Hazardous Waste Generator's Checklist - Web Page 1 of 2

Verify that for containers that hold a compressed gas, the pressure in the container approaches atmosphere.

Verify that for a container or inner liner that held an acute hazardous waste listed in Appendix E, one of the following is done:

Fire hydrants or other source of water (reservoir, storage tank, etc.) with adequate volume and pressure, foam producing equipment, or automatic sprinklers, or water spray systems.

Determine if equipment is tested and maintained as necessary to insure proper operation in an emergency.

Verify that sufficient aisle space is maintained to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the operation.

Review procedures employed by facility management to familiarize police, fire departments, and emergency response teams with the layout of the facility, properties of the waste being handled, and general operations as appropriate for the type of waste and potential need for such services.

Review procedures employed by facility management to familiarize local hospitals with the site and types of injuries that could result in an emergency as appropriate for the type of waste and potential need for such services.

(NOTE: Where state or local authorities decline to enter into arrangements, the facility must document this refusal in the operating record.)HW.32. SQGs must conduct weekly inspections of container storage areas (40 CFR 262.34(d)(2) and 265.174).Verify that inspections are conducted at least weekly to look for leaking containers and signs of deterioration of containers.Disposal of Restricted WastesHW.33. SQGs must test their wastes or use process knowledge to determine if they are restricted from land disposal (40 CFR 268.7(a)(1)).Determine whether the generator determines if wastes have to be treated prior to disposal.

Determine if the facility generates restricted wastes (see Appendix G) by reviewing test results or reviewing procedures employed by facility management where process knowledge was applied in making the waste determinations.HW.34. When an SQG is managing a restricted waste, a written notice must be issued to the TSDF of the appropriate treatment standards and prohibition levels (40 CFR 268.7(a)(2) through 268.7(a)(4), 268.7(a)(10)).(NOTE: EPA is changing the notification requirement under 40 CFR 268.7 to a one-time notification and certification if the composition of the wastes, the process generating the wastes, and the treatment facility receiving the waste do not change (see FR Vol. 62, No. 91, May 12, 1997; pg. 26004).)HW.34 (continued)Verify that, for waste or soil which does not meet the applicable treatment standards or exceeds the applicable prohibition levels, the notice is issued and includes:

- The EPA hazardous waste code and manifest numbers

- The waste is subject to the LDRs and the constituents of concern for F001-F005 and F039 and underlying hazardous constituents in characteristic wastes, unless the waste will be treated and monitored for all constituents (If all constituents will be treated and monitored, there is no need to put them all on the LDR notice.)

- Whether the waste is a nonwastewater or wastewater

- The subcategory of the waste determination, if applicable

- For hazardous debris, when treating with the alternative treatment technologies provided in 40 CFR 268.45, the contaminants subject to treatment, as described in 268.45(b), and an indication that these contaminants are being treated to comply with 268.45.

- For contaminated soil subject to LDRs provided in 40 CFR 268.49(a), the constituents subject to treatment described in 268.49(d), and the following statement: "This contaminated soil [does/does not] exhibit a characteristic of hazardous waste and is [subject to/complies with] the soil treatment provided in 268.49(c) or the universal treatment standards."

Verify that, for waste or contaminated soil which meets the treatment standard at the original point of generation, the notice includes:

(NOTE: SQGs with tolling agreements are required to comply with notification and certification requirements for the initial shipment of waste subject to the agreement. The SQG will retain an on-site copy of the notification and certification along with the tolling agreement for at least 3 years after the termination or expiration of the agreement.)HW.35. SQGs that are managing prohibited wastes in tanks, containers, or containment buildings and treating the waste to meet applicable treatment standards, must develop and follow a written waste analysis plan (40 CFR 268.7(a)(5) and 268.7(a)(10)).Verify that the plan describes the procedures that the generator will follow in order to comply with treatment standards.

(NOTE: SQGs treating hazardous debris under the alternative treatment standards are not required to conduct waste analysis.)

Verify that the plan is kept on-site and:

(NOTE: SQGs with tolling agreements are required to comply with notification and certification requirements for the initial shipment of waste subject to the agreement. The SQG will retain an on-site copy of the notification and certification along with the tolling agreement for at least 3 years after the termination or expiration of the agreement.)HW.36. SQGs are required to keep specific documents pertaining to restricted wastes on-site (40 CFR 268.7(a)(4) through 268.7(a)(7) and 268.7(a)(10)).Verify that if the facility is using generator knowledge to determine whether a waste or contaminated soil meets land disposal restriction requirements, the supporting data used in making this determination is retained on-site in the facility operating files.

Verify that if the facility has determined whether a waste is restricted using appropriate test methods, the waste analysis data is retained on-site in the files.

Verify that if the facility has determined that it is managing a restricted waste that is excluded from the definition of a hazardous waste or solid waste or exempt from RCRA Subtitle C, a one-time notice is placed in the facility’s files stating that the generated waste is excluded.

Verify that a copy of all notices, certifications, waste analysis data and other documentation is kept for at least three years from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal.

Verify that SQGs with tolling agreement retain the agreement and copies of notification and certification for at least three years after the agreement expires.HW.37. The storage of hazardous waste that is restricted from land disposal is not allowed unless specific conditions are met (40 CFR 268.50).Verify that land disposal restricted waste is not stored at the facility unless the SQG is storing the wastes in tanks, containers, or containment buildings on-site only for the purpose of accumulating enough quantity of hazardous waste to facilitate proper recovery, treatment, or disposal and all appropriate standards for containers, tanks, and containment buildings are met.

(NOTE: The prohibition on storage does not apply to hazardous wastes that have met treatment standards.)

Verify that liquid hazardous wastes containing PCBs at concentrations greater than 50 ppm are stored at a site that meets the requirements of 40 CFR 761.65(b) (see Toxic Substances Control Act (TSCA)) and is removed from storage within one year of the date it was first placed into storage.Large Quantity Generators (LQGs)GeneralHW.38. A generator that generates, transports, or handles hazardous wastes must obtain an EPA identification number (40 CFR 262.12(a) and 262.12(b)).Examine documentation from EPA for the facility’s generator identification number.

Verify that the correct identification number is used on all appropriate documentation (i.e., manifests).HW.39. Generators may accumulate hazardous waste on-site for 90 days or less without a permit or interim status provided they meet certain conditions (40 CFR 262.34(a)(2), 262.34(a)(3) and 262.34(b)).Inspect each 90 day storage area and interview the storage area manager. Verify that:

- The date upon which accumulation begins is clearly marked and visible for inspection

- The recorded start date indicates no container or tank has been accumulating a hazardous waste longer than 90 days (unless granted a 30 day extension)

- Each container and tank is labeled or marked clearly with the words HAZARDOUS WASTE.

(NOTE: For a generator the accumulation start date begins when the first waste is poured/placed into the waste container, except at satellite accumulation points.)

(NOTE: A generator who meets these standards is exempt from meeting the closure requirements outlined in 40 CFR 265.110 through 265.156, except for 265.111 and 265.114.)

(NOTE: A generator who accumulates hazardous waste for more than 90 days (without an extension), is subject to all TSDF and permitting requirements.)HW.40. Generators must not offer their waste to transporters or TSDFs that have not received an EPA identification number (40 CFR 262.12(c)).Verify that all transporters of hazardous wastes and TSDFs used by the generator have an EPA identification number by examining facility records pertaining to these services. Examples of such records could include sales agreements or vendor contracts. Auditors could also contact the state regulatory agency or local EPA regional office to confirm that these vendors have the appropriate EPA identification number.HW.41. Generators who shipped hazardous waste off-site to a TSDF must submit a biennial report to the regulatory agency by 1 March of even numbered years (40 CFR 262.40(b) and 262.41(a)).Verify that the biennial report (EPA Form 8700-13A) is complete and was submitted in a timely manner.

