J.6 Environmental Compliance Evaluation Checklist.xlsx

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Campuswide Scrap Metal Recycling Services
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AOCSSB26R0007
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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

SectionItemCompliantPartialNon-CompliantNotes
1. Solid Waste Facility PermitsFacility classified as an Intermediate Materials Recycling Facility under Title 8 DCMR, Chapter 10C.
1. Solid Waste Facility PermitsValid Solid Waste Facility Permit issued by DC Department of Public Works.
1. Solid Waste Facility PermitsFacility is fully enclosed or properly covered to avoid classification as an open facility.
2. Solid Waste Handling & StorageCompliance with Title 21 DCMR, Chapters 7 & 8 for waste containment and sanitation.
2. Solid Waste Handling & StorageProper storage of scrap metals to prevent runoff and contamination.
2. Solid Waste Handling & StorageSpill prevention and cleanup protocols documented.
3. Air Quality & EmissionsEvaluate emissions for particulate matter, VOCs, and hazardous air pollutants.
3. Air Quality & EmissionsDetermine if a Title V Operating Permit or NSR/RACT review is required under Title 20 DCMR.
3. Air Quality & EmissionsMaintain dust suppression and nuisance odor controls.
4. Stormwater ManagementCompliance with Title 21 DCMR, Chapter 5 stormwater rules.
4. Stormwater ManagementImplement Best Management Practices (BMPs) for runoff control.
4. Stormwater ManagementObtain coverage under EPA Multi-Sector General Permit (MSGP) if applicable.
4. Stormwater ManagementMaintain stormwater retention credits or equivalent mitigation measures.
5. Sewer System & DischargeIdentify sewer type (MS4 vs CSS) for facility location.
5. Sewer System & DischargeMaintain NPDES permit documentation and inspection logs.
6. Scrap Metal Handling & SecurityImplement tag-and-hold procedures for catalytic converters and high-risk items.
6. Scrap Metal Handling & SecurityMaintain seller records, weigh tickets, and vehicle details for transparency.
7. Federal Environmental LawsCompliance with Clean Air Act (CAA) for emissions.
7. Federal Environmental LawsCompliance with Clean Water Act (CWA) for stormwater discharge.
7. Federal Environmental LawsCompliance with Resource Conservation and Recovery Act (RCRA) for hazardous waste (if applicable).
8. Documentation & ReportingCopies of all permits and certifications on file.
8. Documentation & ReportingEnvironmental Health & Safety (EHS) plan and training records.
8. Documentation & ReportingStormwater and air quality monitoring reports.
8. Documentation & ReportingIncident and spill response logs.

Maryland Checklist

SectionItemCompliantPartialNon-CompliantNotes
1. Solid Waste Facility PermitPermitted under COMAR 26.04.07 as processing facility, transfer station, or industrial waste landfill as applicable.
1. Solid Waste Facility PermitNo unauthorized operation of solid waste facilities (e.g., open dumps).
1. Solid Waste Facility PermitAnnual 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 LicensingIf located within MDOT right-of-way, obtain MDOT Junkyard & Scrap Metal Processing Facility License.
6. Scrap Metal & Junkyard LicensingMaintain seller records, vehicle info, and operate under tag-and-hold requirements.
6. Scrap Metal & Junkyard LicensingReport 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 & ReportingKeep copies of all permits, annual reports, EPA IDs, and licenses.
8. Recordkeeping & ReportingMaintain environmental logs: stormwater inspections, air quality monitoring, hazardous waste tracking.
8. Recordkeeping & ReportingDocument spill response, training logs, and compliance records.

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