At the time of the inspection, does the facility have any RCRA hazardous waste onsite that has been accumulated onsite for more than __________*days?
*NOTE: Fill in the state’s accumulation time limit applicable to facilities that generate between 100 and 1000 kg of RCRA Hazardous Waste per month.
Inspector will verify conformance based on dates on containers which detail when accumulation begins (if no containers are labeled, then inspector should circle no labels).
Note: inspector must use common sense to verify compliance. For example, if 49 out of 50 drums at a facility are dated to indicate compliance with the timeliness threshold and all contain the same wastes, chances are the facility is in compliance with the timeliness threshold for storage.
Does the facility use a hazardous waste manifest to ship its hazardous waste when a manifest is required?
Inspector will look at one (1) year of manifest records as well as ask the facility if they have kept three (3) years of records. The inspector should look for gaps in the shipments or shipping records
Note: the word “look” in this case means that the inspector will confirm that all shipments have been manifested and not that each and every manifest was filled out correctly.
Has the facility identified all of its hazardous waste streams?
Conformance will be determined based on: review of production processes, type of wastes generated at these processes and whether or not they have been characterized as hazardous waste.
Note: this is something inspectors do routinely. Interns may need to bring this information back to the state project lead.
Emergency Response Indicator
Has the facility posted the current name and telephone number of the emergency coordinator, the location of fire extinguishers and spill control material, and if present, fire alarm, and the telephone number of the fire department, unless the facility has a direct alarm?
Visual inspection of all elements listed and inquiry into whether the information is up to date.
Note: emergency information only has to be posted by 1 phone to be in conformance with this indicator for the purposes of this project.
The States Common Measures Project Final Report