Verify that copies are kept for three years.

(NOTE: Reporting for exports of hazardous waste is covered under the import/export section of this protocol.)

(NOTE: Periods of retention of records may be extended automatically during the course of any unresolved enforcement action or at the request of the regulatory agency.)HW.42. Generators are required to use manifests, file manifest exception reports, and maintain records (40 CFR 262.20, 262.40(a), 262.40(b), 262.40(d), and 262.42(a)).Verify that manifests are used when shipping the waste off-site.

Verify that exception reports were filed with the regulatory agency when a copy of the manifest was not received within 45 days of the waste being accepted by the initial transporter.

Verify that manifests and exception reports are kept for three years.

(NOTE: Periods of retention for reports may be extended automatically during the course of any unresolved enforcement action.)HW.43. Generators are required to keep records of waste analyses, tests, and waste determinations (40 CFR 262.40(c)).Verify that the appropriate records are kept for three years from the date the waste was last sent to the on-site or off-site TSDF.

(NOTE: Periods of retention for reports may be extended automatically during the course of any unresolved enforcement action or at the request of the regulatory agency.)HW.44. Generator storage areas must be designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion, or any unplanned release of hazardous waste or constituents which could threaten human health or the environment (40 CFR 262.34(a)(4) and 40 CFR 265.30 through 265.37).Determine if the following required equipment is easily accessible and in working condition at the storage area (unless none of the hazards posed by the waste managed at the facility would require the particular kind of equipment):

- Internal communications or alarm system capable of providing immediate emergency instruction to facility personnel

- A telephone or hand-held two way radio capable of summoning emergency assistance

- Portable fire extinguishers and fire control equipment, including special extinguishing equipment (foam, inert gas, or dry chemicals)

- Spill control equipment

- Decontamination equipment

- Fire hydrants or other source of water (reservoir, storage tank, etc.) with adequate volume and pressure, foam producing equipment, or automatic sprinklers, or water spray systems.

Determine if equipment is tested and maintained as necessary to insure proper operation in an emergency.

Verify that sufficient aisle space is maintained to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the operation.

Review procedures employed by facility management to familiarize police, fire departments, emergency response teams with the layout of the facility, properties of the waste being handled, and general operations as appropriate for the type of waste and potential need for such services.

Review procedures employed by facility management to familiarize the hospital with the site and the types of injuries that could result in an emergency as appropriate for the type of waste and potential need for such services.

(NOTE: Where state or local authorities decline to enter into arrangements, the facility must document this refusal in the operating record.)Personnel TrainingHW.45. All facility personnel who handle hazardous waste must meet certain training requirements (40 CFR 262.34(a)(4); 40 CFR 265.16(a) through 265.16 (c)).Ensure that the facility personnel complete classroom instruction or on-the-job training as set forth below:

Verify that the training program is directed by a person trained in hazardous waste management procedures and that the program includes instruction which teaches facility personnel hazardous waste management procedures relevant to positions in which they are employed.

Although not specified by the regulations, examples of training topics for hazardous waste management procedures could include (but would not be limited to) the following:

Verify specifically that waste storage area managers and hazardous waste handlers have been trained.HW.46. Training records must be maintained for all facility staff who manage hazardous waste (40 CFR 262.34(a)(4); 40 CFR 265.16(d) and 265.16(e)).Verify that training records include the following by examination:

- Job title and description for each employee by name

- Written description of how much training each position will obtain

- Documentation of training received by name.

Determine if training records are retained for three years for former employees.

Determine if training records on current employees are maintained. (NOTE: Training records on current employees must be maintained until the closure of the facility.)Contingency Plans and Emergency CoordinatorsHW.47. Generators must have a contingency plan (40 CFR 262.34(a)(4) and 40 CFR 265.50 through 265.54).(NOTE: Generating activities may be addressed in the facility's SPCC plan or other emergency plan, or if none exists, in a separate contingency plan.)

Verify that the contingency plan is designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents.

Verify that the plan includes the following:

- A description of actions to be taken during an emergency

- A description of arrangements made with local police departments, fire departments, hospitals, contractors, and state and local emergency response teams as appropriate

- Names, addresses, and phone numbers of all persons qualified to act as emergency coordinator (if more than one name is listed, the plan must identify one person as the primary emergency coordinator with other persons listed in the order in which they will assume responsibility as an alternate)

- A list of all emergency equipment at the facility and where this equipment is required, located, and what it looks like

- An evacuation plan for facility personnel where there is a possibility evacuation would be needed.

Verify that copies of the contingency plan and all revisions are maintained at the facility and also have been submitted to organizations which may be called upon to provide emergency services.

Verify that the contingency plan is routinely reviewed and updated, especially when:

The applicable regulations are revisedThe plan fails in an emergencyThe facility changes (e.g., in its design, construction, operation, maintenance) in a way that materially increases the potential for fires, explosions, or oreleases of hazardous constituents or changes the response necessary in an emergencyThe list of emergency coordinators changesThe list of emergency equipment changes.HW.48. Each generator must have an emergency coordinator on the facility premises or on call at all times (40 CFR 262.34(a)(4) and 40 CFR 265.55).Verify that, at all times, there is at least one employee at the facility or on call with responsibility for coordinating all emergency response measures.

Verify that the emergency coordinator is thoroughly familiar with the facility, including all operations and activities at the facility, the location of all records within the facility, the facility layout, the characteristics of the waste handled, and the provisions of the contingency plan. In addition, verify the emergency coordinator has the authority to commit the resources needed to carry out the contingency plan.HW.49. Emergency coordinators at generators must follow certain emergency procedures whenever there is an imminent or actual emergency situation (40 CFR 262.34(a)(4) and 40 CFR 265.56(a) through 265.56(i)).Verify that the emergency coordinator is required to follow these emergency procedures:

- Immediately activate facility alarms or communication systems and notify appropriate facility, state, and local response parties

- Identify the character, exact source, amount, and a real extent of any released materials

- Assess possible hazards to human health or the environment, including direct and indirect effects (e.g., release of gases, surface runoff from water or chemicals used to control fire or explosions, etc.)

Take all reasonable measures necessary to ensure that fires, explosions and releases do not occur, recur, or spread to other hazardous waste at the facility. These measures must include where applicable:

-- stop processes and operations at the facility when necessary to prevent fires, explosions, or further releases

-- collect and contain the released waste

-- remove or isolate containers when necessary

- Monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment whenever appropriate

Provide for treatment, storage, or disposal of recovered waste, contaminated soil, or surface water, or other material immediately after emergencyEnsure that no waste that may be incompatible with the released material is treated, stored, or disposed of until cleanup is completed

- Ensure that all emergency equipment is cleaned and fit for its intended use before operations are resumed

- Notify EPA, and appropriate state and local authorities that the facility is in compliance with 40 CFR 265.56(h) before operation resumes.

HW.50. Generator operators must record the time, date, and details of any incident that requires implementing the contingency plan (40 CFR 262.34(a)(4) and 40 CFR 265.56(j)).Review facility operating records to determine if incidents have been recorded and corrective actions taken.

Verify that written reports have been submitted to the regulatory agency within 15 days after the incident.ContainersHW.51. Empty containers at generators previously holding hazardous wastes must meet the regulatory definition of empty before they are exempted from hazardous waste requirements (40 CFR 261.7).Verify that for containers or inner liners holding hazardous wastes:

- Wastes are removed that can be removed using practices commonly employed to remove materials from that type of container (e.g., pouring, pumping, and aspirating), and

- No more than 2.5 cm (1 in.) of residue remains, or

- If the container is less than or equal to 110 gal. (416.40 L), no more than 3 percent by weight of total container capacity remains, or

- When the container is greater than 110 gal. (416.40 L), no more than 0.3 percent by weight of the total container capacity remains.

