AAM Environmental Compliance Checklist

Regulatory Areas and Compliance Checklists

Report Number
Facility Name
Conducted on
EPA ID#
Prepared by
Regulatory Programs
- RCRA
- Universal Waste
- Used Oil Management
- EPCRA
- CERCLA
- USTs
- Clean Water Act
- EMS (ISO 14001)

Audit Management

(1) All Notices of Violation or any other environment noncompliance from previous audits have been resolved
(2) Findings from previous internal regulatory audits have been closed.
(3) Closed findings from previous audits have been verified as effective. (List objective evidence in audit report)

Hazardous Waste Identification and Listing 40CFR Part 261

(1) The facility has documented that the waste(s) are a solid waste.
(2) Documents are maintained to verify certain materials are not a waste or is exempt from regulation
(3) The facility has determined if its wastes are hazardous wastes and are assigned the proper D,F, K, P and U codes?
(4) Containers or inner liners that previously held hazardous waste are in compliance with the following: (a) all wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, (e.g., pouring, pumping and aspirating) (b) no more than 2.5 centimeters (1 inch) of residue remain on the bottom of the container or inner liner (c) No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 119 gallons in size or (d) No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 119 gallons in size.
(5) Containers or inner liners that held an acute hazardous waste are: (a) triple rinsed (b) the inner liner is removed and disposed of properly.
(6) Containers which hold a compressed gas are punctured, depressurized, or in some way handled so the in the container approaches atmospheric.

Generators of Hazardous Waste 40CFR Part 262

(1) The facility generator status has been appropriately determined:
- VSQG: Generates no more than 100 kilograms of hazardous waste in a month.
- SQG: Generates greater than 100 kilograms but less than 1000 kilograms of hazardous waste in a calendar month
- LQG: Generates no more than 100 kilograms of hazardous waste in a month.
(2) The Autoliv facility has an EPA ID number and it is used on all appropriate documentation.
(3) The disposal facilities used has an EPA ID number.
(4) The transporters used has an EPA ID number.
(5) Manifest are filled out completely and correctly and copies kept from the hazardous waste shipments.
(6) The generator manifests are: (a) Signed by hand (b) Obtained the original handwritten signature copy of the manifest; in accordance with 262.40(a). (c) Generator gives the transporter the remaining copies of the manifest.
(7) The waste minimization certification has been signed for either small quantity generators or large quantity generators.
(8) Facility has a sound system in place to verify that signed manifest copies are received on time
(9) Exception Reporting: (a) If the manifest has not been received within 45 days, has an Exception Report been submitted to the EPA Regional Administrator.
(10) The facility has packaged the hazardous waste per 49 CFR Parts 173, 178 and 179. - 173 General Requirements for Shipments and Packaging's - 178 Specifications for Packaging - 179 Specifications for Tanks
(11) The facility has labeled waste containers per 49CFR Part 172 prior to transporting or offering for transport.
(12) The facility has marked waste containers per 49CFR Part 172.304: Hazardous Waste label and hazard label.
(13) Before transporting or offering hazardous waste for transportation off-site, the facility has placarded or offered the initial transporter the appropriate placards per 49CFR Part 172 Subpart F.

Large Quantity Generator (90 Day) & Small Quantity Generator (180)

(1) Is the facility maintained and operated to minimize the possibility of a 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.
(2) "No Smoking" signs are conspicuously placed wherever there is a hazard from ignitable or reactive wastes.
(3) Facility personnel have successfully completed a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance.
(4) The training is directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions they are employed.
(5) At a minimum the training program is designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems including where applicable: □ Procedures for using, inspecting, repairing and replacing facility emergency and monitoring equipment; □ Key parameters for automatic waste feed cut-off systems; □ Communications or alarm systems; □ Response to fires or explosions; □ Shutdown of operations.
(6) Facility personnel have successfully completed the training within six months after the date of their employment or assignment to a facility or to a new position at a facility.
(7) Facility personnel have taken part in an annual review of the initial training.
(8) The owner operator must maintain the following documents and records at the facility: □ Job title for each position at the facility related to hazardous waste management and the name of the employee filling the job; □ A written job description for each position . The description may be consistent with descriptions for other similar positions in the same company or bargaining unit, but must include the requisite skill, education or other qualifications assigned to each position; □ A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; person filling a position; □ Records that document that training or job experience required has been given to and completed by facility personnel.
(9) Training records on current personnel are kept until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records must accompany personnel transferred within the same company.
(10) Is the facility equipped with the following: □ An internal communications or alarm system capable of proving immediate emergency instruction (voice or signal) to facility personnel □ A device, such as a cell phone (immediately available at the scene of operations) or a hand-held two way radio, capable of summoning emergency assistance from local police departments, fire departments or State or local emergency response teams □ Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas or dry chemicals), spill control equipment and decontamination equipment; and □ Water at adequate volume and pressure to supply water hose streams or foam producing equipment or automatic sprinklers or water spray systems.
(11) Are all facility communications or alarms 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?
(12) Where hazardous waste is being poured, mixed, spread or otherwise handled, do all personnel involved in the operation have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee?
(13) If there is just one employee on the premises while the facility is operating, does he/she have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance?
(14) Is aisle space maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment to any area of facility operation in an emergency?
(15) Have arrangements been made, as appropriate, for the type of waste handled at the facility for potential need for services of these organizations: □ Arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility and possible evacuation routes; □ Where more than one police and fire department might respond to an emergency; agreements designating primary emergency authority to a specific police and a specific fire department and agreements with any others to provide support to the primary emergency authority; □ Agreements with State emergency response teams, emergency response contractors and equipment suppliers; □ Arrangements to familiarize local hospitals with properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility.

