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STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE

LARGE QUANTITY GENERATOR (LQG) REQUIREMENTS
GENERAL REQUIREMENTS

Did Generator transport, offer for transport, or otherwise send HW only to a designated facility or a facility authorized to receive the HW? [40 CFR 262.10(a)(3)]

Did Generator make an accurate determination as to whether a solid waste was hazardous?  [40 CFR 262.11(a-d)]

Did Generator maintain records that support the HW determination for at least three years?  [40 CFR 262.11(f)]

Did Generator to determine its proper category?  [40 CFR 262.13]

Did LQG ship waste off site within 90 days? [40 CFR 262.17(a)]

Did Generator have an EPA ID number prior to treating, storing, disposing of, transporting, or offering for transportation HW? [40 CFR 262.18(a)]

Did Generator offer HW to transporters or to TSD facilities that have received an EPA ID number?  [40 CFR 262.18(c)]

Did recognized trader have an EPA ID Number prior to arranging for import or export of HW?  [40 CFR 262.18(e)]

USE AND MANAGEMENT OF CONTAINERS

Did LQG immediately transfer HW from a container not in good condition or leaking to a container in good condition? [40 CFR 262.17(a)(1)(ii)]

Did LQG use a container made of or lined with materials that will not react with, and are otherwise compatible with, the HW being accumulated? [40 CFR 262.17(a)(1)(iii)]

Did LQG keep containers holding HW closed except when it was necessary to add or remove waste? [40 CFR 262.17(a)(1)(ivA)]

Did LQG handle containers holding HW in a manner that prevented container rupture and leakage? [40 CFR 262.17(a)(1)(ivB)]

Did LQG inspect central accumulation areas at least weekly looking for leaking containers and for deterioration of containers?  [40 CFR 262.17(a)(1)(v)]

Did LQG locate ignitable or reactive waste at least 15 meters (50 feet) from property line? [40 CFR 262.17(a)(1)(viA)]

Did LQG take precautions to prevent accidental ignition or reaction of ignitable or reactive waste and conspicuously placed “No Smoking” signs wherever there is a hazard from ignitable or reactive waste?  [40 CFR 262.17(a)(1)(viB)]

Did LQG comply with the special conditions for incompatible wastes in a container? [40 CFR 262.17(a)(1)(vii)]

Did LQG mark or label containers with the words “Hazardous Waste” and an indication of the hazards of the contents?  [40 CFR 262.17(a)(5)(iA-B)]

Did LQG mark or label its containers with the accumulation start date clearly visible for inspection on each container? [40 CFR 262.17(a)(5)(iC)]

LABELING AND MARKING CONTAINERS AND TANKS

Did LQG mark or label tanks with the words “Hazardous Waste” and an indication of the hazards of the contents?  [40 CFR 262.17(a)(5)(iiA-B)]

Did LQG maintain the required records showing HW was accumulated for no more than 90 days in a tank and keep records with the required information on site and readily available for inspection?  [40 CFR 262.17(a)(5)(iiC-D)]

SATTELITE ACCUMULATION AREAS (SAA) REQUIREMENTS

Did Generator immediately transfer HW from a satellite container not in good condition or leaking to a container in good condition and not leaking, or immediately transfer and manage the waste in a central accumulation area? [40 CFR 262.15(a)(1)]

Did Generator use a satellite container made of or lined with materials that will not react with, and are otherwise compatible with, the HW being accumulated?  [40 CFR 262.15(a)(2)]

Did Generator comply with the special standards for incompatible wastes in a satellite container?  [40 CFR 262.15(a)(3)]

Did Generator keep satellite container closed except when adding, removing, or consolidating waste, or when temporary venting of a container was necessary? [40 CFR 262.15(a)(4)]

Did Generator mark or label a satellite container with the words “Hazardous Waste” and an indication of the hazards of the contents?  [40 CFR 262.15(a)(5)]

Did Generator comply within three consecutive calendar days with the applicable central accumulation area requirements or remove the excess amounts from the satellite accumulation area to either a central accumulation area or an on-site or off-site facility and mark or label satellite containers holding the excess accumulation of HW with the date the excess amount began accumulating? [40 CFR 262.15(a)(6)]

LQG operating satellite accumulation areas must meet the Preparedness, Prevention and Emergency Procedures in subpart M of 262. [40 CFR 262.15(a)(8)]

PRE-TRANSPORT REQUIREMENTS

Did Generator package hazardous waste in accordance with 49 C.F.R. Parts 173, 178, and 179? [40 CFR 262.30]

Did Generator label each package of hazardous waste in accordance with Part 172? [40 CFR 262.31]

Did Generator mark packages of hazardous waste in accordance with 49 C.F.R. Part 172? [40 CFR 262.32(a)]

Did Generator properly mark each container of HW before transporting or offering for transportation waste off site?  [40 CFR 262.32(b)]

Did Generator placard or offer the appropriate placard for a vehicle containing hazardous waste, in accordance with 49 C.F.R. Part 172, Subpart F? [40 CFR 262.33]

Did Generator comply with the requirement prohibiting the placement of bulk or non-containerized liquid HW or HW containing free liquids (whether or not sorbents have been added) in a landfill? [40 CFR 262.35]

MANIFEST REQUIREMENTS

Did Generator prepare a manifest before transporting or offering hazardous waste for transport off-site? [40 CFR 262.20(a)(1)]

Did Generator designate an authorized facility on the manifest? [40 CFR 262.20(b)]

Did Generator designate an alternate facility or instruct the Transporter to return the waste when the Transporter was unable to deliver the waste? [40 CFR 262.20(d)]

Did LQG properly sign the manifest upon receipt of a returned shipment of HW?  [40 CFR 262.17(g)]

Did Generator use EPA approved manifest forms for shipments of hazardous waste? [40 CFR 262.21(g)(1)]

Did Generator determine if generator or consignment state regulates additional wastes or requires the generator to submit copies of the manifest? [40 CFR 262.21(g)(2)]

Did Generator sign the manifest? [40 CFR 262.23(a)(1)]

Did Generator obtain the signature of the initial Transporter and date of acceptance on the manifest? [40 CFR 262.23(a)(2)]

Did Generator retain one copy of the manifest in accordance with Sec. 262.40(a)? [40 CFR 262.23(a)(3)]

Did Generator supply the Transporter with remaining copies of manifest? [40 CFR 262.23(b)]

Did Generator shipping hazardous waste within the U.S. solely by water send 3 copies of the manifest form signed and dated to the owner or operator of the designated facility or last water Transporter in the U.S.? [40 CFR 262.23(c)]

Did Generator send at least 3 copies of the signed and dated manifest for rail shipments of hazardous waste within the U.S. to next non-rail transporter, designated facility, or last rail transporter in the U.S.? [40 CFR 262.23(d)]

Did Generator using an electronic manifest ensure that all waste handlers named on the manifest are participants in the electronic manifest system? [40 CFR 262.24(c)]

Did Generator provide the initial Transporter with one printed copy of the electronic manifest? [40 CFR 262.24(d)]

Did Generator obtain and complete a paper manifest and continuation sheet if the electronic manifest system became unavailable prior to the time that the initial Transporter electronically signed the manifest? [40 CFR 262.24(e)]

Did the Generator certify  to one of the statements in Item 15 of the hazardous waste manifest? [40 CFR 262.27]

RECORDKEEPING AND REPORTING APPLICABLE TO SMALL AND LARGE QUANTITY GENERATORS

Did Generator keep a copy of each manifest for 3 years? [40 CFR 262.40(a)]

Did Generator keep copy of hazardous waste report or exception report for 3 years? [40 CFR 262.40(b)]

Did Generator keep copies of required records during the course of any unresolved enforcement action(s) or as requested by the Department? [40 CFR 262.40(d)]

Did Generator who is a LQG for at least one month of an odd-numbered year (reporting year) complete and submit Biennial Report using EPA Form 8700–13 A/B by March 1 of each even-numbered year?  [40 CFR 262.41(a)]

Did LQG renotify the Department using EPA Form 8700-12 by March 1 of each even-numbered year?  [40 CFR 262.18(d)(2)]

Did LQG complete and submit Biennial Report using EPA Form 8700-13 A/B by March 1 of each even-numbered year? [40 CFR 262.41(b)]

Did LQG comply with exception reporting requirements? [40 CFR 262.42(a)]

PREPAREDNESS AND PREVENTION

Did LQG maintain and operate facility to minimize the possibility of a fire, explosion, or release?  [40 CFR 262.251]

Did LQG equip facility with emergency equipment?  [40 CFR 262.252(a-d)]

Did LQG test and maintain emergency equipment?  [40 CFR 262.253]

Did LQG maintain immediate access to communications or alarm system? [40 CFR 262.254(a-b)]

Did LQG maintain aisle space for the unobstructed movement of personnel and equipment in an emergency? [40 CFR 262.255]

Did LQG attempt to make required arrangements with PD or FD, ER contractors, equipment suppliers, or local hospitals and maintain records documenting confirmation that the arrangements exist or attempts were made or obtain a waiver?  [40 CFR 262.256]

TRAINING REQUIREMENTS

Did LQG ensure all personnel successfully completed a program of classroom instruction, online training, or on-the-job training? [40 CFR 262.17(a)(7)(iA)]

Did LQG provide a training program that is directed by a person trained in HW management procedures?  [40 CFR 262.17(a)(7)(iB)]

Did LQG provide a training program which is designed to ensure that facility personnel are able to respond effectively to emergencies? [40 CFR 262.17(a)(7)(iC)]

Did LQG ensure personnel had successfully complete the training program required in 262.17(a)(7)(i) within six months? [40 CFR 262.17(a)(7)(ii)]

Did LQG ensure personnel took part in an annual review of the initial training required in 262.17(a)(7)(i)?  [40 CFR 262.17(a)(7)(iii)]

Did LQG maintain the required training documents and records at the facility? [40 CFR 262.17(a)(7)(iv)]

Did LQG keep training records on current personnel until closure of the facility and on former employees for at least three years from the date the employee last worked at the facility?  [40 CFR 262.17(a)(7)(v)]

CONTINGENCY PLAN AND EMERGENCY PROCEDURES

Did LQG have a contingency plan designed to minimize hazards to human health or the environment from fires, explosions, or releases? [40 CFR 262.260(a)]

Did LQG carry out the provisions of the contingency plan immediately whenever there was a fire, explosion, or release?  [40 CFR 262.260(b)]

Did LQG describe in its contingency plan the required actions facility personnel must take to in response to fires, explosions, or releases?  [40 CFR 262.261(a)]

Did LQG amend its existing SPCC plan or some other emergency or contingency plan to incorporate HW management provisions?  [40 CFR 262.261(b)]

Did LQG describe in its contingency plan the arrangements agreed to with the local PD, FD, other ER teams, ER contractors, equipment suppliers, local hospitals, or the Local Emergency Planning Committee?  [40 CFR 262.261(c)]

Did LQG list in its contingency plan names and emergency telephone numbers of persons qualified to act as emergency coordinator or the staffed position and emergency telephone number that can be guaranteed to be answered at all times if operating 24 hours per day?  [40 CFR 262.261(d)]

Did LQG list in its contingency plan all emergency equipment including location, description and capabilities?  [40 CFR 262.261(e)]

Did LQG include in its contingency plan an evacuation plan for personnel with signals, evacuation routes, and alternate routes?  [40 CFR 262.261(f)]

Did LQG maintain a copy of the contingency plan and all revisions at the site?  [40 CFR 262.262]

Did LQG submit a copy of the contingency plan and all revisions to all local emergency responders?  [40 CFR 262.262(a)]

Did LQG that first became subject to these provisions after 5/30/17 or that otherwise amended its contingency plan submit a quick reference guide of the contingency plan to the local emergency responders or the Local Emergency Planning Committee?  [40 CFR 262.262(b)]

Did LQG include all required elements in the quick reference guide? [40 CFR 262.262(b)(1-8)]

Did LQG update the quick reference guide whenever the contingency plan was amended and submit the document to the required local emergency responders or the Local Emergency Planning Committee?  [40 CFR 262.262(c)]

Did LQG review and immediately amend contingency plan as necessary? [40 CFR 262.263]

Did LQG have an emergency coordinator on the premises or on call that is thoroughly familiar with all aspects of the contingency plan, operations and activities at the facility, location and characteristics of waste handled, location of all records within the facility, facility’s layout, and authority to commit the resources needed? [40 CFR 262.264]

Did LQG ensure that the emergency coordinator immediately activated internal alarms, notified state and local agencies if help is needed, and identified the character, source, amount and extent of released materials?  [40 CFR 262.265(a-b)]

Did LQG ensure that emergency coordinator assessed possible hazards to human health or the environment?  [40 CFR 262.265(c)]

Did LQG ensure that emergency coordinator helped with local area evacuation decision, notify appropriate officials, and report the required information when the facility has had a release, fire, or explosion which could threaten human health or the environment outside the facility? [40 CFR 262.265(d)]

Did LQG ensure that emergency coordinator took all reasonable measures necessary to ensure that fires, explosions, and releases did not occur, recur, or spread to other HW at the facility? [40 CFR 262.265(e)]

Did LQG ensure that emergency coordinator monitored for leaks, pressure buildup, gas generation, or ruptures, if the facility stopped operations in response to a fire, explosion or release?  [40 CFR 262.265(f)]

Did LQG ensure that the emergency coordinator immediately provided for treating, storing, or disposing of recovered waste, contaminated soil or surface water, or any other material? [40 CFR 262.265(g)]

Did LQG made sure that emergency coordinator ensured that in the affected areas of the facility no incompatible waste was treated, stored, or disposed of until cleanup procedures were completed and all emergency equipment listed in the contingency plan was cleaned and fit for its intended use before operations were resumed? [40 CFR 262.265(h)]

Did LQG note in operating record that the contingency plan was implemented and submit written report with the required information to Department within 15 days after the incident?  [40 CFR 262.265(i)]

LDR REQUIREMENTS

Did the Generator, Transporter, or TSDF ensure that a restricted waste is not in any way diluted as a substitute for treatment? [40 CFR 268.3(a)]

Did Generator determine if the hazardous waste is restricted from land disposal? [40 CFR 268.7(a)(1)]

Did Generator send a one-time written notice with the initial waste shipment to the TSDF when the waste did not meet the treatment standard or place a copy in the file? [40 CFR 268.7(a)(2)]

Did Generator send a one-time written notice and certification with the initial waste shipment to the TSDF when the waste met the treatment standard or place a copy in the file? [40 CFR 268.7(a)(3)]

Did Generator of waste exempt from meeting treatment standards send a one-time written notice to the land disposal facility or place a copy in the file before the waste was land disposed? [40 CFR 268.7(a)(4)]

Did Generator who is managing and treating prohibited waste develop and follow a written waste analysis plan, and keep plan on site? [40 CFR 268.7(a)(5)]

Did Generator retain on site all data used to determine if a waste is restricted? [40 CFR 268.7(a)(6)]

Did Generator keep a one-time notice on site stating that he is managing a restricted waste that is excluded from the definition of hazardous or solid waste subsequent to the point of generation and noting the disposition of the waste? [40 CFR 268.7(a)(7)]

Did Generator retain documentation required by 268.7 for 3 years or longer during the course of any unresolved enforcement action or as requested by the Department? [40 CFR 268.7(a)(8)]

Did Generator using the alternative treatment standards for lab packs send a one-time written notice and certification with the initial waste shipment to the Treatment Facility or place a copy in the file? [40 CFR 268.7(a)(9)]

Did Generator of a waste that displays a hazardous characteristic determine the underlying hazardous constituents in the waste? [40 CFR 268.9(a)]

Did Generator ensure a prohibited waste exhibiting a characteristic complied with the treatment standards under 268, Subpart D before being land disposed? [40 CFR 268.9(c)]

Did Generator or Treater of a waste that once exhibited a characteristic, but is no longer hazardous, place a one-time notification and certification in a file or send a copy to the Department? [40 CFR 268.9(d)]

Did Generator comply with the land disposal prohibitions of EPA Hazardous Waste Number K181? [40 CFR 268.20]

Did Generator comply with land disposal prohibitions of wood preserving wastes? [40 CFR 268.30]

Did Generator comply with land disposal prohibitions of dioxin-containing wastes? [40 CFR 268.31]

Did Generator comply with the land disposal prohibitions of soils exhibiting the toxicity characteristic for metals and containing PCBs? [40 CFR 268.32]

Did Generator comply with land disposal prohibitions of chlorinated aliphatic wastes? [40 CFR 268.33]

Did Generator comply with land disposal prohibitions of toxicity characteristic metal wastes? [40 CFR 268.34]

Did Generator comply with land disposal prohibitions of petroleum refining wastes? [40 CFR 268.35]

Did Generator comply with the land disposal prohibitions of inorganic chemical wastes? [40 CFR 268.36]

Did Generator comply with land disposal prohibitions of newly identified organic toxicity characteristic wastes and newly listed coke by-product and chlorotoluene production wastes? [40 CFR 268.38]

Did Generator comply with land disposal prohibitions of spent aluminum potliners, reactive and carbamate wastes? [40 CFR 268.39]

Did Generator meet treatment standard requirements found in the table in 40 C.F.R. 268.40 before land disposing of prohibited waste? [40 CFR 268.40]

Did Generator meet treatment standards before land disposing for hazardous debris? [40 CFR 268.45]

Did Generator meet treatment standards for underlying hazardous constituents? [40 CFR 268.48]

Did Generator meet the alternative LDR treatment standards for contaminated soil? [40 CFR 268.49]

Did Generator store restricted HW solely for the purpose of the accumulation of such quantities to facilitate proper recovery, treatment, or disposal? [40 CFR 268.50(a)(1)]

Did Facility store restricted HW solely for the purpose of the accumulation of such quantities to facilitate proper recovery, treatment, or disposal? [40 CFR 268.50(a)(2)]

Did Facility clearly mark container with the words “Hazardous Waste”, the applicable EPA HW codes, and an indication of the hazards of the contents? [40 CFR 268.50(a)(2)(iA-C)]

Did Facility clearly mark containers with the accumulation start date?  [40 CFR 268.50(a)(2)(iD)]

Did Facility clearly mark each tank with a description of its contents, the quantity of each hazardous waste received, and the accumulation start date or record and maintain such information for each tank in the operating record?  [40 CFR 268.50(a)(2)(ii)]

MANAGEMENT OF ACCEPTED VSQG WASTE

Did LQG notify the Department using EPA Form 8700-12 at least thirty (30) days prior to receiving the first shipment from a VSQG and within 30 days after a change in the name or site address for the VSQG? [40 CFR 262.17(f)(1)]

Did LQG maintain records of shipments for three years identifying the name, site address, and contact information for the VSQG and a description of the HW received, including the quantity and the date the waste was received? [40 CFR 262.17(f)(2)]

Did LQG mark or label container or unit with the date the HW was received from the VSQG or the earliest date any HW in container was accumulated when consolidated with incoming HW from other VSQGs?  [40 CFR 262.17(f)(3)]

LARGE QUANTITY GENERATOR (LQG) TANK SYSTEMS

Did Facility obtain and keep a written assessment by a professional engineer attesting to existing tank system’s integrity? [40 CFR 265.191(a)]

Did the written tank assessment comply with the requirements at 265.191(b)? [40 CFR 265.191(b)]

Did Facility assess the integrity of a tank within 12 months of a material becoming a hazardous waste? [40 CFR 265.191(c)]

Did Facility have written assessment by a professional engineer attesting that the tank system has sufficient structural strength? [40 CFR 265.192(a)]

Did Facility have a new tank inspected by a qualified installation inspector or engineer for damage prior to covering, enclosing or placing in use? [40 CFR 265.192(b)]

Did Facility with new tank system or components to use appropriate backfill material? [40 CFR 265.192(c)]

Did Facility have ancillary equipment tested for tightness prior to being covered, enclosed or placed in use? [40 CFR 265.192(d)]

Did Facility have ancillary equipment supported and protected from settlement, vibration, expansion, or contraction? [40 CFR 265.192(e)]

Did Facility provide proper corrosion protection for new tank systems? [40 CFR 265.192(f)]

Did Facility obtain and keep certifications from those professionals responsible for tank system design and installation? [40 CFR 265.192(g)]

Did Facility install secondary containment for hazardous waste tanks within the time frames outlined in 265.193(a)? [40 CFR 265.193(a)]

Was the secondary containment system designed, installed, and operated to prevent migration of wastes or accumulated liquid out of system? [40 CFR 265.193(b)(1)]

Did secondary containment system detect and collect releases and accumulated liquids? [40 CFR 265.193(b)(2)]

Did containment system consist of material compatible with wastes stored or have sufficient strength and thickness? [40 CFR 265.193(c)(1)]

Did Facility construct secondary containment unit on a base or foundation capable of providing support and resistance to pressure gradients? [40 CFR 265.193(c)(2)]

Did Facility construct secondary containment with a leak detection system that is designed and operated to detect the failure of containment structure(s) or the presence of a release? [40 CFR 265.193(c)(3)]

Did Facility remove accumulated precipitation or spilled or leaked waste from secondary containment within 24 hours? [40 CFR 265.193(c)(4)]

Did Facility provide secondary containment featuring an approved device? [40 CFR 265.193(d)]

Did the external liner system meet requirements at 265.193(e)1? [40 CFR 265.193(e)(1)]

Did vault system meet the requirements at 265.193(e)2? [40 CFR 265.193(e)(2)]

Did double-walled tank meet the requirements at 265.193(e)3? [40 CFR 265.193(e)(3)]

Did Facility provide secondary containment for ancillary equipment? [40 CFR 265.193(f)]

Did Facility prevent hazardous wastes or treatment reagents from being placed in tank system if they can cause the tank, its ancillary equipment, or containment system to rupture, leak, corrode, or otherwise fail? [40 CFR 265.194(a)]

Did Facility use appropriate controls and practices to prevent spills and overflows from tanks or containment systems? [40 CFR 265.194(b)]

Did Facility inspect data gathered from monitoring and leak detection equipment at least once each operating day? [40 CFR 265.195(a)]

Did Facility inspect the overfill/spill control equipment, the above ground portions of the tank system and the construction materials and area immediately surrounding the externally accessible portion of the tank system once each operating day? [40 CFR 265.195(b)]

Did Facility inspect ancillary equipment that is not provided with secondary containment at least once each operating day? [40 CFR 265.195(e)]

Did Facility inspect the cathodic protection system according to the schedule found in  264.195(f)? [40 CFR 265.195(f)]

Did Facility document inspections in the facility operating record? [40 CFR 265.195(g)]

Did Facility cease using a tank from which a release occurred or which is unfit for use? [40 CFR 265.196(a)]

Did Facility remove waste from a tank in which a release occurred within 24 hours in order to affect repairs on the unit? [40 CFR 265.196(b)]

Did Facility prevent further migration of the release to soils or water or remove and dispose of any visible contamination of soil or water? [40 CFR 265.196(c)]

Did Facility report a release within 24 hours or submit a spill report within 30 days? [40 CFR 265.196(d)]

Did Facility comply with 265.196(e)2-4 prior to placing a tank back in service following a release? [40 CFR 265.196(e)]

Did Facility obtain a professional engineer’s certification prior to placing a tank back in service following a major repair? [40 CFR 265.196(f)]

Did Facility at closure remove or decontaminate all waste residues, contaminated containment system components, contaminated soils, structures, etc.? [40 CFR 265.197(a)]

Did Facility that has a tank system without secondary containment comply with requirements at 265.197(c)? [40 CFR 265.197(c)]

Did Facility meet specific the requirements of 265.198(a) before placing ignitable or reactive waste in a tank? [40 CFR 265.198(a)]

Did Facility storing or treating ignitable or reactive wastes in tanks comply with NFPA’s buffer zone requirements for tanks? [40 CFR 265.198(b)]

Did Facility prevent the placing of incompatible wastes, or wastes and materials, in same tank, except in compliance with 265.17(b)? [40 CFR 265.199(a)]

Did Facility prevent the placing of hazardous waste in a tank which is not decontaminated and previously held incompatible waste? [40 CFR 265.199(b)]

Did the facility utilizing a tank system conduct waste analysis and trial treatment or storage tests before treating/storing different waste or using a different process? [40 CFR 265.200]

F006 REQUIREMENTS

Did LQG ship F006 HW off site within 180 days? [40 CFR 262.17((c))]

Recycling & Accumulation Amounts: (1) The Large Quantity Generator has implemented pollution prevention practices that reduce the amount of any hazardous substances, pollutants, or contaminants entering F006 or otherwise released to the environment prior to its recycling; (2) The F006 waste is legitimately recycled through metals recovery. (3) No more than 20,000 kilograms of F006 waste is accumulated on site at any one time. [40 CFR 262.17(c)(1)-(3)]

Management Onsite: (i)(A) If the F006 waste is placed in containers, the Large Quantity Generator must comply with the applicable conditions for exemption in 40 CFR 262.17(a)(1); and/or (B) If the F006 is placed in tanks, the Large Quantity Generator must comply with the applicable conditions for exemption of 40 CFR 262.17(a)(2); and/or (C) If the F006 is placed in containment buildings, the Large Quantity Generator must comply with subpart DD of 40 CFR part 265, and has placed its professional engineer certification that the building complies with the design standards specified in 40 CFR 265.1101 in the facility’s files prior to operation of the unit. (1) A written description of procedures to ensure that the F006 waste remains in the unit for no more than 180 days, a written description of the waste generation and management practices for the site showing that they are consistent with the 180-day limit, and documentation that the Large Quantity Generator is complying with the procedures; or (2) Documentation that the unit is emptied at least once every 180 days. [40 CFR 262.17(c)(4)(i)]

Labeling & Marking: (iii) The date upon which each period of accumulation begins is clearly marked and must be clearly visible for inspection on each container; (iv) While being accumulated on site; (A) Each container and tank of F006 waste is labeled or marked clearly with the words “Hazardous Waste”; and (B) Each container and tank of F006 waste tank is labeled or marked clearly with an indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1920.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704). (v) The Large Quantity Generator complies with the requirements in paragraphs (a)(6) – Emergency procedures and (7) – Personnel training of this section. [40 CFR 262.17(c)(4)(iii)-(v)]

Did LQG comply with the F006 accumulation conditions for exemption listed in 262.17(c)(1)-(4)(i)-(ii),(iv)-(v)? [40 CFR 262.17(c)(1-4)(i,ii,iv,v)]

Did LQG mark or label containers holding F006 hazardous waste with the accumulation start date clearly visible for inspection on each container? [40 CFR 262.17(c)(4)(iii)]

Did LQG ship F006 HW off site for metals recovery within 270 days when transported over 200 miles? [40 CFR 262.17(d)]

CLOSURE REQUIREMENTS

Did LQG either place a notice in the operating record within 30 days or meet the closure performance standards and notify using EPA Form 8700-12 when closing a waste accumulation unit?  [40 CFR 262.17(a)(8)(i)]

Did LQG properly notify the Department 30 days prior to closing the facility and within 90 days after closing the facility using form 8700-12? [40 CFR 262.17(a)(8)(ii)]

Did LQG close the waste accumulation unit or facility in a manner that minimizes the need for further maintenance by controlling, minimizing, or eliminating the post-closure escape of HW, hazardous constituents, leachate, contaminated run-off, or HW decomposition products to the ground or surface waters or to the atmosphere?  [40 CFR 262.17(a)(8)(iiiA1)]

Did LQG close the waste accumulation unit or facility in a manner that removes or decontaminates all contaminated equipment, structures and soil and any remaining HW residues from waste accumulation units including containment system components, contaminated soils and subsoils, bases, and structures and equipment contaminated with waste?  [40 CFR 262.17(a)(8)(iiiA2)]

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