•

DANGEROUS WASTE INSPECTION CHECKLIST

Part 4

•• General TSD ~acility Inspection Checklist

FACILITY NAHE: _

INSPECTOR: INSPECTION DATE: ___

This checklist applies to all facilities which treat, store, or dispose of

dangerous waste, including interim status and final status· facilities. A

separate checklist (Part 6) is provided for Permit-By-Rule facilities.

The General TSD Facility Checklist is composed of two sections:

Requirements for facilities that recycle hazardous waste are addressed in

the Recycling Standards Checklist, Part 5, which covers the requirements of

sections 120 and 500 through 525. •

Section A

Section B

General Facility Standards

Closure and Financial Assurance

•

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

as applicable:

y - YES

N .- NO

NA - NOT APPLICABLE

C - SEE COMMENT

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

pages. A narrative explanation sheet is provided for comments at the end

of this checklist.
.c ,Y'~ 'Yes, ·N .'No'

< NA .•. Noe' ApplIcable

. ". "C ... See Comnene

•....•..,., ..,/< "<'SgCTIO!4::X ~:~~~¥~¢~#:r,",ST~AiU>:S.[~80:THR....·.·.•·•....·OUGH395J., ........................:::. ..::.:. -:'." ."./:':=:=:.::.:.

1. Does the facility have an EPA/State 10 Number? [280(3)]

.

"

c

a) If yes, EPA/State ID Number: riA

b) If no, explain:

. 2. Is the facility maintained/operated in a manner that prevents:

[283]

a)

b)

c)

d)

e)

Degradation of ground water quality?

Degradation of air quality?

Degradation of surface water quality?

Destruction or impairment of flora and fauna outside the

active portion of the facility?

Excessive noise?

I

I'

f) Conditions that constitute a negative aesthetic impact for l the public or adjacent landowners?

g) Unstable hillsides or soils?

h) Use of processes that do not treat, detoxify, recycle,

reclaim, and recover waste material to the extent

economically feasible?

i) Endangerment of the health of employees or public?

If no, for any of items a-i above, explsin: (Use narrative

explanati~ sheet if necessary)

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.y YesN -No

··NA,,·."Not Applicable

":. C'. See Coament

3. Has the facility received hazardous waste from a foreign source?

[290(1)] .

. If yes, was Ecology not:ified four weeks prior t:o expect:ed dat:e

of arrival of t:be sbipment:?

4. Has the facility received waste from off-site sources? [290(3)]

If yes, was a not:ice sent: t:o each generat:or st:at:ing t:be facilit:y

bas proper permit:s and will accept: t:be wast:e?

SPECIAL REOUIREMENTS FOR MANAGING SPECIAL WASTES [550 AND 560]

This question applies to "special wastes" defined as any dangerous

waste that is solid only (nonliquid, nonaqueous, nongaseous), that is

not a regulated hazardous waste under 40 CFR Part 261, and that is

designated as o~ly Dangerous Waste (OW) in sections 090, 101, 102, or

103. Any solid waste that is Extremely Hazardous Waste (EHW) or that

is regulated by EPA as hazardous waste cannot be a special waste.

Unless less stringent standards have been approved by the department,

facilities managing special waste are subject to all applicable

provisions of Chapter 173-303 WAC.

5. Has the owner/operator of the facility requested and the

department approved less stringent standards for the management

of special wastes at this facility?

If yes, is t:be facilit:y in compliance wit:b t:bese revised

st:andards?

WASTE ANALYSIS [300 and 40 CFR Part 265]

6. Does the facility maintain a copy of the waste analysis plan

on-site?

a) If yes, does it: include:

1) Parameters for which each waste will be analyzed?

2) Methods used to test for these parameters?

2
··.·,Y·. ·Yes N·'·· No

':':. MA'·.· Not: Applicable

. 'C·.· See ···Coament

3) Method used to obtain representative samples?

4) Frequency with which the initial 'analyses will be

reviewed or repeated?

5) (For off-site facilities) Waste analyses that

generators have agreed to supply?