Verify that for containers that held a compressed gas, the pressure in the container approaches atmosphere.

Verify that for a container or inner liner that held an acute hazardous waste listed in Appendix E, one of the following is done:

- It is triple rinsed

- It is cleaned by another method identified through the literature or testing as achieving equivalent removal

- The inner liner is removed.

Verify that the rinse water has been tested.HW.52. Containers used to store hazardous waste at generators must be in good condition and not leaking (40 CFR 262.34(a)(1)(i) and 265.171).Verify that containers are not leaking, bulging, rusting, damaged or dented.

Verify that waste is transferred to a new container or managed in another appropriate manner when necessary.HW.53. Containers used at generators must be made of or lined with materials compatible with the waste stored in them (40 CFR 262.34(a)(1)(i) and 265.172).Verify that containers are compatible with waste. For example, check that strong caustics and acids are not stored in metal drums.HW.54. Containers must be closed during storage and handled in a safe manner at generators (40 CFR 262.34(a)(1)(i) and 265.173).Verify that containers are closed except when it is necessary to add or remove waste (check bungs on drums, look for funnels).

Verify that handling and storage practices do not cause damage to the containers or cause them to leak.HW.55. The handling of incompatible wastes, or incompatible wastes and materials in containers at generators must comply with safe management practices (40 CFR 262.34(a)(1)(i) and 265.177).Verify that incompatible wastes or incompatible wastes and materials are not placed in the same containers unless it is done so that it does not:

- Generate extreme heat or pressure, fire, or explosion, or violent reaction

- Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health

- Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions

- Damage the structural integrity of the device or facility

- By any other like means threaten human health or the environment

(NOTE: Incompatible wastes, as listed in Appendix F, should not be placed in the same drum.)

Verify that hazardous wastes are not placed in an unwashed container that previously held an incompatible waste or material.

Verify that containers holding hazardous wastes incompatible with wastes stored nearby in other containers, open tanks, piles, or surface impoundments are separated or protected from each other by a dike, berm, wall, or other device.HW.56. Containers used to store hazardous waste at generators should be managed in accordance with specific management practices (MP).Verify the following by inspecting container storage areas:

- Containers are not stored more than 2 high and have pallets between them

- Containers of highly flammable wastes are electrically grounded (check for clips and wires and make sure wires lead to ground rod or system)

- At least 3 ft. (0.91 m) of aisle space is provided between rows of containers.HW.57. Containers with design capacities greater than 0.1 m³ [~26 gal.] and less than or equal to 0.46 m³ [~122 gal.] into which hazardous waste is placed are required to meet specific design and operating standards (40 CFR 262.34(a)(1)(i), 265.178, 265.1087(a) through 265.1087(b)(1)(i), and 265.1087(c)).(NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all the hazardous waste entering the container meets one of the following (40 CFR 265.1083(c)):

- The average VO concentration of the hazardous waste at the point of waste origination is less than 500 ppmw

- The organic content of the hazardous waste entering the waste management unit has been reduced by an organic destruction or removal process

- The waste meets the numerical concentration limits for organic hazardous constituents as specified in 40 CFR 268.40 or has been treated by the treatment technology established by the regulatory agency for the waste in 268.42(a) or an equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

(NOTE: Standards for containers used in waste stabilization processes (40 CFR 265,1087(b)(2)) are in checklist item HW.59.)

Verify that, for containers with a design capacity greater than 0.1 m³ [~26 gal.] and less than or equal to 0.46 m³ [~122 gal.], air emissions are controlled according to the following Container Level 1 standards:

- A container that meets applicable U.S. DOT regulations on the packaging of hazardous materials for transportation

- A container that is equipped with a cover and closure devices that form a continuous barrier over the container openings so that when the cover and closure devices are secured in the closed position there are not visible holes, gaps or other open spaces into the interior of the container

- An open-top container in which an organic vapor suppressing barrier is placed on or over the hazardous waste in the container so that no hazardous waste is exposed to the atmosphere.

Verify that when a container using Level 1 standards, other than DOT approved containers, is used, it is equipped with covers and closure devices composed of suitable materials to minimize exposure of the hazardous waste to the atmosphere and to maintain the equipment integrity for as long as it is in service.

Verify that, whenever waste is in a container using Level 1 controls, covers and closure devices are installed and closure devices are secured and maintained in the closed position except as follows:

- Opening of a closure device or cover is allowed for adding waste or other material to the container as follows:

-- when the container is filled to the intended final level in one continuous operation, the closure device is secured in the closed position and the cover is installed at the conclusion of the filling operation

-- when discrete batches or quantities of material are added intermittently to the container over a period of time, the closure devices are secured in the closed position and covers installed upon either the container being filled to the intended final level, the completion of a batch loading after which no additional material will be added to the container within 15 minutes, the person performing the loading operation leaving the immediate vicinity of the container, or the shutdown of the process generating the material being added to the container, whichever condition occurs first.

HW.57. (continued)

- Opening of a closure device or cover is allowed for removing the hazardous waste as follows:

-- in order to meet the requirements for an empty container

-- when discrete quantities or batches of material are removed from the container but the container is not empty, the closure devices will promptly be returned to the closed position and the covers installed upon completion of batch removal after which no additional material will be removed within 15 minutes or the person performing the unloading leaves the immediate vicinity, whichever condition occurs first

- Opening of a closure device or cover is allowed when access inside the container is needed to perform routine activities other than transfer of hazardous waste

- Opening of a spring loaded, pressure vacuum relief valve, conservation vent, or similar type of pressure relief device which vents to the atmosphere is allowed during normal operations for the purpose of maintaining internal container pressure

- Opening of a safety device to avoid unsafe conditions.

HW.58. Containers with design capacities greater than 0.46 m³ [~122 gal.] into which hazardous waste is placed are required to meet specific design and operating standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1087(a) through 265.1087(b)(1)(ii), 265.1087(b)(1) (iii), 265.1087(c), and 265.1087(d)).(NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all the hazardous waste entering the container meets one of the following (40CFR 265.1083(c)):

- The average VO concentration of the hazardous waste at the point of waste origination is less than 500 ppmw

- The organic content of the hazardous waste entering the waste management unit has been reduced by an organic destruction or removal process

The waste meets the numerical concentration limits for organic hazardous constituents as specified in 40 CFR 268.40 or has been treated by the treatment technology established by the regulatory agency for the waste in 268.42(a) or an equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

(NOTE: Standards for containers used in waste stabilization processes (40 CFR 265.1087(b)(2)) are in checklist item HW.59.)

Verify that, for containers with a design capacity greater than 0.46 m³ [~122 gal.] that are not in light material service, air emissions are controlled according to the following Container Level 1 standards:

- A container that meets applicable U.S. DOT regulations on the packaging of hazardous materials for transportation

- A container that is equipped with a cover and closure devices that form a continuous barrier over the container openings so that when the cover and closure devices are secured in the closed position there are not visible holes, gaps or other open spaces into the interior of the container

- An open-top container in which an organic vapor suppressing barrier is placed on or over the hazardous waste in the container so that no hazardous waste is exposed to the atmosphere.

HW.58. (continued)Verify that, for containers with a design capacity greater than 0.46 m³ [~122 gal.] that are in light material service, air emissions are controlled according to the following Container Level 2 standards:

- A container is used that meets applicable U.S. DOT regulations on the packaging of hazardous materials for transportation

- A container is used that operates with no detectable organic emissions

- A container is used that has been demonstrated within the preceding 12 months to be air tight.

(NOTE: Level 2 standards apply only to containers that are in light material service. For the containers that are not in light material service, Level 1 standards apply. (See 40 CFR 265.1087(b)(ii) and (iii).)

Verify that when a container using Level 1 standards, other than DOT approved containers, is used it is equipped with covers and closure devices composed of suitable materials to minimize exposure of the hazardous waste to the atmosphere and to maintain the equipment integrity for as long as it is in service.

Verify that whenever waste is in a container using Level 1 or Level 2 controls, covers and closure devices are installed and closure devices are secured and maintained in a closed position except as follows:

- Opening of a closure device or cover is allowed for adding waste or other material to the container as follows:

-- when the container is filled to the intended final level in one continuous operation, the closure devices are secured in the closed position and the covers installed at the conclusion of the filling operation

-- when discrete batches or quantities of material are added intermittently to the container over a period of time, the closure devices are promptly secured in the closed position and covers installed upon either:

--- the container being filled to the intended final level

--- the completion of a batch loading after which no additional material will be added to the container within 15 minutes

--- the person performing the loading operation leaving the immediate vicinity of the container

--- the shutdown of the process generating the material being added to the container, whichever condition occurs first

- Opening of a closure device or cover is allowed for removing the hazardous waste as follows:

-- in order to meet the requirements for an empty container

-- when discreet quantities or batches of material are removed from the container but the container is not empty, the closure devices are promptly secured in the closed position and the covers installed either:

--- upon completion of batch removal after which no additional material will be removed within 15 minutes

--- the person performing the unloading leaves the immediate vicinity, whichever condition occurs first

- Opening of a closure device or cover is allowed when access inside the container is needed to perform routine activities other than transfer of hazardous waste

- Opening of a spring loaded, pressure vacuum relief valve, conservation vent, or similar type of pressure relief device which vents to the atmosphere and is allowed during normal operations for the purpose of maintaining internal container pressure

- Opening of a safety device to avoid unsafe conditions.

HW.58. (continued) Verify that the transfer of hazardous waste in or out of containers meeting Container Level 2 controls is done in a manner to minimize exposure of the hazardous waste to the atmosphere (i.e., a submerged fill pipe, a vapor balancing system, a vapor recovery system, a fitted opening in the top of the container through which the hazardous waste is filled and subsequently purge the transfer line before removing it). HW.59. Containers with design capacities greater than 0.1 m³ [~26 gal.] used for the treatment of a hazardous waste by a waste stabilization process are required to meet specific design and operating standards (40 CFR 262.34(a)(1)(i), 265.178, 265.1087(a) through 265.1087(b)(2), and 265.1087(e)(1) through 265.1087(e)(3)). (NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all the hazardous waste entering the container meets one of the following (40 CFR 265.1083(c)):

- The average VO concentration of the hazardous waste at the point of waste origination is less than 500 ppmv

- The organic content of the hazardous waste entering the waste management unit has been reduced by an organic destruction or removal process

- The waste meets the numerical concentration limits for organic hazardous constituents as specified in 40 CFR 268.40 or has been treated by the treatment technology established by the regulatory agency for the waste in 268.42(a) or an equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

(NOTE: Safety devices may be installed and operated as necessary.)

Verify that containers with design capacities greater than 0.1 m³ [~26 gal.] used for the treatment of a hazardous waste by a stabilization process meet the following Container Level 3 standards at those times during the waste stabilization process when the hazardous waste in the container is exposed to the atmosphere:

A container is vented directly through a closed-vent system to a control deviceA container is vented inside an enclosure which is exhausted through a closed-vent system to a control deviceThe container closure is designed and operated in accordance with the criteria for a permanent total enclosure under 40 CFR 52.741The closed-vent system and control device is designed and operated in accordance with 265.1088 (see checklist item HW.62).HW.60. Facilities are required to have a written plan and schedule for inspection and monitoring requirements for containers and meet specific inspection requirements (40 CFR 262.34(a)(1)(i), 265.178, 265.1087(c)(4), 265.1087(d)(4), and 265.1089). (NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

Verify that the facility has a written plan and schedule for performing inspections and monitoring.

Verify that the plan and schedule are being met.

Verify that inspections of the containers and their covers and closure devices for containers using Container Level 1 or Level 2 controls are done as follows:

When a hazardous waste is already in the container when it is first accepted and the container is not emptied within 24 hours after it is accepted, it is visually inspected within 24 hours after acceptance for cracks, holes, gaps, or other open spacesWhen a container is used for managing hazardous waste for 1 year or more, it is visually inspected at least once every 12 months for visible cracks, holes, gaps, or other open spaces when the cover and closure devices are secured in the closed position.

Verify that when a defect is detected, the first efforts at repairs are within 24 hours after detection, and repair is completed as soon as possible but no later than 5 calendar days after detection.

(NOTE: If repair cannot be completed within 5 calendar days, the hazardous waste must be removed from the container.) HW.61. Facilities are required to meet documentation requirements for containers (40 CFR 262.34(a)(1)(i), 265.178, 265.1087(c)(5), 265.1090(a), and 265.1090(d) through 265.1090(i). (NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

Verify that a copy is available of the procedure used to determine that containers with a capacity of 0.46 m³ [~122 gal.] or greater which do not meet DOT standards are not managing hazardous waste in light material service.

Verify that if using Container Level 3 air emissions controls, the facility prepares and maintains records that:

Include the most recent set of calculations and measurements performed by the owner/operator to verify that the enclosure meets the criteria of a permanent total enclosure as specified in 40 CFR 52.741, Appendix BThe same records as required for closed-vent systems.

Verify that if using a closed-vent system and control device, the following records are maintained:

Certification that is signed and dated by the owner/operator stating that the control device is designed to operate at the performance level documented by a design analysis or by performance tests when the container is operating at capacity or the highest level reasonably expected to occurDesign documents if design analysis is used, including certification that the equipment meets the applicable specificationA performance test plan if performance tests are used and all test resultsDescription and date of each modification, as applicableIdentification of operating parameters, description of monitoring devices, and diagrams of monitoring sensor locations, as applicableSemiannual records of the following for those planned routine maintenance operations that would require the control device to exceed limitations:

-- a description of the planned routine maintenance that is anticipated to be performed for the control device during the next 6-month period, including the type of maintenance needed, planned frequency, and lengths of maintenance periods.

-- a description of the planned routine maintenance that was performed for the control device during the previous 6-month period, including the type of maintenance performed and the total number of hours during those 6-months that the control device did not meet applicable requirements

Records of the following for those unexpected control device system malfunctions that would cause the control device to not meet specifications:

-- the occurrence and duration of each malfunction of the control device system

-- the duration of each period during a malfunction when gases, vapors, or fumes are vented from the waste management unit through the closed-vent system to the control device while the control device is not properly functioning

-- actions taken during periods of malfunction to restore a malfunctioning control device to its normal or usual manner of operation

-- records of the management of the carbon removed from a carbon adsorption system.

Verify that, for exempted containers, the following records are prepared and maintained as applicable:

If exempted under the hazardous waste concentration conditions, information used for the waste determination in the facility operating log and/or the date, time, and location of each waste sample if analysis results for samples are usedIf exempted under incinerator use or process destruction use, the identification number for the incinerator, boiler, or industrial furnace in which the hazardous waste is treated.HW.61. (continued) Verify that covers designated as unsafe to monitor are listed in a log kept in the facility operating record with an explanation of why they are unsafe to inspect and monitor and a plan and schedule of inspection and monitoring is recorded.

