J.6 Environmental Compliance Evaluation Checklist.xlsx
XLSX spreadsheet 12 KB Posted
- Attached to
- Campuswide Scrap Metal Recycling Services
- Solicitation number
- AOCSSB26R0007
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Architect of the Capitol
About this file
This is an Environmental Compliance Evaluation Checklist designed to assess a scrap metal recycling facility's adherence to environmental regulations in the District of Columbia and Maryland. The checklist is organized by jurisdiction and covers eight primary compliance areas for DC and eight for Maryland, providing a structured framework for evaluating facility operations against state and federal environmental standards.
The DC section addresses compliance with Title 8 DCMR and Title 21 DCMR requirements, including solid waste facility permitting (classified as an Intermediate Materials Recycling Facility), proper waste handling and storage to prevent contamination and runoff, air quality emissions management under Title 20 DCMR, stormwater management with Best Management Practices and EPA Multi-Sector General Permit coverage, sewer system discharge documentation, scrap metal security protocols with tag-and-hold procedures for high-risk items, and compliance with the Clean Air Act, Clean Water Act, and RCRA. The Maryland section similarly requires permits under COMAR 26.04.07, compliance with hazardous waste regulations (COMAR 26.13.02.06), stormwater management under COMAR 26.17.02, air quality assessments for emissions from processing equipment (COMAR 26.11), scrap metal and junkyard licensing requirements including MDOT right-of-way compliance, and RCRA hazardous waste program adherence. Both sections mandate comprehensive documentation including permits, certifications, Environmental Health & Safety plans, monitoring reports, training records, seller transaction logs, weigh tickets, and incident response logs, ensuring transparency and regulatory accountability for scrap metal recycling operations.
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DC Checklist
| Section | Item | Compliant | Partial | Non-Compliant | Notes |
| 1. Solid Waste Facility Permits | Facility classified as an Intermediate Materials Recycling Facility under Title 8 DCMR, Chapter 10C. | ||||
| 1. Solid Waste Facility Permits | Valid Solid Waste Facility Permit issued by DC Department of Public Works. | ||||
| 1. Solid Waste Facility Permits | Facility is fully enclosed or properly covered to avoid classification as an open facility. | ||||
| 2. Solid Waste Handling & Storage | Compliance with Title 21 DCMR, Chapters 7 & 8 for waste containment and sanitation. | ||||
| 2. Solid Waste Handling & Storage | Proper storage of scrap metals to prevent runoff and contamination. | ||||
| 2. Solid Waste Handling & Storage | Spill prevention and cleanup protocols documented. | ||||
| 3. Air Quality & Emissions | Evaluate emissions for particulate matter, VOCs, and hazardous air pollutants. | ||||
| 3. Air Quality & Emissions | Determine if a Title V Operating Permit or NSR/RACT review is required under Title 20 DCMR. | ||||
| 3. Air Quality & Emissions | Maintain dust suppression and nuisance odor controls. | ||||
| 4. Stormwater Management | Compliance with Title 21 DCMR, Chapter 5 stormwater rules. | ||||
| 4. Stormwater Management | Implement Best Management Practices (BMPs) for runoff control. | ||||
| 4. Stormwater Management | Obtain coverage under EPA Multi-Sector General Permit (MSGP) if applicable. | ||||
| 4. Stormwater Management | Maintain stormwater retention credits or equivalent mitigation measures. | ||||
| 5. Sewer System & Discharge | Identify sewer type (MS4 vs CSS) for facility location. | ||||
| 5. Sewer System & Discharge | Maintain NPDES permit documentation and inspection logs. | ||||
| 6. Scrap Metal Handling & Security | Implement tag-and-hold procedures for catalytic converters and high-risk items. | ||||
| 6. Scrap Metal Handling & Security | Maintain seller records, weigh tickets, and vehicle details for transparency. | ||||
| 7. Federal Environmental Laws | Compliance with Clean Air Act (CAA) for emissions. | ||||
| 7. Federal Environmental Laws | Compliance with Clean Water Act (CWA) for stormwater discharge. | ||||
| 7. Federal Environmental Laws | Compliance with Resource Conservation and Recovery Act (RCRA) for hazardous waste (if applicable). | ||||
| 8. Documentation & Reporting | Copies of all permits and certifications on file. | ||||
| 8. Documentation & Reporting | Environmental Health & Safety (EHS) plan and training records. | ||||
| 8. Documentation & Reporting | Stormwater and air quality monitoring reports. | ||||
| 8. Documentation & Reporting | Incident and spill response logs. |
Maryland Checklist
| Section | Item | Compliant | Partial | Non-Compliant | Notes |
| 1. Solid Waste Facility Permit | Permitted under COMAR 26.04.07 as processing facility, transfer station, or industrial waste landfill as applicable. | ||||
| 1. Solid Waste Facility Permit | No unauthorized operation of solid waste facilities (e.g., open dumps). | ||||
| 1. Solid Waste Facility Permit | Annual tonnage reports submitted to MDE for waste/recycling activities. | ||||
| 2. General Solid Waste Management (COMAR 26.04.07.03) | No nuisances, air pollution, vermin attraction, or hazards from waste-handling operations. | ||||
| 2. General Solid Waste Management (COMAR 26.04.07.03) | Burning of solid waste only allowed if explicitly permitted. | ||||
| 2. General Solid Waste Management (COMAR 26.04.07.03) | Adequate procedures in place for cleanup, runoff control, pests, etc. | ||||
| 3. Hazardous Waste / Recyclable Materials (COMAR 26.13.02.06) | Recyclable eligible under COMAR if exempt from hazardous status (e.g., most scrap metals). | ||||
| 3. Hazardous Waste / Recyclable Materials (COMAR 26.13.02.06) | If hazardous materials present (e.g., lead-acid batteries), comply with generator, transporter, and storage regulations. | ||||
| 3. Hazardous Waste / Recyclable Materials (COMAR 26.13.02.06) | Maintain EPA ID number, labeling, container standards, and accumulation limits per COMAR 26.13. | ||||
| 4. Stormwater Management (COMAR 26.17.02) | Comply with COMAR 26.17.02, implementing ESD planning, BMPs, or structural measures. | ||||
| 4. Stormwater Management (COMAR 26.17.02) | Implement runoff controls per Maryland Stormwater Design Manual. | ||||
| 4. Stormwater Management (COMAR 26.17.02) | Maintain operation and maintenance records for stormwater systems. | ||||
| 5. Air Quality / Emissions (COMAR 26.11 & Clean Air Act) | Assess emissions from shredders or cutting equipment (particulates, VOCs). | ||||
| 5. Air Quality / Emissions (COMAR 26.11 & Clean Air Act) | Determine if Title V permits, NSR, or RACT applicability is required. | ||||
| 5. Air Quality / Emissions (COMAR 26.11 & Clean Air Act) | Install necessary controls (e.g., dust suppression, thermal oxidizers). | ||||
| 6. Scrap Metal & Junkyard Licensing | If located within MDOT right-of-way, obtain MDOT Junkyard & Scrap Metal Processing Facility License. | ||||
| 6. Scrap Metal & Junkyard Licensing | Maintain seller records, vehicle info, and operate under tag-and-hold requirements. | ||||
| 6. Scrap Metal & Junkyard Licensing | Report transactions to law enforcement within required timeframe. | ||||
| 7. Hazardous Waste Program (RCRA Authorized by Maryland) | If storing or handling hazardous waste, comply with Maryland's authorized RCRA program (COMAR 26.13). | ||||
| 7. Hazardous Waste Program (RCRA Authorized by Maryland) | Ensure containment, labeling, and manifest systems implemented correctly. | ||||
| 8. Recordkeeping & Reporting | Keep copies of all permits, annual reports, EPA IDs, and licenses. | ||||
| 8. Recordkeeping & Reporting | Maintain environmental logs: stormwater inspections, air quality monitoring, hazardous waste tracking. | ||||
| 8. Recordkeeping & Reporting | Document spill response, training logs, and compliance records. |
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