Transporters of Hazardous Waste 40CFR Part 263

(1) The transporter delivers the entire quantity of hazardous waste accepted from a generator or a transporter to: (a) the designated facility listed on the manifest, or (b) the alternated designated facility, or (c) the next designated transporter.
(2) Has the transporter complied with 40CFR 263.21(b)(2) (i)(ii) for rejected shipments?
(3) Does the transporter keep copies of the signed manifest for a period of three years from the date the hazardous waste was accepted by the initial transporter?

Large Quantity Generators

Is this facility a Large Quantity Generator
(1) Is the facility maintained and operated to minimize the possibility of a 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.
(2) "No Smoking" signs are conspicuously placed wherever there is a hazard from ignitable or reactive wastes.
(3) Facility personnel have successfully completed a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance.
(4) The training is directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions they are employed.
(5) At a minimum the training program is designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems including where applicable: □ Procedures for using, inspecting, repairing and replacing facility emergency and monitoring equipment; □ Key parameters for automatic waste feed cut-off systems; □ Communications or alarm systems; □ Response to fires or explosions; □ Shutdown of operations.
(6) Facility personnel have successfully completed the training within six months after the date of their employment or assignment to a facility or to a new position at a facility.
(7) Facility personnel have taken part in an annual review of the initial training.
(8) The owner operator must maintain the following documents and records at the facility: □ Job title for each position at the facility related to hazardous waste management and the name of the employee filling the job; □ A written job description for each position . The description may be consistent with descriptions for other similar positions in the same company or bargaining unit, but must include the requisite skill, education or other qualifications assigned to each position; □ A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; person filling a position; □ Records that document that training or job experience required has been given to and completed by facility personnel.
(9) Training records on current personnel are kept until closure of the facility . Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records must accompany personnel transferred within the same company.
(10) Is the facility equipped with the following: □ An internal communications or alarm system capable of proving immediate emergency instruction (voice or signal) to facility personnel; □ A device, such as a cell phone (immediately available at the scene of operations) or a hand-held two way radio, capable of summoning emergency assistance from local police departments, fire departments or State or local emergency response teams; □ Portable fire extinguishers, fire control equipment (including special extinguishing equipment, such as that using foam, inert gas or dry chemicals), spill control equipment and decontamination equipment; and □ Water at adequate volume and pressure to supply water hose streams or foam producing equipment or automatic sprinklers or water spray systems.
(11) Are all facility communications or alarms 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?
(12) Where hazardous waste is being poured, mixed, spread or otherwise handled, do all personnel involved in the operation have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee?
(13) If there is just one employee on the premises while the facility is operating, does he/she have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance?"
(14) Is aisle space maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment to any area of facility operation in an emergency?
(15) Have arrangements been made, as appropriate, for the type of waste handled at the facility for potential need for services of these organizations: □ Arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility and possible evacuation routes; □ Where more than one police and fire department might respond to an emergency; agreements designating primary emergency authority to a specific police and a specific fire department and agreements with any others to provide support to the primary emergency authority; □ Agreements with State emergency response teams, emergency response contractors and equipment suppliers; □ Arrangements to familiarize local hospitals with properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility.
(16) Documentation on file if State or local authorities decline to enter into such arrangements.
(17) Does the facility have a contingency plan and does it contain the following: □ A "Quick Reference Guide"? □ Actions facility personnel take in response to fires, explosions or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water at the facility; □ Arrangements agreed to by local police departments, fire departments, hospitals, contractors and State and local emergency response teams to coordinate emergency services; □ A list of names, addresses and phone numbers (office and home) of all persons qualified to act as emergency coordinator. Where more than one person is listed, one must be names as primary emergency coordinator and others must be listed in the order in which they will assume responsibility as alternates. List Primary
(18) Waste containers holding hazardous waste are in good condition.
(19) Containers used to hold hazardous wastes are compatible with the wastes. (a) Incompatible wastes or materials must not be placed in the same container; (b) Hazardous waste must not be placed in an unwashed container the previously held an incompatible waste or material; (c) a storage container holding a hazardous waste that is incompatible with any other materials stored nearby in other containers, piles open tanks or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall or other device.
(20) Containers holding hazardous waste are closed during storage except when it is necessary to add or remove waste.
(21) Containers holding hazardous waste are not opened, handled or stored in a manner which may rupture the containers or cause them to leak.
(22) Areas where containers are stored are inspected at least weekly.
(23) Containers holding ignitable or reactive waste must be located at least 15 meters from the facility's property line.
(24) The facility meets the Air Emissions Standards for Process Vents Subpart AA
(25) The facility meets the Air Emissions Standards for Equipment Leaks Subpart BB
(26) The facility meets the Air Emissions Standards for Tanks, Surface Impoundments and Containers Subpart CC
(1) Is the facility maintained and operated to minimize the possibility of a 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.
(2) "No Smoking" signs are conspicuously placed wherever there is a hazard from ignitable or reactive wastes.
(3) Facility associates have successfully completed on-the-job training that teaches them to perform their duties in a way that ensures the facility's environmental compliance. a) The training is directed by a person trained in hazardous waste management procedures, and includes instruction to facility associates on hazardous waste management procedures relevant to the positions they are employed.
(5) Facility personnel have successfully completed the training within six months after the date of their employment or assignment to a facility or to a new position at a facility.
(6) Facility personnel have taken part in an annual review of the initial training.
(7) The owner operator must maintain the following documents and records at the facility: - Job title for each position at the facility related to hazardous waste management and the name of the employee - Job description for each position, must include the requisite skill, education or other qualifications assigned to each position
(8) Training records on current personnel are kept until closure of the facility . Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records must accompany personnel transferred within the same company.
(9) Is the facility equipped with the following: - An internal communications or alarm system capable of proving immediate emergency instruction (voice or signal) - Cell phone (immediately available at the scene of operations) or a hand-held two way radios - Portable fire extinguishers, fire control equipment (including special extinguishing equipment) - Water at adequate volume and pressure to supply water hose streams or foam producing equipment or automatic sprinklers or water spray systems.
(10) Are all facility communications or alarms 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?
(11) Where hazardous waste is being poured, mixed, spread or otherwise handled, do all personnel involved in the operation have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee?
(12) If there is just one employee on the premises while the facility is operating, does he/she have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance?
(13) Is aisle space maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment to any area of facility operation in an emergency?
(14) Have arrangements been made, as appropriate, for the type of waste handled at the facility for potential need for services of these organizations: - Arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility and associated hazards, places where facility personnel would normally be working, entrances to roads inside the facility and possible evacuation routes - Where more than one police and fire department might respond to an emergency; agreements designating primary emergency authority to a specific police and a specific fire department and agreements with any others to provide support to the primary emergency authority; - Agreements with State emergency response teams, emergency response contractors and equipment suppliers; - Arrangements to familiarize local hospitals with properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility.
(15) Documentation on file if State or local authorities decline to enter into such arrangements.
(16) Does the facility have a contingency plan and does it contain the following: - A "Quick Reference Guide"? - Actions facility personnel take in response to fires, explosions or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water at the facility; - Arrangements agreed to by local police departments, fire departments, hospitals, contractors and State and local emergency response teams to coordinate emergency services; - A list of names, addresses and phone numbers (office and home) of all persons qualified to act as emergency coordinator. Where more than one person is listed, one must be names as primary emergency coordinator and others must be listed in the order in which they will assume responsibility as alternates.
(17) Is the contingency plan up to date?
(18) Waste containers holding hazardous waste are in good condition.
(19) Containers used to hold hazardous wastes are compatible with the wastes. (a) Incompatible wastes or materials must not be placed in the same container (b) Hazardous waste must not be placed in an unwashed container the previously held an incompatible waste or material; (c) a storage container holding a hazardous waste that is incompatible with any other materials stored nearby in other containers, piles open tanks or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall or other device.
(20) Containers holding hazardous waste are closed during storage except when it is necessary to add or remove waste
(21) Containers holding hazardous waste are not opened, handled or stored in a manner which may rupture the containers or cause them to leak.
(22) Areas where containers are stored are inspected at least weekly.
(23) Containers holding ignitable or reactive waste must be located at least 15 meters from the facility's property line.

Land Disposal Restrictions 40CFR Part 268

(1) The facility has determined and documented if a waste has to be treated before it can be land disposed. This is done either by testing the waste or process knowledge.
(2) Do the wastes meet applicable LDR standards.
(3) If the wastes are subject to 268.48 standards, are constituents of concern listed?
(4) Has the facility submitted an LDR form on the initial shipment of the waste(s) and on subsequent shipments if constituents or properties of the waste(s) changes. The LDR has the following information: (a) EPA hazardous waste codes (b) manifest number (c) whether the waste is a waste water or non-waste water (d) the subcategory of the waste determination, if applicable (e) that the waste is subject to the LDR and (f) the constituents of concern
(5) The facility has a written waste analysis plan if it manages prohibited wastes in tanks or containment buildings and treats the waste to meet applicable treatment standards.

Universal Wastes 40CFR Part 273

(1) Is the facility a small quantity handler of universal waste?
(2) Does the facility handle the following materials as universal waste: - Batteries - Pesticides - Mercury Containing Equipment - Lamps - Antifreeze - Aerosol can
(3) Are the universal wastes marked as follows: - Universal Waste-Batteries or Waste Batteries or Used Batteries? - Universal Waste-Pesticides or Waste Pesticides? - Universal Waste-Mercury Containing Equipment or Waste Mercury Containing Equipment or Used Mercury Containing Equipment or Universal Waste-Mercury Thermostats or Waste Mercury Thermostats or Used Mercury Thermostats
(4) Is the date that the universal waste was first generated marked on the waste or waste containers?
(5) Universal wastes have not been accumulated on site for more than one year from the date of generation.
(6) Universal waste containers are structurally sound, remain closed and lack evidence of leakage.
(7) All employees who handle or have responsibility for managing universal waste have been trained on proper handling and emergency procedures appropriate to the types of universal waste handled at the facility.
(8) Releases of universal wastes and other residues for universal wastes are immediately contained.
(9) The facility determined and documented whether materials from releases of universal waste are hazardous waste and are handled according to applicable requirements of 40CFR 260 through 272.
(10) The facility ships universal waste only to another universal waste handler, a destination facility or a foreign destination.
(11) If the facility self-transports the universal waste off-site, the facility complies with the requirements of subpart D of this part.
(12) The universal waste being shipped off-site is packaged, labeled, marked and placarded per 49CFR parts 172 through 180.

Used Oil 40CFR Part 279

(1) Used oil is stored in tanks or containers.
(2) The containers and above-ground tanks are in good condition and are not leaking.
(3) "Used Oil" is clearly marked or labeled on: containers, above-ground tanks and fill pipes used to transfer used oil.
(4) The facility has calculated the aggregate above-ground oil storage capacity.
(5) The facility has a Spill Prevention, Control and Countermeasure plan (SPCC) if the storage capacity exceeds 1320 gallons.
(6) The SPCC plan complies with 40CFR Part 112 Subpart A 112.7.

Part 300 National Oil and Hazardous Substances Pollution Contingency Plan

(1) The facility has notified the EPA that it has hazardous substances which are stored, treated or disposed of at the facility, or the facility has been properly permitted under RCRA.
(2) The facility maintains an inventory of potential inactive waste sites and the inventory includes: (a) the site location (b) the site history (c) facility responses to environmental problems
(3) Remediation activities are managed properly

Part 355 Emergency Planning

(1) Does the facility have any extremely hazardous substances (EHS) in an amount equal to or greater than its threshold planning quantity (TPQ) listed in Appendices A and B of this part.
(2) If there have been any releases of EHS above TPQ levels, have the notifications in the table in 40CFR 3355.20 been made?

Part 370 Hazardous Chemical Reporting: Community Right to Know

(1) Hazardous chemicals that require SDSs (Safety Data Sheets) and are present in amounts greater than 10,000 pounds have been identified.
(2) The facility has submitted SDSs to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and fire department(s) for hazardous substances on-site that exceeded the appropriate threshold quantity within 60 days after the facility first became subject to these requirements.
(3) Are revised SDSs provided to the SERC, LEPC and fire department(s) within three months after the discovery of significant new information concerning the hazardous chemical or after a chemical crosses the threshold limit?
(4) The facility has submitted Tier II reports to the SERC, LEPC and fire department(s) by March 1 each year for applicable substances.
(5) Does the facility have a method in place to notify the LEPC of changes at the facility that are relevant to emergency planning?

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

(1) Does the facility have ten or more employees and have a SIC code identified in 40CFR 372.22?
(2) Has the facility exceeded the following threshold levels: (a) Manufactured or processed 25,000 pounds per year or more of a toxic chemical or (b) otherwise used 10,000 pounds per year or more of a toxic chemical during the year.
(3) Has the facility submitted a completed Form R to the EPA on or before July 1 for each toxic chemical exceeding a reporting threshold?
(4) Does the facility retain the Form R and supporting documentation for three years?

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

(1) Does the facility verify that all ingredients of substances are on the TSCA list before manufacture or import?
(2) If the facility has manufactured or imported an item not on the TSCA list, was the TSCA Coordinator contacted?
(3) Does the facility manufacture or import for commercial purposes a TSCA listed chemical in an amount greater than 25,000 pounds?

PCBs Note: See documentation located on the Environmental Services

(1) Does the facility have documentation that it contains no PCBs?
(2) Does the facility have any transformers or capacitors on-site?
(3) Have transformers or equipment been identified as containing PCBs?
(4) Are all PCB liquids (>50 ppm), articles and containers (>500 ppm) incinerated at a permitted waste incinerator or otherwise disposed of using allowable methods per 40CFR 761.60?
(5) Does the facility have a corrective action plan to replace the PCB generating equipment?

Asbestos

(1) Does the facility have documentation that it does contain or does not contain asbestos?
(2) If the facility does have asbestos, is there a plan to prevent exposure?
(3) If asbestos has been removed from the site, was removal and disposal in accordance with RCRA guidelines?

Underground Storage Tanks 40CFR Part 280

(1) Does the facility have any USTs and if so, does the facility maintain and up to date list of the USTs?
(2) If USTs present, have the State or local UST implementing agency been notified of the existence of the USTs?
(3) Do the USTs have spill and overfill controls and corrosion protection?
(4) Do USTs have release detection systems that meet the standard (40CFR 280.40. 280.43 and 280.44)?
(5) Do USTs and underground piping have secondary containment?
(6) Does the facility have procedures in place to prevent leaks, spills and overflows when emptying or adding?

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

(1) Does the facility have an air permits? If no, skip to Part 82 below.
(2) Does the facility have air an emissions inventory?
(3) Does the facility have registration(s) for the minimum quantities of emissions?
(4) Is the facility aware of rather or not they are located in a non-attainment area?
(5) Does the air permit cover all applicable emissions and sources at the facility to include generators and fuel tanks?
(6) Is the facility in compliance with all reporting, monitoring, recordkeeping, calibration and operating requirements of the permit?
(7) Is the facility in compliance with any additional requirements of the permit?
(8) Are emission limits being met?
(9) If the facility is required to comply with NESHAP, PSD, NSR or other related regulations, is it in compliance with those regulations?
(10) Does the facility have air-conditioning and/or refrigeration equipment containing CFCs or HCFCs?
(11) Are technicians who maintain, service or repair CFC equipment at the facility properly certified as a Type I technician?
(12) Is equipment used for servicing, repairing and disposing of appliances certified to EPA 40CFR 82.1672(a)(b)(c) ?
(13) Are CFC recordkeeping and reporting requirements being met?

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

(1) Have all discharge points from the facility been identified?
(2) Does the facility have all necessary NPDES permits or exemption certifications on file?
(3) Facility personnel are aware of the penalties of violating permit conditions. (40CFR 122.41(a)(2))
(4) The facility properly operates and maintains (including adequate laboratory controls and quality assurance procedures) all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of the permit.
(5) Records of monitoring information required by the permit related to the permittee's sewage sludge use and disposal activities are retained for a period of at least five years.
(6) Records of all monitoring information, including calibration and maintenance records and original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by the permit and records of all data used to complete the application for this permit are retained for a period of at least 3 years.
(7) Records of monitoring information include: - The date, exact place and time of sampling or measurements; - The individual(s) who performed the sampling or measurements; - The date(s) analyses were performed; - The individual(s) who performed the analyses; - The analytical techniques or methods used; and - The results of such analyses.
(8) Monitoring reports are submitted at intervals specified in the permit.
(9) Any noncompliance which may endanger the health or the environment is reported orally within 24 hours from the time the facility becomes aware of the circumstances.
the time the facility becomes aware of the circumstances.
(10) A written submission was provided by the facility within 5 days of the time of becoming aware of the circumstances.
(11) The following information was reported within 24 hours of permit noncompliance awareness: - Any unanticipated bypass which exceeds any effluent limitation in the permit. - Any upset which exceeds any effluent limitation in the permit. - Violation of maximum daily discharge limitation for any of the pollutants listed in the permit.

Stormwater Permit

(1) Does the facility have a Stormwater Pollution Prevention Plan (SWP3) on site?
(2) Is the SWP3 current?
(3) Is the SWP3 available to the public?
(4) Have all training requirements mentioned in the stormwater permit been met?
(5) Have all monitoring requirements in the permit been met?
(6) Have all assessments or evaluations required in the permit been conducted?
(7) Have all other permit requirements been fulfilled?

Land Disposal Restrictions 40CFR Part 268

(1) The facility has determined and documented if a waste has to be treated before it can be land disposed. Either by testing the waste or process knowledge
(2) Do the wastes meet applicable LDR standards
(3) If the wastes are subject to 268.48 Universal Treatment table standards, are constituents of concern listed?
(4) Has the facility submitted an LDR form on the initial shipment of the waste(s) and on subsequent shipments if if constituents or properties of the waste(s) changes. The LDR has the following information: (a) EPA hazardous waste codes (b) manifest number (c) whether the waste is a waste water or non-waste water (d) the subcategory of the waste determination, if applicable (e) that the waste is subject to the LDR (f) the constituents of concern
(5) The facility has a written waste analysis plan if it manages prohibited wastes in tanks or containment buildings and treats the waste to meet applicable treatment standards

Universal Wastes 40CFR Part 273

(1) Does the facility handle any of the following materials as universal waste: □ Batteries □ Pesticides □ Mercury Containing Equipment □ Lamps □ Antifreeze □ Aerosol can
(2) Are the universal wastes marked as follows: □ Universal Waste-Batteries or Waste Batteries or Used Batteries? □ Universal Waste-Pesticides or Waste Pesticides? □ Universal Waste-Mercury Containing Equipment or Waste Mercury Containing Equipment or Used Mercury Containing Equipment or Universal Waste-Mercury Thermostats or Waste Mercury Thermostats or Used Mercury Thermostats
(4) Is the date that the universal waste was first generated marked on the waste or waste containers?
(5) Universal wastes have not been accumulated on site for more than one year from the date of generation.
(6) Universal waste containers are structurally sound, remain closed and lack evidence of leakage.
(7) All employees who handle or have responsibility for managing universal waste have been trained on proper handling and emergency procedures appropriate to the types of universal waste handled at the facility.
(8) Releases of universal wastes and other residues for universal wastes are immediately contained.
(9) The facility determined and documented whether materials from releases of universal waste are hazardous waste and are handled according to applicable requirements of 40CFR 260 through 272.
(10) The facility ships universal waste only to another universal waste handler, a destination facility or a foreign destination.
(11) If the facility self-transports the universal waste off-site, the facility complies with the requirements of subpart D of this part.
(12) The universal waste being shipped off-site is packaged, labeled, marked and placarded per 49CFR parts 172 through 180.
Does the facility store Used Oil 40CFR Part 279
(1) The used oil is stored in tanks or containers.
(2) The containers and above-ground tanks are in good condition and are not leaking.
(3) "Used Oil" is clearly marked or labeled on: containers, above-ground tanks and fill pipes used to transfer used oil.
(4) The facility has calculated the aggregate above-ground oil storage capacity.
(5) The facility has a Spill Prevention, Control and Countermeasure plan (SPCC) if the storage capacity exceeds 1320 gallons.
(6) The SPCC plan complies with 40CFR Part 112 Subpart A 112.7.

Superfund, Emergency Planning and Community Right-To-Know Programs 40CFR Parts 300, 355, 370 and 372

(1) The facility has notified the EPA that it has hazardous substances which are stored, treated or disposed of at the facility, or the facility has been properly permitted under RCRA.
(2) The facility maintains an inventory of potential inactive waste sites and the inventory includes: (a) the site location, (b) the site history and (c) facility responses to environmental problems.
(3) Remediation activities are managed properly.

Part 355 Emergency Planning

(1) Does the facility have any extremely hazardous substances (EHS) in an amount equal to or greater than its threshold planning quantity (TPQ) listed in Appendices A and B of this part.
(2) If there have been any releases of EHS above TPQ levels, have the notifications in the table in 40CFR 3355.20 been made?

Part 370 Hazardous Chemical Reporting: Community Right to Know

(1) Hazardous chemicals that require SDSs (Safety Data Sheets) and are present in amounts greater than 10,000 pounds have been identified.
(2) The facility has submitted SDSs to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and fire department(s) for hazardous substances on-site that exceeded the appropriate threshold quantity within 60 days after the facility first became subject to these requirements.
(3) Are revised SDSs provided to the SERC, LEPC and fire department(s) within three months after the discovery of significant new information concerning the hazardous chemical or after a chemical crosses the threshold limit?
(4) The facility has submitted Tier II reports to the SERC, LEPC and fire department(s) by March 1 each year for applicable substances.
(5) Does the facility have a method in place to notify the LEPC of changes at the facility that are relevant to emergency planning?

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

(1) Does the facility have ten or more employees and have a SIC code identified in 40CFR 372.22?
(2) Has the facility exceeded the following threshold levels: (a) Manufactured or processed 25,000 pounds per year or more of a toxic chemical or (b) otherwise used 10,000 pounds per year or more of a toxic chemical during the year.
(3) Has the facility submitted a completed Form R to the EPA on or before July 1 for each toxic chemical exceeding a reporting threshold?
(4) Does the facility retain the Form R and supporting documentation for three years?

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

(1) Does the facility verify that all ingredients of substances are on the TSCA list before manufacture or import?
(2) If the facility has manufactured or imported an item not on the TSCA list, was the TSCA Coordinator contacted?
(3) Does the facility manufacture or import for commercial purposes a TSCA listed chemical in an amount greater than 25,000 pounds?

PCBs Note: See documentation located on the Environmental Services

(1) Does the facility have documentation that it contains no PCBs?
(2) Does the facility have any transformers or capacitors on-site?
(3) Have transformers or equipment been identified as containing PCBs?
(4) Are all PCB liquids (>50 ppm), articles and containers (>500 ppm) incinerated at a permitted waste incinerator or otherwise disposed of using allowable methods per 40CFR 761.60?
(5) Does the facility have a corrective action plan to replace the PCB generating equipment?

Asbestos

(1) Does the facility have documentation to show it does contain or does not contain asbestos?
(2) If the facility does have asbestos, is there a plan to prevent exposure?
(3) If asbestos has been removed from the site, was removal and disposal in accordance with RCRA guidelines?

Underground Storage Tanks 40CFR Part 280

(1) Does the facility have any USTs and if so, does the facility maintain and up to date list of the USTs?
(2) If USTs present, have the State or local UST implementing agency been notified of the existence of the USTs?
(3) Do the USTs have spill and overfill controls and corrosion protection?
(4) Do USTs have release detection systems that meet the standard (40CFR 280.40. 280.43 and 280.44)?
(5) Do USTs and underground piping have secondary containment?
(6) Does the facility have procedures in place to prevent leaks, spills and overflows when emptying or adding?

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

(1) Does the facility have an air permits? If no, skip to Part 82 below.
(2) Does the facility have air an emissions inventory?
(3) Does the facility have registration(s) for the minimum quantities of emissions?
(4) Is the facility aware of rather or not they are located in a non-attainment area?
(5) Does the air permit cover all applicable emissions and sources at the facility to include generators and fuel tanks?
(6) Is the facility in compliance with all reporting, monitoring, recordkeeping, calibration and operating requirements of the permit?
(7) Is the facility in compliance with any additional requirements of the permit?
(8) Are emission limits being met?
(9) If the facility is required to comply with NESHAP, PSD, NSR or other related regulations, is it in compliance with those regulations?
(10) Does the facility have air-conditioning and/or refrigeration equipment containing CFCs or HCFCs?
(11) Are technicians who maintain, service or repair CFC equipment at the facility properly certified as a Type I technician?
(12) Is equipment used for servicing, repairing and disposing of appliances certified to EPA 40CFR 82.1672(a)(b)(c) ?
(13) Are CFC recordkeeping and reporting requirements being met?

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

(1) Have all discharge points from the facility been identified?
(2) Does the facility have all necessary NPDES permits or exemption certifications on file?
(3) Facility personnel are aware of the penalties of violating permit conditions. (40CFR 122.41(a)(2))
(4) The facility properly operates and maintains (including adequate laboratory controls and quality assurance procedures) all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of the permit.
(5) Records of monitoring information required by the permit related to the permittee's sewage sludge use and disposal activities are retained for a period of at least five years.
(6) Records of all monitoring information, including calibration and maintenance records and original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by the permit and records of all data used to complete the application for this permit are retained for a period of at least 3 years.
(7) Records of monitoring information include: □ The date, exact place and time of sampling or measurements; □ The individual(s) who performed the sampling or measurements; □ The date(s) analyses were performed; □ The individual(s) who performed the analyses; □ The analytical techniques or methods used; and □ The results of such analyses.
(8) Monitoring reports are submitted at intervals specified in the permit.
(9) Any noncompliance which may endanger the health or the environment is reported orally within 24 hours from the time the facility becomes aware of the circumstances.
(10) A written submission was provided by the facility within 5 days of the time of becoming aware of the circumstances.
(11) The following information was reported within 24 hours of permit noncompliance awareness: □ Any unanticipated bypass which exceeds any effluent limitation in the permit. □ Any upset which exceeds any effluent limitation in the permit. □ Violation of maximum daily discharge limitation for any of the pollutants listed in the permit.

Part 403

(1) Does facility have a pretreatment permit from the local municipality?
(2) Are facility discharges in compliance with the municipality requirements?
(3) If required, was proper notification given to the POTW and all other applicable regulatory agencies of applicable discharges?
(4) Has the facility complied with all recordkeeping, monitoring, testing and other requirements of the pretreatment permit?
(5) Does the facility have procedures in place to prevent prohibited discharges (e.g. excess heat, volume, flow, TSS, pH, oil and grease and other specific contaminants)?
(6) Have all employees involved in the discharge been properly trained?

Stormwater Permit

(1) Does the facility have a Stormwater Pollution Prevention Plan (SWP3) on site?
(2) Is the SWPPP current?
(3) Is the SWPPP available to the public?
(4) Have all training requirements mentioned in the stormwater permit been met?
(5) Have all monitoring requirements in the permit been met?
(6) Have all assessments or evaluations required in the permit been conducted?
(7) Have all other permit requirements been fulfilled?

AAM Environmental Compliance Checklist

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Audit Management

Hazardous Waste Identification and Listing 40CFR Part 261

Generators of Hazardous Waste 40CFR Part 262

Large Quantity Generator (90 Day) & Small Quantity Generator (180)

Transporters of Hazardous Waste 40CFR Part 263

Large Quantity Generators

Land Disposal Restrictions 40CFR Part 268

Universal Wastes 40CFR Part 273

Used Oil 40CFR Part 279

Part 300 National Oil and Hazardous Substances Pollution Contingency Plan

Part 355 Emergency Planning

Part 370 Hazardous Chemical Reporting: Community Right to Know

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

PCBs Note: See documentation located on the Environmental Services

Asbestos

Underground Storage Tanks 40CFR Part 280

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

Stormwater Permit

Land Disposal Restrictions 40CFR Part 268

Universal Wastes 40CFR Part 273

Superfund, Emergency Planning and Community Right-To-Know Programs 40CFR Parts 300, 355, 370 and 372

Part 355 Emergency Planning

Part 370 Hazardous Chemical Reporting: Community Right to Know

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

PCBs Note: See documentation located on the Environmental Services

Asbestos

Underground Storage Tanks 40CFR Part 280

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

Part 403

Stormwater Permit

Related checklists

AAM Environmental Compliance Checklist

Free AAM Environmental Compliance Checklist Checklist

Go digital today!

Convert your paper checklists into digital forms

Audit Management

Hazardous Waste Identification and Listing 40CFR Part 261

Generators of Hazardous Waste 40CFR Part 262

Large Quantity Generator (90 Day) & Small Quantity Generator (180)

Transporters of Hazardous Waste 40CFR Part 263

Large Quantity Generators

Land Disposal Restrictions 40CFR Part 268

Universal Wastes 40CFR Part 273

Used Oil 40CFR Part 279

Part 300 National Oil and Hazardous Substances Pollution Contingency Plan

Part 355 Emergency Planning

Part 370 Hazardous Chemical Reporting: Community Right to Know

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

PCBs Note: See documentation located on the Environmental Services

Asbestos

Underground Storage Tanks 40CFR Part 280

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

Stormwater Permit

Land Disposal Restrictions 40CFR Part 268

Universal Wastes 40CFR Part 273

Superfund, Emergency Planning and Community Right-To-Know Programs 40CFR Parts 300, 355, 370 and 372

Part 355 Emergency Planning

Part 370 Hazardous Chemical Reporting: Community Right to Know

Part 372 Toxic Chemical Release Reporting: Community Right-To-Know

Toxic Substances Control Act (TSCA) 40CFR Parts 704-711, 761 and 763

PCBs Note: See documentation located on the Environmental Services

Asbestos

Underground Storage Tanks 40CFR Part 280

Clean Air Act (CAA) 40CFR Parts 60, 82 and Facility Permit

Clean Water Act (CWA) 40CFR Parts 122, 403 and Stormwater Permits

Part 403

Stormwater Permit

Related checklists