Verify that, for containers not using the air emissions controls specified in 40 CFR 265.1085 through 265.1088 (see checklist items HW.57 through HW.62), the following information is maintained:

A list of the individual organic peroxide compounds manufactured at the facility if it produces more than one functional family of organic peroxides or multiple organic peroxides within one functional family, and one or more of these organic peroxides could potentially undergo self-accelerating thermal decomposition at or below ambient temperaturesA description of how the hazardous waste containing the organic peroxide compounds identified in the above list are managed, including:

-- a facility identification number for the container or group of containers

-- the purpose and placement of this container or group of containers in the management train of this hazardous waste

-- the procedures used to ultimately dispose of the hazardous waste handled in the containers

Explanations why managing these containers would be an undue safety hazard.

Verify that all records, except design information records, are kept for at least 3 years.

Verify that design information records are maintained in the operating record until the air emissions control equipment is replaced or otherwise no longer in service.

(NOTE: See also the recordkeeping requirements for carbon adsorption units in checklist item HW.65.) HW.62. Facilities are required to meet specific requirements for closed-vent systems and control devices used to achieve compliance (40 CFR 262.34(a)(1)(i), 265.178, and 265.1088). (NOTE: The requirements of 40 CFR 265.1088 do not apply to containers in which all the hazardous waste entering the container meets one of the following (40 CFR 265.1083(c)):

- The average VO concentration of the hazardous waste at the point of waste origination is less than 500 ppmw

- The organic content of the hazardous waste entering the waste management unit has been reduced by an organic destruction or removal process

The waste meets the numerical concentration limits for organic hazardous constituents as specified in 40 CFR 268.40 or has been treated by the treatment technology established by the regulatory agency for the waste in 268.42(a) or an equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(NOTE: These requirements do not apply to a container that has a design capacity less than or equal to 0.1 m³ [~26 gal.] (40 CFR 265.1080(b)(2)) or to containers of any size at satellite accumulation points.)

Verify that closed-vent systems meet the following:

It routes the gases, vapors and fumes emitted from the hazardous waste in the waste management unit to a control deviceIt is designed and operated in accordance with 40 CFR 265.1033(j) (see checklist item HW.64)If it includes bypass devices that could be used to divert the gas or vapor stream to the atmosphere before entering the control device, one of the following equipment requirements is met for each type of bypass device (NOTE: low leg drains, high point bleeds, analyzer vents, open-ended valve or lines, spring loaded pressure relief valves, and other fittings used for safety purposes are not considered bypass devices):

-- a flow indicator is installed, calibrated, maintained, and operated at the inlet to the bypass line used to divert gases and vapors from the closed-vent system to the atmosphere at a point upstream of the control device inlet

-- a seal or locking device is placed on the mechanism by which the bypass device position is controlled when the bypass valve is in the closed position so that the bypass device cannot be opened without breaking the seal or removing the lock.

Verify that the seal or closure mechanism is visually inspected at least once every month.

 

Verify that one of the following control devices are used:

A device designed and operated to reduce the total organic content of the inlet vapor stream vented to the control device by at least 95 percent by weightAn enclosed combustion device designed and operated in accordance with 265.1033(c) (see checklist item HW.64)A flare designed and operated in accordance with 40 CFR 265.1033(d) (see checklist item HW.64).

Verify that, when a closed-vent system and control device is used, the following are met:

Periods of planned routine maintenance of the control device during which the device does not meet specifications do not exceed 240 hours per yearControl device system malfunctions are corrected as soon as practicableIt is operated such that gases, vapors, and/or fumes are not actively vented to the control device during periods of planned maintenance or control device system malfunction, except in cases where it is necessary to do so in order to avoid an unsafe condition or to implement malfunction corrective actions or planned maintenance actions.HW.62. (continued) Verify that, if a carbon absorption system is used, the following requirements are met: All activated carbon is replaced with fresh carbon on a regular basis as outlined in 40 CFR 265.1033(g) and 265.1033(h) (see checklist item HW.64)All carbon removed from the devices is managed in a correct manner.

Verify that, if a control device other than a thermal vapor incinerator, flare, boiler, process heater, condenser, or carbon absorption system is used, the requirements in 40 CFR 265.1033(i) are met (see checklist item HW.64).

Verify that, for control devices, it is demonstrated by either a performance test or a design analysis that the device achieves compliance except for the following:

A flareBoiler or process heater with a design heat input capacity of 44 MW or greaterA boiler or process heater into which the vent stream is introduced with the primary fuelA boiler or process heater burning hazardous waste for which the owner or operator has been issued a final permit under 40 CFR 270 and has designed and operates the unit in accordance with the requirements of 40 CFR 266, subpart HA boiler or industrial furnace burning hazardous waste for the owner or operator has certified compliance with the interim status requirements of 40 CFR 266, subpart H.

Verify that the readings from each control device are inspected at least once each operating day to check control device operation. Emissions from Process Vents HW.63. Generators with process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations, that manage hazardous wastes with organic concentrations of at least 10 ppmw, are required to meet specific standards (40 CFR 262.34(a)(1)( i), 265.178, 265.1030(b), 265.1030(e) and 265.1032). (NOTE: This applies only if the operations are conducted in one of the following: A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container).)

Verify that one of the following is met:

Total organic emissions from the process vents do not exceed 1.4 kg/h (3 lb/h) and 2.8 Mg/yr (3.1 tons/yr)Total organic emissions are reduced by use of a control device from all process vents by 95 weight percent.

(NOTE: A process vent is not subject to these standards if the facility owner/operator certifies that all the regulated process vents at the facility are equipped with and operating air emission controls in accordance with the requirements of the Clean Air Act (CAA) 40 CFR Parts 60, 61, and 63.) HW.64. When a generator uses a closed-vent system and control device to meet the standards for total organic emissions, the closed-vent system and control device must meet certain minimum requirements (40 CFR 262.34(a)(1)(i), 265.178, 265.1033(b) through 265.1033(k)). (NOTE: This applies to generators with process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations, that manage hazardous wastes with organic concentrations of at least 10 ppmw, if the operations are conducted in one of the following: A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container).)

Verify that control devices involving vapor recovery are designed and operated to recover organic vapors vented to the air with an efficiency of 95 weight percent or greater, unless the total organic emission limit can be attained at an efficiency of less than 95 weight percent.

Verify that, if an enclosed combustion device is used (i.e., vapor incinerator, boiler, or process heater), it is designed and operated to reduce the organic emissions vented to it by 95 weight percent or greater, to achieve a total organic compound concentration of 20 ppmv expressed as the sum of the actual compounds, not carbon equivalents, on a dry basis corrected to 3 percent oxygen, or to provide a minimum residence time of 0.50 seconds at a minimum temperature of 760 degrees Celsius [1400 degrees Fahrenheit].

Verify that, if a boiler or process heater is used as the control device, the vent stream is introduced into the flame zone of the boiler or process heater.

Verify that, if flares are used:

They are designed and operated with no visible emissions except for periods not in excess of 5 minutes during any 2 consecutive hoursThey are operated with a flame present at all timesThey are used only if the net heating value of the gas being combusted is 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam assisted or air assistedIf nonassisted, the net heating value of the gas being combusted is 7.45 MJ/scm (200 Btu/scf) or greaterIf nonassisted or steam assisted, have an exit velocity less than 18.3 m/s (60 ft/s) except when the net heating value of the gas being combusted is greater than 37.3 MJ/scm (1000 Btu/scf) and the exit velocity is equal to or greater than 18.3 m/s (60 ft/s) but less than 122 m/s (400 ft/s).

Verify that each monitor and control device is inspected on a routine basis. HW.64. (continued) Verify that each required control device is installed, calibrated, monitored and inspected as follows: A flow indicator is installed in the vent stream at the nearest feasible point to the control device inlet, but before being combined with other streams, and provides a record of vent stream flow from each affected process vent to the control device at least once every hourA control device to continuously monitor control device operations as specified:

-- a temperature monitoring device equipped with a continuous recorder for a thermal vapor incinerator

-- a temperature monitoring device equipped with a continuous recorder for a catalytic vapor incinerator

-- a heat sensing monitor with a continuous recorder for flares

-- a temperature monitoring device equipped with a continuous recorder to measure parameters that indicate good combustion operating practices are being used for a boiler or process heater having a design heat input capacity less than 44 MW

-- for a condenser, one of the following:

--- a monitoring device with a continuous recorder to measure the concentration level of the organic compound in the exhaust vent stream from the condenser

--- a temperature monitoring device equipped with a continuous recorder capable of monitoring temperature in the exhaust vent stream from the condenser with an accuracy of +/- 1 percent of the temperature being monitored in Celsius or in +/-0.5 ^oC, whichever is greater

-- for a carbon absorption system such as a fixed carbon bed absorber that regenerates the carbon bed directly in the control device, one of the following:

--- a monitoring device equipped with a continuous recorder to measure the concentration levels of the organic compounds in the exhaust vent stream from the carbon bed

--- a monitoring device equipped with a continuous recorder to measure a parameter that indicates the carbon bed is regenerated on a regular, predetermined time cycle.

Verify that readings from monitoring devices are checked at least once a day.

Verify that, if a carbon absorption system is being used that regenerates the carbon bed directly on-site, the existing carbon in the control device is replaced with fresh carbon at a regular, predetermined time interval.

(NOTE: The predetermined time interval is based on the design analysis required under 40 CFR 265.1035(b)(4)(iii)(F).)

Verify that if a carbon absorption system is being used that does not regenerate the carbon bed directly on-site in the control device, the existing carbon in the control device is replaced on a regular basis.

(NOTE: When to replace the carbon is determined by one of the following procedures:

Monitoring the concentration level of the organic compound in the exhaust vent stream from the carbon absorption system daily or at an interval no greater than 20 percent of the time required to consume the total carbon working capacity, whichever is longerReplace the carbon at a regular predetermined time interval that is less than the design carbon replacement interval.)HW.64. (continued) Verify that closed-vent systems meet one of the following: Are designed and operated with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background as determined by the procedures in 40 CFR 265.1034(b) and by visual inspectionAre designed to operate at a pressure below atmospheric pressure and are equipped with at least one pressure gauge or other pressure measurement device that can be read from a readily accessible location.HW.65. Generators are required to maintain specific records pertaining to process vent emissions (40 CFR 262.34(a)(1)(i), 265.178, and 265.1035). Verify that the following information is kept in the operating record: An implementation scheduleUp-to-date documentation of compliance with process vents and with closed-vent systems and control devicesThe test plan if test data is used to determine the organic removal efficiency or total organic compound concentration achieved by a control deviceDocumentation of compliance with 40 CFR 265.1033, including:

-- a list of all information, references and sources used in preparing the documentation

-- records, including the dates of required compliance tests

-- design analysis, specifications, drawing, schematics, and piping and instrumentation diagrams if engineering calculations are used

A statement signed and dated by the operator or owner certifying that the operating parameters used in the design analysis reasonably represent the conditions which exist when the hazardous waste management unit is or would be operating at the highest load or capacity level reasonably expectedA statement signed and dated by the owner or operator certifying that the control device is designed to operate at an efficiency of 95 percent or greater unless the total organic concentration limit is achieved at an efficiency of less than 95 weight percent, or the total organic emissions limits for affected process vents can be attained by a control device involving vapor recovery at an efficiency less than 95 weight percentAll performance test results if used to demonstrate complianceDesign documentationMonitoring and inspection results for each closed-vent system and control deviceNotations of exceedance of control device parameter design valueExplanation for each period of exceedanceFor carbon absorption systems:

-- when the carbon is replaced in carbon absorption systems

-- date and time when a control device is monitored for carbon breakthrough

The date of each control device startup and shutdown.

Verify that records of monitoring operations and inspection information are kept for 3 years. HW.66. Closed-vent systems are required to be monitored, inspected, and leaks repaired (40 CFR 262.34(a)(1)(i), 265.178, 265.1033(k) and 265.1033(n)). (NOTE: This applies to generators with process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations, that manage hazardous wastes with organic concentrations of at least 10 ppmw, if the operations are conducted in one of the following: A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container).)

Verify that closed-vent systems designed and operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, are monitored as follows:

An initial leak detection monitoring of the closed-vent system using the procedures specified in 40 CFR 265.1034(b) on or before the date the system became subject to this section of the CFRAfter initial leak detection monitoring:

-- visual inspection at least once a year for closed-vent system joints, seams, or other connections that are permanently or semi-permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted and gasketed ducting flange)

-- whenever a component is repaired or replaced, monitor according to 40 CFR 265.1034(b)

-- annually and at times required by the regulatory agency for all other parts of the system using the procedures specified in 40 CFR 265.1034(b).

Verify that closed-vent systems designed to operate at no detectable emissions, as indicated by an instrument reading of less than 500 ppmv above background, are monitored as follows:

Annual visual inspection to check for defects that could result in air pollutant emissionsInitial inspection on or before the date the system becomes subject to this section of the CFR.

(NOTE: For closed-vent systems designed to operate at no detectable emissions, as indicated by an instrument reading of less than 500 ppmv above background, portions of the system designated as unsafe to monitor are exempt from the visual monitoring if:

The components are unsafe to monitor because monitoring personnel would be exposed to an immediate dangerA written plan that requires monitoring as practicable during safe to monitor periods is in place and followed.)

Verify that detectable emissions, as indicated by visual inspection or by an instrument reading of greater than 500 ppmv above background, are controlled as soon as practicable but not later than 15 days after the emissions are detected.

Verify that a first attempt at repair is made no later than 5 calendar days after the emission is detected.

(NOTE: Delay of repair of a closed-vent system for which leaks have been detected is allowed if the repair is technically infeasible without a process unit shutdown, or if it is determined that the emissions resulting from the immediate repair would be greater than the fugitive emissions likely to result from delay of repair.) HW.67. Closed-vent systems and control devices used to comply with the provisions of 40 CFR 265.1030 through 265.1035 are required to be operated at all times when emissions may be vented to them (40 CFR 262.34(a)(1)(i), 265.178, and 265.1033(l)). (NOTE: This applies to generators with process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations, that manage hazardous wastes with organic concentrations of at least 10 ppmw, if the operations are conducted in one of the following: A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container).)

Verify that closed-vent systems and control devices are operated at all times when emissions may be vented to them. HW.68. When carbon absorption systems are used, operators are required to manage all carbon that is a hazardous waste according to specific parameters (40 CFR 262.34(a)(1)(i), 265.178, and 265.1033(m)). (NOTE: This applies to generators with process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam stripping operations, that manage hazardous wastes with organic concentrations of at least 10 ppmw, if the operations are conducted in one of the following: A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container).)

Verify that carbon removed from control devices that is a hazardous waste is managed in one of the following manners, regardless of the average VOC concentration of the carbon:

Regenerated or reactivated in a thermal treatment unit that meets one of the following:

-- the unit has a final permit under 40 CFR 270 which implements the requirements of 40 CFR 264, subpart X

-- the unit is equipped with and operating air emission controls in accordance with applicable requirements

Incinerated in a hazardous waste incinerator for which the operator either:

-- has a final permit under 40 CFR 270 which implements the requirements of 40 CFR 264, subpart O

-- has designed and operates the incinerator in accordance with the interim status required in 40 CFR 265, subpart O

Burned in a boiler or industrial furnace for which the operator either:

-- has been issued a final permit under 40 CFR 270 implementing 40 CFR 266

-- has designed and operates the boiler or industrial furnace in accordance with the interim status requirements of 40 CFR 266, subpart H.

Air Emission Standards for Equipment Leaks (NOTE: This section applies to equipment that contains or contacts hazardous waste with organic concentrations of at least 10 percent by weight that are managed in one of the following (40 CFR 265.1050(b): A unit that is subject to the permitting requirements of 40 CFR 270A unit (including a hazardous waste recycling unit) that is not exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous waste recycling unit that is not a 90-day tank or container) and that is located at a hazardous waste management facility that is otherwise subject to the permitting requirements of 40 CFR 270A unit that is exempt from permitting under the provisions of 40 CFR 262.34(a) (i.e., a 90-day tank or container) and is not a recycling unit under the provisions of 40 CFR 261.6.)

(NOTE: This section does not apply to (40 CFR 265.1050(d) and 265.1050(e)):

Equipment that is in vacuum service and is identified as such on the required listEquipment that contains or contacts hazardous waste with an organic concentration of at least 10 percent by weight for less than 300 hours per calendar year and is identified as such.)HW.69. Generators with pumps in light liquid service, that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight, are required to meet specific standards (40 CFR 262.34(a)(1)(i), 265.178, 265.1052). Verify that pumps in light liquid service are monitored monthly according to designated reference methods and inspected visually weekly.

(NOTE: A leak is detected if there is an instrument reading of 10,000 ppm or greater or if there is an indication of liquid dripping from the pump seal.)

Verify that, when a leak is detected, the first attempt at repair is made within 5 calendar days and repair is completed within 15 calendar days.

(NOTE: Pumps equipped with dual mechanical seal systems and pumps designated for no detectable emissions that meet standards outlined here do not have to be monitored monthly or visually checked weekly.)

Verify that pumps equipped with a dual mechanical seal system which do not have to be monitored monthly or visually checked weekly, meet the following design and operation requirements:

The dual mechanical seal system is operated with barrier fluid at a pressure that is at all times greater than the pump stuffing box, or equipped with a barrier fluid degassing reservoir that is connected by a closed-vent system to a control device, or equipped with a system that purges the barrier fluid into a hazardous waste stream with no detectable emission to the atmosphereThe barrier fluid system has no hazardous waste with organic concentrations 10 percent or greater by weightThe barrier fluid system is equipped with a sensor that will detect failure if the seal is brokenPumps are checked by visual inspection weeklySensors are checked daily or equipped with an audible alarm that is checked monthly.

(NOTE: Each owner or operator must determine, based on design considerations and operating experience, criteria that indicate failure of the seal system, the barrier fluid system, or both.)

Verify that pumps designated for no detectable emissions meet the following:

They are operated with no detectable emissions, as indicated by an instrument reading of 500 ppm above background or lessThey are tested for compliance as indicated by an instrument reading of 500 ppm above background or less initially upon designation, annually, and at other times as requested by the regulatory agencyNo externally actuated shaft penetrates the pump housing.HW.69. (continued) (NOTE: Any pump that is equipped with a closed-vent system capable of capturing and transporting any leakage from the seal or seals to a control device is exempt from all above requirements.) HW.70. Generators with compressors that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight are required to meet specific standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1053). Verify that each compressor is equipped with a seal system which includes a barrier fluid system and prevents leakage of total organic emissions to the atmosphere except if: It is equipped with a closed-vent system capable of capturing and transporting any leakage from the seal to a control device, andIt is designated for no detectable emissions as indicated by an instrument reading of less than 500 ppm above background, andIt is tested for compliance initially upon designation, annually, and at times as requested by the regulatory agency.

Verify that the compressor seal systems meet one of the following:

It is operated with the barrier fluid at a pressure that is at all times greater than the compressor stuffing box pressureIt is equipped with a barrier fluid system that is connected to a closed-vent system or a control deviceIt is equipped with a system that purges the barrier fluid into a hazardous waste stream with no detectable emissions to the atmosphere.

Verify that the barrier fluid is not a hazardous waste with organic concentrations 10 percent or greater by weight.

Verify that each barrier system is equipped with a sensor which will detect failure of the seal system, barrier fluid system, or both.

Verify that each sensor is checked daily or it is equipped with an audible alarm that is checked monthly.

(NOTE: Sensors on compressors located within the boundary of an unmanned site must be checked daily.)

(NOTE: Each owner or operator must determine, based on design considerations and operating experience, criteria that indicate failure of the seal system, the barrier fluid system, or both.)

Verify that, when a leak is detected, the first attempt at repair is made within 5 calendar days and the repair is made within 15 calendar days. HW.71. Generators with pressure relief devices in gas/vapor service that contain or contact hazardous waste with organic concentrations of at least 10 percent by weight are required to meet specific standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1054). Verify that, except during pressure releases, each pressure relief device in gas/vapor service is operated with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background.

Verify that if there is a pressure release, the device is returned to a no detectable emission status within 5 calendar days and the device is monitored to ensure compliance.

(NOTE: Any pressure relief device that is equipped with a closed-vent system capable of capturing and transporting leakage from the pressure relief device to a control device is exempt from these requirements.) HW.72. Generators with sampling connecting systems that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight are required to meet specific standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1055). Verify that each sampling connection system is equipped with a closed-purge, closed loop system or closed-vent system.

Verify that each system collects the sample purge for return to the processing or for routing to the appropriate treatment system.

(NOTE: Gases displaced through filling of the sample container are not required to be collected or captured.)

Verify that each closed-purge, closed-loop system or closed-vent system does one of the following:

Returns the purged process fluid directly to the process lineCollects and recycles the purged process fluidIs designed and operated to capture and transport all the purged process fluid to a waste management unit that is in compliance or a control device that is in compliance,

(NOTE: In-situ sampling systems are exempt from these requirements.) HW.73. Generators with open-ended valves or lines that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight are required to meet specific standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1056). Verify that each open-ended valve or line is equipped with a cap, blind flange, plug or second valve.

Verify that the cap, blind flange, plug, or second valve seals the open end at all times, except during operations requiring hazardous waste stream flow through the open-ended valve or line.

Verify that each open-ended valve or line equipped with a second valve is operated so the valve on the hazardous waste stream end is closed before the second valve is closed.

Verify that, when a double block and bleed system is being used, the bleed valve is shut or plugged except during operations that require venting the line between the block valves. HW.74. Generators with valves in gas/vapor service or light liquid service, that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight, are required to meet specific monitoring and repair standards (40 CFR 262.34(a)(1)(i), 265.178, 265.1057, and 265.1062). Verify that valves in gas/vapor service or light liquid service are monitored monthly to detect leaks.

(NOTE: A leak is detected if an instrument reading of 10,000 ppm or greater is measured. If a leak is not detected for 2 consecutive months, monitoring may be cut back to quarterly until a leak is detected.)

(NOTE: Valves that are designated for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, do not have to be monitored monthly if:

The valve has no external actuating mechanism in contact with the hazardous waste streamThe valve is operated with emissions less than 500 ppm above backgroundThe valve is tested initially upon designation, annually, and at the request of the regulatory agency.)

(NOTE: Valves that are designated as unsafe to monitor are exempt from the requirement for monthly monitoring if:

The valve is unsafe to monitor because monitoring personnel would be exposed to an immediate dangerA written monitoring plan is followed that requires monitoring as often as is reasonably practicable during safe to monitor times.)HW.74. (continued) (NOTE: The generator may elect to have all valves within a hazardous waste management unit comply with an alternative standard of no greater than 2 percent of the valves to leak; see checklist item HW.78.)

(NOTE: Valves that are designated as difficult to monitor are exempt from the requirement for monthly monitoring if:

The valve cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surfaceThe hazardous waste management unit within which the valve is located was in operation before 21 June 1990A written monitoring plan is followed that requires the monitoring of the valve at least once per calendar year.)

(NOTE: The following are alternatives to the prescribed monitoring schedule which can be used until the percentage of valves leaking is greater than 2 percent:

After 2 consecutive quarterly leak detection periods with the percentage of valves leaking equal to or less than 2 percent, an owner or operator may begin to skip one of the quarterly leak detection periods for the valves subject to 40 CFR 265.1057After 5 consecutive quarterly leak detection periods with the percentage of valves leaking equal to or less than 2 percent, an owner or operator may begin to skip three of the quarterly leak detection periods for the valves subject to 40 CFR 265.1057.)

Verify that the first attempt at repairing a leak is done within 5 calendar days after detection and leak repair is completed within 15 calendar days after detection.

(NOTE: First attempts at repair include but are not limited to:

Tightening of bonnet boltsReplacement of bonnet boltsTightening of packing gland nutsInjection of lubricant into lubricated packaging.)HW.75. Generators with pumps and valves in heavy liquid service, pressure relief devices in light liquid service or heavy liquid service, and other connectors that contain or contact hazardous wastes with organic concentrations of at least 10 percent by weight are required to meet specific monitoring and repair standards (40 CFR 262.34(a)(1)(i), 265.178, and 265.1058). Verify that pumps and valves in heavy liquid service, pressure relief devices in light liquid service or heavy liquid service, and other connectors are monitored within 5 days if evidence of a potential leak is found by visual, olfactory, audible, or other detection method.

(NOTE: Any connector that is inaccessible or is ceramic or ceramic-lined is exempt from the monitoring requirements.)

(NOTE: A leak is detected if an instrument reading of 10,000 ppm or greater is measured.)

Verify that, when a leak is detected, the first attempt at repair occurs within 5 days and repair is done within 15 days after discovery.

(NOTE: First attempts at repair include, but are not limited to:

Tightening of bonnet boltsReplacement of bonnet boltsTightening of packing gland nutsInjection of lubricant into lubricated packaging.)HW.76. Generators are required to keep specific records pertaining to the valves, pumps, pressure relief devices, and connecting systems being monitored for leaks and to submit certain reports (40 CFR 262.34(a)(1)(i), 265.178, 265.1058(e) and 265.1064). Verify that the following information is maintained in the generator's operating record: Equipment identification number and hazardous management unit identificationApproximate locationsType of equipmentPercent-by-weight total organics in the hazardous waste stream at the equipmentHazardous waste state at the equipment (gas, liquid, vapor)Method of complianceImplementation schedule if neededA performance plan for control devices if neededDocumentation of complianceDocumentation of repair, including:

-- the instrument and operator identification numbers and the equipment identification number

-- the date evidence of a potential leak was found

-- the date the leak was detected and the date of each attempt to repair the leak

-- repair methods applied in each attempt

-- "Above 10,000" if the maximum instrument reading after each repair attempt is greater than 10,000 ppm

-- "Repair Delayed" and the reason for delay if the leak is not repaired within 15 calendar days after discovery

-- documentation supporting the delay of repair of a valve

-- signature of the owner or operator whose decision it was that the repair could not be effected without a hazardous waste management unit shutdown

-- the expected date of successful repair of the leak when it is not repaired within 15 calendar days

-- the date of the successful repair of the leak

Design documentation and monitoring, operating, and inspection information for each closed-vent system control device required to comply with the provisions of 40 CFR 265.1060Monitoring and inspection information indicating proper operation and maintenance of the control device for a control device other than a thermal vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater, condenser, or carbon absorption systemThe following information for all equipment subject to 40 CFR 265.1052 through 40 CFR 265.1060:

-- a list of identification numbers for equipment (except welded fittings)

-- a list of identification numbers for equipment that the owner or operator elects to designate for no detectable emissions

-- a list of equipment identification numbers for pressure relief devices

-- the dates of required compliance tests, background levels, and maximum instrument reading measured during the compliance test

-- a list of identification numbers for equipment in vacuum service

-- identification either by list or location (area or group) of equipment that contains or contacts hazardous waste with an organic concentration of at least 10 percent by weight for less than 300 hours per calendar year.

Verify that the following information is kept for all valves subject to 40 CFR 265.1057(g) and (h):

A list of identification numbers for valves listed as unsafe to monitor, an explanation for each valve stating why it is difficult to monitor, and the plan for monitoring each valveA list of identification numbers for valves that are designated as difficult to monitor, an explanation for each valve stating why it is difficult to monitor, and the plan for monitoring each valveThe following for all valves complying with 40 CFR 265.1062:

-- a schedule of monitoring

-- the percent of valves found leaking in each monitoring period.

HW.76. (continued) Verify that the following information is kept for use in determining exemptions: An analysis determining the design capacity of the unitA statement listing the hazardous waste influent to and effluent from each unit subject to 40 CFR 265.1052 through 265.1060 and an analysis determining whether these hazardous wastes are heavy liquidsAn up-to-date analysis and the supporting information and data used to determine if equipment is subject to the requirements.

(NOTE: Any connector that is inaccessible or is ceramic or ceramic lined is exempt from the recordkeeping requirements.) HW.77. Each piece of equipment subject to the requirements in 40 CFR 265.1050 through 265.1064 is required to be marked so that it can be distinguished from other equipment (40 CFR 262.34(a)(1)(i), 265.178, and 265.1050(c)). Verify that each piece of equipment subject to the requirements in 40 CFR 265.1050 through 265.1064 (see checklist items HW.69 through HW.76) is marked so that it can be distinguished from other equipment. HW.78. When a generator has elected to comply with alternative standards, specific actions are required (40 CFR 262.34(a)(1)(i) and 265.1061). Determine if the owner/operator subject to 40 CFR 265.1057 (see checklist item HW.74) has elected to have all valves within a hazardous waste management unit comply with an alternative standard of allowing 2 percent of the valves to leak.

Verify that the following actions have been taken if the owner/operator has decided to comply with the 2 percent alternative:

The regulatory agency has been notified of the choice to comply with the alternative standardsA performance test was conducted initially upon designation, annually, and at other times as required by the regulatory agencyIf a valve leak is detected, first attempt at repair is within five calendar days and leak repair is completed within 15 days after detection.

Verify that if the owner/operator has decided to no longer comply with the 2 percent rule, the regulatory agency has been notified. Satellite Accumulation Points HW.79. Generators may accumulate as much as 55 gal. of hazardous waste or 1 qt. of acutely hazardous waste in containers at or near any point of initial generation without complying with the requirements for on-site storage if specific standards are met (40 CFR 262.34(c)). (NOTE: This type of storage area is often referred to as a satellite accumulation point.)

Verify that the satellite accumulation point is at or near the point of generation and is under the control of the operator of the waste generating process.

Verify that the containers are in good condition and are compatible with the waste stored in them and the containers are kept closed except when waste is being added or removed.

Verify that the containers are marked HAZARDOUS WASTE or other appropriate identification.

(NOTE: See Appendices A, B, C, D, and E for a guidance list of hazardous and acutely hazardous wastes.)

Verify by interviewing the shop managers that when waste is accumulated in excess of quantity limitations, the following actions are taken:

- The excess container is marked with the date the excess amount began accumulating

- The waste is transferred to a 90 day or permitted storage area within three days.