LARGE QUANTITY GENERATOR CHECKLIST
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1 Facility: Date: LARGE QUANTITY GENERATOR CHECKLIST Note: The Oklahoma Hazardous Waste Management Regulations [OK Adm. Code (OAC) 252:205] incorporates by reference at OAC 252: the applicable federal hazardous waste and used oil regulations of 40 CFR Additional state regulations of OAC 252:205 are further identified. On multiple part questions, circle those not in compliance. Use these pages for Generators which generate at least 1000 kg (2200 #) of hazardous waste per month. This checklist is used for both TSD generators & < 90- day storage (i.e. "generator only") (40 CFR ) Section A - EPA ID Number & Disposal Plan (40 CFR & OAC 252: ) 1. Does Generator have an EPA ID Number: 2. Does Generator have a DEQ Disposal Plan Number: Section B - Hazardous Waste Determination - (40 CFR ) 1. Does generator generate hazardous waste(s) listed in Subpart D [40 CFR ]? 2. Does generator generate solid waste(s) that exhibit hazardous characteristics (Corrosivity, ignitability, reactivity, TCLP toxicity - 40 CFR )? a. *If yes, list wastes and quantities on attachment. (Include Hazardous Waste Codes and provide waste name and description.) b. Does generator determine characteristics by TESTING or KNOWLEDGE OF PROCESS? i. If determined by testing, did generator use test methods in 40 CFR Part 261, Subpart C (or equivalent)? ii. Are these records kept for a period of three years - 40 CFR (c)? iii. If equivalent test methods used, attach copy of equivalent methods Page 1 of 11 Rev. 2/99
2 3. Are there any other solid wastes deemed non-hazardous by generators (i.e. process waste streams, collected matter from air pollution control equipment, water treatment sludge, etc.)? a. *If yes, did generator determine non-hazardous characteristics by TESTING or KNOWLEDGE OF PROCESS? i. If determined by testing, did generator use test methods in 40 CFR Part 261, Subpart C (or equivalent)? ii. Are these records kept for a period of three years - 40 CFR (c)? iii. If equivalent test methods are used, attach copy of equivalent method used. b. List wastes and quantities deemed non-hazardous or processes from which non-hazardous wastes were produced (Use narrative explanation sheet(s)). 4. Has the generator completed an appropriate hazardous waste determination for each solid waste produced? *If yes, check the method(s) used for the determination: a. Listed as a hazardous waste in 40 CFR Part 261, Subpart D b. Process or material knowledge c. Tested for characteristic as identified in 40 CFR Part 261, Subpart C (if equivalent method used, attach a copy). Identify the person and lab that made the determination: Name Title Lab 5. Are any wastes recycled on site? *If yes, use narrative to describe the type and quantity of the waste and the method used for recycling. 6. Are any wastes shipped off-site for recycling? *If yes, use narrative to describe the type and quantity of the waste and its destination. Also give a description of storage prior to shipment. Page 2 of 11 Rev. 2/99
3 7. Total quantity of non-acutely hazardous wastes generated per month: 8. Total quantity of acutely hazardous wastes generated per month: 9. Does this facility generate used oils? *If yes, include narrative description of storage and disposition. Section C - Manifest (40 CFR 262 Subpart B) 1. Does generator ship hazardous waste off-site? a. *If no, Go to Section E - Satellite Accumulation b. *If yes, identify primary off-site facilities. 2. Does generator use a manifest? *If yes, is manifest form approved by DEQ? (Check manifests. Indicate how many manifests were inspected, how many violations were noted and the type of violation.) Number of manifests reviewed: 3. Does all the following information appear on the manifest(s) (40 CFR )? Check Deficiencies: a. Manifest document number b. Generator's name c. Generator's EPA ID number d. Generator's State ID number (disposal plan number) OAC 252: e. Generator's address f. Generator's telephone number g. Generator's signature h. Date that waste was offered for shipment i. Transporter's name j. Transporter's EPA ID number k. Transporter's OK ID number l. Transporter's telephone number Page 3 of 11 Rev. 2/99
