.~" . ,

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DANGEROUS WASTE INSPECTION CHECKLIST

Part 2

•• Generator Inspection Checklist

GENERATOR NAME: _

INSPECTOR: _ INSPECTION DATE: ......-. _

•

This part of the checklist applies to any person whose actions or processes

generate dangerous wastes as defined in Chapter 173-303 WAC.

Because WAC 173-303-120 and 500 through 525 provide special requirements for

recyclable materials, a separate checklist, Part 5 - Recycling Standards

Inspection Checklist, is provided for generators who produce dangerous wastes

which are recycled .

Comments can be entered either at the bottom of each page or on separate

pages. Blank pages are provided for comments at the end of this checklist.

To complete this checklist, enter the following codes at the right margin as

applicable:

•

Y - YES

N ... NO

NA NOT APPLICABLE

C - SEE COMMENT
:..

•

.y ·.Ye" N _. No

'NA • Not: Applicable

:··~C-·'See Coament:

i·.··.·::·\ •• isEdTiON'.'A.•:.•.9..•....•:.PANGERO~.S..TiAST~:.,P~ERH. .INATION/NOTIFICATION:··,·····,':· .... -.- ;.: :.:.: : :.::..:.:.:.::::.. . ;..:: ; :;:;.;.::.:::;::.::-::.;.:: .

DANGEROUS WASTE DETERMINATION [070]

1. Does the generator generate solid wastes listed under Sections

9903 or 9904?

2. Does the generator generate any characteristic dangerous

wastes?

If yes,

a) Does the generator determine characteristics by testing or

applying knowledge of processes?

b) If determined by testing did generator use test methods in

Section 110, or equivalent?

• c)

If equivalent testing methods were used, attach copy of

testing methods.

Is the waste a state-only corrosive w~ste, designated under

090(6)(a)(11i)?

3. Does the generator generate state-only toxic dangerous wastes

designated under Sections 084 or 101?

If yes, were the wastes designated through testing or book, .

designation?

•

4. Does the generator generate state-only persistent wastes?

If yes, was the waste designated using test data from the waste

or concentration calculations?

1
Y - Yes N·· No

i NA-··.·Not. .Applicable

.. '' .:.co .S.. e COlIIDent.

5. Does the generator generate state-only carcinogenic wastes?

If yes, was t:bis was~e designa~ed under sec~ion 084(7) or 1037

6. Are any other solid wastes generated at this site which have not

been designated, but which the inspector believes maybe

dangerous wastes?

If yes, lis~ solid vas~es and describe processes from wbich t:bey

are genera~ed.

7. Has the ge~erator properly designated all dangerous wastes DWor

EHW?

o

8. Has the generator assigned all applicable. dangerous waste

numbers to hisfher waste streams, and used all applicable

dangerous waste numbers on manifests, annual reports, land

disposal restriction notices and certificat~ons, etc.?

9. If designation involved performing tests and analyses of" the

wastes:

a) Does the generator have on-site, or have ready access to,

equipment for obtaining and preserving waste samples for

tests?

b) Do the waste analyses and test results provide enough

information to accurately designate the generator's

dangerous wastes?

c) Does the generator retain copies of all waste analyses used

to designate his dangerous wastes for a minimum of five

years? [210(3)]

o

.....

10. Has the generator determined appropriate QELs for all waste

streams?

2

()
• .. Y·;·.···Yes N· No

·.NA;··;.·Not .Applicable

:·:.C·.·See Ccament

If yes, is the generat:or a large quant:it:y generat:or (great:er

than 2200 Ibs. per month or bat:cb), a medium quant:it:y generat:or

(220 t:o 2200 Ibs. per month or bat:cb) or ~ll quant:it:y

generat:or (less than 220 pounds per month or bat:cb)? '

EPA/STATE ID NUMBER [170(2)]

11. Has the generator obtained an EPA/state ID number?

If yes,

a) EPA/State ID No.: WA _

•

•

b)

c)

Does the Form 2 on file at Ecology contain current

information?

Does the generator keep a copy of the most current Form 2

on-site?

3

" .
Y -'Y;;s N··- No

'·.NK·-,·Not·. Applicable

..... ··C· -.·See .Conment

II

SMALL QUANTITY GENERATORS [070(8)]

Complete questions 1 through 4 below only if the generator is a small

quantity generator.

1. Does the generator treat or dispose of dangerous waste in an onsite facility?

2. Does the generator ensure delivery to an off-site facility which is:

a. Permitted under WAC 173-303-800 through 840?

b. Authorized to manage dangerous waste by another state with

a hazardous waste program approved under 40 CFR Part 271,

or by EPA under 40 CFR Part 270?

0,

c. Permitted to manage moderate-risk waste under Chapter 173-304

WAC (Minimum Functional Standards for Solid Waste Handling),

operated in accordance with state and local regulations, and

consistent with the applicable local hazardous waste plan that

has been approved by the department? o

d. Permitted to manage municipal or industrial solid waste'in

accordance with state or local regulations, or in accordance

with another state's solid waste laws if the waste is sent out

of state?

3. Does the generator send his waste to a facility which will beneficially use, reuse, legitimately recycle, or reclaim the waste,

or that will treat the waste prior to recycling it?'

4. If the generator currently has an 1D number, does sfhe submit a

Generator Annual Dangerous Waste Report, Form 4?

Note: If "yes" was answered to question 4, and one of the,

following: 1, 2a, b, c, d, or 3, you need not continue on

with the remainder of this checklist.

4

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•

Y>·. Yes N·· No

NA·...·.Not.o.Applicable

. C·.··.See Coament.

The remainder of the questions in this checklist apply to medium and

large quantity generators.

CONTAINER REQUIREMENTS [200 and 630]

1. Is the waste stored in containers?

If yes,

a) Are the containers in good condition? [630(2)]

•

•

b) Is the container labeled with the words "Hazardous Waste"

or "Dangerous Waste"? [200(1)(d)]

c) Is the container labeled in a manner which identifies the

major risk(s) associated with the waste? '[630(3) and

200(1)(d) ]

d) Is the date upon which each period of accumulation begins

. marked on each container and clearly visible for

inspection? [200(1)(c)]

e) Upon transfer of. waste from one container to another, are

labels affixed to the new container? [630(3)]

f) Are labels removed from containers which previously held

dangerous waste unless those containers will continue to

hold dangerous waste? [630(3)]

g) Are the labels readable and unobscured? [630(3)]

h) Are containers compatible with the wastes stored within?'

[630(4)]

i) Are containers closed except when waste is added or

removed? [630(5)(a)]

5
"-.Y··. "Yes .N·· No

··"NA'·""Not Applicable

... :C'·. 'See Caa.nent;

j) Are containers opened, handled, or stored in a manner which

will not damage the integrity of the drum? [630(5)(b)]

k) Is a distance of 30 inches maintained between aisles of

containers holding dangerous waste? [630(5)(c)]

1) Are container storage areas inspected in least weekly?

[630(6)]

m) Was the container storage area put into use after September

30, 1986? [200(1)(b) and 630(7)]

·If yes.

1) Does the container storage area have an impervious

base (free of cracks or gaps) that is designed to

collect and hold spills and leaks?

2) ·Is the base sloped or otherwise designed to drain and

remove liquids from leaks, spills, or precipitation?

o

3) Are uncovered storage areas capable of holding the

additional volume that would result from the

precipitation of a maximum twenty-five year storm of

twenty-four hours duration? o

4) Is the containment area designed for positive drainage

control (such as a locked drainage valve)?

5) For storage areas with containers holding free

liquids, or F020, F02l, F022, F023, F026, or F027

waste, does the containment system'have sufficient

capacity to contain ten percent of the volume of all

containers or the volume of the largest container,

whichever is greater?

6) Is run-on into the containment system prevented?

7) Are containers holding EHW protected from the elements

by means of a building or other protective covering?

6

o
•

8)

. ,Y·:_:.Yes N···.: No

::·NA,·.Not. .Appl1:eable

'.',C • See Coament.

For storage areas which hold wastes that do not

contain free liquids; do not exhibit either the

characteristic of ignitability or reactivity; and are

not F020, F02l, F022 , F023, F026, or F027 , in lieu of

the requirements above is the containment system:

i)

ii)

Sloped or otherwise designed and operated to

drain and remove liquid resulting from

precipitation or,

Are the containers elevated or otherwise

protected from contact with accumulated liquids?

0) Are storage areas for ignitable wastes, and reactive wastes

(other than those described in question 8 above), managed'

in accordance with the Uniform Fire Code? [630(8)(b)]

•

n)

p)

Are containers holding explosive, reactive wastes as

defined in 090(7) (a),(vi), (vii), or (viii) stored in a

manner equivalent to the Uniform Fire Code's "American

Table of Distances For Storage of Explosives," Table 77-

201, 1979 Edition? [630(8)(a)]

Does the generator comply with the requirements of

395(1)(d) Lor ignitable and reactive wastes (yearly

inspection of waste storage areas by someone familiar with

the Uniform Fire Code)? [630(8)(b)]

If yes, is a log kept which documents:

i) Date and time?

ii) Inspector name?

iii) Observations and remediations?

..--

•

q) Are incompatible wastes placed in the same container?

[630(9)(a)]

If yes, .is 395(1)(b) complied with?

r) Is dangerous waste placed in unwashed containers that

previously held incompatUHe waste-?" [630(9) (b)]

7
..:Y.·_·Yes N·. No

">HA:' • :Not: Applicable

C ..- ..See· Conment

s) Are containers holding dangerous wastes that are

incompatible with wastes or materials stored nearby kept

separate from those wastes. or materials by means of a dike,

berm, wall, or other device? [630(9)(c)]

o

Note: For generators storing dangerous waste in tanks, complete

Part 7 of the Dangerous Waste Inspection Checklist.

GENERAL INSPECTION [320]

2. Does the generator maintain a written schedule at the facility

for inspecting:

a) Monitoring equipment?

b) Safety and emergency equipment?

c) Security devices?

3.

d) Operating and structural equipment that help to prevent,

detect, or respond to hazards?

Does the schedule identify types of problems to look for:

a) Malfunction?

b) Operator error?

o

c) Discharges?

4. Does the generator maintain an inspection log?

If yes. does it: include:

a) Date and time of inspection?

b) Name and signature of inspector

c) Notation of observations?

d) Date and nature of repairs or remedial action?

8

o
•

- -Y • Yes N ·-No

'-NA - Not -Applicable

C-.cSeeCoament

e) Are there any malfunctions or other deficiencies noted in

the inspection log that have not been corrected?

(If yes, use narrat:ive explanat:ion sheet: t:o explain

problems not:ed.)

MANIFESTING AND PRETRANSPORT REOUIREMENTS [180]

5. Does the generator ship dangerous waste off-site?

a) If no, do not: fill out: quest:ions 6 t:hrough 12 of t:his

sect:ion.

b) If yes, ident:ify primary off-sit:e facilit:ies. Use

narrat:ive explanat:ion sheet:, if necessary.

6. Does the generator- use the Uniform Hazardous Waste Manifest?

• a) If DO, does t:he generat:or use an alt:ernat:lve manifest:

syst:em for special wast:e in accordance wit:h (170(4))1

b) If yes,

1) Do the manifests include all information required

under 40 CFR Part 262, Subpart B and the Appendix to

Part 262, and WAC 173-303-180(1)1

•

2) Are the manifests filled out completely and

accurately, including state-only sections required

under 180(1)1

If no, explain deficiencies or inaccuracies.

9
:Y'·-Yes N _. No

<'·NA·c. Not Applicable,

..C .-·'See Coament:

3) Does the manifest consist of enough copies to provide

one for the generator, all transporters, and the

receiving facility, and an additional copy to be sent

back to the generator?

4) Does the generator sign and date all manifests?

5) Does the generator obtain handwritten signature and

date of acceptance from initial transporter?

6) Does the generator obtain one copy of the manifest

signed and dated by generator and transporter?

7) Do returned manifests include facility owner/operator

signature and date of acceptance?

8) Are completed manifests returned to the generator

within 45 days?

..

o

If no, Eor t:hose manifests which exceeded t:he 45 day

liJDit, did t:he generator subliJi.t an exception report to

t:he department which included:

i)

11)

A legible copy of the manifest for which the

generator does not have confirmation of

delivery?

A cover letter signed by the generator or his

representative explaining the efforts taken to

locate the waste and the results of those

efforts?

o

.. " .

9) Does the generator retain copies of all manifests for

five years?

10) For bulk shipments of dangerous waste within the

United States by water, does the generator send three

copies of the manifest dated and signed to the

designated facility or, if exported by water, to the

last water transporter to handle the waste in the

U.S. ?

10

o
•

.y.• Yes N·· No

: ·.Nk···NotAppllcable

..... .··C· -.:'See' Comment

11) For rail shipments originating at the site of

generation, does the generator send at least three

copies of the manifest dated and signed to the next

nonrai1 transporter (if any), or the designated

facility (if transported solely by rail), or the last

rail transporter to handle the waste in the U.S.?

7. Does the generator package waste in accordance with 49 CFR Parts

173, 178, and 179 (DOT requirements)?

•

•

8. Are containers to be shipped bulging, leaking, or corroding?

Describe cont:ainers t:he wast:e is sbipped in and t:heir condit:ion.

9. Does the generator label the containers to be shipped in

accordance with the requirements of 49 CFR Part 172?

10. Does the generator mark each container to be shipped in

accordance with the requirements of 49 CFR Part 172?

11. Is each container of 110 gallons or less marked with the words:

"HAZARDOUS WASTE" - State and federal law prohibits improper

disposal. If found, contact the nearest· police or public safety

authority, and the Washington State Department of Ecology or the

United States Environmental Protection Agency," and does the

label include the generator's name and address, and the manifest

document number? .

12. Does the generator provide the transporter with placards in

accordance with 49 CFR Part 172, Subpart F?

