RFI-Attachment_A.pdf

EMP Environmental Management Plan, Version 6 M-1 Appendix M 2016

MULTI-MEDIA ENVIRONMENTAL INSPECTION REPORT

Initial Inspection 7 Day Re-inspection 15 Day Re-inspection

_____ GREEN Commendable - No violations of Kansas, Federal or Army Regulations & no more than 2 BMP deficiencies.

_____ AMBER Satisfactory - No violations of Kansas, Federal or Army Regulations & no more than 15% of inspected BMPs deficient. Highest rating an organization can receive on a 7 or 15 Day Re-inspection.

_____ RED Unsatisfactory - violations of Kansas, Federal or Army Regulations and/or more than 15% of inspected BMPs deficient and/or repeat finding of deficient BMP(s)

A re-inspection will be conducted on ______________________________ to verify the organization has returned to compliance with Regulations and the Installation’s standard for BMPs conformance.

Notification:

Green or Amber Inspection: Chief, Environmental Division & Organization’s Facility Representative.

Red Initial Inspection: Chief, Environmental Division & Organization’s Facility Representative and Director/Battalion Commander.

Red 7-Day Re-inspection: Chief, Environmental Division & Organization’s Facility Representative and Director/Battalion Commander.

Red 15-Day Re-inspection: Chief, Environmental Division & Organization’s Facility Representative and Director/Battalion Commander & Garrison Commander.

Note: Items Corrected on the Spot (COS) will be considered non-compliant for determination of the overall inspection rating despite being COS.

Date & Time of Inspection

Inspected Organization & Bldg Number

Organization’s POC & Telephone Number

Organization’s Representative’s Signature

Inspector’s Name & Telephone Number

Inspector’s Signature

Organization’s Director or Battalion Commander

Remarks:

Attachment A

This is an UNCONTROLLED DOCUMENT printed on 2/27/2017 for reference only.

EMP Environmental Management Plan, Version 6 M-3

ITEM #

ASSESSMENT TOPIC /

REGULATORY ISSUE

CITATION INSPECTED ITEMS C NC COS FINDING

Site Files

SF1 Environmental Team BMP (EMP – Ch 4)

Does the organization have an appointed Environmental Team within 30 days of the site being activated?

Is the Team Leader an Officer or NCO Sergeant First Class or higher?

Is a team member present during the inspection?

Is the alternate Team Leader in the rank of E-5 or above (the equivalent for civilian organizations)?

SF 2 Environmental Management Plan (EMP)

BMP

(EMP – Ch 4)

Each organization will have a copy of the most recent EMP.

SF 3 Site Specific Spill Contingency Plan

(SSSCP)

40 CFR 112

(EMP - Ch 11)

Does the organization have a complete Site Specific Spill Contingency Plan

(SSSCP)?

Has the SSSCP been reviewed annually and signed by the Team Leader?

SF 4 Hazardous Waste Determination

40 CFR 261.3,

261.4(b), 261.11

261.21 through

261.24 (HW)

(EMP – Ch 4)

Does the organization have a current Generation Statement for the hazardous waste, universal waste and controlled material generated at the organization?

Check the Site File to ensure the Generation Statement is accurate for the activities being conducted.

Has the Environmental Team Leader met with the Environmental Division, Hazardous Waste Coordinator at least once per year to update the Generation Statement?

Training

T 1 General Training 40 CFR 264.16

(EMP – Ch 13)

Have personnel on the Environmental Team received Environmental Team Training or been scheduled within 60 days of appointment to the team?

Are Environmental Team Leaders’ and Members’ training records current;

have they attended training within the last 12 months?

Has substitute training been approved by the Environmental Division and documented in the Site File?

Are Environmental Team Training certificates being kept for three years from the date personnel last worked at the organization?

T 2 Spill Training

40 CFR 112.21, 264

Subpart D

SPCCP/ISCP –

Appendix K

Personnel in organizations that have a Site-Specific Spill Contingency Plan must take part in annual training in spill prevention and response.

Does the organization perform an annual test/training of the SSSCP?

Verify that all appropriate personnel have received the training.

Verify the training consisted of: who to notify in case of a spill, how to contain a spill, emergency evacuation signal, evacuation routes and safety practices to prevent spills.

