Superfund Amendments and Reauthorization Act (SARA)

1. Emergency Planning and Community Right to Know (EPCRA)

  • 1.1 Tier II/HMBP assessment completed for existing/new chemicals

  • 1.2 Tier II/HMBP submitted by deadline

  • 1.3 Tier II/HMBP Report Records available for Previous 5 years or since start of operations.

2. Toxic Release Inventory (TRI) Reporting

  • 2.1 Annual usage of TRI chemicals assessed

  • 2.2 TRI report submitted by July 1st deadline, records available for previous 5 years or since start of operations

  • 2.3 Pollution Prevention Plan reviewed and summary submitted annually

  • 2.4 Pollution Prevention Progress Report submitted by July 1st deadline

Resource Conservation and Recovery Act (RCRA)

3. Waste Management

  • 3.1 Waste profiles and reporting current

  • 3.2 Employee training current and documentd

  • 3.3 Waste properly disposed

  • 3.4 "2 signature" and "3 signature" copies of each manifest available, if use manifest

  • 3.5 Shipping manifests or other shipping documentation available for at least 3 years

  • 3.6 California only: EPA ID Verification completed (annual)

4. Waste Storage Area(s)

  • 4.1 Spill kit accessible

  • 4.2 Spill kit contains absorbents

  • 4.3 Spill kit contains PPE

  • 4.4 Fire Extinguisher accessible

  • 4.5 Fire extinguishers inspected and maintained as required

  • 4.6 Employee readily available or within short distance to respond to emergency situation

  • 4.7 Emergency response phone posting at storage areas

  • 4.8 Waste storage area labeled

  • 4.9 Waste stored on impervious surface with 100% containment

  • 4.10 Imcompatible wastes are adequately separated

  • 4.11 Storage areas free of spills and/or leaks

  • 4.12 Aisle spacing sufficient

  • 4.13 Accumulation amount within generator quantity

5. Waste Container Management and Inspection

  • 5.1 Containers (drums, boxes, pails) closed and/ or funnel lids latched

  • 5.2 Containers labeled with the words "Hazardous Waste"

  • 5.3 Container label clearly indicates contents

  • 5.4 Containers labeled with accumulation start dates

  • 5.5 Container tops free of spillage

  • 5.6 Containers are compatible with wastes stored

  • 5.7 Containers are in good condition

  • 5.8 Flammable waste containers properly grounded and bonded

  • 5.9 Documented inspections of all Containers completed at least every 7 days

  • 5.10 Inspection records available for at least 3 years

6. Satellite Accumulation

  • 6.1 Satellite Accumulation areas do not exceed 55 gallons of storage

  • 6.2 Satellite containers stored at point of waste generation

  • 6.3 Satellite accumulation containers dated correctly

  • 6.4 Spill kit accessible and stocked

7. Universal Waste Batteries

  • 7.1 Batteries (lead acid, rechargeable) are properly stored

  • 7.2 Any waste batteries showing evidence of leakage, spillage, or damage stored in closed, structurally sound, compatible container

  • 7.3 Waste batteries stored in closed container

  • 7.4 Waste batteries stored in container labeled with contents

  • 7.5 Waste batteries container(s) labeled with accumulation start date

  • 7.6 Waste batteries packaged so terminals will not come in contact with each other

  • 7.7 Waste batteries shipped offsite within 1 year of accumulation start date

  • 7.8 Waste battery shipping documentation available for at least 3 years

  • 7.9 Waste batteries recycled

  • 7.10 Spill kit accessible and stocked appropriately for waste batteries storage

8. Universal Waste Lamps

  • 8.1 Any broken lamps are stored separately in sealed container labeled with contents

  • 8.2 Waste lamps container closed unless lamps are being added or removed

  • 8.3 Waste lamps stored in container(s) labeled with contents

  • 8.4 Waste lamp container(s) labeled with accumulation start date

  • 8.5 Waste lamps shipped offsite within 1 year

  • 8.6 Waste lamp shipping documentation available for at least 3 years

  • 8.7 Waste lamps recycled

  • 8.8 Spill kit accessible and stocked appropriately for waste lamp storage

9. Used Oil

  • 9.1 Used oil containers are in good condition

  • 9.2 Used oil containers are closed and/or funnel lids are attached unless oil is being added or removed

  • 9.3 Used oil containers are labeled as "Used Oil"

  • 9.4 Empty oil containers for reuse are designated as empty

  • 9.5 Used oil is not mixed with other wastes

  • 9.6 Used oil is shipped with registered waste hauler with EPA ID number

  • 9.7 Used oil shipping documentation available for at least 3 years

  • 9.8 Used oil is recycled

  • 9.9 Spill kit is accessible and stocked appropriately for used oil storage

Clean Water Act

10 Wastewater- Industrial Discharge

  • 10.1 All waste water discharges evaluated/approved

  • 10.2 Discharge Permit current

  • 10.3 Reporting current

  • 10.4 Sampling current and within limits

  • 10.5 Spill/Slug/TTO Plan

11 Storm Water

  • 11.1 No Exposure Certification maintained

  • 11.2 Storm water permit current

  • 11.3 Pollution Prevention Plan current

  • 11.4 Best Management Practices sufficient for current outdoor storage

  • 11.5 Inspections/Visual current

  • 11.6 Sampling (analytical) current and within limits

  • 11.7 Reporting current

  • 11.8 Training current

  • 11.9 Outdoor area free from process water discharges and drips from haul trucks

  • Surface waters free of debris

12. Spill Prevention, Control, and Countermeasures (SPCC)

  • 12.1 SPCC Plan current

  • 12.2 Inspections current

  • 12.3 Training current

  • 12.4 Secondary containment adequate (passive and active)

  • 12.5 Containment drain valve closed

  • 12.6 No signs of leakage around tank, containment, or ground

  • 12.7 Tank liquid level gauge readable and in good condition

Clean Air Act

13. Air Permitting

  • 13.1 Emission units assessed

  • 13.2 Air Permit current

  • 13.3 Air Permit available onsite

  • 13.4 Material usage/emissions record keeping current and within limits

  • 13.5 Reporting current

  • 13.6 Greenhouse Gas Reporting current, if required

  • 13.7 Compliance testing current and within limits

  • 13.8 Operating and Maintenance Plan current

  • 13.9 Operating requirement: Daily fugitive and visual emission inspections

  • 13.10 Operating requirement: Maintain records of equipment maintenance

  • 13.11 Operating requirement: Keep equipment functioning to manufacturers specs and perform annual tune-up as specified by the manufacturer.

14. Ozone Depleting Substance (ODS)

  • 14.1 Current refrigerant equipment inventory

  • 14.2 Service orders for maintenance of all ODS refrigerant units

  • 14.3 Certifications of service personnel available onsite

  • 14.4 Service and refrigerant log books current

  • 14.5 Leak rate tracking log current for 50 lb and greater units

  • 14.6 Leak repair and reporting current, if needed

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