PREPAREDNESS AND PREVENTION [ 340]

13. Is there evidence of fire, explosion, or contamination of the

environment?

IE yes, use narrat:ive explanat:ion sbeet: t:o explain.

14. Is the.faciHty equipped"with:

11
:Y •.Yes N .. :No

,··NAc·. ·Not.:·Applicable

.". ·'-:.C· .·:·See Coument:

a) Internal communication or alarm system?

If yes, is it: easily accessible in case of emergency?

b) Telephone or two-way radio to call emergency response

personnel?

c) Portable fire extinguishers, fire control equipment, spill

control equipment, and decontamination equipment?

d) Water of adequate volume for hoses, sprinklers, or water

spray system?

Describe source of water:

e) Are the above items tested or inspected for proper

operation?

15. Is there sufficient aisle space to allow unobstructed movement

of personnel and equipment?

16. Has the generator made arrangements with the local authorities

to familiarize them with characteristics of the facility?

(Layout of facility, properties of hazardous waste handled and

associated hazards, places where facility personnel would

normally be working, entrances' to roads inside facility,

possible evacuation routes.)

17. In the case that more than one police or fire department might

respond, is there a designated primary authority?

If yes, name primary aut:horit:y:

18. Does the generator have phone numbers of and agreements with

State emergency response teams, emergency response contractors,

and equipment suppliers?

Are they readily available to all personnel?

19. Has the generator arranged to familiarize local hospitals with

the properties of hazardous waste handled and types of injuries

that could result from fires, e~plosions, or releases at the

facility?

12

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o
•

•

•

<y - Yes - N - - No

c; MA-- Not- Applicable

--C----oSee -Coament

20. If State or local authorities decline to enter into an

agreement, is this entered in the operator record?

REPORTING [220]

21. Does the generator submit by March 1 of each year a Generator

Annual Dangerous Waste Report (Form 4)?

If yes. is t:he report: filled out: complet:ely and accurat:ely?

If t:he report: is inaccurat:e or incomplet:e. explain deficiencies

22. Does the generator keep for five years copies of all annual

reports?

SPILLS AND DISCHARGES TO THE ENVIRONMENT [145]

23. Has there been any spills or discharges of dangerous waste on

the generator's site since the last inspection?

If yes. I

a) Describe material spilled, date of incident, quantity

spilled, and description of incident. ~--

•

b) Was the spill or discharge reported to Ecology, and local

authorities in accordance with the local emergency plan

and, for air emissions, the local air pollution control

authority?

13
. y'.= ·Yes N D No

HADNot Appl1.cable

1·..,,·C'.See. Comment:

If no. provide an explsnat:ion belOtl (e.g .• t:he spill was tio

t:ot:ally enclosed secondary cont:ainment:. t:he discharge was

permit:t:ed under stzet:e , federal or local laws or

regulat:ions. or simply failure't:o report:).

. c) Did the generator take immediate action to protect human

health and the environment?

d) Describe further action, if any, required by Ecology

regarding the spill or discharge.

IMPORTING/EXPORTING DANGEROUS WASTE [230]

24. Has the generator received from or transported to a foreign

source any dangerous waste?

If yes.

a) Has the generator filed a notice with the department?

b) Is this waste manifested and signed by a foreign consignee?

o

o

c) If the generator shipped the waste out of the country, did

s/he receive confirmation of delivery of shipment?

14

o
•

.y = Yes N = No

NA- Not Applicable

·C·. See Comnent

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1. Does the generator generate acutely hazardous waste, as defined

in 040(2)?

If yes, b&is section does not apply. The generator is subject to

the requirements for large quantity generators. Complete

Section E of this checklist.

2. Does the generator accumulate waste on-site in containers before

transport?

If yes,

•

a) Is the waste sent off-site for treatment, storage or

disposal, placed in an on-site permitted storage area,

recycled on-site, or treated .in containers or tanks (with

regional approval) within 180 days of generation?

If no, was a 90-day extension granted by Ecology due to

circumstances requiring transport greater t:han 200 miles

for treatment, storage, or disposal?

•

b) In lieu of the requirements of 350 and 360 (contingency

plan and emergency procedures):

1) Is there, at all times, an emergency coordinator

either on-site or on-call to coordinate emergency

response measures.

2) Is the following posted next to all emergency

communication devices?

i) Name and phone number of emergency coordinator?

ii) Location of fire extinguishers and spill control

material, and fire alarm?

iii) Telephone number of the fire department, unless

the £acilityhas "a"direct 'alarm?

15

,,".
3) Does the generator ensure that all employees are

thoroughly familiar with proper waste handling and

emergency procedures relevant to their assigned

responsibilities?

16

..y' - Yes N - No

"NA- Not. .Applicable

C,·-Seeeoument.

o

o

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o