4 m. Secondary transporter information (if applicable) n. Disposal facility name o. Disposal facility EPA ID number p. Disposal facility address q. Disposal facility telephone number r. Alternate facility information (if any) s. D.O.T. description of waste(s) t. Total quantity of each hazardous waste by units of weight or volume, and the type and number of containers as loaded onto a vehicle. u. EPA waste code (optional) v. Emergency information (optional) w. Waste minimization certification 4. Is the following certification on each manifest form? "I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations. If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practical method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment; OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford. 5. Does the generator have a waste minimization plan in place? 6. Did generator obtain handwritten signature and date of acceptance from initial transporter [40 CFR (a)]? 7. Does generator retain for three years copies of manifests signed and dated by generator, transporter, and TSD facility [40 CFR (a)/262.40(a)]? 8. If copy of manifest from TSD was not returned to the generator within 45 days, did generator file with the DEQ an exception report [262.42(a)(2)]? *If yes, did it contain the following information: i. Legible copy of manifest? ii. Cover letter explaining generator efforts to locate waste? Section D - Pre-Transport Requirements (40 CFR 262 Subpart C) (These requirements apply only to containers that are being offered for shipment off-site, at time of the inspection). Page 4 of 11 Rev. 2/99
5 1. Does generator package waste? *If no, Go to Section E - Satellite Accumulation *If yes, continue 2. Does generator package waste in accordance with 49 CFR 173, 178 and 179 (DOT requirements - 40 CFR )? 3. Does the generator follow DOT labeling requirements before transport in accordance with 49 CFR 172 (40 CFR )? 4. Does the generator mark each package before transport in accordance with 49 CFR 172 (40 CFR )? 5. Is each container of 110 gallons or less marked with the following label before transport (40 CFR )? "HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency. Generator's Name & Address Manifest Document Number *If other labels exist, identify in narrative. 6. If there are any vehicles present on-site loading or unloading hazardous waste, inspect for presence of placards. Note this instance on narrative explanation sheet (40 CFR ). Section E - Satellite Accumulation [40 CFR (c)] 1. Does the generator accumulate waste in containers at or near "satellite" generation points? *If no, Go to Section F - Accumulation Storage Time *If yes, continue. 2.. Are containers in good condition? 3. Is the waste compatible with the containers? 4. Is waste transferred from leaking containers or otherwise managed to control leakage? Page 5 of 11 Rev. 2/99
6 5. Are containers closed? 6. Are containers marked with the words "hazardous waste" or identification of the contents? 7. Has waste accumulation exceeded one (1) quart of acutely hazardous waste (262.34) or 55 gallons of other hazardous waste? *If yes: a. Has the container holding the excess amount been marked with the date the excess began accumulating? b. Have excess amounts remained in the satellite accumulation area longer than three (3) days? Section F - Storage Accumulation Time - (40 CFR ) 1. Is facility a: permitted storage facility interim status facility generator only facility (< 90 days) 2. If generator only facility: a. Is hazardous waste shipped off-site within ninety (90) days? b. Is waste stored in containers and/or tanks? (circle as appropriate) **Complete the appropriate container &/or tank checklist(s). Section G - Personnel Training [40 CFR (a)(4)/265.16] 1. Does the owner/operator have a personnel training program that includes where applicable (40 CFR ): a. Procedures for using, inspecting, repairing, and replacing facility emergency & monitoring equipment? b. Key parameters for automatic waste feed cut-off systems? Page 6 of 11 Rev. 2/99
7 c. Procedures for using communications or alarm systems? d. Responses to fires & explosions? e. Response to spills and/or groundwater contamination incidents? f. Shutdown of operations? 2. Is the training program directed by a person trained in hazardous waste management procedures (40 CFR )? 3. Does the owner/operator maintain Personnel Training records at the facility (40 CFR )? a. *If yes, do the training records include: i. Job title for each position related to hazardous waste management? ii. Written job description for each job title including the requisite skill, education, or other qualifications, and duties of personnel assigned to each position? iii. Description of type and amount of both introductory and continuing training that will be given to each person filling a position? iv. Records that document that the required training has been given to or completed by facility personnel? b. Do personnel take part in an annual review of the training required? Section H - Preparedness and Prevention [40 CFR (a)(4)/265 Subpart C] 1. Is there evidence of fire, explosion or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment? (40 CFR )? Page 7 of 11 Rev. 2/99
