Inspector Checklist

for the

Auto Body Self-Certification Program

**\[Revised Copy February 12, 2004\]**

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**2004**

**Delaware Department of Natural Resources and Environmental Control\
89 Kings Hwy Dover, DE 19901**

[**www.dnrec.state.de.us**](http://www.dnrec.state.de.us/)

**Contents**

**2004 Inspector Checklist**

> Section A. Facility Information
>
> Section B. Hazardous Waste Management
>
> Section C. Air Pollution
>
> Section D. Water Pollution
>
> Section E. Solid Waste Management
>
> Section F. Recycling

*This checklist is not copyrighted. It may be reproduced for educational
purposes, but may not be sold for profit.*

**Directions:**

Please answer all questions, unless you are directed to skip a question.
Do *[not]{.underline}* answer questions that you are directed to skip.
Mark each box with a dark check mark and avoid stray marks on the
checklist pages. A section for notes is provided at the end of the
checklist for your convenience, if you wish to take notes.

**Key to Codes in the Checklist:**

**Proposed Environmental Business Practice Indicator (EPBI) questions
are in bold text**.

*Notes to inspectors filling out the checklist are printed in italics.*

The following codes are used to designate different types of questions:

-   (Req) = Required Compliance Measure

-   (Req - CESQG) = Compliance Measure is required only for
    Conditionally Exempt Small Quantity Generators of Hazardous Waste
    (CESQGs)

-   (Req - SQG) = Compliance Measure is required only for Small Quantity
    Generators of Hazardous Waste (SQGs)

-   (Req -- CESQG and SQG) = Compliance Measure is Required both for
    CESQGs and SQGs

-   (BMP)= Best Management Practice -- practice is not required by
    regulations

-   (P2) = Pollution Prevention Measure -- practice contributes to
    source reduction. Questions marked P2 are not required.

> Unless otherwise noted, for required compliance measures, a "Yes"
> response indicates the shop is in compliance, and a "No" response
> indicates the shop is out of compliance.
>
> Unless otherwise noted, all questions are referring to the *current
> conditions* at the shop.

![](media/image1.png){width="1.5583333333333333in"
height="1.0465277777777777in"}**Delaware Department of Natural
Resources**

**and Environmental Control (DNREC)**

**Auto Body Self-Certification Program**

**2004 Inspector Checklist**

Section A: General Facility Information

1.  Date of Inspection (mm/dd/yyyy): \_ \_ /\_ \_ / \_ \_ \_ \_

2.  Inspection Team Members:

  -------------------------------- --------------------------------------
  [Name (First Name, Last          [Affiliation (DNREC
  Name)]{.underline}               Office)]{.underline}

                                   

                                   

                                   

                                   

                                   

                                   
  -------------------------------- --------------------------------------

3.  Facility ID \# from DNREC ERP database:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

4.  Business Name:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

5.  Alternate Business Names (if Any):
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

6.  Street Address:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

7.  Street Address City, Zip:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

8.  Latitude/Longitude:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

9.  Mailing Address (if different from above):
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

10. Mailing Address City, Zip:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

11. Business Phone Number: \_\_\_\_(\_\_\_\_\_)\_\_\_\_\_\_\_ \--
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

12. Business Fax Number: \_\_\_\_(\_\_\_\_\_)\_\_\_\_\_\_\_ \--
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

13. Business Email:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

14. Tax Parcel Number:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

15. Federal Employer ID \# (FEIN):
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

16. Number of Employees:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

17. Name of Contact Interviewed
    (First/Last):\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

18. Contact Person's Phone (if different from business phone):
    (\_\_\_\_)\_\_\_\_\_ \-- \_\_\_\_\_\_\_\_

19. Name of Business Owner
    (First/Last):\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

20. Owner's Phone (if different from business phone):
    (\_\_\_\_)\_\_\_\_\_ \-- \_\_\_\_\_\_\_\_

21. Has this business changed any of the following information in the
    last year:

 Yes - *Answer A.22 and A.23*  No

Business name  Yes - *Answer A.24*  No

Business ownership  Yes - *Answer A.25*  No

22. Previous Street Address:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

23. Previous Street Address City, Zip:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

24. Previous Business Name:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

25. Previous Owner Name (First/Last):
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

26. SIC Code:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

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27. Business Type: (*Check only one*):

>  Franchise/Chain (i.e., facilities under contract to another company
> that owns more than one auto body facility; includes company-owned
> stores and independent franchise owners)
>
>  Independent (i.e., facilities that owe no allegiance to any other
> company or corporation)
>
>  Government (includes federal, state, and local government
> facilities)
>
>  Educational (i.e., technical schools that train students in auto
> body work)
>
>  Other (*Specify*)
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

28. Type of Services Provided (*Check all that apply*): *(Note: This
    program applies only to shops that do auto body work and only
    addresses environmental requirements relevant to auto body work. If
    the shop provides auto body as well as other types of services,
    e.g., mechanical repair, it should be included. However, if the shop
    [does not]{.underline} provide auto body service, it should not be
    included in the baseline survey.)*

 Auto Body Work

 Mechanical Repairs

 Car Wash

 Salvage Yard

 Gas Station

 Car Dealership

 Fleet Maintenance

 Other (*Specify*) \_\_\_\_\_\_\_

29. Average number of vehicles processed per week: \_\_\_\_\_\_\_

30. Has the shop been inspected by DNREC within the last year?

>  Yes  No - *Skip to Section B*

31. Which DNREC section conducted the inspection?
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

32. When was the inspection conducted? (mm/yyyy) (
    \_\_\_\_/\_\_\_\_\_\_\_\_)

33. Has the shop heard about the baseline inspections conducted as part
    of the self-certification program prior to this visit?

     Yes  No

    Section B: Hazardous and Universal Waste Management

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1.  Does the shop generate any hazardous waste?

     Yes  No \-- *skip to B.50*

2.  **Has the shop conducted a complete, accurate hazardous waste
    determination for each waste it generates? (Req)**  Yes  No

3.  Has the shop tested potentially hazardous wastes?

>  Yes  No \-- *Skip to B.5*

4.  Has the shop retained records of all test results utilized to make a
    hazardous waste determination for 3 years? (Req - SQG)  Yes  No

5.  **Does the shop track hazardous waste accumulation totals? (BMP)** 
    Yes  No

6.  Does the shop generate any acute hazardous waste?  Yes  No *- Skip
    to B.8*

7.  If yes, is the maximum amount of acute hazardous waste accumulated
    on site less than 1 kg (2.2 pounds)?  Yes  No

  ------------------------------ ------------- ------------- -------------
  **GUIDELINES FOR DETERMINING                               
  GENERATOR STATUS**                                         

                                 CESQG         SQG           LQG

  Maximum Amount of Hazardous    Less than 220 220-2,200     More than
  Waste Generated in any         pounds        pounds        2,200 pounds
  calendar month                                             

  Amount of Hazardous Waste      Less than     Less than     More than
  Accumulated at any one time    2,200 pounds  13,000 pounds 13,000 pounds

  Amount of Acute Hazardous      Less than 1   Less than 1   More than 1
  Waste Accumulated              kg            kg            kg

  Amount of Hazardous Waste      Less than 300 More than 300 
  Stored in Hazardous Waste      gallons       gallons       
  Tanks                                                      
  ------------------------------ ------------- ------------- -------------

8.  **What is the shop's hazardous waste generator status?  CESQG  SQG
     LQG\***

*\*This checklist is designed for small shops, and therefore does not
specify requirements for LQGs.*

9.  Does the facility have a hazardous waste identification number? (Req
    -- SQG)

>  Yes  No - *Skip to B.11*

10. If yes, what is it? [\#]{.underline}

    Hazardous Waste Shipment

11. **Does the shop send all hazardous wastes to a permitted hazardous
    waste treatment, storage, or disposal facility or a state authorized
    facility? (Req -- CESQG and SQG)**

>  **Yes**  **No**

12. Does the shop maintain required\* waste shipment records? (Req --
    CESQG and SQG)

     **Yes**  **No**

    *\*Requirements specific to each generator status are noted below*:

-   *SQGs are required to maintain hazardous waste manifests*

-   *CESQGs may maintain either hazardous waste manifests or other
    documentation (e.g., bill of ladings, receipts, tolling agreement,
    letter of acceptance)*

13. Does the shop maintain required records for hazardous waste shipment
    for at least 3 years? (Req -- CESQG and SQG)

>  **Yes**  **No**

Hazardous Waste Management

14. **Are all hazardous waste containers properly\* labeled? (Req --
    CESQG and SQG) []{.mark}**

>  Yes  No

*\*Requirements specific to each generator status are noted below*:

-   *SQGs are required to label all hazardous waste containers in the
    storage area with the words "Hazardous Waste"*

-   *SQGs are required to label all hazardous waste containers at the
    satellite accumulation area with the words "Hazardous Waste" or with
    other words that identify the contents of the container*

-   *CESQGs are required to label hazardous waste containers with the
    words "Hazardous Waste" or with other words that identify the
    contents of the container*

15. Do container labels indicate that incompatible wastes have not been
    placed in the same container? (Req --SQG)  Yes  No

16. Are all hazardous waste containers closed except when materials are
    being added or removed? (Req -- CESQG and SQG)  Yes  No

17. Are containers in good condition? (No leaks, corrosion, bulges,
    etc.) (Req -- SQG)

>  Yes  No

18. Are containers handled in a manner to prevent rupture, leaks, and
    spills? (Req -- SQG)

>  Yes  No

19. Are containers and/or their liners compatible with the hazardous
    waste they hold? (Req -- SQG)  Yes  No

20. Are all used containers cleaned before adding hazardous wastes that
    would be incompatible with materials previously stored in the
    containers? (Req -- SQG)

>  Yes  No

21. Are containers holding incompatible waste kept apart by physical
    barriers (e.g., a dike, berm, or wall)? (Req -- SQG) *(If the shop
    has no incompatible waste, mark "N/A")*  Yes  No  N/A

Hazardous Waste Accumulation and Storage

22. Where is the hazardous waste being accumulated/stored?

*(Check all that apply, and then fill in appropriate section(s))*

 Satellite Accumulation Area(s) - *Answer Questions B.23-B.27 and then
skip to B. 32*

>  A 180-Day Storage Area -- *Skip to Question B.28*

***[Satellite Accumulation Area]{.underline}***:

23. Are all satellite accumulation containers under control of the
    operator and at or near the point of generation? (Req -- SQG)  Yes
     No

24. Is the amount of hazardous waste stored at each satellite
    accumulation area 55 gallons or less? (Req -- SQG) Yes  No

25. Is the amount of acute hazardous waste stored at each satellite
    accumulation area 1 kg or less? (Req -- SQG)  Yes  No

26. Is the satellite accumulation container closed? (Req -- SQG)

>  Yes  No

27. Is the satellite accumulation container in good condition? (Req --
    SQG)

>  Yes  No

***[Hazardous Waste Storage Area]{.underline}***

28. **Is the accumulation area inspected weekly for signs of spills or
    container deterioration? (Req- SQG)**  Yes  No

29. Does the shop keep written records of its inspection of the
    hazardous waste accumulation area for 3 years? (Req- SQG)  Yes  No

30. Is each container labeled with the appropriate\* date? (Req - SQG)

>  Yes  No
>
> *\*If the storage container is not for satellite accumulation, the
> date needs to be recorded as soon as the first drop of waste is added.
> If the container is a satellite accumulation container, it needs to be
> dated as soon as 55 gallons are reached and it is moved to the storage
> area.*

31. Is the shop shipping the hazardous waste off-site according to the
    180-day storage time limit (i.e., no container can remain on site
    for more than 180 days after its accumulation start date unless the
    receiving TSD is 200 or more miles away)? (Req -SQG)

>  Yes  No

32. Has information on the shop and its waste accumulation areas been
    submitted to local police, fire departments, and hospitals? (Req-
    SQG)

>  Yes  No

33. Does the shop maintain an internal communication system if the
    accumulation area is remote? (Req - SQG) *(If there is an
    accumulation area but it is not remote, mark "N/A")*

>  Yes  No  N/A

34. Does the shop maintain a telephone to summon emergency response
    teams? (Req - SQG)

>  Yes  No

35. Does the shop maintain fire extinguishing equipment? (Req - SQG)

>  Yes  No - S*kip to B. 37*

36. Does the shop test fire extinguishing equipment? (Req - SQG)

>  Yes  No

37. Is the accumulation area itself secure and protected from storm
    water? (BMP)

>  Yes  No

38. Does the hazardous waste storage area employ secondary containment
    (i.e. spill/leak containment capability)? (BMP)

>  Yes  No

39. Does the storage area contain ignitable or reactive wastes?

>  Yes  No - S*kip to B. 41*

40. Are ignitable and reactive wastes protected from any materials or
    conditions that could cause them to ignite or react? (Req- SQG)

     Yes  No

41. Are flammable material drums grounded? (BMP)

     Yes  No

42. Does aisle space allow unobstructed movement of personnel and
    emergency equipment? (Req- SQG)  Yes  No

43. Does the shop have a hazardous waste tank?

>  Yes  No - S*kip to B. 46*

44. Are all hazardous waste tanks labeled and closed? (Req - CESQG and
    SQG)

>  Yes  No

45. Do all hazardous waste tanks have less than 300 gallons of waste?
    (Req - CESQG)

>  Yes  No
>
> *If more than 300 gallons of waste are stored, a CESQG becomes a SQG.
> SQGs are allowed to store more than 300 gallons of hazardous waste.*

Hazardous Waste Emergency Planning and Training

46. **Does the shop have a program that trains employees who handle
    hazardous waste in proper waste management procedures? (Req -
    SQGs)**

 Yes  No

47. Does the shop have records indicating that an employee-training
    program is occurring? (Req-SQGs)

 Yes  No

48. Does the shop have a sign by the telephone that lists telephone
    numbers of the local fire department, location of emergency
    equipment, and the phone number of one of more people who are on
    standby and who will coordinate an emergency response? (Req-SQGs)

 Yes  No

49. Does the shop have a written contingency plan designed to help the
    shop reduce hazards associated with the possibility of an explosion,
    fire, or unplanned/accidental release of hazardous materials? (BMP)

 Yes  No

Universal Wastes

50. **Does the shop handle [any]{.underline} of the following
    materials?**

 Yes  No -- Skip to B.59

*(Check all that apply)*

-   **Batteries**

-   **Mercury thermostats**

-   **Mercury containing fluorescent lights** *(usually those with a
    silver end cap)*

-   **Other universal wastes (Please specify:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_)**

    *If a shop has chosen to manage any of these wastes as a hazardous
    waste instead of a universal waste, add them to the hazardous waste
    table above in the "other wastes" section and skip to B.59.*

51. **Are shop employees aware that these materials need to be handled
    according to requirements for universal wastes?**

 Yes  No

52. Are all universal wastes stored in closed containers that prevent
    the release of the waste or waste components? (Req)

    1.   Yes  No

53. Are all universal waste containers labeled with the type of waste
    contained? (Req)

    1.   Yes  No

54. Are all universal wastes accumulated for no longer than one year
    from the date generated? (Req)  Yes  No

55. Does the shop maintain records of the generation date for universal
    wastes? (Req)

    1.   Yes  No

56. Does the shop ensure all employees handling universal wastes have
    been provided information on proper handling and emergency
    procedures? (Req)

    1.   Yes  No

57. Does the shops send all universal wastes to another universal waste
    handler, a permitted facility, or a foreign destination? (Req)

    1.   Yes  No

58. Does the shop maintain shipping manifests for universal wastes?
    (Will be required in 2004)

    1.   Yes  No

        Used Oil and Fuel Tanks

59. Does the shop have one or more above ground tanks for fuel or oil?

    1.   Yes\*  No

60. Does the shop have one or more underground storage tanks for fuel or
    oil?

    1.   Yes\*  No

> *\* If the shop has ASTs or USTs, refer them to tank regulations not
> included in this checklist.*

61. Does the shop generate used oil?

    1.   Yes  No - *Skip to B.68*

62. Are all used oil containers and tanks labeled with the words \"Used
    Oil\"? (Req)

    1.   Yes  No

63. Does the shop send used oil for recycling? (BMP)

    1.   Yes  No - *Skip to B.66*

64. Does the shop keep manifests or bills of lading for shipments of
    used oil? (BMP)

    1.   Yes  No

65. Does the shop avoid mixing used oil and hazardous waste? (Req)

    1.   Yes  No

66. Is used oil burned in a heater?

    1.   Yes  No - *Skip to B.68*

67. Does the shop have a permit to burn used oil in a heater? (Req)

    1.   Yes  No

        Pollution Prevention

*Note: Answer the following questions based on current practices*

68. Does the shop pre-clean parts with mechanical techniques (e.g., a
    squeegee, rag or wire brush) to reduce use of solvent? (P2)  Yes 
    No

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68. Does the shop use solvent recycler to reuse thinners, gun cleaners,
    or other solvents? (P2)

>  Yes  No

69. Does the shop store partially used absorbents in closed, labeled
    containers for reuse? (P2)  Yes  No

70. Does the shop keep containers of liquids, including parts washers,
    covered and cool to reduce evaporation? (P2)  Yes  No

71. Does the shop avoid buying high mercury florescent lamps? (P2)

>  Yes  No

72. Does the shop reuse or recycle all waste electronics? (P2) *(If the
    shop does not generate waste electronics, mark "N/A")*

>  Yes  No \*  N/A
>
> *\*Be sure to mention how the shop can send functioning electronics
> for reuse, and that the shop can take advantage of free electronics
> collection for recycling.*

73. Does the shop take steps to avoid drips and spills of used oil? (P2)

>  Yes  No

74. Does the shop keep spill absorbent material available to clean up
    spills (P2)?

>  Yes  No

Section C: Air Pollution

General

1.  Is the shop creating an odor or nuisance present outside the
    facility's property boundary? (Req)

    *(If yes, the shop is out of compliance)*  Yes  No

    Sanding and Painting Dust

2.  Does the shop generate sanding and/or painting (overspray
    particulate) dust?

    1.   Yes  No - *Skip to C.8*

3.  **Does any airborne sanding or painting dust (i.e., fugitive dust)
    leave the business premises and create a condition of air pollution?
    (Req)** *(If yes, the shop is out of compliance)*

    1.   Yes  No

4.  Does the shop control fugitive dust emissions from the facility
    using a specific device?

    1.   Yes  No - Skip to C.8

5.  Does the dust collection equipment discharge to the atmosphere?

     Yes  No

6.  Does the shop have a permit or registration for dust collection
    equipment? (Req)

     Yes  No

7.  What type of dust control measure is adopted? *(Check all that
    apply)*

>  **Ventilated sander (dustless vacuum) system (BMP)**
>
>  Wet sanding
>
>  Other (*please specify*)

Volatile Organic Compounds (VOCs) and Hazardous Air Pollutants (HAPS)

8.  **Does the facility avoid any use of methylene chloride-based paint
    strippers? (BMP, P2)**

    ** Yes  No**

  ----------------------------- ----------- ------------------------------
  ***Maximum Volatile Organic               
  Compound (VOC) Content for                
  Automobile Refinish                       
  Coatings***                               

  ***Coating category***        ***Grams    ***Equivalent Pounds VOC per
                                VOC per     gallon (for information only,
                                liter***    not for determining
                                            compliance)***

  *Pretreatment wash primers*   *780*       *6.5*

  *Primers/primer surfacers*    *580*       *4.8*

  *Primer sealers*              *550*       *4.6*

  *Single/two-stage topcoats*   *600*       *5.0*

  *Topcoats of more than two    *630*       *5.2*
  stages*                                   

  *Multi-colored topcoats*      *680*       *5.7*

  *Specialty coatings*          *840*       *7.0*
  ----------------------------- ----------- ------------------------------

9.  **Does the shop [only]{.underline} use coatings that comply with
    state and federal VOC emission limitations, as shown in the table
    above? (Req)**

 Yes  No

10. **Is all painting carried out in a spray booth to contain paint
    emissions and over-spray? (BMP)**

    1.   Yes  No

11. **Do the painters and technicians use [only]{.underline} the
    following painting techniques? (Req)**

    1.   Yes  No

        *(Check all that apply)*

         Any non-atomized application technique (e.g., Flow/curtain
        coating, Dip coating, Roller coating, Brush coating,
        Cotton-tipped swab application coating, Electrodeposition
        coating, etc.)

         High Volume Low Pressure (HVLP) spraying;

         Electrostatic spray;

         Airless spray;

         Any other coating application technique that the person has
        demonstrated and DNREC has determined achieves emission
        reductions equivalent to HVLP or electrostatic spray (Please
        specify)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

         Airbrush application methods for graphics, stenciling,
        lettering, and other identification markings \*

>  An application technique to cover finish imperfections equal to or
> less than 1 inch in diameter \* (Please
> specify)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
>
> (\**These two application techniques are exempt from the regulatory
> requirements on air emissions)*

12. Do the painters and technicians use other (i.e., conventional)
    air-assisted painting techniques that atomize paint (Req)? *(If yes,
    the shop is out of compliance)*

     Yes  No

13. **Does the shop clean the spray guns use [only]{.underline} the
    following methods? (Req)**

 Yes  No - *Skip to C.14*

*(Check all that apply)*

>  Use of an enclosed spray gun cleaning system that is kept closed
> when not in use.
>
>  The unatomized discharge of solvent into a paint waste container
> that is kept closed when not in use.
>
>  The disassembly of the spray gun and cleaning in a vat that is kept
> closed when not in use.
>
>  The atomized spray into a paint waste container that is fitted with
> a device designed to capture atomized solvent emissions

14. Does the shop use a spray gun cleaning system that recirculates the
    cleaning solvent and collects the solvent for proper disposal? (BMP)

    1.   Yes  No

    2.  

15. **Does the shop store absorbent paint applicators (e.g., shop
    rags/towels) in closed containers? (Req)**

 Yes  No

16. Does the shop use aerosol cans in its refinishing processes? *(If
    yes, this should be considered in permit requirement
    determination.)*

 Yes  No

17. Does the shop use cold solvent cleaners?

 Yes  No - *Skip to C.18*

C.  17 a) Is the vapor pressure of the solvent used less than 1 mmHg at
    68 ^o^F? (Req)

 Yes  No

18. Does the shop store fresh and used coatings, solvents, and cleaning
    solvents in non-absorbent, non-leaking containers? (Req)

     Yes  No

19. Does the shop keep containers for fresh and used coatings, solvents,
    and cleaning solvents closed at all times except when filling or
    emptying? (Req)

     Yes  No

20. **Does the shop use detergents, high-pressure water, or other
    non-VOC cleaning options to clean coating lines and containers when
    practical? (BMP, P2)**

 Yes  No

21. Does the shop reuse excess coating? (BMP, P2)

    1.   Yes  No

        Record Keeping

22. Does the shop keep the following records at the shop for a period of
    at least 5 years: (Req)

    a.  The name, identification number and manufacturer of each
        coating, reducer, catalyst, surface preparation product, and
        cleanup solvent used at the shop; (BMP)

 Yes  No

b.  The volume of each coating, reducer, surface preparation product,
    and cleanup solvent used at the shop [each month]{.underline}; (BMP)

 Yes  No

c.  Certified Product Data Sheets showing the VOC content, in pounds of
    VOC per gallon of material of each coating and surface preparation
    product used at the shop? (BMP)

 Yes  No

Training Program

23. **Does the shop employ a training program in the proper use and
    handling of coatings, solvents and waste products to minimize air
    emissions? (Req)**

 Yes  No

24. Are the painters of the shop fully trained in proper spraying
    techniques to minimize overspray? (P2)

    1.   Yes  No

    2.  Section D: Water Pollution

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1.  Does the facility have any floor drains in the shop area?

 Yes  No -*Skip to D.2*

D.  1 a) Does the shop have any open floor drains?

 Yes  No -*Skip to D.1 d)*

> **D. 1 b) Are all open floor drains connected to a public sewer?
> (Req)**
>
>  Yes  No - \*

*\*If [none]{.underline} of the open floor drains are connected to a
public sewer, skip to D.1 d)*

D.  1 c) Are those open floor drains connected to a public sewer
    permitted to discharge to the sewer? (Req)

 Yes  No

[]{.mark}

> D. 1 d) Does the shop have any closed floor drains?

 Yes  No -*Skip to D.2*

> D. 1 e) Have all closed floor drains been inspected by DNREC's
> Underground Injection Control (UIC) Program? (Req)

 Yes  No

D.  **1 f) Are all closed floor drains properly closed or sealed,
    according to the UIC Program?**

 Yes  No

2.  Is the facility on a public sewer system?

>  Yes  No

3.  Does the facility generate any [process wastewater]{.underline}
    (e.g., water from wet sanding, water from washing auto body tools
    and equipment, work area washing, or car washing), or any
    [industrial wastewater]{.underline} containing solvents, thinners,
    paint strippers, paints, cleaners, degreasers, auto fluids or any
    other pollutant?

>  Yes  No - *Skip to D.7*

4.  Is process wastewater or industrial wastewater discharged to:

> D. 4 a) An open floor drain?
>
>  Yes  No

D.  4 b) Bathroom/ kitchen sinks, toilets, showers, shop wash basins,
    emergency showers, eyewash stations, or other non-industrial
    drainage outlets?

>  Yes  No

D.  4 c) Storm drains or other runoff outlets (e.g., water runs down the
    street, water runs off to soil or sand area, or water just puddles
    up and evaporates)?

>  Yes  No

D.  4 d) Streams, tax ditches, swales, or wetlands  Yes  No

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D.  4 e) Other (specify) \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
     Yes  No

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5.  What are potential receiving points for process waste or
    contaminated sanitary wastewater?

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D.  5 a) A septic system (i.e., a wastewater treatment or pretreatment
    system)

>  Yes  No

D.  5 b) A drywell or other subsurface leaching system (i.e. french
    drain)

>  Yes  No

D.  5 c) Direct discharge to a waterway  Yes  No

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D.  5 d) A holding tank  Yes  No

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D.  5 e) A cesspool  Yes  No

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D.  5\. f) A sewer system  Yes - *Answer D.6*  No

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D.  5 g) Other (Please Specify)  Yes  No

> *Unless you answered yes to D. 5 f), skip to D.7*

**SEWER SYSTEM**

6.  Does the shop have a process wastewater discharge permit,
    pretreatment permit, or other proper documentation allowing
    discharge to the local sewer? (Req)

>  Yes  No

1.  **OTHER WASTEWATER MANAGEMENT PRACTICES**

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7.  Does the shop discharge [non-process]{.underline} wastewater to the
    subsurface (underground) by way of a septic system? (Req)

    1.   Yes  No - *Skip to D.8*

        D. 7 a) Does the shop have DNREC's approval to discharge
        [non-process]{.underline} wastewater to the subsurface
        (underground) by way of a septic system? (Req)

         Yes  No

8.  **Does the shop have secondary containment for all chemicals,
    including paints, thinners, strippers, cleaners and automotive
    fluids, so as to prevent potential spills from entering open floor
    drains or other access ways to water sources? (BMP)**

    1.   Yes  No

9.  **Does the shop post signs prohibiting the discharge of industrial
    chemicals and/or wastewater to bathroom/ kitchen sinks, toilets,
    showers, shop wash basins, emergency showers, eyewash stations, or
    other non-industrial drainage outlets? (Req)**

 Yes  No

10. **Does the shop prevent discharge of concentrated paints, fuels,
    oils and other vehicle fluids, solvents, thinners, strippers,
    cleaners (including concentrated soaps), and solid materials
    generated from sanding operations and other auto body repair
    preparation materials to underground and surface waters? (Req)**

 Yes  No

11. **Does the shop use dry cleaning methods, such as sweeping and
    vacuuming, when cleaning the shop? (P2)**

>  Yes  No

12. **Does the shop avoid sweeping, blowing, or washing floor dirt,
    dust, and/or other debris ("sweepings") down open floor drains, sink
    drains, or some other access way to water sources? (Req)**

 Yes  No

**D.13** **Does the shop keep paints, cleaners, and any chemicals or
materials that can cause runoff (indoors or otherwise) protected from
rainwater? (P2)**

>  Yes  No

Section E: Solid Waste Management

1.  **Does the shop dispose of hazardous waste separately from solid
    waste? (Req)**

    1.   Yes  No

2.  Does the shop have access to municipally provided solid waste
    pick-up /disposal services in Delaware?

    1.   Yes *- Skip to E.3*  No

> E.2 a) Does the shop hire a contractor who is licensed/permitted to
> pick up and dispose of solid waste? (Req)

2.   Yes  No

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3.  Does the shop avoid storing parts or scrap material for long periods
    (i.e., longer than one year)? (BMP)

    1.   Yes  No

        *If needed, refer shops to the list of recyclers for windshield
        glass and plastic prepared by DNREC.*

        **Best Management Practices for Pollution Prevention and Waste
        Reduction (BMP)**

4.  Does the shop keep storage and work areas clean and well organized?

    1.   Yes  No

5.  Does the shop inspect materials upon delivery, and immediately
    return unacceptable materials to the supplier?

    1.   Yes  No

6.  Does the shop keep accurate records of material usage to measure
    reductions in use?

    1.   Yes  No

7.  Does the shop assign someone to distribute and keep track of
    supplies and raw materials?

    1.   Yes  No

8.  Does the shop locate and repair all leaks to prevent losses?

    1.   Yes  No

9.  Does the shop practice preventive maintenance to avoid future losses
    from leaks?

    1.   Yes  No

10. Does the shop keep all containers covered to prevent evaporation and
    spillage?

    1.   Yes  No

11. Does the shop keep waste streams separate to increase their
    potential for reuse, recycling, or treatment?

    1.   Yes  No

12. Has the shop installed flow meters, flow control devices, and/or
    shut-off nozzles to cut down on water usage?

    1.   Yes  No

13. Has the shop made raw material changes in the last twelve months
    that reduced or eliminated hazardous materials used in its
    operations?

    1.   Yes  No

14. Does the shop label [all]{.underline} waste containers to prevent
    contamination of non-hazardous waste? (P2)

>  Yes  No

15. **Does the shop have a first-in first-out policy for product storage
    areas to prevent materials from becoming outdated? (P2)**

>  Yes  No

Section F: Recycling

**Best Management Practices for Recycling (BMP)**

1.  **Is the shop recycling any of its waste products?**

>  Yes  No

2.  **Is the shop undertaking any reclamation activities?**

>  Yes  No

3.  **Has the shop purchased or used recycled products in the last
    twelve months?**

>  Yes  No

Notes:

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