Compliance and Implementation Toolkit

This chapter is designed to assist users in designing checklists that can be used to evaluate and assess the performance of their environmental programs and ultimate compliance. Environmental compliance requires strategic planning and evaluation that is continuous and changes as processes and practices change and as areas of improvement are discovered. The compliance and implementation toolkit contains a series of checklists and tools intended for guidance and instructional purposes. The items within the toolkit were adapted from checklists and guidance developed by the Environmental Protection Agency (EPA), federal agencies and state regulatory agencies that are available in the public domain. The checklists included in the toolkit are presented to assist users in assessing compliance with some of the common regulatory requirements, as presented in the regulatory sections of Chapter 3 in this book. The checklists are intended to provide a series of templates that users can modify to assist in evaluating compliance. The checklists provided in the appendices of this book were adapted from documents that were developed by the various aforementioned agencies over several years. The checklists and any modifications should be verified against current regulations at the federal, state and local levels as they apply to individual regulatory environments within each individual company. The checklist covering specified regulatory requirements are enlisted in Table 12.1.

TABLE 12.1

Regulatory Compliance Tools

Compliance Checklist	Appendix
RCRA	A
NPDES	В
CAA	C
EPCRA	D
SDWA	E
SPCC	F
FIFRA	G
TSCA	H
NEPA	I
CERCLA	J

Appendix A: Toolkit for Evaluating Resource Conservation and Recovery Act (RCRA)

Toolkit for Evaluating Resource Conservation and Recovery Act (RCRA)

This appendix provides a series of checklists intended to assist compliance managers and personnel performing inspections and assessments of some of the more common operations involving nonhazardous and hazardous wastes covered under RCRA. These tools are provided for instructional purposes and guidance only and are not intended to represent an all-inclusive collection of RCRA regulatory requirements. The tools provided in this appendix are adapted from EPA checklists and organized within this appendix as follows.

Nonhazardous Solid Waste (RCRA Subtitle D):

1. Storage and collection of solid wastes
2. Recycling

Hazardous Waste (RCRA Subtitle C):

1. Generator category determination
2. Waste stream characterization and determination
3. Very small quantity generator requirements
4. Small quantity generator requirements
5. Large quantity generator requirements
6. Used oil
7. Universal waste
8. Land disposal restrictions for soil and debris
9. Organic air emissions
10. Underground storage tanks

TABLE A.1

Storage/Collection of Solid Waste Checklist (applies to residential, commercial and institutional solid wastes and street wastes)

TABLE A.2

Solid Waste Recycling Checklist

TABLE А.З

Generator Category Determination Date:_______________

TABLE А.З

Generator Categories (Source: 40 CFR 262.13)

The following hazardous wastes are not included when making the monthly quantity-based determinations:

1. Waste which is exempt from regulation under 40 CFR 261.4(c) through (f), 261.6(a)(3). 261.7(a) (Dor 261.8

2. Waste that is managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units or totally enclosed treatment facilities as defined in 40 CFR 260.10

3. Waste that is recycled, without prior storage or accumulation, only in an on-site process subject to regulation under 40 CFR 261.6(c)(2)

4. Used oil managed under the requirements of 40 CFR 261.6(a)(4) and 40 CFR part 279

5. Spent lead-acid batteries managed under the requirements of 40 CFR part 266 subpart G

6. Universal waste managed under 40 CFR 261.9 and 40 CFR part 273

7. Hazardous waste that is an unused commercial chemical product (listed in 40 CFR part 261 subpart D or exhibiting one or more characteristics in 40 CFR part 261 subpart C) that is generated solely as a result of a laboratory cleanout conducted at an eligible academic entity pursuant to §262.213

8. Is managed as part of an episodic event in compliance with the conditions of subpart L of this part.

9. Hazardous waste pharmaceutical, as defined in §266.500, that is subject to or managed in accordance with 40 CFR part 266 subpart P or is a hazardous waste pharmaceutical that is also a Drug Enforcement Administration-controlled substance and is conditionally exempt under §266.506

10. Hazardous waste when it is removed from on-site accumulation, so long as the hazardous waste was previously counted once

11. Hazardous waste generated by on-site treatment (including reclamation) of the generator’s hazardous waste, so long as the hazardous waste that is treated was previously counted once

12. Hazardous waste spent materials that are generated, reclaimed and subsequently reused on-site, so long as such spent materials have been previously counted once

TABLE A.4

Waste Stream Characterization Checklist