Spill Documentation

SD 1 Spill Reporting BMP (EMP – Ch 9 & Ch 11)

Any spills of hazardous material, hazardous waste, universal waste and controlled material over 5 gallons or any amount that enters the environment must be immediately reported to the Fire Department.

Verify the organization stores or dispenses petroleum in a way that reduces the potential for a spill.

Did the organization prepare and retain in the Site File a copy of the Spill Report submitted to the Environmental Division, Spills Coordinator?

SD 2 Spill Reporting BMP (EMP – Ch 9 & Ch 11)

Has emergency or non-emergency action been taken for any spills, leaks, or contaminated soil in the work area?

Has contaminated soil been removed, bagged and the area restored?

Are stains visible on asphalt and/or concrete surfaces, if so, are efforts being made to clean up?

Is contamination visible around edges of motor pool (i.e., stressed vegetation, visible product)?

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REGULATORY ISSUE

CITATION INSPECTED ITEMS C NC COS FINDING

Inspections and Records Retention

IRR 1 Inspections and Records Retention

40 CFR

262.34(a)(1)(i), 40

CFR 264.174 & 40

CFR 265.174 (HW &

UW)

(EMP – Ch 14)

Are organizations conducting weekly multi-media inspections of accumulation points and are inspection forms kept for a minimum of 3 years?

Verify if they have a copy of the weekly inspections (1 year in Site File, 2 in historical file).

Verify weekly inspections are filled out completely.

IRR 2 Inspections and Records Retention

BMP

(EMP – Ch 14)

Has the Environmental Team Leader reviewed and signed each weekly inspection at least monthly?

IRR 3 Inspections and Records

BMP

(EMP – Ch 14)

Is the person performing the weekly inspection appointed to the organization’s Environmental Team?

IRR 4 Inspections and Records

BMP

(EMP – Ch 4)

Have work/service orders been submitted for any maintenance or repair work on any real property associated with the management of hazardous waste, universal waste and controlled material?

Check status of the work/service order, determine if response time is appropriate to ensure environmental and/or safety risks are acceptable.

Recycling

R 1 Recycling

BMP

(EMP – Ch 2)

Can the organization verify they have a recycle program in place?

Verify the organization has clearly marked containers to collect recyclable materials.

Verify that recyclable material is not disposed of in trashcans and dumpsters.

General Accumulation Point Management

GAPM 1

General Accumulation Point

BMP

(EMP – Ch 4)

Is the site accessible to hazardous waste, universal waste and controlled material handlers?

If locked, is there a procedure for obtaining a key?

Are vehicles and containers placed in such a way as not to restrict access?

GAPM 2 Container Management 40 CFR 262.34(a)(1)(i) and 264.173 (HW, UW, CM & Used Oil)

(EMP – Ch 4 & Ch 9)

Containers of hazardous waste, universal waste and controlled materials must be handled in a safe manner and closed when not in use.

Verify that each container is closed (locking ring and/or bung must be more than finger tight).

Verify that containers aren’t damaged during handling, or affected in any way that could cause a leak.

Verify that containers of flammable or combustible waste are grounded.

GAPM 3 Labeling 40 CFR 262.31,

262.32 and 279.22

29 CFR 1910.1200

(HW, UW, CM, Used Oil)

(EMP – Ch 4)

Are the appropriate labels and/or markings affixed to containers holding hazardous waste, universal waste, controlled material and Used Oil and are they filled out completely and correctly?

Is the label completely filled out; accumulation start date, contents, etc.?

Is the information placed on labels using permanent markers?

Are labels placed in the top half of the container and visible?

GAPM 4 Secondary Containment 40 CFR 264.175 (HW & ≥ 55 gal)

BMP

(EMP – Ch 4)

Do containers of hazardous waste, universal waste and controlled material have secondary containment?

GAPM 5 Incompatibles 40 CFR 262.34(a)(1)(i) and 264.177 (HW, UW, CM)

(EMP – Ch 4)

Are all incompatibles segregated and stored in separate containers?

Verify that separate containers are used for each type of hazardous waste, universal waste and controlled material.

EMP Environmental Management Plan, Version 6 M-5

REGULATORY ISSUE

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GAPM 6 DOT Labeling 49 CFR 172.301 (HW, UW, CM)

(EMP – Ch 4)

Are containers of hazardous waste, universal waste and controlled material properly marked with a DOT hazard label?

Verify that materials listed in the EMP (if present at the organization) as requiring DOT labels are labeled.

Are labels placed in the top half of the container and visible?

GAPM 7 Compatibility 40 CFR 262.34(a)(1)(i) and 264.172 (HW, UW, CM)

(EMP – Ch 4)

Containers used must be made of or lined with materials compatible with the waste stored in them.

Verify that anything, which is labeled caustic or corrosive, is in DOT-approved containers.

Is the container compatible with the material being stored in it?

GAPM 8 Empty Containers BMP

(EMP – CH 4)

Are empty containers (55-gallon or larger) that will be reused for storage marked with an “Empty” label?

Verify that materials have been removed from container leaving no more than 1 inch of residue.

Empty labels will be white with black lettering.

GAPM 9 Useable Products in AP BMP

Verify that useable products are not stored in the accumulation point.

GAPM 10 Filter Draining BMP (EMP – Ch 5)

Are oil containers, oil and fuel filters drained in the appropriate containers and not longer than 24 hours?

GAPM 11 Asbestos K.A.R. 28-50-14 (EMP – App J)

Is asbestos (brakes, clutch, and rags) correctly collected, double bagged in 6-mil plastic, and stored in a closed container?

GAPM 12 General Housekeeping

Specific housekeeping requirements must be met in areas where hazardous waste, universal waste and controlled material are stored.

Verify that there isn’t clutter and general poor housekeeping in the AP, including the secondary containment area that could contribute to a hazard from tripping, fire, explosion, or pests.

GAPM 13 Handling Procedures BMP

Are the appropriate handling procedures posted above the containers in the accumulation points?

Verify the procedure is placed in a visible location above the container.

Verify that the procedure is current and applicable to the storage container.

GAPM 14 Signage BMP

Is the appropriate “Danger Hazardous Waste Accumulation Point”, “Danger Controlled Material Accumulation Point”, “Danger Universal Waste Accumulation Point” or magnetic UWAP/CMAP sign posted on the AP bldg. or in the AP area?

GAPM 15 Signage BMP

Is the “Danger No Smoking within 50 ft” sign posted on all sides of the Environmental Material Storage area or in the general area if storage area is not fenced?

GAPM 16 Safety 40 CFR 262.34(a)(4) &

264.30 through

264.37 (HW, UW, CM)

Storage areas must be designated, constructed, maintained, and operated to minimize the possibility of a fire, explosion or any unplanned release of hazardous waste.

Verify that there is a portable fire extinguisher on hand that has a rating of at least 15 ABC.

Verify that spill kits conform to guidance in the EMP.

Verify that there is enough aisle space (at least three feet) to allow free movement of emergency personnel, fire extinguishers, hoses, spill control equipment and decontamination equipment.

GAPM 17 Time Limit BMP

Is universal waste being stored no more than 6 months from the “accumulation start date”?

GAPM 18 Time Limit BMP

Are controlled materials being stored no more than 6 months from the “accumulation start date”?

GAPM 19 Issued Equipment BMP

Is all issued equipment listed on the MFR in or near the site and serviceable?

EMP Environmental Management Plan, Version 6 M-6

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Satellite Accumulation Points Management

SAP 1 Satellite Accumulation Points

BMP

(EMP – Ch 4)

Does the Satellite Accumulation Point (SAP) have the required SAP sign?

SAP 2 Satellite Accumulation Points

40 CFR 262.34(c)

(HW)

(EMP – Ch 4)

Is the waste moved to the 90 day storage area within 6 months of generation start date or within 3 days of the accumulation start date (when container is full)?

SAP 3 Satellite Accumulation Points

40 CFR 262.34(c)(1)

(HW)

(EMP – Ch 4)

All generators may accumulate as much as 55 gallons of hazardous waste or 1 quart of acutely hazardous waste in containers at or near any point of initial generation.

Verify if the facility has any SAPs.

Verify that the SAP is at or near the point of generation (within the confines of the facility).

Verify that the container is under the control of the operator of the process that generates the waste.

Verify that the containers are marked correctly with the SAP label.

Verify that the containers are moved to a 90 day storage area or HMPC when the container is full or before you begin to fill a second container.

Collection Shelter Management

CS 1 General Housekeeping BMP (EMP – Ch 11)

Is secondary containment under the Collection Shelter not more than 75% full?

CS 2 General Housekeeping BMP (EMP – Ch 11)

Is the Collection Shelter being maintained in an orderly fashion (housekeeping)?

MOTOR POOL, MAINTENANCE BAYS, & SHOP AREAS

Work Areas

WA 1 Flammable cabinets BMP

(EMP – Ch 3)

Flammable materials stored inside will be stored in flammable storage cabinets.

Verify cabinets have not been modified (drilled holes, rivets, etc.).

Verify cabinets are not placed within 3 feet of a circuit box.

Verify incompatibles are not stored in the same cabinet.

Verify the cabinet is labeled “Flammable – Keep Fire Away”.

Modified cabinets are placed outside if used for flammable products.

WA 2 Shop Towels BMP

Are shop towels managed properly?

Verify that soiled shop towels are collected and stored properly.

Verify that rag containers are properly labeled.

Verify that container is lined with a plastic bag.

Verify that solvent contaminated shop towels (reusable or disposable) are not disposed of in solid waste.

WA 3 POL Container Management

40 CFR 112.8 (≥55

gal)

(EMP – Ch 3 & Ch 9)

Are POL containers managed properly?

Are containers stored within secondary containment?

Are containers labeled properly?

Are containers in good condition and closed when not in use?

Is the storage area neat and orderly?

WA 4 “In-ground” Oil Water Separators

(EMP – Ch 6)

Are in-ground oil water separators properly maintained and operated?

Are alarm systems, if present, in working order?

Is there access to the system to remove oil and inspect the system (is the access point readily available)?

Does the operator understand the system and able to troubleshoot any problems?

Is there any oily discharge from the separator system discharge point?

Is there a clearly defined maintenance program or inspection program for the system?

EMP Environmental Management Plan, Version 6 M-7

REGULATORY ISSUE

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WA 5 Eye Wash Stations BMP (EMP – Ch 4)

Is eyewash available for immediate emergency use?

Have eyewash stations been flushed weekly and is there a log near the eye wash station that is used to document the flushing?

Verify there is clear access to all eyewash and shower devices.

WA 6 Battery Management BMP (EMP – Ch 3)

Are batteries managed properly?

Verify that batteries are stored on secondary containment.

Check that stacked batteries have cardboard between them.

Verify that lithium batteries are disposed of at the HMPC.

Verify that unit personnel do not deactivate lithium batteries by depressing the Complete Discharge Device (CDD).

Drip Pans

DP 1 Drip Pan Management BMP (EMP – Ch 9 & Ch 11)

Are dip pans managed properly?

Check for abandoned drip pans.

Are drip pans placed under all leaking vehicles?

Are drip pans serviceable?

Are drip pans not more than 75% full?

DP 2 Portable Oil Water Separators

40 CFR 279.22 &

29 CFR 1910.1200

(EMP – Ch 11)

Are portable oil water separators properly maintained and operated?

Is there visible staining to indicate loss of product during separation?

Is an excessive amount of oil retained in the oil water separator, which could impact the separation process?

Are the devices stenciled as oil water separators?

Is the device designed so that rainwater cannot get in, i.e., has a lid?

If tipped over, is the design such that it won’t discharge oil?

Hazardous Material Storage/Management

HMS 1 Damaged Containers BMP (EMP – Ch 3 & Ch 9)

Are leaking or damaged hazardous materials promptly and properly over-packed or transferred to another container?

HMS 2 Shelf Life HMMP Labels

BMP

(EMP – Ch 3 &

HMMP SOP)

Are items with expired shelf life turned in or shelf life extended?

Are all materials labeled with the HMMP barcode? (unit responsibility) Is the “CHECK FOR EXPIRED SHELF LIFE” sign visible inside the building?

HMS 3 Container Management 29 CFR 1910.1200

(EMP – Ch 3 & Ch 9)

Containers will be managed in accordance with good management practices.

Verify containers are in good condition, properly labeled and closed when not in use.

Verify incompatible materials are segregated.

Verify containers aren’t stacked more than manufacturer recommendation.

Verify there is at least three feet of aisle space between rows of containers.

Verify containers stored outside are protected from the elements.

HMS 5 Secondary Containment 40 CFR 112.8 (≥ 55 gal)

(EMP – Ch 3 & Ch 9)

Are containers of liquid hazardous materials stored within secondary containment?

Verify that secondary containment is drained/cleaned as needed (POL, rainwater, trash, etc.).

HMS 6 Compressed Gas Cylinders

29 CFR 1910.101

(EMP – Ch 3)

Compressed gas cylinders should be properly stored outside of occupied buildings.

Verify that incompatible cylinders are stored at least 20 feet apart.

Verify that cylinders are secured and stored upright with the protective caps in place.

Verify that cylinders are protected from the sun and weather elements.

Verify the hazard classification or name of the gas being stored is prominently marked in the storage area and that “No Smoking” signs are posted where appropriate.

EMP Environmental Management Plan, Version 6 M-8

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Wash Racks

WR 1 Wash Rack Management National Pollutant Discharge Elimination System (NPDES) permit #F-

KS97-PO02

(EMP – Ch 10)

Follows proper vehicle washing procedures when using Tactical Equipment Shop (TES) wash racks.

Is the wash rack soil residue less than 3 inches deep?

Verify that excess oil/fuel does not exceed one inch deep in the drain basin.

Is there evidence that contaminated soil is not being managed properly?

Verify that vehicle washing is not conducted in a manner that causes wash water to enter a storm drain.

WR 2 Wash Rack Management NPDES permit #F-

KS97-PO02

(EMP – Ch 10)

Wash tactical vehicles at Installation Vehicle Wash Facility (IVWF) and GSA vehicles at an approved on or off-site commercial facility.

Verify that tactical vehicle exteriors are washed initially at the CVWF.

Verify that excessive amounts of soil dropped from vehicles in motorpools is cleaned up and does not enter the storm drain.

WR 3 Wash Rack Management 40 CFR 403.5(a) and 403.5(c)(2) and NPDES permit #

F-KS97-PO02

(EMP – Ch 10)

Do not discharge into the industrial wastewater system any pollutant, which would cause “pass through” or “interference.”

Verify that only approved degreasers, solvents, soaps or emulsifiers are present at the wash rack.

Solvent Basins

SB 1

Solvent Degreasers 40 CFR 63.462(b) and 63.462(c)(1) through 63.462(c)(2)

Solvent degreasers must be operated in a way that minimizes the release of solvent and fumes.

Verify lids are closed (no gloves, rags, etc impeding closure) except when in use.

Verify that the drains are not plugged and that the fusible link is present.

Verify sponges, fabrics, woods, paint brushes and paper products are not cleaned in the degreaser.

Solvent basins are kept clean (no dry sweep, rags, etc).

PPE is available for use at the solvent basins (gloves, apron and splash goggles). Location of PPE is posted on solvent tank if it is stored at a separate location.

Air Quality

A 1 Filter Log Book Clean Air Act (CAA) Part 70 Operating Permits

Filter Change Logs are maintained for paint booths, abrasive blast booths and woodworking facilities.

A 2 Filter Change Procedures CAA Part 70 Operating Permits

Control Equipment Maintenance Plans (SOPs) are established and maintained for filter changes.

A 3 Paint & Abrasive Usage Log

CAA Part 70 Operating Permits

Usage logs must be maintained for paint booth and abrasive blast booth facilities.

A 4 Blast Booth CAA Part 70 Operating Permits

Verify SDSs are maintained for all products used.

Aboveground Storage Tanks

ST 1 Inspections and Records 40 CFR 284 &

40 CFR 112.7

Are ASTs gauged and inspected?

Fuel storage/dispersal ASTs are to be gauged daily (duty days).

Verify the fuel storage/dispersal log is on site for verification.

Gauging must include a visual inspection of the entire tank to ensure no cracks or leaks are present.

Verify that used oil ASTs are being gauged weekly.

Verify that gauging logs are retained for 3 years.

Verify exterior of tank is free of oily residue.

EMP Environmental Management Plan, Version 6 M-9

REGULATORY ISSUE

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ST 2 Storage Tanks: General BMP (EMP – Ch 6)

Tanks used to store used oil must have filter screens in place and operational hinges.

Verify that screens are in place to catch large debris.

Verify that funnel hinges are operational.

Verify that funnel lids are kept closed except when material is being added.

Verify that there is no trash, dry sweep, or any other material than what the tank is marked to contain being placed in the AST.

ST 3 Permits K.A.R. 28-44-29

Is the current AST permit available and is a copy visibly posted on/near the tank?

ST 4 Labeling 40 CFR 279.22

Is the AST labeled with the tank contents?

ST 5 Secondary Containment 40 CFR 112.7(e)(2)(ii) (EMP – Ch 6 & Ch 11)

All bulk storage tanks must have secondary containment for the entire contents of the largest single tank plus sufficient free board to allow for precipitation.

Verify that ASTs have some form of secondary containment (usually a cement case will be built and the tanks placed on brackets inside).

Alternatives to dikes and berms include diversionary gutters, drainage trenches leading to holding ponds, etc.; anything that conducts spilled material to a safe place where it can be recovered.

Verify that each dike or berm is “impervious,” which, in this case, means no cracks or holes (including animal burrows) are present. Earthen berms are required to be solid enough that leaks cannot quickly seep through.

Report all cracks.

Verify that the containment is large enough to hold all of the contents of the tank plus 10% for accumulated precipitation.

The storage area must be graded away from occupied buildings.

Verify drain valves on secondary containment are sealed when not in use.

Check for water accumulated in secondary containment to ensure no hazardous substances have been released to it before discharge.

Check to see if records are maintained of drainage activities.

ST 6 Mobile Fuelers and Secondary Containment

40 CFR 112.7(e)(1), 112.7(e)(2) and 112.7(e)(2)(iii)

(EMP – Ch 6, Ch 9 & Ch 11))

Are all stationary “mobile fuelers” containing more than 150 gallons parked properly and secondary containment maintained?

Verify that fuelers are at least 25 ft away from storm drain inlets and manholes.

Verify that fulers are parked in/on secondary containment.

Verify that containment is serviceable, all of the sides are in the up position, and drainage valves are closed when not in use.

Verify that drainage valves are attended when opened to release accumulated stormwater.

Verify that accumulated stormwater is inspected for possible contamination and that records of each release are kept for 3 years.

Verify that accumulated stormwater contaminated with petroleum products is properly treated, recovered or disposed and reported.

Industrial Stormwater

SW 1 Special Requirements EPA General Permit Part IV.D.8

Cover salt storage area with a roof or use temporary cover if a permanent cover is not planned.

Additional Comments:

EMP Environmental Management Plan, Version 6 N-1 Appendix N 2016

APPENDIX N

ORGANIZATION WEEKLY

MULTI-MEDIA INSPECTION CHECKLIST

RESULTS: COMPLIANT NON- COMPLIANT

1. References:

a. U.S. Code of Federal Regulations (CFR) Title 40 Parts 260-282; 49 CFR Parts 171-173.

b. Kansas Statutes Annotated 65-3430 et seq., Kansas Administrative Regulations 28-31-1 through 28-31-14.

c. Fort Riley Environmental Management Plan, 2016, et seq.

2. General Information:

a. Date of Inspection:

b. Time of Inspection:

c. Name of Inspected Organization:

d. Building Number of Inspected Organization:

e. Inspector’s Name: f. Inspector’s Telephone Number:

g. Environmental Team Leader Certification: (Review and sign inspections monthly)

3. Criteria: C (Compliant) NC (Non-Compliant) COS (Corrected on Spot) NA (Not Applicable)

NOTE: For your information, minimum fines possible by the Kansas Department of Health & Environment are in parenthesis. The amount of the fine will be increased by the number of days in violation and number of containers in violation.

Additional information may be attached to this form if necessary.

A. Site File (up to $25,000/day/violation)

(1) Generation Statement. Environmental Team Appointment Orders.

Environmental Team Training Certificates/Documentation. All Environmental

Team personnel training up-to-date. Current SSSCP. SSSCP annual training documented. Spill Reports. Ft. Riley EMP on site.

(2) Weekly inspections up-to-date. Environmental Team Leader Certification completed. Weekly inspections kept for 3 years.

C

NC

COS

Comments

EMP Environmental Management Plan, Version 6 N-2

B. Hazardous Waste, Universal Waste, Controlled Material & Satellite Accumulation Points (SAP, UWAP, CMAP, SAP) (up to $25,000/day/violation)

(1) HW, UW and CM Danger & No Smoking sign in place. POC name & number on sign. Site accessible. Adequate aisle space. Current handling procedures posted. No usable products stored. Incompatible wastes separated. Separate containers for each waste. Oil & fuel filters drained correctly. Asbestos collected correctly. Containers closed when not in use.

Good general housekeeping.

(2) UWAP/CMAP: Waste & material turned in within 6 months of accumulation start date. SAP: Waste turned in within 6 months of generation start date or 3 days of full container (whichever occurs first). Only 1 container of each type of waste, not to exceed a total of 55 gallons

(3) Appropriate marking used. Contents identified on marking with permanent ink. Start date on marking. Containers stenciled if applicable. All other product labeling removed or obliterated. Containers spillproof and in good condition. Appropriate headspace left. Waste or material overpacked in drums if containers are leaking, corroded, or deteriorated.

(4) Complete spill kit & absorbent stored at site (Motor pools must use an appropriately marked container). Fire extinguisher near site (15 lb. ABC).

(5) All issued equipment listed on the MFR is present and serviceable. AP building is organized in accordance with Appendix F.

C. Collection Shelter (up to $5,000/day/violation)

Drained 5-gallon metal containers and air filters stored correctly. Containment floor empty and clean. Handling procedures posted. Good housekeeping.

NA

EMP Environmental Management Plan, Version 6 N-3

D. Hazardous Material Storage Area (up to $10,000/day/violation)

Only approved material present. Material protected from the elements and stored on secondary containment. Containers properly labeled and in good condition. Good housekeeping. Adequate aisle space. Material inspected for shelf life. Incompatible material kept segregated. Flammables stored properly.

Compressed gasses stored properly. Containers closed if not in use. Empty drums have been marked or stenciled “Empty”.

E. Work Area (up to $37,500/day/violation)

POL containers managed properly. Flammables stored inside are in serviceable flammable cabinets. Soiled rags managed properly. Eyewash flushed weekly w/documentation. Batteries managed properly. No open containers, standing waste, or waste/material entering storm drains. No soil contamination. Washrack soil residue less than 3 inches. Fuel tankers not within 25 ft. of storm drain and are on secondary containment. Drip pans under leaking vehicles. Drip pans not over 75% full. Recyclables managed properly.

Solvent tanks managed properly.

F. Aboveground Storage Tank (AST) (up to $37,500/day/violation)

Visually inspect tank daily. Gauge tank weekly. Gauging log retained for 3 years. If tank is 75% full, appointment has been made for pick up. Record of work orders kept. Area around tank and funnel clean. Markings indicating contents are in place. Only material that the tank is marked to contain is placed in the AST. Covers and grates functional. KDHE permit on site. Exterior free of oily residue.

NA

G. Legibility on all labels, markings & documents C NC COS

EMP Environmental Management Plan, Version 6 N-4

H. Identification of Waste/Material at Accumulation Point:

NAME OF HAZARDOUS WASTE ON CONTAINER: GENERATION START

DATE (SAPs ONLY)

ACCUMULATION

START DATE:

ESTIMATED QUANTITY:

NAME OF CONTROLLED MATERIAL ON CONTAINER:

(Ex – Used Antifreeze, Off Spec Fuel, Used Grease, etc.)

ACCUMULATION START DATE: ESTIMATED QUANTITY:

NAME OF UNIVERSAL WASTE ON CONTAINER:

(Ex – Spent Lamps, Unserviceable Batteries, etc.)

ACCUMULATION START DATE: ESTIMATED QUANTITY:

I. General Comments: