(1) Color (normal) Yes No
(2) Opacity Yes No
-------
F-45
c. Does the owner/operator monitor the incinerator
and associated equipment at least daily including:
(circle those not in compliance)
(1) Pumps, valves, conveyors, pipes for leaks,
spills and fugitive emissons. (Use
narrative explanation sheet.) Yes No
(2) Emergency shutdown controls Yes No
(3) System alarms Yes No
d. Are these inspections referenced in the
inspection log? Review inspection plan,
note deficiencies in narrative. Yes No
5. Is a closure plan maintained for the incinerator? Yes No
If yes, is it kept at the facility? Yes No
6. What wastes are incinerated onsite?
Weight or Volume
EPA Hazardous Waste No. Description Incinerated Daily
-------
F-46
NOTE:
Table F-13
THERMAL TREATMENT CHECKLIST
(Subpart P - 265.370-265.399)
Applies to thermal treatment of hazardous waste in devices other
than incinerators.
1. Is the process a non-continuous (batch) process?
a. If no, is the process operating at steady State
conditions (including temperature) before
adding hazardous waste?
2. Is a waste analysis, for wastes not previously burned,
documented in the operating record?
a. Does it include analyses for the following:
(1) Heating value
(2) Halogen content
(3) Sulfur content ~
(4) Concentation of lead
(5) Concentration of mercury
b. Is this information documented in the operating
record?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
(NOTE: 4 and 5 are not required if the facility has written documented
data that show the elements are not present.)
3. Are the existing instruments which relate to combus-
tion and emission control monitored at least every
15 minutes?
Existing
Monitored
a.
Waste feed
Yes
No
b.
Auxiliary fuel feed
Yes
No
c.
Treatment process temp.
Yes
No
d.
Relevant process flow
Yes
No
e.
Relevant controls (e.g.,
afterburner and tempera-
ture controls, 02 and CO
meters)
Yes
No
Are stack plume (emissions) monitored at least
hourly?
a. Color (normal)
b. Opacity
Is thermal treatment process equipment monitored at
least daily including: (NOTE: circle those not in
commpliance).
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
-------
a. Pumps, valves, conveyors, pipes, etc., (for
leaks,.spills and fugitive emissions) Yes
b. Emergency shutdown controls Yes
c. System alarms Yes
Is a closure plan maintained at the facility? Yes
Is open burning or detonation of waste explosives
conducted? Yes
a. If yes, is the detonation performed in
accordance with the following table? Yes
Minimum Distance From Open
Pounds of Waste Explosives
or Detonation to the
or Propellants
Property of Others
0-100
204m (670 ft.)
101-1,000
380m (1,250 ft.)
1,000-10,000
530m (1,730 ft.)
10,001-30,000
690m (2,260 ft.)
Is there evidence of open burning of
hazardous wastes except for waste explosives? Yes
Use narrative explanations sheet to describe
details.
-------
F-48
Table F-14
CHECKLIST
Subpart Q
(Chemical, Physical and Biological Treatment, 265.400)
NOTE: Applies to treatment in other than tanks, surface impoundments and
land treatment facilities.
1. Describe treatment process (include information on wastes treated).
2. Check treatment process and equipment:
a. Are there any leaks, corrosion or other failures
evident? Yes No
If yes, describe.
3. Is the process a continuous feed system? Yes No
a. If yes, is it equipped with a means to stop
waste inflow (e.g., waste feed cutoff system
or bypass). Yes No
4. If hazardous waste is to be treated which is substantially different
from any hazardous waste previously treated at the facility or if a
substantially different process than any previously used at the facil-
ity is to be used to chemically treat hazardous wastes, are the fol-
lowing obtained:
a. Waste analyses and trial treatment tests (e.g.,
bench scale)? Yes No
OR
b. Written, documented information on similar
treatment or similar wastes? Yes No
5. Does the owner/operator inspect the following,
where present (indicate which items are present)?
a. At least daily
(1) Discharge control and safety equipment
(e.g., waste feed cutoff, bypass, drainage
or pressure relief systems)? Yes No
(2)
Data gathered from monitoring equipment
(e.g., pressure and temperature gauges)?
Yes No
-------
F-49
b. At least weekly.
(1) Construction materials of treatment process
or equipment to detect erosion or obvious
signs of leakage? Yes No
(2) Construction materials of an area
immediately surrounding discharge
confinement structures? Yes No
6. Does the facility have a closure plan? Yes No
7. Where is the plan maintained?
8. Are ignitable or reactive wastes placed in the
treatment process (circle appropriate waste). Yes No
a. If yes, is the waste treated, rendered or mixed
before or immediately after being placed in the
treatment process so it no longer meets the
definition of ignitable or reactive? Describe
or attach a copy of the treatment. Yes No
9. Has the facility treated incompatible wastes? Yes No
a. If yes, what were the results. Use narrative explanations sheet.
Look for signs of mixing of incompatible wastes (e.g., fire, toxic
mist., heat generation, etc.)
10. If a waste is to be placed in treatment equipment
that previously held an incompatible waste, was
that equipment washed? Yes No
a. If yes, describe washing procedures. Use narrative explanations
sheet.
Describe how it is possible for incompatible wastes to be placed
in the same treating equipment. Use narrative explanations
sheet.
-------
APPENDIX G
CERCLA CHECKLIST
-------
CERCLA CHECKLIST
1. Notification
a. Has the facility notified the proper regulatory
authorities concerning sites of past hazardous
substance releases and former hazardous sub-
stance storage,.treatment and disposal areas
[CERCLA 103(a) and (c)]? Yes No
b. What sites have been listed in any notification?
2. Unreported Sites
a. Are there indications of other sites at the
facility which may be appropriate for notifi-
cation (from records review, interviews,
evidence of spills, aerial photographs, etc.)? Yes No
b. List any potentially contaminated sites which have not been
reported.
3. Is this a Department of Defense (DO0) facility? Yes No
(If so, go to question 5)
4. Non-DOD facilities
a. Has the facility (non-DOD) participated in any
response actions (40 CFR 300.25)? Yes No
b. What is the facility's participation?
-------
G-2
c. What is the status of any response by regulatory agencies?
5. DOD Facility Sites:
a. (1) Has the preliminary assessment (40 CFR
300.64) been completed? Yes No
(2) Was the preliminary assessment adequate? Yes No
(3) Findings and status:
b. (!) Were immediate removals
conducted at any of the
(2) Was the removal adequate
data)?
(3) Findings and status:
(40 CFR 300.65)
sites? Yes No
(verification
Yes No
c. (1) Has there been an evaluation and determina-
tion of appropriate response-for a planned
removal and remedial action (40 CFR 300.66)? Yes No
(2) Was this evaluation and determination
adequate? Yes No
(3) Status:
-------
d. (1) Was a planned removal or remedial action
(40 CFR 300.67 and 68) taken? Yes No
(2) Was this planned removal or remedial action
successful? Yes No
(3) Status:
6. Comments:
-------
APPENDIX H
TSCA AND PCB CHECKLIST
-------
PCB COMPLIANCE INSPECTION REPORT
(40 CFR Part 761)
SECTION A. FACILITY SUMMARY
Name and address of facility (include county, state and zip code)
(Responsible Official) (Title) (Phone)
(Facility Representative) (Title) (Phone)
Type of facility (utility, salvage yard, etc.)
SECTION B. INSPECTION/REVIEW
Inspected by:
(Signature) (Agency and Date)
COMMENTS:
(Signature)
(Agency and Date)
-------
H -2
SECTION C. INVENTORY
1. As of July 2, 1978, did facility contain in-
service, stored for future use, or disposal:
a. 50 or more large high- or low-voltage
PCB capacitors?
Yes No N/A C/A *
b. One or more PCB transformers?
Yes No N/A C/A
c. 45 kgs (99.4 lbs.) or more PCB chemi-
cals, substances or mixtures?
Yes No N/A C/A
2. Disposition of PCB items at time of inspec-
tion:
Identify source of the above information (company records, manufacturer1s
labels, etc.)
N/A-Not applicable
C/A-Comments attached
-------
H-3
If any PCB items are not properly marked, describe deficiencies below.
Description must include information on amount of PCBs involved.
3. If company has PCB-contaminated transformers, explain how company
determined the transformers contained 50 to 500 ppm PCB.
4. Does the facility have any other PCB items
(electromagnets, hydraulic systems, etc.)? Yes No N/A C/A
If yes, list number and type of item; whether it is in-service, storage,
or sent to disposal; and if it is properly marked.
5. a. Were there observations of leaks or
spills or any sign of improper dis-
posal of PCB substances or mixtures. Yes No N/A C/A
b. If yes, document, sample and describe below. Description must
include information on amount of PCBs involved.
6. a. Was there any indication that water-
ways in the vicinity have been con-
taminated by spills, leaks or improper
di sposal?
Yes No N/A C/A
b. If yes, document, sample and describe below. Description must
include information on the amount of PCBs involved and the name of
the waterway.
-------
H-4
7. a. Were samples collected for analysis
of PCB residual concentration? Yes No N/A C/A
b. If yes, describe below.
SECTION D. STORAGE AND HANDLING
1. Location:
a. Does the facility have its own
storage site for PCB? Yes No N/A C/A
b. If the storage site is not within the boundary of the facility,
give the site's name and address.
2. Does storage site meet physical requirements
(761.42(a) - Physical Requirements)
a. Provide protection from rainfall?
b. Meet floor requirements with 6-inch
continuous curbing?
c. Meet containment volume requirements?
(1) What is total containment volume o
(Length x Width x Height)
(2) What is the internal volume of the largest PCB article or
container stored within the storage site?
Yes No N/A C/A
Yes No N/A C/A
Yes No N/A C/A
Yes No N/A C/A
storage site?
(3) What is the total internal volume of all PCB articles and
containers within the storage site?
Is item 1 greater than two
times item 2? Yes No N/A C/A
or
25% of item 3? Yes No N/A C/A
-------
H-5
d. (1) 15 the area within the curbed
area void of drains, valves,
expansion joints or other
openings? Yes No N/A C/A
(2) If no, document location of opening, drainage patch and ulti-
mate disposal location in logbook and describe below.
e. Is storage site located above the
100-year flood water elevation level? Yes No N/A C/A
f. Are storage areas adequately marked? Yes No N/A C/A
g. Any deficiencies in permanent storage facility must be documented
with photographs and described below. Description must include
amount of PCBs involved.
3. Containers:
a. Are all PCB items which are located
within storage areas dated
[761.42(c)(8)]? Yes No N/A C/A_
b. Do PCB containers comply with DOT
specifications except as noted in 3c
and 3d below [761.42(c)(6)]? Yes No N/A C/A
c. Are any non-liquid PCBs being stored
in containers larger than those speci-
fied in DOT regulations
[761.42(c)(6)]? Yes No N/A C/A_
(1) Do these containers provide as
much protection and have the
same strength as DOT containers? Yes No N/A C/A
d. Are any liquid PCBs being stored in
containers larger than those specified
in DOT regulations [761.42(c)(7)]? Yes No N/A C/A
(1) Do containers comply with OSHA
specif i cations? Yes No N/A C/A
-------
H-6
4. Storage Site Operations:
a. Are all PCB items arranged so they can
be located by date? [761.42(c)(8)] Yes No N/A C/A_
b. Do observations indicate good house-
keeping procedures? Yes No N/A C/A_
c. Is moveable equipment decontaminated
by approved procedures? Yes No N/A C/A_
d. Are PCB items stored and handled in
a manner that protects them from acci-
dental breakage or damage? Yes No N/A C/A_
5. Other Storage Areas:
a. Are any of the following temporarily
being stored outside the prescribed
area: [761-42(c)(l)]
1) Nonleaking PCB articles and PCB
equipment? Yes No N/A C/A_
Is date removed from service
rioted on the article or equipment? Yes No N/A C/A_
Have they been there fewer than
30 days? Yes No N/A C/A_
2) Leaking PCB articles and PCB
equipment placed in a non-
leaking PCB containers? Yes No N/A C/A_
Is the date removed from service
noted on the container? Yes No N/A C/A_
Have they been there fewer than
30 days? Yes No N/A C/A_
(3) Containers of liquid PCBs at con-
centrations of 50 to 500 ppm? Yes No N/A C/A_
Is SPCC plan available pertaining
to temporary storage area? Yes No N/A C/A_
Are containers marked to indicate
the liquid does not exceed 500 ppm? Yes No _N/A C/A_
Is the date removed from service
noted on the containers? Yes No N/A C/A
-------
H-7
Have containers been there fewer
than 30 days?
Are there any large high voltage
capacitors or PCB contaminated trans-
formers next to the storage site
[761.42(c)(2)]?
Are they on pallets?
Is there adequate space within the
storage site to contain 10% of the
volume of these capacitors and
transformers?
Yes No N/A C/A_
Yes No N/A C/A_
Yes No N/A C/A_
Yes No N/A C/A
Any deficiencies in temporary storage must be documented with
photographs and described below. Descriptions must include infor-
mation on the amount of PCBs involved.
SECTION E. DECONTAMINATION
1. Does the facility drain or cleanse PCB
transformers or other equipment containing
PCB substances or mixtures prior to dis-
posal or decontaminate movable equipment? Yes No N/A C/A_
2. Does the facility claim to have an
exception? Yes No N/A C/A
3. Is the drainage and solvent filling site
adequate to protect against spills and
leaks and consequent contamination of sur-
rounding areas and waterways? Yes No N/A C/A_
4. Do solvents to be used for removing PCBs
contain less than 50 ppm PCBs [761.42(a)]? Yes No N/A _C/A_
5. Was a sample of the solvent which was used
for PCB removal obtained? Yes No N/A C/A_
6. Was the rinse volume of the dilutant approxi-
mately equal to 10% of the container's total
volume [761.43(a)]? Yes No N/A C/A_
7. Are PCB transformers completely filled
with solvent and allowed to stand for at
least 18 hours before being drained
[761.10(b)(1)]? Yes No N/A C/A
-------
H-8
8. Are the drained PCB chemical substances
or PCB solvent mixtures properly disposed
of or stored? Yes No N/A C/A_
9. Are solvents or materials which have been
used for decontamination of PCB equipment
disposed of or stored in the same manner as
PCB mixtures? Yes No N/A C/A
10. If decontamination procedures were not
observed during inspection, did facility
representative demonstrate knowledge of
proper decontamination procedures? Yes No N/A C/A_
11. Does facility have written decontamination
procedures? Yes No N/A C/A_
12. Any deficiencies in the decontamination procedures must be described
below.
SECTION F. RECORDKEEPING
1. Do records indicate the date PCBs were:
a. Removed from service? Yes No N/A C/A
b. Placed in storage for disposal? Yes No N/A C/A
c. Placed in transport for disposal? Yes No N/A C/A
2. Do records indicate the quantity of the above items as follows:
a. The weights of PCBs and PCB items in
containers? Yes No N/A C/A
b. The contents of PCB containers? Yes No N/A C/A
c. The number of PCB transformers? Yes No _N/A C/A
d. The weight of PCBs in PCB transformers? Yes No N/A C/A
e. The number of PCB large, high- and low-
voltage capacitors? Yes No N/A C/A
3. Oo records indicate the quantities of PCBs remaining in service broken
down as follows:
-------
H-9
a. The weight of PCBs and PCB items in
PCB containers? Yes No N/A C/A_
b. The identification of the contents
in PCB containers? Yes No N/A C/A
c. The number of PCB transformers? Yes No N/A C/A_
d. The weight of PCBs in PCB transformers? Yes No N/A C/A_
e. The number of PCB large, high- and low-
voltage capacitors? Yes No N/A C/A_
4-.. a. Is the information requested in para-
graphs 1, 2 and 3 above compiled in an
annual document? (This document must
be prepared by July 1 and cover the
previous calendar year.) Yes No N/A C/A_
b. List years for which annual documents
are available.
5. Any deficiencies in recordkeeping must be described below including
information on amount of PCBs involved.
6. If owners or operators maintain more than
one facility that contains PCBs in the
quantities prescribed in paragraph C 1,
are records and documents kept at a single
location? Yes No N/A C/A
If yes, list location.
7. Do records provide information on a PCB
disposal facility? Yes No N/A C/A
If yes, list name, location and type of facility (i.e., incinerator,
boiler, landfill,~etc.
-------
10
Section G. DISPOSAL
1. Are PCB articles or containers, which were
stored for disposal after January 1, 1983,
disposed of within 1 year? Yes No
2. Were items stored for disposal before
January 1, 1983? Yes No
a. Were they disposed of by January 1, 1984? Yes No
3. What items are disposed and state the disposal methods?
-------
Company Name
INSPECTION CHECKLIST FOR PCB INCINERATORS
Location
Incinerator Plant
Date of Inspection
Type of Waste Burned
Parameters
Requirement
Actual
Combustion criteria
Combustion Efficiency
CE =
CO,
C02 + CO
X 100
Rate and quantity of
PCBs fed to incinerator
Temperatures of the
incineration process
Flow of PCBs to
inci nerator
Excess 02 monitor
Calibration
Carbon monoxide
Monitor calibration
Draft of Incinerator
Particulate Emissions
Maintenance of Records
Opacity of stack
Emissions
Water scrubbers for
HC1 control
>3% excess oxygen in stack gas
2-sec. dwell 0 1200° C (±100° C)
or 1% sec. dwell @ 1600° C
(±100° C) and 2% excess oxygen
in stack gas
at least 99.9%
Recorded at regular interval
at least every i5 minutes
Continuously measured and
recorded
Stops automatically when
temperature drops below
that required under
combustion criteria
Must be calibrated every
24 hrs. when burning PCBs
Must be calibrated every
24 hrs. when burning PCBs
Negative
State permit or 0.08 gr/dscf
@ 12% C02
761.45
(b) dates and amts. of PCBs
rec'd, disposed & stored.
(c) dates, amts., combustion
criteria.
(f) documents & corres. from
state and local agencies.
State permit (Method 9)
99.% (state-of-art)
0 =
Dwel 1 =
Temp =
%
sec.
° C
Time of measurement
C02 = %
CO = ppm
CE = %
Feed rate =
PCB cone =
PCB feed
rate =
lb/hr
lb/hr
Minimum temperature of
previous 48 hrs.
Cut-off at following
Temp = 0 F
02 = %
CD - ppm
Calibration:
Date
Time
Concentration =
Calibration
Date
Time
Concentration =
Where measured:
Draft = inches Hz0
Particulate Emissions
lb/hr
gr/dscf
12% C02
Results of Last Test:
Date
removal eff = %
HC1 emissions lb/hr
Storage,
decontamination
and marking
761.42 - Storage and disp.
761.43 - Decontamination
761.44 - Marking formats
-------
APPENDIX I
TSCA CONFIDENTIAL BUSINESS INFORMATION PROCEDURES AND FORMS
-------
CONFIDENTIALITY NOTES AND DISCUSSIONS
The TSCA Notice of Inspection [Figure I~l] and Inspection Confidentiality
Notice [Figure 1-2] are presented to the facility owner or agent in charge
during the opening conference. These notices inform facility officials of
their right to claim as confidential business information any information
(documents, physical samples or other material) collected by the inspector.
Authority to Make Confidentiality Claims
The inspector must ascertain whether the facility official to whom the
notice were given has the authority to make business confidentiality claims
for the company. The facility official's signature must be obtained at the
appropriate places on the notices certifying that he does or does not have
such authority.
The facility owner is assumed to always have the authority to
make business confidentiality claims. In most cases, it is
expected that the agent in charge will also have such authority.
It is possible that the officials will want to consult with their
attorneys (or superiors in the case of agents in charge) regard-
ing this issue.
If no one at the site has the authority to make business confi-
dentiality claims, a copy of the TSCA Inspection Confidentiality
Notice and Notice and Declaration of Confidential Business Infor-
mation form [Figure 1-3] are to be sent to the chief executive
officer of the firm within 2 days of the inspection. He will
then have 7 calendar days in which to make confidentiality claims.
The facility official may designate a company official, in addi-
tion to the chief executive officer, who should also receive a
copy of the notices and any accompanying forms.
-------
1-2
Figure 1-1
v/EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
NOTICE OF INSPECTION
Form Approved
OMB No. 2070-0007
Approval expires 8-31-85
1. INVESTIGATION IDENTIFICATION
2. TIME
DATE
INSPECTOR NO. DAILY SEQ. NO
3. FIRM NAME
4. INSPECTOR ADDRESS
5. FIRM ADDRESS
REASON FOR INSPECTION
Under the authority of Section 11 of the Toxic Substances Control Act:
CD For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establish-
ment, facility, or other premises in which chemical substances or mixtures or articles containing same are manufactured, proc-
essed or stored, or held before or after their distribution in commerce (including records, files, papers, processes, controls, and
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same in connection
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether the
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such premises or
conveyance have been complied with.
~ In addition, this inspection extends to (Check appropriate blocksj:
Da. Financial data
~ B. Sales data
CI C. Pricing data
CH 0. Personnel data
dl E. Research data
The nature and extent of inspection of such data specified in A through E above is as follows;
INSPECTOR SIGNATURE
RECIPIENT SIGNATURE
NAME
NAME
TITLE
~ ATE SIGNED
TITLE
OATE SIGNED
CD A Cr
INSPECTION FILE
-------
Figure 1-2
1-3
&EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
TSCA INSPECTION CONFIDENTIALITY NOTICE
Form Approved
OMfl No. 2070-0007
Approval expire* 8-31-8S
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
DATE
INSPECTOR NO.
DAILYSEQ.NO.
a. . gSPECTOR NAME
A. FIRM ADDRESS
S VSPECTOR ADDRESS
6. CHIEF EXECUTIVE OFFICER NAME
7. TITLE
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that SPA will receive public requests for release of the
information obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act (FOIA), 5 USC 552; EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act (TSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of the
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the information collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to bB confidential business infor-
mation. If you assert a CBI claim, EPA wilt disclose the information
only to the extent, and by means of the procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you have claimed as confidential business information.
A confidential business information (CBI) claim may be asserted at any
time. You may assert a CBI claim prior to, during, or after the infor-
mation is collected. The declaration form was developed by the Agency
to assist you in asserting a CGI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential business information," it is
not necessary for you to use this form. The inspector will be glad to
answer any questions you may have regarding the Agency's CBt
procedures.
While you may claim any collected information or sample as confiden-
tial business information, such claims are unlikely to be upheld if they
are challenged unless the information meets the following criteria:
1. Your company hat taken measures to protect the confi-
dentiality of the information, and it intends to continue
to take such measures.
3.
4.
The information is not, and has not been, reasonably obtainable
without your company's consent by other persons (other than
governmental bodies) by use of legitimate means (other than
discovery based on showing of special need in a judicial or
quasi-judicial proceeding).
The information is not publicly available elsewhere.
Disclosure of the information would cause substantial
harm to your company's competitive position.
At the completion of the inspection, you will be given a receipt for all
documents, samples, and other materials collected. At that time, you
may make claims that some or all of the information is confidential
business information.
If you are not authorized by your company to assert a CBI claim, this
notice will be sent by certified mail, along with the receipt for docu-
ments, samples, and other materials to the Chief Executive Officer of
your firm within 2 days of this date. The Chief Executive Officer must
return a statement specifying any information which should receive
confidential treatment.
The statement from the Chief Executive Officer should be addressed
to:
Ms. Geraldine Hilden
National Enforcement Investigations Center
Bldg. 53, Box 25227
Denver Federal Center, Denver, CO 80225
and mailed by registered, return-receipt requested maii within 7 calen-
dar days of receipt of this Notice. Claims may be made any time
after the inspection, but inspection data will not be entered into the
special security system for TSCA confidential business information
until an official confidentiality claim is made. The data will be handled
under the agency's routine security system unless and until a claim is
made.
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE:
I have received and read ihe notice
If there is no one on the premises of the facility who is authorized to make
business confidentiality claims for the firm, a copy of this Notice and other
inspection materials will be sent to the company's chief executive officer. 11
there is another company official who should also receive this information,
please designate below.
GNATURE
NAME
NAME
TITLE
TITLE
~ ATE SIGNED
ADDRESS
EPA Form 7740-4(12-82)
INSPECTOR'S FILE
-------
I_4 Figure 1-3
US ENVIRONMENTAL PROTECTION AGENCY
J| WASHINGTON, OC 20460
yBFfa TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
Form Approved
OMB No. 2070-0007
Approval expireI 8-31-85
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
DATE 1 INSPECTOR NO.
DAILY SEQ. NO.
3. INSPECTOR ADDRESS
4. FIRM ADDRESS
INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION
NO.
DESCRIPTION
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would causa substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE
CLAIMANT SIGNATURE
1
NAME
NAME
TITLE
~ ATE SIGNED
TITLE
INSPECTION FILE
-------
1-5
Confidentiality Discussion
Officials should be informed of the procedures and requirements that
EPA must follow in handling TSCA confidential business information. The
inspector should explain that these procedures were established to protect
the companies subject to TSCA and cover the following points during the
discussion.
Data may be claimed confidential business information during the
closing conference if a person authorized to make such claims is
onsite at the facility.
It is suggested that a company official accompany the inspector
during the inspection to facilitate designation (or avoidance, if
possible) of confidential business data.
A detailed receipt for all documents, photographs, physical
samples, and other materials [Figure 1-4] collected during the
inspection will be issued at the closing conference.
An authorized person may make immediate declarations that some or
all of the information is confidential business information. This
is done by completing the Declaration of Confidential Business
Information form. Each item claimed must meet all four of the
criteria shown on the TSCA Inspection Confidentiality Notice.
If no authorized person is available onsite, a copy of the notice*
along with the Receipt for Samples and Documents, will be sent by
certified, return-receipt-requested mail to the Chief Executive
Officer of the firm and to another company official, if one has
been designated.
Four copies are made of the Declaration of Confidential Information
m and distributed to:
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1-6
Facility owner or agent in charge
Other company official (if designated)
Document Control Officer
Inspection report
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Figure 1-4
1 US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20490
' TOXIC SUBSTANCES CONTROL ACT
Vrtlrt RECEIPT FOR SAMPLES AND DOCUMENTS
Form Approvtd
OMfl No. 2010-0007
Approval ixplrtt 8-318S
1. INVESTIGATION IDENTIFICATION
2. FIRM NAME
DATE IINSPECTOR NO.
DAILY SEQ. NO.
3. INSPECTOR ADDRESS
4. FIRM AODRESS
The documents and samples of chemical substances and/or mixtures described below were collected in connection with the
administration and enforcement of the Toxic Substances Control Act.
RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
NO.
DESCRIPTION
OPTIONAL:
DUPLICATE OH SPLIT SAMPLES: REQUESTED AND PROVIDED O NOT REQUESTED O
INSPECTOR SIGNATURE
RECIPIENT SIGNATURE
NAME
NAME
TITLE
DATE SIGNED
TITLE
DATfa sIGNcU
EPA Form 7740-1 (12-82)
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APPENDIX J
PESTICIDE CHECKLIST
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PESTICIDE INSPECTION CHECKLIST
INTERVIEW/RECORDS
1. Are pesticides used at the facility? Yes No
a. Circle general types used:
Algacides Insecticides Punqicides Herbicides Rodenticides
Other
2. Are any restricted use pesticides used
at this facility? Yes No
3. Are pesticides applied by facility personnel? Yes No
4. Are pesticides handlers certified? Yes No
a. Circle type of certification:
EPA State DOD Other
b. Are pesticide handlers authorized for
restricted use pesticides? Yes No
c. Are licenses/certificates current (not expired)? Yes No
5. Has the facility pesticide program been inspected
before? Yes No
a. Circle by whom:
EPA State DOD Other
b. General results
6. Does the facility have application records? Yes No
7. Has the facility filed restricted use pesticide
reports? Yes No
8. Does the facility have inventory records? Yes No
9. Are target pests indicated on application records? Yes No
a. Are the pesticides used registered for use
against the target pest? Yes No
10. Are pesticide handlers training records current? Yes No
a. Types of training
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J-2
STORAGE
1. Is the storage area located on a flood plain? Ves No
2. Is the storage area fenced? _ Yes No
3. Is the storage area kept locked? Yes No
4. Are pesticides stored under cover? Yes No
5. Is the area well ventilated? Yes No
6. Is the area posted with pesticide or chemical warning
signs (i.e. , OANGER - POISON)? Yes No
7. Are pesticides separated by type? Yes No
8. Are the pesticides properly labeled? Yes No
9. Are pesticides stored in other than original
containers? Yes No
a. Explain, if yes.
MIXING/LOADING
1. Is there a mixing/loading area? , Yes No
2. Is the mixing/loading equipment functional? ^ Yes No
3. Does the equipment help reduce the handlers exposure
to pesticide? Yes No
4. Are label directions followed? Yes No
5. Is protective clothing worn by handlers? Yes No
6. Does protective clothing look used? Yes No
7. Is there a mechanism for rinsing containers? Yes No
8. How is rinse liquid disposed of?
9. Is spray equipment cleaned between applications?
a. Hovy is rinse liquid disposed?
Yes No
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J-3
CONTAINER DISPOSAL
1. Are label directions followed? Yes No
2. Are empty containers triple rinsed? Yes No
3. Are containers offered for scrap or recycle? Yes No
4. Are containers punctured or crushed to help prevent
improper reuse? Yes No
5. Are drums given away for burn barrels, etc.? Yes No.
6. Is there a container disposal site at the facility? Yes No
7. Is the site fenced and locked? Yes No
8. Are there pesticide or chemical warning signs posted? Yes No
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APPENDIX K
WATER SUPPLY CHECKLIST
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WATER SUPPLY CHECKLIST
2.
3.
4.
Oate of Inspection
Community Noncommunity
Basic Information
Supply Name
County
I.D. Number
Phone
Establishment
No. of Service Connections
Period of Operation: 12 month Seasonal
If Seasonal: From To
Pop. Served
Surface - Other community system
Other community system name
Wei 1 s
Spring surface
Wells (source of information)
Well log (attached)
Year installed
Casing Diameter
Distance to potential contamination
Controlled access to well?
If yes, distance
Comments:
in. Depth
"ft. Source"
ft.
Yes
No
Well Details:
Well house
Heated, lighted
Casing above grade
Subject to flooding
Pump•Detai Is:
Brand and Model
Capacity
Yes
No
Well seal
Yes
No
Yes
No
Water level
device
Yes
No
Yes
No
Grouted
Yes
No
Yes
No
Casing vent
Yes
No
Horsepower
gpm at
ft. head
Type: (Circle)
Submersible
Vertical turbine
Deep well jet
Shallow well jet
Shallow well centrifugal
Pump removal provision
Pump to waste piping
Capacity adequate
Sample tap
Comments
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K-2
5. Other Source Spring Surface source
Security (signs, fences, etc.)
Minimum available flow gpm Measured Estimate
Sources of contamination
Source area ownership
Springs
Fencing
Yes
No
Screened Overflow
Yes
No
Surface runoff
Hatch and curbing
Yes
No
ditch
Yes
No
Bottom drain
Yes
No
Spri ngbox
Yes
No
Comments:
Surface Source
Impoundment
Yes
No
Spi1Iway
Yes
No
Diversion dam
Yes
No
Intake screens
Yes
No
Infi1tration
Drain
Yes
No
gal 1ery
Yes
No
Source name:
Comments:
Storage
General: Volume gallons Type:
Reservoir Hydro-pneumatic
Separate inlet/
outlet
Hatch
Water level
indicator
Yes
Yes
Yes
No
No
No
Drain to
daylight
Flap valve
Booster pump
Yes No
Yes No
Yes No
Reservoir: Material
Overflow
Screened vent
Covered
Hydro-pneumatic tank: Operating range
7. Distribution System
Types of piping
Yes No
Yes No
Yes. No
Adequate pressure (20)
Flushi ng program
Yes No
Yes No
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K-3
8. Chi or illation: Continuous chlorination? Yes No
Sodium hypochlorite
Yes
No
Proportional
Calcium hypochlorite
Yes
No
to flow
Yes
No
Gas Chlorine
Yes
No
DPD chlorine
test kit
Booster pump
Yes
Yes
No
No
Type of chlorinator:
Contact time provided by:
Volume of contact chamber:
Estimated maximum system flow
Contact time - A/B -:
Commments:
gallons (A)
(B)
mi nutes
9. Monitoring; Type of system (check)
Groundwater
Surface water
Purchase from other water system
Sampling
Required Current? Met MCL's?
Parameter Frequency Yes No Yes No
Coliform bacteria
Turbidity
Inorganics (nitrate) ,
Radiologic
contaminants
Organics
Other
Comments:
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