SMALL QUANTITY GENERATOR CHECKLIST Note: The Oklahoma Hazardous Waste Management Regulations [OK Adm. Code (OAC) 252:205] incorporates by reference at OAC 252:205-3-2 the applicable federal hazardous waste and used oil regulations of 40 CFR 260-279. 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 greater than 100 kg but less than 1000 kg of hazardous waste per month. Section A - Notification (40 CFR 262.12) Does Generator have EPA ID Number: Section B - Hazardous Waste Determination (40 CFR 262.11) 1. Does generator generate hazardous waste(s) listed in Subpart D (40 CFR 261.30-261.33)? *If yes, list wastes and quantities on attachment. (Include Hazardous Waste Codes & provide waste name and description) 2. Does generator generate solid waste(s) that exhibit hazardous characteristics (Corrosivity, ignitability, reactivity, TCLP - 40 CFR 261.20-261.24)? 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. If equivalent test methods used, attach copy of equivalent methods used. 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 Page 1 of 10
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. If equivalent test methods are used, attach copy of equivalent method used. b. List wastes and quantities deemed nonhazardous 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 (40 CFR 262.11)? *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. 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) Page 2 of 10
1. Does generator ship hazardous waste off-site? a. *If No, Go to Section E - Satellite Accumulation b. *IF Yes, does the generator process or dispose of the hazardous waste at an on-site facility, or ensure delivery to an off-site storage, processing, or disposal facility, which is (Circle those that apply): i. Permitted facility ii. Interim status iii. Permitted, licensed or registered by a state to manage municipal or industrial solid waste iv. A facility which beneficially uses or recycles hazardous waste. c. Identify primary off-site facilities. 2. Does generator use a manifest? by DEQ? *If yes, is manifest form approved (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 262.20)? 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) 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 Page 3 of 10
k. Transporter's OK ID number l. Transporter's telephone number 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. Does the generator properly complete the manifest [40 CFR 262.20 (a - b)]? 7. Did generator obtain handwritten signature and date of acceptance from initial transporter [40 CFR 262.23(a)]? 8. Does generator retain for three years copies of manifests transporter, and TSD facility [40 CFR 262.23(a)/262.40(a)]? 9. If copy of manifest from facility was not returned within 60 days, did generator file an exception report [40 CFR 262.42 (b)]? *If yes, did it contain the following information: a. Legible copy of manifest b. Explanation that waste on returned copy of manifest Page 4 of 10
was not received. Section D - Pre-transport Requirements (40 CFR 262, Subpart C) (These requirements apply only to containers that are being offered for shipment offsite, at time of the inspection) 1. Does generator package waste? *If no, Go to Section E - Satellite Accumulation yes, continue *If 2. Does generator package waste in accordance with 49 CFR 173, 178 and 179 (DOT requirements - 40 CFR 262.30)? 3. Does generator follow DOT labeling requirements before transport in and mark each accordance with 49 CFR Part 172 (40 CFR 262.31)? 4. Does the generator mark each package before transport in accordance with 49 CFR 172 (40 CFR 262.32)? 5. Is each container of 110 gallons or less marked with the following label before transport (40 CFR 262.32)? HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If fournd, 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 262.33)? Section E - Satellite Accumulation [40 CFR 262.34(c)] 1. Does the generator accumulate waste in containers at or near "satellite" generation points? *If no, Go to Section F - Preparedness and Prevention *If yes, continue. 2. Are containers in good condition? Page 5 of 10
3. Is the waste compatible with the containers? 4. Is waste transferred from leaking containers or otherwise managed to control leakage? 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 (40 CFR 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 262.34) 1. Is facility a: permitted storage facility generator only facility (< 180 days [270]) 2. If generator only facility: a. Does the generator allow waste to accumulate more than 180 days (or 270 days if he must transport his waste, or offer his waste for transportation, over a distance of 200 miles or more) becoming an operator of a storage facility and subject to the requirements of 40 CFR parts 264 and 265 and the permit requirements of 40 CFR 270 [40 CFR 262.34 (f)]? b. Has the quantity of waste accumulated on-site exceeded 6,000 kilograms (13,200 lbs)? c. Is waste stored in containers and/or tanks? (circle as appropriate) **Complete the appropriate container &/or tank checklist(s). Page 6 of 10
Section G - Preparedness and Prevention [40 CFR 262.34(d)/265 Subpart C] 1. Does facility have an emergency coordinator on site or within short driving distance [40 CFR 262.34(d)(5)(i)]? Who is the emergency coordinator? Name Title 2. Is the following information next to telephone [40 CFR 262.34(d)(5)(ii)]: a. Name & telephone number of emergency coordinator? b. Location of fire extinguishers & spill control material & fire alarms? c. Telephone number of fire department unless equipped with direct alarm? 3. Does generator familiarize employees with proper waste handling & emergency procedures [40 CFR 262.34(d)(5)(iii)]? 4. Is emergency coordinator familiar with responses to emergencies [40 CFR 262.34(d)(5)(iv)]? 5. Is there evidence of fire, explosion or any unplanned release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment? (40 CFR 265.31)? explain. *If yes, use narrative explanation sheet(s) to 6. Has an incident occurred requiring the facility to immediately notify the DEQ (OAC 252:200-3-2 and 252:200-13-2)? sheet(s) to explain. *If yes, use narrative explanation 7. Is the facility equipped, if applicable, with the following (40 CFR 265.32): Page 7 of 10
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, spr spray system? i. Describe source of water: storage ii. Indicate flow rate and/or pressure and capacity if known: 8. 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 265.34)? 9. 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 265.33)? 10. Is there sufficient aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment (40 CFR 265.35)? 11. 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 Page 8 of 10
265.37(a)(1)]? *If no, has the owner/operator attempted to make such arrangements? 12. In the case that more than one police or fire department might respond, is there a designated primary authority [40 CFR 265.37(a)(2)]? a. *If yes, indicate primary authority: b. Is the fire department a city or volunteer fire department? 13. Does the owner/operator have phone numbers of and agreements with emergency response contractors [40 CFR 265.37(a)(3)]? 14. 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? this? *If no, has the owner/operator attempted to do 15. 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 265.37 (b)]? Section H - Recordkeeping and Reporting (40 CFR 262.44) Note: For hazardous waste generated or accumulated in quantities greater than 100 kg but less than 1,000 kg per month. 1. Does Generator reclaim waste under a contractual agreement [40 CFR 262.20(e)]? *If no, go to question 2. *If yes: a. Does agreement specify, i. Type of waste? ii. Frequency of shipments? Page 9 of 10
b. Is vehicle used to transport waste to recycling facility and regenerated material to generator owned and operated by the reclaimer? c. Does generator maintain copy of reclamation agreement for 3 years after its termination? 2. Does the generator maintain the following records and reports (if applicable) three years (40 CFR 262.44): a. Shipping Manifest? b. Test and Analyses? c. Exception Report? Section I - 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 262.52/262.53]? 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 262.56)? Page 10 of 10