8 *If yes, use narrative explanation sheet(s) to explain. 2. Has an incident occurred requiring the facility to immediately notify the DEQ (OAC 252: )? *If yes, use narrative explanation sheet(s) to explain. 3. Is the facility equipped, if applicable, with the following (40 CFR ): a. Internal communications or alarm system capable of providing immediate emergency instruction to facility personnel (voice or signal)? b. Telephone or two-way radio (that is immediately available at the scene of operations) to call emergency response personnel? c. Portable fire extinguishers, fire control equipment, spill control? d. Water of adequate volume and pressure for hoses, sprinklers, or water spray system? i. Describe source of water: ii. Indicate flow rate and/or pressure and storage capacity if known: 4. Is the communications equipment or internal alarm immediately accessible to personnel involved in any aspect of hazardous waste handling that could result in a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents (CFR )? 5. Is facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, tested and maintained as necessary to assure its proper operation in time of emergency (40 CFR )? 6. Is there sufficient aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment (40 CFR )? Page 8 of 11 Rev. 2/99
9 7. Has the owner/operator familiarized the local authorities with characteristics of the facility (layout of facility, properties of hazardous waste handled and associated hazards, places where facility personnel would normally be working, entrances to roads inside facility, possible evacuation routes) [40 CFR (a)(1)]? *If no, has the owner/operator attempted to make such arrangements? 8. In the case that more than one police or fire department might respond, is there a designated primary authority [40 CFR (a)(2)]? a. *If yes, indicate primary authority: b. Is the fire department a city or volunteer fire department? 9. Does the owner/operator have phone numbers of and agreements with emergency response contractors [40 CFR (a)(3)]? 10. Has the owner/operator familiarized local hospitals with the properties of hazardous waste handled and types of injuries that could result from fires, explosions, or releases at the facility? *If no, has the owner/operator attempted to do this? 11. If the State, or local authorities decline to enter into the above-referenced agreements, has this situation been entered in the operating record [40 CFR (b)]? Section I - Contingency Plan and Emergency Procedures [40 CFR (a)(4)/ 265 Subpart D] 1. Does the facility have a contingency plan (40 CFR )? *If yes, is it maintained at the facility and submitted to all local police and fire departments, hospitals, and emergency response services that may be called upon (40 CFR )? NOTE: This includes Local DEQ offices as well as local fire and police departments. Page 9 of 11 Rev. 2/99
10 2. Is the contingency plan a revised SPCC Plan (40 CFR )? 3. Does the contingency plan contain the following information (40 CFR ): a. A description of the actions to be taken by facility personnel in the event of fire, explosion, or release hazardous waste? b. A description of the arrangements with local authorities, i.e. police, fire, hospital, etc.? c. A list of names, addresses, and phone numbers (office and home) of all persons qualified to act as emergency coordinator? Is a primary coordinator identified? d. A list of all emergency equipment including: (1) the location of each item; (2) a physical description of each item on the list; and (3) an outline of each item's capabilities? e. An evacuation plan where there is a possibility that evacuation could be necessary including: i. Signals to begin evacuation ii. Evacuation routes iii. Alternate evacuation routes 4. Is there an emergency coordinator on site or within short driving distance of the plant at all times (40 CFR )? 5. Has the contingency plan been updated and amended as necessary (40 CFR )? 6. Has the contingency plan ever been implemented (40 CFR )? Section J - Recordkeeping and Reports (40 CFR 262 Subpart D) 1. Is the generator keeping the following reports (40 CFR )? NOTE: Those with an (*) must be kept for a minimum of three (3) years Page 10 of 11 Rev. 2/99
11 a. *Manifests and signed copies from designated facilities? b. Quarterly reports? (OAC 252: ) c. *Exception reports? d. *Test results where applicable? e. *Biennial Reports for each odd number year? 2. Where are records kept (at facility or elsewhere)? 3. Who is in charge of keeping the records? Name: Title: Section K - Import/Export (40 CFR 262 Subparts E & F) Has generator received from or transported to a foreign source any hazardous waste? *If yes: a. Has he filed a notice with the EPA (export only) [40 CFR /262.53]? b. Is this waste manifested and signed by Foreign Consignee? c. If generator transported wastes out of the country, has he received confirmation of delivered shipment? d. Has the generator filed an annual report (by March 1 of each year) summarizing the type, quantity, frequency, and destination of all exported hazardous waste (40 CFR )? Page 11 of 11 Rev. 2/99
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