6) (For off-site facilities) Procedures for confirming

that wastes received match wastes specified on the -

manifest or shipping paper including:

i. Procedures for identifying the movement of each

waste stream at the facility?

ii. Sampling method to be used to obtain

representative sample of the waste to be

identified?

7) For Interim Status facilities sto~ing waste in

containers:

-i) Methods for determining compatibility of a waste

to a container (if not determined when

containers were first selected)? [265.172]

ii) Methods for determining compatibility of a waste

to other wastes or materials stored nearby?

[265.177(c)]

iii) Methods for determining compatibility of a waste

to wastes previously held in reused containers

that were not decontaminated? [265.177(b)]

iv) Methods for analyzing ignitable/reactive

containerized wastes?

8) For .Interim Status facilities storing waste in tanks:

i) Methods for determining compatibility of a waste

to a tank and its secondary containment (if not

determined when the tank waste first selected)?

[265.199]

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SECURITY [310]

•

• 7.

""Y" - Yes" "N -" No

""HA - Not" Applicable

""C"""-" See 'Coament

ii) Methods for determining compatibility of a waste

to any raw materials or other waste potentially

or previously held in the tank by conducting

analyses or trial treatment or storage tests,

(e.g., bench scale, pilot plant) or by obtaining

written documented information on similar wastes

under similar conditions? [265.200]

iii) Methods for determining compatibility of a waste

to other wastes or materials held or treated

nearby?

iv) Methods for analyzing ignitable/reactive wastes

managed in tanks? [265.198]

9) Methods for meeting additional waste analysis

requirements under 40 CFR Part 265 Subparts F through

R for interim status facilities and WAC 173-303-630

through 670 for final status facilities?

For security, does the facility have:

a) Signs warning unauthorized personnel to keep out posted at

each entrance, legible from 25 feet or more?

I

b) 24-hour surveillance system a barrier surrounding the

active portion of the facility with a means to control

entry to the facility?

Describe a) and b) above:

,.. -

•

GENERAL INSPECTION [320]

8. Does the owner/operator maintain a written schedule at the

facility for inspecting:

4
·Y:,·•. ·Yes ·N •. No

:.·:Hk-··Not·:Appl'lcable

.:C • See: Coament

a) Monitoring equipment?

b) Safety and emergency equipment?

c) Security devices?

d) Operating and structural equipment that help to prevent,

detect, or respond to hazards?

9. Does the schedule indicate frequency of inspections for specific

items (e.g., areas subject to spills should be inspected daily)?

10. Does the schedule identify types of problems to look for

including:

a) Malfunction?

b) Operator error?

c) Discharges?

11. Does the inspection schedule include the applicable items and

frequencies required in:

a) 40 CFR- Part 265 Subparts F through R for interim status

facilities?

b) 630 through 680 for final status facilities?

12. Does the owner/operator maintain an inspection log?

a) If yes. does it include:

1) Date and time of inspection?

2) Name and signature of inspector?

3) Notation of observations?

4) Date and nature of repairs or remedial action?

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• . :.'.y',.•. ,Yes' . N··. No

,·jIA'··. Not Applicable'

'.. '" '..C' "'··'See Coament

b) Are there any malfunctions or other deficiencies not

corrected? (If yes, use narra~ive explana~ion shee~ ~o

explain problems no~ed.)

PERSONNEL TRAINING [330]

13. Does the owner/operator maintain a written training plan at the

facility?

a) If yes, does the plan include:

1) Job.tit1e and written job description, employee name

for each dangerous waste management related position?

2) Description of type and amount of training for each

position?

3) Records documenting training completion?

b) Are training records for former employees kept for three

years from last date of employment?

• c) Is the training program directed by a person knowledgeable

in dangerous waste handling practices?

d) Is the training relevant to the positions in which the

facility staff are employed?

e) Do facility personnel participate ~n an annual review of

the training provided in the program?

•

f) Is training given within 6 months of employment or within 6

months of an employee being assigned to a new position?

