EPA Annual Audit

• Safety and Regulatory Compliance Department Internal Audit Report

• Location Code:

• Inspection Date:

  Date

• Auditor:

  Select Ellen Dolinar Brent Grandidier Brandon Keeling Russell Parks Max Vernon

  • Ellen Dolinar
  • Brent Grandidier
  • Brandon Keeling
  • Russell Parks
  • Max Vernon

• Debriefed (Name and Title):

• Response Due By:

  Date

EPA Binder

• Select Site's Classification:

  SQG

  VSQG

• ID Number: Expiration Date:

• Is a copy of the Site's EPA Waste Permit/Number in the EPA Binder?<br>40 CFR 262.12(a)

  N/A

  N/O

  Compliant

  Class B

• Site's Waste Records (and associated documents) contain Hazardous Waste, Universal Waste, Used Oil, Non-Hazardous Manifests, and/or Bills-Of-Lading... as applicable?

  N/A

  N/O

  Compliant

  Class B

• Site's Waste Records (and associated documents) contain External Audits, Inspections, and/or Correspondence?

  N/A

  N/O

  Compliant

  Class B

• Confirm that Weekly Inspections of Waste Storage Areas are being performed, logged, and affectively conducted?<br>40 CFR 265.174

  N/A

  N/O

  Compliant

  Class B

Training

• Site has a current Environmental Coordinator (EC)?

  N/A

  N/O

  Compliant

  Class A

• Employee Name: Training Date:

• Most current EC training records/certificates are on file in EPA Binder and are retrievable for 36 Months?<br>40 CFR 265.16(e)

  N/A

  N/O

  Compliant

  Class B

Hazardous Waste Manifest

• Return To Generator Hazardous Waste Manifests are reconciled within the Time Limit (within 60 days of Shipment Date)?<br>List finding(s) in details.<br>40 CFR 262.42

  N/A

  N/O

  Compliant

  Class B

• Site only uses DOT or EPA Certified personnel to sign as Generator Offerer?<br>49 CFR 172.205 and 40 CFR 262.34(d)(5)

  N/A

  N/O

  Compliant

  Class A

• Hazardous Waste Manifests are maintained, with a minimum of 36 Rolling Months being immediately available?<br>40 CFR 262.40(a)

  N/A

  N/O

  Compliant

  Class B

• Confirm that Site uses a Permitted Hazardous Waste Transporter (and) a Permitted Treatment, Storage, and Disposal Facility (TSDF)?<br>40 CFR 262.12(c)<br>List Transporter and TSDF in details.

  N/A

  N/O

  Compliant

  Class A

Emergency Preparedness

• Either Landlines or Cell Phones are available, at or near the Scene of Waste Operations?<br>40 CFR 265.34(b)

  N/A

  N/O

  Compliant

  Class B

• Republic Safety Hotline is posted, at or near the Scene of Waste Operations?

  N/A

  N/O

  Compliant

  Class B

• Local Emergency Information is posted, at or near the Scene of Waste Operations?<br>40 CFR 262.34(d)(5)(ii)

  N/A

  N/O

  Compliant

  Class B

• MSDS Information (Posters or Stickers) is posted, at or near the Scene of Waste Operations?<br>1910.1200(g)(8)

  N/A

  N/O

  Compliant

  Concern

• A No Smoking Sign is posted, at or near the Scene of Waste Operations?

  N/A

  N/O

  Compliant

  Class B

• Fire Extinguishing Equipment is located, at or near the Scene of Waste Operations (~ 50 feet max)?<br>40 CFR 265.32(c) & 29 CFR 1910.157(d)(4)

  N/A

  N/O

  Compliant

  Class B

• Spill Clean-up Kits and/or Materials are provided, at or near the Scene of Waste Operations?<br>29 CFR 1910.106(e)(2)(iv)(b)

  N/A

  N/O

  Compliant

  Class B

Hazardous Waste Management

• Used and/or Contaminated Flammable Paints and Flammable Solvents (MEK, Isopropyl Alcohol, Acetone), are managed as Hazardous Waste?<br>40 CFR 261.3

  N/A

  N/O

  Compliant

  Class B

• Spill Clean-up Materials (Pigs, Absorbant, Mats, Rags, etc) contaminated with Flammable Paints and Flammable Solvents (MEK, Isopropyl Alcohol, Acetone), are managed as Hazardous Waste?<br>40 CFR 261.3

  N/A

  N/O

  Compliant

  Class B

• Rags contaminated with Flammable Solvents are managed as:

  Select Recycled Laundered Hazardous Waste Red Rag Container

  • Recycled
  • Laundered
  • Hazardous Waste
  • Red Rag Container

• Spent and/or Fired O2 Generators are managed as Hazardous Waste?<br>40 CFR 261.3

  N/A

  N/O

  Compliant

  Class B

• "Broken" Fluorescent Lamps and Residue are managed as Hazardous Waste?

  N/A

  N/O

  Compliant

  Concern

• Used, Spent, Empty Aerosol Cans (Flammables and/or Corrosives) are managed as Hazardous Waste [40 CFR 261.7(b)(2)] or are properly purged via an Aerosol Can Puncture Unit?

  N/A

  N/O

  Compliant

  Class B

• Aerosol Cans are managed as:

  Hazardous Waste

  Aerosol Can Puncture Unit

Expired "Regulated" Material

• Expired "Regulated" Material is managed as Hazardous Waste?<br>40 CFR 261.33

  N/A

  N/O

  Compliant

  Class B

• Expired "Regulated" Material (Hazardous Waste) is moved immediately to the appropriate Hazardous Waste Container (no intermediate staging)?

  N/A

  N/O

  Compliant

  Class B

Fluorescent Lamps - Universal Waste Management

• Are Used, "Intact/Unbroken" Fluorescent Lamps generated at this Site?

  Yes

  No

• Fluorescent Lamp Area

Area

• Accumulation Area Designation:

• Fluorescent Lamp Universal Waste Accumulation Area is managed and placarded as Universal Waste?<br>40 CFR 273.13(d)

  N/A

  N/O

  Compliant

  Class B

• Fluorescent Lamp Universal Waste Accumulation Containers are labeled Universal Waste Lamps, Waste Lamps, or Used Lamps?<br>40 CFR 273.14(e)

  N/A

  N/O

  Compliant

  Class B

• Fluorescent Lamp Universal Waste Accumulation Containers are Closed and Secured?<br>40 CFR 265.171

  N/A

  N/O

  Compliant

  Class B

• Fluorescent Lamp Universal Waste Accumulation Containers have been Dated when the first UW was placed into the Container?<br>40 CFR 273.15(c)

  N/A

  N/O

  Compliant

  Class B

• No Containers of Universal Waste have been on-site for more than 365 Days?<br>40 CFR 273.15(b)

  N/A

  N/O

  Compliant

  Class B

• There are no Broken Lamps in the Universal Waste Container.

  N/A

  N/O

  Compliant

  Class A

Batteries - Universal Waste Management

• Are Used Lead-Acid Batteries, Ni-Cad Batteries, or Lithium Batteries generated at this Site?

  Yes

  No

• Battery Accumulation Area

Area

• Accumulation Area Designation:

• Accumulation Area for Universal Waste Batteries are managed and placarded as Universal Waste?<br>40 CFR 273.13(a)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Universal Waste Batteries are labeled Universal Waste Battery(ies), Waste Battery(ies), or Used Battery(ies)?<br>40 CFR 273.14(a)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Universal Waste Batteries are Closed?<br>40 CFR 264.173(a)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Universal Waste Batteries have been Dated when the First UW was placed into the Container?<br>40 CFR 273.15(c)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Universal Waste Batteries have been on-site for less than 365 Days?<br>40 CFR 273.15(b)

  N/A

  N/O

  Compliant

  Class B

Mercury - Universal Waste Management

• Are Mercury Containing Equipment (Switches/Thermostats/Devices) generated at this Site?<br>

  Yes

  No

• Mercury Accumulation Area

Area

• Accumulation Area Designation:

• Mercury Containing Equipment (Switches/Thermostats/Devices) are managed and area is placarded as Universal Waste?<br>40 CFR 273.13(c)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Mercury Containing Equipment (Switches/Thermostats/Devices) are marked Universal Waste Mercury Containing Equipment, Waste Mercury Containing Equipment, or Used Mercury Containing Equipment?<br>40 CFR 273.14(d)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Mercury Containing Equipment (Switches/Thermostats/Devices) have been Dated when the First UW was placed into the Container?<br>40 CFR 273.15(c)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Mercury Containing Equipment (Switches/Thermostats/Devices) have been on-site for less than 365 Days?<br>40 CFR 273.15(b)

  N/A

  N/O

  Compliant

  Class B

Hazardous Waste Container / Area Management

• Is there a Hazardous Waste Accumulation Area at this Site?

  Yes

  No

• Hazardous Waste Accumulation Area

Area

• Type of Accumulation Area: Accumulation Area Designation:

• Hazardous Waste Accumulation Area is Placarded as such?<br>SAFE 3.5.8

  N/A

  N/O

  Compliant

  Class B

• Hazardous Waste Accumulation Area is Free of Spills and/or Leaks?<br>40 CFR 265.174

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers for "Liquid" Hazardous Waste have Secondary Containment, which are free of excessive liquids?<br>40 CFR 264.175

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers for Hazardous Waste are Closed & Secured?<br>40 CFR 264.173

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers for Hazardous Waste are in good condition (40 CFR 265.171) and compatible with the contents (40 CFR 265.172)?

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers are legibly Labeled with contents identified?

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers for Hazardous Waste are Labeled or Marked as Hazardous Waste [40 CFR 262.34(a)(3)] and have the appropriate Hazard Classification Label on the Container?

  N/A

  N/O

  Compliant

  Class B

• All Accumulation Containers for Hazardous Waste are Dated (CAA - 180 Day Area) or Not Dated (SAA)?<br>40 CFR 262.34(c)(2)

  N/A

  N/O

  Compliant

  Class B

• Total quantity of Hazardous Waste in any one Satellite Accumulation Area is < 55 Gallons?<br>40 CFR 262.34(c)(1)

  N/A

  N/O

  Compliant

  Class B

• Are all Waste Containers properly separated by Type (Hazardous, Universal, Used Oil), so that they are not encroaching into another Waste Area? <br>40 CFR 265.177(c)

  N/A

  N/O

  Compliant

  Concern

• Exterior Hazardous Waste Storage Areas are protected from the weather?<br>SAFE 3

  N/A

  N/O

  Compliant

  Concern

Oil Management

• Is Oil "Consumed and/or Dispensed" at this Site?

  Yes

  No

• Empty Oil Containers are Satisfactorily Drained before Disposal?

  N/A

  N/O

  Compliant

  Class B

• Empty Oil Containers are Recycled or Trashed?

  Recycled

  Trashed

• Is "Used Oil" generated and managed as "Used Oil" at this Site?

  Yes

  No

• Used Oil Area

Area

• Accumulation Area Designation:

• Accumuation Area for Used Oil is placarded as Used Oil?

  N/A

  N/O

  Compliant

  Concern

• Accumulation Containers for Used Oil are marked as "Used Oil"?<br>40 CFR 279.22(c)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Used Oil have Secondary Containment?<br>40 CFR 264.175

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Used Oil, with Lids/Caps/Funnels are DOT certified and Closed?<br>40 CFR 279.22

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Used Oil are separated from Oxidizers by 20 feet, or an appropriate barrier? <br>49 CFR 177.848

  N/A

  N/O

  Compliant

  Class B

• Are "Used Oil Filters" generated at this Site?

  Yes

  No

• Used Oil Filter Containment

Container

• Used Oil Filter Accumulation Containers are marked as "Used Oil Filters"?<br>40 CFR 279.22(c)

  N/A

  N/O

  Compliant

  Class B

• Used Oil Filters are appropriately "Hot Drained", prior to placing in the Accumulation Container?<br>40 CFR 261.4(b)(13)

  N/A

  N/O

  Compliant

  Class B

• Accumulation Containers for Used Oil Filters have Secondary Containment?<br>40 CFR 264.175

  N/A

  N/O

  Compliant

  Concern

• Exterior Used Oil Storage Areas are protected from the weather?<br>SAFE 3

  N/A

  N/O

  Compliant

  Concern

Fuel Management

• Is Waste Fuel generated at this Site?

  Yes

  No

• Waste Fuel is picked up/blended with Used Oil?

  N/A

  N/O

  Compliant

  Class B

• Waste Fuel is picked up as Hazardous Waste?

  N/A

  N/O

  Compliant

  Class B

Aircraft Drinking Water Rule

• Is there a Potable Water Cabinet or Station?

  Yes

  No

• Potable Water Cabinet

Cabinet

• Area Designation and Cabinet Identifier:

• Potable Water Cabinet / Station Doors are Closed, and No Unrelated Material on Top?

  N/A

  N/O

  Compliant

  Concern

• Potable Water Cabinet / Station Interior is Clean, with no Excessive Leaks?

  N/A

  N/O

  Compliant

  Class B

• Potable Water Cabinet / Station Hose is Secured to Post on inside (or) has Cap to Prevent Contamination.

  N/A

  N/O

  Compliant

  Class B

• Is there an AWOCS Unit?

  Yes

  No

• AWOCS Unit

Unit

• Area Designation and Unit Identifier:

• Unit is Clean, with Connection Ports either Capped or Otherwise Protected?

  N/A

  N/O

  Compliant

  Class B

• If Unit has Pre-Filter, has it been Changed within the last 365 Days?

  N/A

  N/O

  Compliant

  Concern

Miscellaneous

• Is there a Room/Cabinet/Other Area, utilized at the Ramp?

  Yes

  No

  NA

• Review Area and note all details, which might inlcude Findings.

• Are there Outside Areas (Bone Yard) that need to be reviewed?

  Yes

  No

• Review Outside Areas and note all details, which might include Findings.

• General Observations: