Section_J_-_SAA_DPW-ENRD_Inspection_Checklist_rev7MAY14.pdf

WASTE ACCUMULATION AREA INSPECTION CHECKLIST

AUTHORIZATION ID:

INSPECTION DATE: LOCATION:

COMMENTS

1. Yes No

4. Yes No Are containers stored in a manner that avoids direct contact with the flooring (i.e., on a pallet)?

HWMMP Section 5.5.2. 2. Containers must be stored in a manner such as to avoid direct contact with the foundation or flooring by the use of pallets or other suitable device to facilitate inspections.

3. Is container closed except when adding or removing waste?

Yes No 40 CFR 262.34(c)(1). A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste provided he: (i) Complies with §§ 265.171, 265.172, and 265.173(a) of this chapter

40 CFR 265.173(a). A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.

Is waste accumulated at or near the point of generation and “under the control of the operator”?

40 CFR 262.34(c)(1). A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste.

2. Is container in good condition ‐ no dents, corrosion, leaks, noticeable spills, or bulging?

Yes No 40 CFR 262.34(c)(1). A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste provided he: (i) Complies with §§ 265.171, 265.172, and 265.173(a) of this chapter

40 CFR 265.171. If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of this part.

SAA DESCRIPTION:

INSPECTOR:

QUESTION CITATION

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COMMENTSQUESTION CITATION

6. Yes No

7. Yes No

8. Yes No

9. Is container marked with the contents of the container?

Yes No 40 CFR 262.34(c)(1)(ii). Marks his containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers.

HWMMP Section 5.5.4. Hazardous waste containers must be marked clearly with the words "HAZARDOUS WASTE" and a description of the contents.

Are wastes properly segregated according to compatibility?

HWMMP Section 5.5.1. Only compatible wastes will be stored together as indicated in the hazardous materials/waste compatibility chart found in Appendix L.

Are containers of highly flammable wastes properly grounded?

HWMMP Section 5.5.2. 3. Containers of highly flammable wastes must be properly grounded

Does aisle space allow for unobstructed movement of personnel and equipment (i.e., fire protection, spill control, decon)?

HWMMP Section 5.5.2. 7. Sufficient aisle space must be maintained in accumulation areas to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment

5. Is waste compatible with container that it is stored in?

Yes No 40 CFR 262.34(c)(1) A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste provided he: (i) Complies with §§ 265.171, 265.172, and 265.173(a) of this chapter

40 CFR 265.172. The owner or operator must use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.

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10. Yes No b.

c.

11. Yes No

Universal Waste 40 CFR 273.34. A large quantity handler of universal waste must label or mark the universal waste to identify the type of universal waste as specified

Non‐Regulated Waste HWMMP Section 11.3. Containers of non‐regulated wastes should be labeled with the type of waste and the date waste was first added to the container.

Is the volume of waste present less than the authorized amount? 40 CFR 262.34(c)(1). A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste.

Is the container marked with the appropriate type of waste?

a. Hazardous Waste 40 CFR 262.34(c)(1)(ii). Marks his containers either with the words

“Hazardous Waste” or with other words that identify the contents of the containers.

HWMMP Section 5.5.4. Hazardous waste containers must be marked clearly with the words "HAZARDOUS WASTE" and a description of the contents.

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12. Yes No a.

b.

c.

13. Yes No

14. Yes No

15. Yes No Is a current Site Specific Spill Plan posted in accumulation area? HWMMP Section 5.7. Each SAA will have a Site‐Specific Spill Plan.

Non‐Regulated Waste: date waste first added to container

HWMMP Section 11.3. Containers of non‐regulated wastes should be labeled with the type of waste and the date waste was first added to the container.

Are liquid wastes stored in secondary containment that is large enough to hold 110% of volume stored?

HWMMP Section 5.5.3. A means of secondary containment (for the entire volume of the container plus 10 percent freeboard) must be used for liquids such as placement of containers in appropriately sized containment pallets, drip pans, or impermeable berms.

Is a compatible spill kit located ≤ 50 ft from accumulation area?

HWMMP Section 5.7. Adequate spill control and containment material must be on hand (within 50 feet of the SAA) to contain and clean up minor spills.

Is the container dated appropriately?

Hazardous Waste: no date unless full;

when full, add date and move to 90‐day

HWAS

40 CFR 262.34(c)(2). A generator who accumulates either hazardous waste or acutely hazardous waste listed in § 261.33(e) in excess of the amounts listed in paragraph (c)(1) of this section at or near any point of generation must, with respect to that amount of excess waste, comply within three days with paragraph

(a) of this section or other applicable provisions of this chapter.

During the three day period the generator must continue to comply with paragraphs (c)(1)(i) through (ii) of this section. The generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.

Universal Waste: date waste first added to container 40 CFR 273.35(c). A large quantity handler of universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. The handler may make this demonstration by: (1) Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received rev7MAY14 Page 4 of 5

16. Yes No

17. Yes No

18. Yes No Are SAA areas inspected and documented weekly? HWMP Section 5.8. The SAA must be inspected weekly (every 7 days) using the SAA Inspection Checklist located in Appendix D.

Is a current authorization letter posted in the accumulation area? HWMMP Section 5.3. The SAA manager must submit an application to operate a SAA no later than 1 December each year.

... DPW‐ENRD will review the applications and issue authorization letters for each SAA. The SAA letter allows operation of the SAA under conditions specified within the letter for one year.

Are training certificates available for all applicable personnel? HWMP Section 5.9. Training is required for personnel who handle hazardous waste and for managers and supervisors of personnel, who handle hazardous waste, including those who maintain and operate the SAAs in their shops and work areas (SAA Managers).

All training will be conducted in accordance with the ESOP for Hazardous Waste Training, which is located in Appendix B.

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