1-6
1. Wastes must be characterized and coordinated with the Hazardous Waste Program Manager(HWPM - 355 CES Environmental) or HAZMART to determine proper management and disposal. [40 CFR 261 and 262, D-M HWMP 1.6, Table 4-2,Appendix R (Tab B)]
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a) Verify all hazardous materials used are authorized through EESOH-MIS (unless exempt)
b) Verify each workplace maintains a current list of wastes generated along with proper disposal procedures (in Tab B of their Hazardous Waste Record Book as prescribed in Appendix R for SAAs or elsewhere for non-SAAs)
Note: units who track hazardous materials in EESOH-MIS but do not have an SAA must maintain a list of wastes (using Appendix R as a template) but are exempted from the other Hazardous Waste record keeping requirements in Appendix R. -
ECAMP Category: HW.10.1.US Major
2. SAA managers must be appointed in writing and letter of designation maintained in Tab A of HazWaste Record Book [AFI 32-7042, Para 2.5.1.2, D-M HWMP 1.4.4]
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a) Verify personnel on the appointment letter signed by supervisor are still assigned to the unit and have SAA duties (can be TDY or on leave).
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ECAMP Category: HW.2.1.AF Minor
3. SAAs must be inspected weekly (Once a calendar week). [D-M HWMP 3.3.5, Appendix O, Tab D of HW Records]
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a) Verify Inspection checklists must have the inspector’s name, signature (not initials), the inspection date(including year), the inspection time, and identify the locations, which are inspected.
b) Verify completed weekly inspection records are maintained by the SAA manager for a minimum of 3 years -
ECAMP Category: HW.2.1.AF Minor
4. Personnel who handle hazardous waste must be trained in hazardous waste management and training must be documented. [AFI 32-7042, Para. 2.3.1, D-M HWMP section 5 Appendix N, Tabs E & F of HW Record Book]
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a) Verify that new employee training is completed within 3months of beginning hazardous waste management activities.
b) Do personnel who generate or handle HW at SAAs receive the initial RCRA training course taught by CEIE or delegate within 3 months of beginning duties?
c) Verify that personnel ALSO receive annual “Workplace Specific” training by SAA managers.
d) Verify that SAA managers receive annual training from the HWPM.
e) Verify RCRA training is documented IAW Appendix N of the DM HWMP.
f) Are copies of local training records documenting RCRA training maintained for 3 years [AFI 32-7042, par 2.3.3]? -
ECAMP Category: HW.60.1.US, HW.10.6.AF, HW.2.1.AF Minor
5. The current Davis-Monthan (HWMP) must be readily accessible [D-M HWMP App. R]
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a) Verify a copy of the current plan or the URL to the link in eDASH is in Tab G of the HW Records book
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ECAMP Category: HW.2.1.AF Minor
6. RCRA Wastes must be stored at or near the point of generation. [40 CFR 262.34(c)(1), D-M HWMP 3.3]
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a) Verify there are no temporary accumulation sites where RCRA wastes accumulate prior to being put in the SAA waste drums
b) Verify RCRA wastes are not accepted from other workplaces - this includes aerosol cans.
c) Verify that vacuums used to clean up hazardous waste are either emptied into containers at the SAA immediately after use, OR marked as waste containers and stored at the SAA. -
ECAMP Category: HW.75.1.US Major
7-13
7. RCRA wastes must be under the control of the generator [40 CFR 262.34(c)(1)(i), DM HWMP 3.3]
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a) Verify RCRA waste containers are stored in secure areas, and if stored outside are locked.
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ECAMP Category: HW.75.1.US Major
8. Signs showing SAA manager(s), and RCRA wastes must be signed by HWPM and posted at the SAA [D-M HWMP 3.3.1, Appendix K]
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a) Verify the sign is signed by the HWPM
b) the RCRA wastes on the sign match the actual wastes stored
c) Signs are legible (not faded or water-damaged) -
ECAMP Category: HW.2.1.AF Minor
9. Containers must be in good condition [40 CFR 262.34(c)(1)(i), and 40 CFR 265.171]
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a) No leaks, bulges, or creases.
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ECAMP Category: HW.75.1.US Major
10. RCRA containers must be kept closed when not adding waste [40 CFR 262.34(c)(1)(i), [DM HWMP 3.3.2 and 3.4.3]
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a) Ensure containers are closed when not in use
b) If container has a funnel in the bung it must be closed with a latching device or valves, have no visible gaps, and will not spill if tipped over. -
ECAMP Category: HW.70.4.US Major
11. There must be adequate aisle space for clear egress on one side of the drums [D-M HWMP 3.3.6]
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a) Verify clear egress (minimum 3 feet)
b) Label’s and markings should be clearly visible -
ECAMP Category: HW.2.1.AF Major
12. Non-compatible wastes must be segregated [40 CFR265.177, D-M HWMP 3.3.6, ,40 CFR 262.34(a)(1)(i)]
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a) Verify wastes types are segregated
b) Verify incompatible wastes are stored separately so in the event of a spill there would be no chemical reaction that could generate toxic fumes, fire, etc. -
ECAMP Category: HW.70.5.US Major
13. Satellite accumulation containers must be marked with the words "Hazardous Waste" or other words that identify the contents [40 CFR 262.34(c)(1)(ii)]
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a) Verify the satellite accumulation containers are marked with the words "Hazardous Waste" or other words describing contents.
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ECAMP Category: HW.75.1.US Major
14-20
14. RCRA containers must be labeled with DOT Hazard labels, top half of yellow "Hazardous Waste" label, waste profile #, waste name, generator’s workplace name and unit/office symbol [D-M HWMP 3.4.2]
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a) Verify containers have marking and stickers IAW Appendix "D” DM HWMP
b) Day Use containers and SAAs assigned to persons (wipes tracked by AMARG Tool room) are exempt from this (just the name of waste is adequate) -
ECAMP Category: HW.2.1.AF Minor
15. SAAs must stock spill response supplies [D-M HWMP 3.3.1]
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a) Verify unit has adequate spill clean-up supplies on hand (inventory not required)
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ECAMP Category: HW.2.1.AF Minor
16. Hazmat Incident Response Procedures must be posted (HWMP 3.3.1 Appendix J]
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a) Ensure workplace personnel know where this is and it is affixed to a wall (not just in a notebook unless a Mobile SAA)
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ECAMP Category: HW.2.1.AF Minor
17. No more than 55 gallons accumulated UNLESS containers marked with Accumulation Start Date (ASD) when 55 gallons is exceeded and transferred to HAZMART within 3 days of ASD. [40 CFR 262.34(c)(1)(i), [DM HWMP 3.3.3]
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a) If more than 55 gallons are stored there must be a start date on the drum, and not stored for more than 3 days.
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ECAMP Category: HW.75.1.US Major
18. Are spills cleaned up promptly? Spills not cleaned up can be construed as hazardous waste storage not in a container. [40 CFR 265.171(D-M HWMP 3.3.2 and Appendix J Spill Response Procedures]
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a) Check for signs of recent spills, or spills that have not been cleaned up, waste remaining in secondary containment or on tops or sides of drums.
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ECAMP Category: HW.10.1.US Major
19. Containers of liquids require secondary containment IF spilled liquid would enter a floor drain, O/W separator, or the environment. [40 CFR 122.21,22,26,41; D-M HWMP 3.3.2]
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a) Check liquid containers to see where spilled liquid would flow to.
b) Ensure secondary containment is adequate if required -
ECAMP Category: HW.10.2.US Major
20. Containers holding flammable liquid wastes must be grounded when pouring or pumping liquids [AFOSH Std 91-501 Para 22.4.1.4, 22.4.6.2; D-M HWMP Table 3-2, Appendix A]
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a) Verify flammable liquid waste containers are grounded. Ground Safety may require other drums (sorbents with jet fuel, used oil, waste adhesives, etc.) be grounded also.
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ECAMP Category: HW.2.1.AF Minor
21-26
21. Contracts for waste disposal or recycling must be coordinated though the HWPM [D-M HWMP 3.2.8]
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a) Verify that contracts for parts cleaning tanks (like Safety-Keen) plastic media recycling, filter change out, etc. have been approved by the HWPM and are listed on the Tab B Waste Inventory
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ECAMP Category: HW.2.1.AF Minor
22. Wastes from process units (fluids, filters, spent media) must be characterized and properly managed [D-M HWMP 3.2.9]
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a) Verify tanks, parts washer or other units are marked with waste and disposal information (units with Safety-Kleen markings are exempted)
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ECAMP Category: HW.10.1.US Major, HW.2.1.AF Minor
23. Containers used to store petroleum products must be properly marked [40 CFR 279.22(c); D-M HWMP 3.2.15 and 3.2.16]
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a) Check for markings such as “Used Oil” (exact wording) or Reclaimed Jet Fuel, Off-Spec gasoline, etc. Drums must have unit identifying information.
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ECAMP Category: PO.65.6.US Major
24. Containers used to store non-RCRA wastes must be properly marked [D-M HWMP 3.2.13]
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a) Verify containers have marking and stickers IAW Appendix "D”; verify the blue “non-RCRA” labels are used instead of yellow “Hazardous Waste” labels.
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ECAMP Category: HW.2.1.AF Minor
25. Containers used to store PCBs wastes short term must be properly marked, dated, and not accumulated past 30 days, [40 CFR 761.65; D-M HWMP 3.2.17]
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a) Verify containers are being dated and turned in within 30 days OR they are meeting the additional requirements for longer storage.
TI.40.2.US Major -
ECAMP Category: TI.40.2.US Major
26. Fluorescent and other Mercury Lamps Waste lamps must be stored in the workplace for no longer than 9 months, marked with “Appendix E” sign affixed to the box, dated when first lamp placed in box, and boxes closed. [40 CFR 273.33(d), 40 CFR 273.34, 40 CFR 273.35,[D-M HWMP 3.2.2]
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If shop stores lamps check:
a) If there is no date on the container assume more than 1 year and use # HW.370.2.US
b) If the container is not labeled “Waste Lamps” use # HW.380.6.US
c) If the container is not closed use # HW.400.1.US
d) If it has the date but is missing Appendix E use # HW.2.1.AF
e) If date exceeds 1 year use #HW.370.2.US
f) If date exceeds 9 months use # HW.2.1.AF -
ECAMP Category: See Above
27-30
27. Waste Batteries must be stored in the workplace for no longer than 9 months marked with “Appendix F” sign affixed to the container, dated when first battery lamp placed in container. + terminal of batteries must be taped (see exceptions). Leaking batteries should be placed in a plastic bag or other closed container. Battery containers must be closed. 40 CFR 273.33(a)(1) and (a)(2), 40 CFR 273.34, 40 CFR 273.35]; [D-M HWMP 3.2.3]
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If shop uses any batteries check:
a) If there is no date on or exceeds 1 year use reference # HW.370.2.US
b) If a leaking container is not closed use reference # HW.380.6.US
c) If the container is not labeled “Waste Batteries” use reference # HW.400.1.US
d) If it has the date but is missing Appendix F, is not closed, OR exceeds 9 months use reference # HW.2.1.AF -
ECAMP Category: See Above
28. Waste aerosol cans to be punctured must be stored in a closed, marked container. A shelf in a locker is not a container. [40 CFR 261.3, 261.4(b), 261.21 THRU 261.24, AND 261.11, 40 CFR 270.1(c), [D-M HWMP 3.2.5]
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If shop uses any aerosol cans check:
a) Stored in a closed metal container
b) The container must also be marked “Aerosol Cans to be punctured”
c) Appendix “H” must be posted on or near the container. -
ECAMP Category: HW.10.1.US Major, HW 2.1.AF Minor
29. Units that handle items with liquid mercury (use thermometers, remove thermostats, etc.) must have mercury spill kits and trained to respond to a mercury spill. [D-M HWMP 3.2.11, OSHA 29 CFR 1910.1200(h)]
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a) Verify mercury spill kit is available
b) Mercury awareness training is on Form 55s for all personnel who handle items
c) Mercury spill clean-up is in shops written Hazard Communication training plan. -
ECAMP Category: HW.2.1.AF Minor
30. Units with rags laundered by contract must affix the sign in Appendix Q on the container and follow requirements [DM-HWMP 3.2.19, 40 CFR 261.4(a)(26)]
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a) Verify all management requirements marked on the sign are being adhered to
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ECAMP Category: HW.10.3.US Major
31. HAZMAT purchases must be tracked
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a) Verify all HAZMAT is tracked and Hazardous waste generated is managed properly
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PWS 4.1.3 Hazardous Material Customer Storage Facility
Signatures:
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Inspector's Signature
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Shop Rep Signature