J

g) Are new employees supervised until they complete the

training program?

h) Does the training program:

1) Teach personnel to perform their duties in a way that

ensures compliance with WAC 173-303?

6
:,...y:. ·yes ,N:····No

··'RA·. Not Applicable

.:c.·.seeeoament

2) Instruct personnel on contingency plan implementation?

3) Familiarize personnel with emergency equipment and

systems, and emergency procedures?

REQUIREMENTS FOR IGNITABLE. REACTIVE. OR INCOMPATIBLE WASTES

[395(1)]

14. Does the facility handle ignitable or reactive wastes?

a) If yes, is WBS~e separa~ed and pro~ec~ed from sources of

igni~ion or reac~ion (open flBDJes, SlIIOking, cutitiing and .

welding, bot: surfaces, fric~ional hea~), sparks (s~a~ic,

elec~rical, or mechanical), spon~aneous·igni~ion (e.g.,

from beet: producing chemical reac~ions), and radian~ hea~?

1) If yes, use narra~ive explana~ion shee~ ~o describe

separa~ion and confinemen~ procedures.

2) If no, use narra~ive explana~ion shee~ ~o describe

sources of igni~ion or reac~ion.

b) Are smoking and open flame confined to specifically

designated areas?

c) Are "No Smoking" signs posted in areas where there is a

hazard from ignitable or reactive wastes?

d) Are precautions documented in the operating record

(required under section '380(1»?

e) Are storage areas for ignitable and reactive wastes

inspected yearly by a person familiar with the Uniform Fire

Code?

1) If yes, are ~e following notzed in ~e inepectiion log

or opera~ing record:

i) Date and time of inspection?

ii) Name of professional inspector or fire marshal?

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Y- Yes W ·,No

-MA- Not Applicable

C-- See Coament

iii) Notation of observations?

iv) Remedial actions taken?

CONTAINER MANAGEMENT [630 and 40 CFR Part 265]

15. Are containers in good' condition? [265.171]

16. Are containers holding hazardous wastes closed? [265.173]

17. Are the containers opened, handled, or stored in a manner which

may rupture the container or cause it to leak? [265.173]

18. Are the containers inspected at least weekly for leaks and

deterioration? [265.174]

19. Do container areas have a containment system capable of holding

spills and leaks, and accumulated rainfall? [630(7)]

If yes,

• . a)

b)

Is the base sloped or otherwise designed to drain and

remove liquids from leaks, spills, .or precipitation?

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?

c) Is the containment area designed for positive drainage

control?

d) For containers holding free liquids, or F020, F021, 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?

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

f) Are containers holding EHW protected from the elements by

means of'a building or o~her -protective covering?

8
g)

..:·.:ri-. Yes·' :,N·'·- No

I,' ifA,'···· Not. AppU:cable .'C :·~See Coament.

For storage areas which hold wastes that do not contain

free liquids; do not exhibit either the characteristic of

ignitabi1ity; or reactivity; and are not F020, F021, F022,

F023, F026, or F027, in lieu of the requirements above is

the containment system:

1) sloped or otherwise designed and operated to drain and

remove liquid resulting from precipitation or,'

2) are the containers elevated or otherwise protected

from contact with accumulated liquids?

C~

20. Are containers holding ignitable and reactive wastes located at

least 15 m (50 ft) from facility property lines? [265.176]

21. Are containers made of materials that will not react with the

wastes stored within? [265.172]

22. Are incompatible wastes or materials. placed in the same

container? [265.177(a)]

23. Are containers washed or cleaned prior to storage of a waste

which is incompatible with the contents held previously?

[265.17i(b)]

24. Are incompatible wastes separated from each other by a berm,

dike, wall, or other device? [265.177(c)]

CONTAINER AND TANK LABELING [630(3) AND 395(6)]

25. Are containers and tanks labeled in a manner which adequately

identifies the major risk(s) a$sociated with the contents of the

containers?

26. Upon transfer of waste from one container to another is a label

affixed to the new container, and the label on the old container

destroyed (unless the container will continue to be used for

storage of wastes)?

27. Are the labels on containers and tanks unobscured and readable?

28. For ta~ks, are labels legible at a distance of 50 feet?

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':,Y:·. Yes "N • No

i :HA:., Not AppU:eable

>.,,"':C .'·:See 'Coament

LOADING AND UNLOADING AREAS [395(4)]

29. For

the

and

a)

b)

c)

d)

facilities that receive or ship liquid dangerous waste, are

loading and unloading areas designed, constructed, operated,

maintained to:

Contain spills and leaks?

Prevent release of dangerous wastes to ground or surface

waters?

Contain contaminated washwaters?

Allow for rapid removal of collected wastes from spills,

leaks, and equipment cleaning?

•

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PREPAREDNESS AND PREVENTION [340]

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

environment?

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

31. Is the facility equipped with: ,:.: <

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?

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.."-
·y. ·Yes ·N· ···No

NA -Not Applicable

.. >C··.···See Coament

32. Is there sufficient aisle space to allow unobstructed movement

of personnel and equipment?

33. Has the owner/operator 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.)

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

respond, is there a designated primary authority?

If yes, name pr1.ma.ry authori~:

35. Does the owner/operator have phone numbers of and agreements

with State emergency response teams, emergency response

contractors, and equipment suppliers?

Are the phone numbers readily available to all personnel?

36. Has the owner/operator arranged to familiarize local hospitals

with the properties of hazardous waste handled and types of

injuries that could result from fires, explosions, or releases

at the facility?

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

agreement, is this entered in the operating record?

CONTINGENCY PLAN AND EMERGENCY PROCEDURES [350 and 360]

~8. Is a contingency plan maintained at the facility?

a) If. yes, is it: a revised SPCC (or other emergency) plan?

b) Does the contingency plan include:

1) A description of actions facility personnel must take

to comply with sections 350 and 360?

11

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2)

'y.,. Yes N·· No

11K- ·Not Applicable

":C - See Coument

For off-site facilities, a description of actions to

be taken upon receipt of an unacceptable dangerous

waste shipment which presents a hazard to public

health and the environment?

•

•

3) Arr~ngements with local emergency response

organizations? '.

4) Emergency coordinators' names, phone numbers, and

addresses?

5) List of all emergency equipment at facility,

descriptions of equipment, and locations?

6) Evacuation plan for facility personnel?

c) Were copies of the contingency plan and revisions submitted

to local emergency organizations?

d) Is the plan current?

39. Is there an emergency coordinator on-site or on-call at all

times?

MANIFEST' SYSTEM, RECORD KEEPING, AND REPORTING [370, 380, 390]

40. Does the facility receive wastes from off-site?

If yes, does t:he owner/operat:or ret:ain copies of all manifest:s

for t:hree years from dat:e of delivery?

a) Are manifests signed and dated and returned to the

generators within 30 days of delivery?

b) Is a .signed copy given to the transporter?

41. Does the facility receive any waste from a rail or water (bulk

shipment) transporter?

If yes, is it: accompanied by a manliest: or shipping paper?

12

c-
··..yio...··y...s·· .o·N"·,;,·oNo

tu..·NotApp11cable

.... ·/:.c ...~o:See Coament

a) Does the owner/operator sign and date the manifest or

shipping paper and return a copy to the generator within 30

days?

b) Is a signed copy given to the transporter?

c) Are copies· of manifests and shipping papers kept at the

facility at least three years from date of delivery?

42. Has the owner/operator received any shipments of waste that were

inconsistent with the manifest (manifest discrepancies)?

a) IE yes. bas s/he attempted to reconcile the discrepancy

with the generator and transporter?

b) IE DO. bas Ecology been DotUied?

43. Has the facility received any regulated quantities of dangerous

waste not accompanied by a manifest?

IE yes. bas s/he submitted an unmaniEested waste report to

EcoloV?

44. Does the owner/operator keep a written operating record at the

facility?

IE yes. does it include:

a) Description and quantity of each hazardous waste received?

b) Methods and dates of treatment, storage, and disposal?

c) Location of each hazardous waste and quantity of each

hazardous waste at each location?

d) For disposal facilities, a map or diagram of each cell or

disposal area?

e) Cross-references to manifests/shipping papers?

f) Records and results of waste analyses?

13

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Y'..··Yes N - No

'.. NA ... ··Not: Applicable

.... ···C - See ·Coament

•

g)

h)

i)

Report of incidents involving implementation of the

contingency plan?

Records and results of required inspections?

Monitoring, testing, or analytical data and corrective

action required under 40 CFR Part 265 Subparts F through R

for interim status facilities, and WAC 173-303-630 through

680 for final status facilities?

j) Closure cost estimates and, for disposal facilities, postclosure cost estimates?

k) Copies of notices to generators as specified in 290(3)?

45. Does the facility submit a TSD Facility Dangerous Waste Report

(Form 5) to Ecology by March 1 of each year?

If yes, are t:he report:s complet:e and accurat:el

46. Does the facility submit to Ecology reports on all incidences

requiring implementation of the contingency plan within 15 days

of their occurrence ·as specified in 360(2)(k)?

.• 47. If applicable, does the facility submit to Ecology reports on

interim status groundwater monitoring data as specified in 40

CFR 265.94(a)(2) and (b)(2)?

WASTE REDUCTION

48. Was the facility referred to Ecology's Waste Reduction,

Recycling and Litter Control Program?

49. Does the facility have a waste minimization plan on file?

•

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CLOSURE PLAN [40 CFR Part 265.112]

This section applies to owners/operators of all dangerous waste

facilities.

1. Does the facility have a written closure plan?

If yes. does t:be plan include:

a) A description of how each dangerous waste management unit

at the facility will be closed?

b) A description of how final closure of the facility will be

conducted, identifying the maximum extent of the operation

which will be unclosed during the active life of the

facility?

1\

c) An estimate of the maximum inventory of dangerous waste

ever on-site over the active life of the facility?

d)

e)

A detailed description of the methods to be used during

partial closures- and- final closure (e.g. methods for

removing, transporting, treating, storing and disposing of

all dangerous wastes) and identification of the type(s) of

off-site dangerous waste management units to be used?

A detailed description of the steps needed to remove or

decontaminate all dangerous waste residues and contaminated

containment system components, equipment, structures, and

soils including, but not limited to, procedures for

cleaning equipment and removing contaminated soils, methods

for sampling and testing surrounding soils, and criteria

for determining the extent of decontamination required to

satisfy the closure performance standards?

o

f) A detailed description of other activities necessary during

the closure period to ensure that all partial closures and

final closure satisfy the closure performance standards,

including, but not limited to, groundwater monitoring,

leachate collection, and run-on and run-off control?

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Y'aYes N..a·' No

'!fA' .·Not'.Applicable

. ,C' •... See 'C0am8nt

g) A schedule for closure of each dangerous waste management

unit and for final closure of the facility to include the

total time required to close each dangerous waste

management unit and the time required for intervening

closure activities which will allow tracking of the

progress of partial and final closure?

h) For facilities that use trust funds for financial assurance

under 265.143 or 265.145 and whose remaining operating life

is less than 20 years and for facilities without approved

closure plans, an estimate of the expected year of final

closure?

2 . Was there:

a)

b)

Change(s) in operating plans or facility design which would

affect the closure plan?

A change in the expected year of closure?

c) Unexpected events in conducting partial ,or final closure

activities which would require modification of the closure

plan?

• 1) If yes,. t:o a), b). or c) above. has t:he ownerjoperat:or

submit:t:ed a vrit:t:enrequest: t:o amend t:he closure plan?

If no, explain: _ '.

•

3. Was the closure plan amended 60 days prior to the proposed

change in the facility design or operation; 60 days after an

unexpected event which has affected the closure plan; or 30 days

after an unexpected event if it occurred during the partial or

final closure period?

16
··.r-Yes N-··No

...·NA -'Not·· Appl icable·

·C a··See Coament·

4. For facilities with approved closure plans, was the modified

plan submitted 60 days prior to the proposed change in facility

design; 60 days after an unexpected event which has affected the

closure plan; or 30 days after an unexpected event if it

occurred during the partial or final closure period?

NOTIFICATION OF PARTIAL AND FINAL CLOSURE· [40 CFR Part 265.ll2(d)]

5. Has the facility's permit been terminated, or has the facility

been ordered by judicial decree or final order to cease

receiving dangerous wastes or to close?

If yes. did the owner or operat:or submit: the closure plan within

15 days sft:er such occurrence?

6. For surface impoundments, waste piles, land treatment, or

landfill units, did the owner/operator submit the closure plan

at least 180 days prior to the date on which s/he expects to

begin closure of the first unit or final closure of any such

unit, whichever occurred earlier?

7.

8.

For facilities with only tanks, container storage, or

incinerator units, did the owner/operator submit the closure

plan at least 45 days prior to the date at which s/he expects to

begin final closure?

For surface impoundments, waste piles, land treatment and

landfill units with approved closure plans, did the owner or

operator notify the department in writing at least 60 days prior

to the date on which s/he expects to begin closure?

o

9. For facilities with approved plans that have only tanks,

container storage, or incinerator units, did the owner/operator

notify the department in writing at least 45 days prior to the

date on which s/he expects to begin final closure?

10. Is the expected date for beginning closure no later than 30 days

after the date the dangerous waste management unit receives the

final volume of dangerous waste or, if the unit is to receive

additional dangerous wastes, within one year of the date the

unit received the most recent volume of dangerous waste?

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::--y,-. Yes N--·"No _

::,HA:· -Not ApplicableC • -See Co<mnent:

If no, has an ext:ension been grant:ed t:o t:be one-year limit:?

11. Was the closure plan approved?

If not, exp1ain, _

CLOSURE [40 CFR Part 265.113]

12. Has the owner/operator treated, removed from the unit or

facility, or disposed of on-site all dangerous waste within 90

days after receiving the final volume of dangerous waste or

within 90 days of approval of the closure plan?

If no, did t:be depart:ment: grant: an ext:ension t:o t:be 90-day

limit:?

13. Were partial or final closure activities completed in accordance

with the approved closure plan and within 180 days after

receiving the final volume of dangerous wastes or 180 days after

approval of the closure plan, whichever is later?

If no, did t:be depart:ment: grant: an ext:ension t:o t:be 180- day

limit:?

14. Were all contaminated equipment, structures and soils properly

disposed of or decontaminated during the partial or final

closure periods?

15. Within 60 days of completion of closure of each dangerous waste

management unit (including tank systems and container storage

areas), and within 60 days of completion of final closure, did

the owner/operator submit to the department a certification that

the dangerous waste management unit or facility was closed in

accordance with specifications in the closure plan?

If yes, was t:be cert:ificat:ion signed by t:be otmer/operat:or and

by an independent: regist:ered professional engineer?

18
.y. -·.Yes ·N.·-No

'NA·.·-'·Not. :Applicable

.., \:'C.·': See Coament. .

FINANCIAL ASSURANCE FOR CLOSURE [40 CPR Part 265.142 AND .143]

16. Does the owner/operator have a detailed, written estimate of the

cost of closing the facility in accordance with the requirements

of chapter 173-303 WAC?

a} If yes, will ebe coet: es~ima~e fully cover ebe aost: of

closure of ebe facili~?

b} If no, explain: _

17. Does the facility have adequate financial assurance

documentation covering closure?

LIABILITY COVERAGE [40 CPR Part 265.147]

18. Does the facility have adequate financial assurance

documentation covering sudden accidental occurrences?

19. If the facility has a regulated unit on-site as defined in

040(75), does the facility have adequate financial assurance

documentation covering non-sudden accidental occurrences?

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DANGEROUS WASTE INSPECTION CHECKLIST

-- Narrative Explanation Sheet -- .

FACILITY NAME: _

INSPECTOR: INSPECTION DATE: _

Please indicate which Part, Section, and question number your comments

correspond to: