University Of South Carolina
Department of Environmental Health and Safety
Office of Hazardous Waste
Environmental Audit Program
Underground Storage Tanks, Hazardous Waste,
Universal Waste, and Used Oil Management
Issued: June 18, 2007
USC EHS Office of Hazardous Waste
(EHS-F-125) Environmental Audit Program
Page 1 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
TABLE OF CONTENTS
UNDERGROUND STORAGE TANK (UST) PROGRAM .............................................................................. 3
UST Audit Report ............................................................................................................................................. 4
UST Audit Checklist ......................................................................................................................................... 5
HAZARDOUS WASTE (HW) PROGRAM ....................................................................................................... 7
HW Audit Report .............................................................................................................................................. 8
HW Audit Checklist.......................................................................................................................................... 9
Conditionally Exempt Small Quantity Generator ..................................................................................... 9
Small Quantity Generator .......................................................................................................................... 10
Large Quantity Generator ......................................................................................................................... 14
UNIVERSAL WASTE (UW) PROGRAM ....................................................................................................... 21
UW Audit Report ............................................................................................................................................ 22
UW Audit Checklist ........................................................................................................................................ 23
Small Quantity Handler ............................................................................................................................. 23
Large Quantity Handler ............................................................................................................................. 26
USED OIL PROGRAM ..................................................................................................................................... 29
Used Oil Audit Report .................................................................................................................................... 30
Used Oil Audit Checklist ................................................................................................................................ 31
USC EHS Office of Hazardous Waste
(EHS-F-125) Environmental Audit Program
Page 2 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Section V:
UNDERGROUND STORAGE TANK (UST) PROGRAM
USC EHS Office of Hazardous Waste
(EHS-F-125) Environmental Audit Program
Page 3 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
UST Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
USC EHS Office of Hazardous Waste
(EHS-F-125) Environmental Audit Program
Page 4 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
UST Audit Checklist
Yes
No
N/A
1. Are all USTs of greater than 1,100 gallon capacity registered with the State?
____
____
____
2. Has a permit to install been obtained for all USTs?
____
____
____
3. Has a permit to operate been obtained for all USTs?
____
____
____
4. Has the annual registration been paid for all USTs?
____
____
____
5. Is a certificate of registration displayed at the site where the UST is located?
____
____
____
6. Required spill prevention measures are in place and operational, including:
A spill bucket that does not have any cracks or holes
A drain mechanism that is not broken or impaired by debris
____
____
____
____
____
____
____
____
____
8. The buried tank and any metal piping components (swing joints,
Flex-connectors, etc.) are protected by a corrosion protection system that
provides continuous protection?
____
____
____
9. The corrosion protection system has been tested within the last three years?
____
____
____
10. All tanks that contain substances that are hazardous are double-walled?
____
____
____
11. If any tanks or piping have undergone structural repairs have the following been
completed:
a. The system is internally inspected after the repair OR monitored for releases
using a monthly monitoring method OR the system is tested using another
approved method
____
____
____
____
____
____
c. IF the repairs were made to a cathodically protected UST, corrosion protection
systems were tested and/or inspected within 6 months of the repair.
____
____
____
d. Records of all UST system repairs are maintained onsite for the operating life
of the UST system.
____
____
____
7. An appropriate overfill prevention device is in place and operational? (check one)
Flapper valve
Alarm
Ball float valve
b. The system was tightness tested within 30 days of the completion of the
repair.
USC EHS Office of Hazardous Waste
(EHS-F-125) Environmental Audit Program
Page 5 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
12. All USTs have been equipped with a permissible method of release detection
that is able to detect a release from any portion of the USt system that routinely
contains product. The release detection system is operational and meets the
necessary performance standards.
____
____
____
13. All tanks and piping are monitored monthly for releases and the records available
onsite for the past 12 months of operation
____
____
____
14. Designated employees are familiar with applicable release reporting procedures.
____
____
____
15. A financial responsibility mechanism is in place and has been reported to the State.
____
____
____
16. The State UST program has been notified at least 30 days prior to the permanent
closure date of any UST and site assessment results are maintained onsite for a
minimum of three years?
____
____
____
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 6 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Section VI:
HAZARDOUS WASTE (HW) PROGRAM
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 7 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
HW Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 8 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
HW Audit Checklist
Conditionally Exempt Small Quantity Generator
Yes
No
N/A
1. Does the facility produce Less than 100 Kilograms (220 pounds) of
hazardous waste per month?
____
____
____
2. Does the facility accumulate onsite no greater than 1,000 Kilograms
(2,200 pounds) of hazardous waste at any one time?
____
____
____
3. Does the facility produce less than 1 Kilograms (2.2 pounds) of acutely
hazardous waste per month?
____
____
____
4. Does the facility produce less than 100 Kilograms (220 pounds) of residue,
soil, waste or other debris from clean-up of acute hazardous waste spill per month?
____
____
____
5. Is all waste disposed of through a permitted treatment, storage and disposal facility? ____
____
____
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 9 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
HW Audit Checklist
Small Quantity Generator
Generator Size Determination
Yes
No
N/A
1. Does the facility produce greater than 100 Kilograms (220 pounds) but less
than 1000 Kilograms (2200 pounds) of hazardous waste per month?
____
____
____
2. Does the facility accumulate onsite no greater than 6,000 Kilograms
(13,200 pounds) of hazardous waste at any one time?
____
____
____
3. Does the facility produce less than 1 Kilograms (2.2 pounds) of acutely
hazardous waste per month?
____
____
____
a. Is it excluded under 261.4?
____
____
____
b. Is it listed in subpart D of 261 or appendix XI of 261?
____
____
____
c. Has the waste been analyzed?
____
____
____
d. Has generator knowledge of the hazard characteristics of the waste in
light of the materials used been applied?
____
____
____
e. Have other regulatory exclusions and/or restrictions been applied?
____
____
____
2. Does the generator have an EPA ID number?
____
____
____
3. Has the generator filed a new form 2701 upon generation of a new waste
stream at his site?
____
____
____
4. Have wastes that have been newly classified or listed hazardous been reported
on form 2701?
____
____
____
5. Has a new form 2701 been filed each time its contents becomes outdated?
____
____
____
6. If company no longer produces hazardous waste has DHEC been notified through
submission of a 2701?
____
____
____
7. Is a copy of the manifest maintained onsite for three years?
____
____
____
8. Are test results, waste analysis or other waste determination documentation
maintained onsite for three years?
____
____
____
9. If a signed copy of a manifest has not been received within 60 days has an
exception report been filed with DHEC?
____
____
____
10. Has generator status been declared on or before January 31 using DHEC 1961?
____
____
____
11. Are land disposal requirements met as outlined in R.268?
____
____
____
12. Are LDRs maintained onsite for three years?
____
____
____
Hazardous Waste Determination
1. Has an accurate hazardous waste determination been made on all solid wastes by
utilizing the following criteria:
Documentation
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 10 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
13. Does the generator us a uniform manifest when shipping hazardous waste offsite?
____
____
____
14. Does generator designate on the manifest one facility which is permitted
to handle the waste?
____
____
____
15. If necessary, does generator designate an alternate facility?
____
____
____
____
____
____
a. generator’s name, address, phone number, and ID number?
____
____
____
b. Name and ID number of each transporter
____
____
____
c. Name, address and ID number of designated facility and, if any,
alternate facility?
____
____
____
d. DOT description of waste
____
____
____
e. Total quantity if each waste by units of weight and the type and number
of containers as loaded onto the transport vehicle?
____
____
____
f. Items 19 and 35: Discrepancy indication space - does the TSDF enter
that actual weight in pounds in this space it the amount varies any from
that specified by the generator or if the generator uses units of measure
other than pounds.
____
____
____
g. Have items A-K and L-T been completed?
____
____
____
h. Does the SC generator’s certification appear on the manifest?
____
____
____
i. Does the generator sign the manifest certification by hand?
____
____
____
j. Obtain handwritten signature from the initial transporter and date of
acceptance?
____
____
____
k. Does generator retain one copy?
____
____
____
____
____
____
Note: The manifest requirements do not apply to small quantity generators if the
following requirements are met:
a. their waste is reclaimed under a contractual agreement
b. the vehicle used to transport the waste and return the regenerated material
back to the generator is owned and operated by the reclaimer of the waste
c. there is a copy of the agreement available onsite
Note: Manifests do no have to be used to transport waste on public or private rights
of way within or along the border of contiguous property
16. Does the generator use a permitted transporter to ship waste off-site?
17. Is the manifest completed as required by the instructions printed on back:
Storage
18. Before transporting, or offering for transport, does generator mark each container
of 110 gallons or less with the following:
a. “HAZARDOUS WASTE – federal law prohibits improper disposal.
If found, contact the nearest police or public safety authority or the U.S.
Environmental Protection Agency.”
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 11 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
b. Generator’s name and address
____
____
____
c. Manifest document number
____
____
____
d. Accumulation start date
____
____
____
19. Has hazardous waste been accumulated onsite for greater than 180 days?
____
____
____
20. Has greater than 13,200 pounds of hazardous waste been accumulated onsite
at any time?
____
____
____
21. Does generator comply with subparts I and J of 265?
____
____
____
22. Is each storage container marked with an accumulation start date and EPA
hazardous waste number?
____
____
____
23. Is there always at least one person on the premises or on call to act as
emergency coordinator?
____
____
____
24. Is the name and telephone number of the emergency coordinator, Location
of fire extinguishers, spill control equipment, and if present, fire alarm, the telephone
number of the fire department unless the facility has a direct alarm
____
____
____
25. Are all employees trained in waste handling and emergency procedures relevant
to their responsibilities during normal and emergency operations?
____
____
____
26. Are all containers in good condition?
____
____
____
27. Are all containers compatible with the waste they contain?
____
____
____
28. Are all containers closed except when adding or removing waste?
____
____
____
29. Are containers handled in a way that prevents rupture or leaking?
____
____
____
30. Is each container marked with the following or equivalent statement:
“Hazardous waste – federal laws prohibit improper disposal.”
____
____
____
31. Is each container marked with an EPA waste number
____
____
____
32. Is each container marked with an accumulation start date?
____
____
____
33. Are incompatible waste separated by a physical barrier?
____
____
____
34. Does generator accumulate no more than 55 gallons of hazardous waste
or nor more than one quart of acutely hazardous waste at or near the point
of generation?
____
____
____
35. Are containers in good condition?
____
____
____
36. Are containers compatible with the waste that they hold?
____
____
____
37. Is the container kept closed except when adding or removing waste?
____
____
____
38. Is the container marked either as “hazardous waste” or other words that identify
its contents?
____
____
____
39. Do facility personnel complete classroom or on the job training that teaches them
to perform their duties in a way that ensures compliance?
____
____
____
Satellite accumulation
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 12 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
40. Is the training program designed to ensure that personnel are able to respond
effectively to emergencies, including the following:
a. Procedures for using, inspecting, repairing and replacing emergency and
monitoring equipment
____
____
____
b. Communications or alarms systems
____
____
____
c. Response to fires or explosions
____
____
____
d. Response to groundwater contamination
____
____
____
e. Shutdown of operations
____
____
____
____
____
____
42. Are all areas where containers are stored being inspected at least weekly for
compliance with regulatory requirements?
____
____
____
43. Are inspections documented and maintained onsite?
____
____
____
41. Are records of training maintained onsite for three years?
Inspections
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 13 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
HW Audit Checklist
Large Quantity Generator
Generator Size Determination
Yes
No
N/A
1. Does the facility produce greater than 1000 Kilograms (2200 pounds) of hazardous
waste per month?
____
____
____
2. Does the facility produce greater than 1 Kilograms (2.2 pounds) of acutely hazardous
waste per month?
____
____
____
____
____
____
b. Is it listed in subpart D of 261 or appendix XI of 261?
____
____
____
c. Has the waste been analyzed?
____
____
____
d. Has generator knowledge of the hazard characteristics of the waste in light of
the materials used been applied?
____
____
____
e. Have other regulatory exclusions and/or restrictions been applied?
____
____
____
45. Does the generator have an EPA ID number?
____
____
____
46. Does the generator only offer waste to TSDs who are permitted and have
an EPA ID number.
____
____
____
47. Has the generator filed a new form 2701 upon generation of a new waste stream
at his site?
____
____
____
48. Have wastes that have been newly classified or listed hazardous been reported
on form 2701?
____
____
____
49. Has a new form 2701 been filed each time its contents becomes outdated?
____
____
____
50. If company no longer produces hazardous waste has DHEC been notified through
submission of a 2701?
____
____
____
51. Does the generator file quarterly reports as required?
____
____
____
52. Does the generator maintain quarterly reports onsite for a minimum of
three years?
____
____
____
53. Is a waste minimization report filed by January 31 each year?
____
____
____
54. Are waste minimization reports maintained onsite for a minimum of three years?
____
____
____
55. Is a copy of the manifest maintained onsite for three years?
____
____
____
56. Are test results, waste analysis or other waste determination documentation
maintained onsite for three years?
____
____
____
Hazardous Waste Determination
44. Has an accurate hazardous waste determination been made on all solid wastes
by utilizing the following criteria:
a. Is it excluded under 261.4?
Documentation
57. If a signed copy of a manifest has not been received within 35 days was the
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 14 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
designated facility contacted to determine the status of the waste?
____
____
____
58. If a signed copy of the manifest was not received from the transported within 45
days was an exception report filed with DHEC that included a legible copy of the
manifest and a description of actions taken to determine the status of the waste?
____
____
____
59. Has generator status been declared on or before January 31 using DHEC 1961?
____
____
____
60. Are land disposal requirements met as outlined in R.268?
____
____
____
61. Are LDRs maintained onsite for three years?
____
____
____
62. Does the generator us a uniform manifest when shipping hazardous waste offsite?
____
____
____
63. Does generator designate on the manifest one facility which is permitted to
handle the waste?
____
____
____
64. If necessary, does generator designate an alternate facility?
____
____
____
____
____
____
b. Name and ID number of each transporter
____
____
____
c. Name, address and ID number of designated facility and, if any,
alternate facility?
____
____
____
d. DOT description of waste
____
____
____
____
____
____
____
____
____
g. Have items A-K and L-T been completed?
____
____
____
h. Does the SC generator’s certification appear on the manifest?
____
____
____
i. Does the generator sign the manifest certification by hand?
____
____
____
j. Obtain handwritten signature from the initial transporter and date of
acceptance?
____
____
____
k. Does generator retain one copy?
____
____
____
Note: Manifests do no have to be used to transport waste on public or private
rights of way within or along the border of contiguous property
65. Does the generator use a permitted transporter to ship waste off-site?
66. Is the manifest completed as required by the instructions printed on back:
a. Generator’s name, address, phone number, and ID number?
e. Total quantity if each waste by units of weight and the type and number of
containers as loaded onto the transport vehicle?
f. Items 19 and 35: Discrepancy indication space - does the TSDF enter that
actual weight in pounds in this space it the amount varies any from that
specified by the generator or if the generator uses units of measure other
than pounds.
Storage
67. Before transporting, or offering for transport, does generator mark each container
of 110 gallons or less with the following:
a. HAZARDOUS WASTE – federal law prohibits improper disposal.
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 15 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
If found, contact the nearest police or public safety authority or the
U.S. Environmental Protection Agency
____
____
____
b. Generator’s name and address
____
____
____
c. Manifest document number
____
____
____
d. Accumulation start date
____
____
____
68. Has hazardous waste been accumulated onsite for greater than 90 days?
____
____
____
69. If waste is stored greater than 90 days did generator request an extension?
____
____
____
70. Does generator comply with subparts C and D of section 265?
____
____
____
71. Is each storage container marked with an accumulation start date and EPA
hazardous waste number?
____
____
____
72. Is there always at least one person on the premises or on call to act as emergency
coordinator?
____
____
____
73. Is the name and telephone number of the emergency coordinator, Location of
fire extinguishers, spill control equipment, and if present, fire alarm, the telephone
number of the fire department unless the facility has a direct alarm
____
____
____
74. Are all employees trained in waste handling and emergency procedures relevant
to their responsibilities during normal and emergency operations?
____
____
____
75. Are all containers in good condition?
____
____
____
76. Are all containers compatible with the waste they contain?
____
____
____
77. Are all containers closed except when adding or removing waste?
____
____
____
78. Are containers handled in a way that prevents rupture or leaking?
____
____
____
79. Are containers stacked no more than two containers high?
____
____
____
80. Is each container marked with the following or equivalent statement:
“Hazardous waste – federal laws prohibit improper disposal.”
____
____
____
81. Is each container marked with an EPA waste number
____
____
____
82. Is each container marked with an accumulation start date?
____
____
____
83. Are incompatible waste separated by a physical barrier?
____
____
____
84. Does the owner/operator maintain adequate aisle space to allow the
unobstructed movement of personnel, fire protection equipment, spill control
equipment, and decontamination equipment to any area of the facility operated
in an emergency?
____
____
____
____
____
____
85. For areas where liquid waste is stored:
a. Is there a base under containers which is free of cracks and gaps,
and is sufficiently impervious to contains leaks of hazardous waste
and accumulated precipitation
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 16 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
b. Is the base sloped to remove spillage or accumulated precipitation?
____
____
____
86. Does the containment system have sufficient volume to contain 10 % of the volume
of the containers or 100% of the volume of the largest container?
____
____
____
87. Is run-on prevented unless there is sufficient excess capacity to contain it?
____
____
____
88. Is run-on prevented, unless there is sufficient excess capacity?
____
____
____
89. Is spilled or leaked waste and precipitation removed in a timely manner?
____
____
____
90. For areas where wastes without free liquids are stored is the storage area
sloped or otherwise designed and operated to remove precipitation or other
liquids?
____
____
____
91. Are containers elevated to prevent contact with accumulated liquid?
____
____
____
____
____
____
____
____
____
94. Are containers in good condition?
____
____
____
95. Are containers compatible with the waste that they hold?
____
____
____
96. Is the container kept closed except when adding or removing waste?
____
____
____
97. Is the container marked either as “hazardous waste” or other words that
identify its contents?
____
____
____
98. Do facility personnel complete classroom or on the job training that teaches
them to perform their duties in a way that ensures compliance?
____
____
____
____
____
____
b. Communications or alarms systems
____
____
____
c. Response to fires or explosions
____
____
____
d. Response to groundwater contamination
____
____
____
e. Shutdown of operations
____
____
____
Is the training performed by an individual trained in hazardous waste
management?
____
____
____
101.
Are records of training maintained onsite for three years?
____
____
____
102.
Are new employees trained within three years?
____
____
____
Satellite accumulation
92. Does generator accumulate no more than 55 gallons of hazardous waste or nor
more than one quart of acutely hazardous waste at or near the point of generation?
93. Does generator remove any waste in excess of 55 gallons from satellite
accumulation to storage within 72 hours of exceeding 55 gallons?
Training
99. Is the training program designed to ensure that personnel are able to respond
effectively to emergencies, including the following:
a. Procedures for using, inspecting, repairing and replacing emergency and
monitoring equipment
100.
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 17 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
103.
Is training renewed annually?
____
____
____
104.
Are training records maintained until facility closure or for three years
for former employees?
Are the following hazardous waste training related records maintained
at the facility:
____
____
____
a. Job title for each position related to hazardous waste management
____
____
____
b. Written job description related to hazardous waste management
____
____
____
c. Written description for the type and amount of initial and continuing training
____
____
____
d. Records that demonstrate that the training has been completed
____
____
____
Are all areas where containers are stored being inspected at least weekly for
compliance with regulatory requirements?
____
____
____
107.
Are inspections documented and maintained onsite?
____
____
____
108.
Does the inspection log include the name of the inspector, the date and
____
____
____
____
____
____
b. Telephone or two way radio immediately available at the scene of
operation capable of summoning emergency assistance from police,
fire of emergency response teams?
____
____
____
c. Portable fire extinguishers, fire control equipment, spill control
equipment, and decontamination equipment?
____
____
____
d. Water at adequate volume and pressure?
____
____
____
105.
Inspections
106.
time, a notation of any observations made and the date and nature of any
repairs or remedial actions taken?
Emergency Response
109. Is the facility equipped with the following:
a. Internal communication or alarm system capable of providing
immediate emergency instruction?
110.
Is the emergency equipment tested and maintained as necessary?
____
____
____
111.
Do employees who handle hazardous waste have immediate access to an
alarm or emergency communication device?
____
____
____
When employees work alone do they have immediate access to a phone or
two-way radio capable of summoning emergency assistance?
____
____
____
Has the facility made the following arrangements:
a. Arrangements to familiarize police, fire and emergency response teams
with the layout of the facility, properties of the hazardous waste that is
handled, places where employees would normally be working, entrances to
the facility and evacuation routes?
____
____
____
112.
113.
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 18 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
b. Agreements with police and fire departments designating a primary
emergency authority?
____
____
____
c. Agreements with State emergency response teams, emergency response
contractors and equipment suppliers?
____
____
____
d. Arrangements to familiarize local hospitals with the properties of hazardous
waste handled at the facility and the types of injuries or illnesses which
could result from fires, explosions, or releases?
e. Where State or local authorities decline to enter into such arrangements,
has the facility documented the refusal in his operating record?
____
____
____
____
____
____
114.
Does the facility have a contingency plan?
____
____
____
115.
Are the provisions of the contingency plan carried out immediately in the
event of an emergency?
____
____
____
Does the plan describe arrangements agreed to by local police,
fire depts, hospitals, contractors, and State and local emergency response
teams to coordinate emergency services?
____
____
____
Does the plan have an updated list names, addresses, and phone numbers
(office and home) of all persons qualified to act as emergency coordinators.
(Where more than one person is listed, one must be designated as primary.)
____
____
____
Does the plan contain:
a. A list of all emergency equipment at the facility?
____
____
____
b. A brief description of the equipments abilities?
____
____
____
c. Location of the equipment at the facility?
____
____
____
Does the plan include an evacuation plan that includes the following:
a. A description of signals used to begin an evacuation?
____
____
____
b. Evacuation routes?
____
____
____
c. Alternate evacuation routes?
____
____
____
120.
Is a copy of the plan maintained at the facility?
____
____
____
121.
Is a copy submitted to all local police, fire depts, hospitals, and State and
local emergency response teams that may be called upon for emergency
services?
____
____
____
Is the plan reviewed, and amended, whenever:
a. Regulations are revised
____
____
____
b. The plan fails
____
____
____
c. The facility changes in its design or construction
____
____
____
d. The list of emergency coordinators changes
____
____
____
e. The list of emergency equipment changes
____
____
____
116.
117.
118.
119.
122.
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 19 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
123.
Is a qualified person on call at all times to act as emergency coordinator?
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 20 of 31
____
____
____
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Section VII:
UNIVERSAL WASTE (UW) PROGRAM
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 21 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
UW Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 22 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
UW Audit Checklist
Small Quantity Handler
(<5,000 of waste at one time)
Batteries
Yes
No
N/A
1. Are batteries handled in a manner that will prevent releases to the environment?
____
____
____
2. Have any batteries that show evidence of leakage or damage been contained in
a compatible and closed container?
____
____
____
3. Has the handler conducted any of the following activities:
a. Sorting by type
____
____
____
b. Mixing different types in one container
____
____
____
c. Discharging energy
____
____
____
d. Regenerating used batteries
____
____
____
e. Disassembling batteries or packs into different cells
____
____
____
f. Removing batteries from consumer products
____
____
____
g. Removing electrolytes
____
____
____
4. If any of the above activities were performed, was an accurate hazardous waste
determination made to determine whether resulting materials are a hazardous
waste?
____
____
____
5. Are hazardous wastes handled according to the hazardous waste management
regulations?
____
____
____
6. Are universal waste pesticides being handled in a manner that will prevent
releases to the environment?
____
____
____
7. Are universal waste pesticides being managed in containers that are compatible
with the contents and closed?
____
____
____
8. Are damaged containers over-packed?
____
____
____
9. Are universal waste thermostats being handled in a manner that will prevent
releases to the environment?
____
____
____
10. Are universal waste thermostats being managed in containers that are
compatible with the contents and closed?
____
____
____
11. Has the handler removed mercury containing ampules from universal waste
thermostats in one of the following ways:
a. Remove ampules in such a way to prevent breakage
____
____
____
Pesticides:
Thermostats:
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 23 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
b. Remove ampules over containment device (e.g., tray or pan)
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
12. Has handler managed lamps in such a way to prevent releases of any universal
waste to the environment?
____
____
____
13. Are universal waste lamps managed in containers that are closed, structurally
sound, adequate to prevent breakage, and compatible with the contents?
____
____
____
14. Are broken lamps immediately cleaned up and placed in containers that are
closed, structurally sound, adequate to prevent breakage, and compatible with
the contents?
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
c. Ensure that mercury clean-up system is available & that spills and releases
are transferred to a container the meets subpart I requirements?
d. Ensure the area where ampules are removed is well ventilated and meets
OSHA exposure limits for mercury.
e. Ensure that employees removing ampules are thoroughly familiar with
proper waste handling and emergency procedures.
f. Stores removed ampules in closed, non-leaking containers in good
condition.
g. Packs removed ampules in container with adequate packing material to
prevent breakage.
h. Has the handler determined that material generated from separating
ampules from thermostats exhibits the characteristics of hazardous waste?
Lamps:
Labeling
15. Has the handler ensured that universal wastes are labeled/marked with one
of the following:
a. For batteries; “universal waste – battery(ies),” or “waste battery(ies),” or “
used battery(ies).”
b. For pesticides; The original manufacturers product label, or “universal
waste-pesticide(s)”, or “waste pesticide(s).”
c. For thermostats; “universal waste-mercury thermostat(s)”, or “waste
mercury thermostat(s)”, or “used mercury thermostat(s)”.
d. For lamps; “universal waste-lamp(s)”, or waste lamp(s)”, or “used lamp(s)”.
Accumulation time limits
16. Has the handler accumulated universal wastes for longer than one year?
17. If wastes were accumulated longer than one year, was it for the purpose of
accumulating sufficient quantities to facilitate proper recovery, treatment, or
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 24 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
disposal?
____
____
____
____
____
____
b. each individual item labeled with a date
____
____
____
c. an inventory system that ID’s the date of each universal waste
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
20. Has handler sent universal waste to only another universal waste handler,
destination facility, or a foreign destination?
____
____
____
21. Has handler transported his own universal waste? If so:
a. Does he comply with USDOT shipping requirements?
____
____
____
____
____
____
18. Is the handler able to demonstrate the length of time universal wastes have
been accumulated? Which of the following methods in used:
a. Waste is placed in containers that are marked with the earliest date
universal waste was placed in the container
d. an inventory system that ID’s the earliest date any universal waste in a
group of universal waste items or a group of containers became a waste
e. waste is placed in a specific accumulation area identifying the earliest date
that any universal waste in the area became a waste
f. any other method that clearly demonstrates the length or time that
universal wastes have been accumulated
Employee training
19. Has the handler informed all employees who handle universal waste of
proper handling and emergency procedures?
Off site shipments
b. Does handler ensure that receiving facility agrees to accept shipment?
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 25 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
UW Audit Checklist
Large Quantity Handler
(>5,000 of waste in one year)
Documentation
1. Has large quantity handler notified the Department of its universal waste
activity using DHEC form 2701?
____
____
____
2. Are batteries handled in a manner that will prevent releases to the environment?
____
____
____
3. Have any batteries that show evidence of leakage or damage been contained in a
compatible and closed container?
____
____
____
4. Has the handler conducted any of the following activities:
a. Sorting by type
____
____
____
c. Mixing different types in one container
____
____
____
d. Discharging energy
____
____
____
e. Regenerating used batteries
____
____
____
f. Disassembling batteries or packs into different cells
____
____
____
g. Removing batteries from consumer products
____
____
____
h. Removing electrolytes
____
____
____
5. If any of the above activities were performed, was an accurate hazardous waste
determination made to determine whether resulting materials are a hazardous waste? ____
____
____
6. Are hazardous wastes handled according to the hazardous waste management
regulations?
____
____
____
7. Are universal waste pesticides being handled in a manner that will prevent releases
to the environment?
____
____
____
8. Are universal waste pesticides being managed in containers that are compatible
with the contents and closed?
____
____
____
9. Are damaged containers over-packed?
____
____
____
10. Are universal waste thermostats being handled in a manner that will prevent
releases to the environment?
____
____
____
11. Are universal waste thermostats being managed in containers that are compatible
with the contents and closed?
____
____
____
Batteries
Pesticides:
Thermostats:
12. Has the handler removed mercury containing ampules from universal waste
thermostats in one of the following ways:
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 26 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
a. Remove ampules in such a way to prevent breakage
____
____
____
b. Remove ampules over containment device (e.g., tray or pan)
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
13. Has handler managed lamps in such a way to prevent releases of any universal
waste to the environment?
____
____
____
14. Are universal waste lamps managed in containers that are closed, structurally
sound, adequate to prevent breakage, and compatible with the contents?
____
____
____
15. Are broken lamps immediately cleaned up and placed in containers that are
closed, structurally sound, adequate to prevent breakage, and compatible with the
contents?
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
____
c. Ensure that mercury clean-up system is available & that spills and
releases are transferred to a container the meets subpart I requirements?
d. Ensure the area where ampules are removed is well ventilated and meets
OSHA exposure limits for mercury.
e. Ensure that employees removing ampules are thoroughly familiar with
proper waste handling and emergency procedures.
f. Stores removed ampules in closed, non-leaking containers in good
condition.
g. Packs removed ampules in container with adequate packing
material to prevent breakage.
h. Has the handler determined that material generated from separating
ampules from thermostats exhibits the characteristics of hazardous waste?
Lamps:
Labeling
16. Has the handler ensured that universal wastes are labeled/marked with one of
the following:
a. For batteries; “universal waste – battery(ies),” or “waste battery(ies),”
or “used battery(ies).”
b. For pesticides; The original manufacturers product label, or “universal
waste-pesticide(s)”, or “waste pesticide(s).”
c. For thermostats; “universal waste-mercury thermostat(s)”, or “waste
mercury thermostat(s)”, or “used mercury thermostat(s)”.
d. For lamps; “universal waste-lamp(s)”, or waste lamp(s)”, or “used lamp(s)”.
Accumulation time limits
17. Has the handler accumulated universal wastes for longer than one year?
18. If wastes were accumulated longer than one year, was it for the purpose of
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 27 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
accumulating sufficient quantities to facilitate proper recovery, treatment, or
disposal?
____
____
____
19. Is the handler able to demonstrate the length of time universal wastes have been
accumulated? Which of the following methods in used:
a. Waste is placed in containers that are marked with the earliest date
universal waste was placed in the container
____
____
____
b. each individual item labeled with a date
____
____
____
c. an inventory system that ID’s the date of each universal waste
____
____
____
d. an inventory system that ID’s the earliest date any universal waste in a
group of universal waste items or a group of containers became a waste
____
____
____
e. waste is placed in a specific accumulation area identifying the earliest date
that any universal waste in the area became a waste
____
____
____
f. any other method that clearly demonstrates the length or time that
universal wastes have been accumulated
____
____
____
____
____
____
21. Has handler sent universal waste to only another universal waste handler,
destination facility, or a foreign destination?
____
____
____
22. Has handler transported his own universal waste? If so:
a. Does he comply with USDOT shipping requirements?
____
____
____
____
____
____
23. Receipt of shipments: Does handler track each shipment of Universal waste
showing the name/address of the originator, quantity of waste received, and
the date of receipt?
____
____
____
24. Off-site shipments: Does handler keep a record of each shipment sent which
includes name/address of handler, destination facility: the quantity and type of
each universal waste sent: the date the shipment was sent?
____
____
____
25. Does handler retain these records for at least three years?
____
____
____
26. Has transporter complied with all applicable USDOT regulations in 49 CFR
part 171-180?
____
____
____
Employee training
20. Has the handler informed all employees who handle universal waste of proper
handling and emergency procedures?
Off site shipments
b. Does handler ensure that receiving facility agrees to accept shipment?
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 28 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Section VII:
USED OIL PROGRAM
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 29 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Used Oil Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 30 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______
Used Oil Audit Checklist
Yes
No
N/A
1. Has an accurate determination been made to ensure that the material is not
A hazardous waste?
____
____
____
2. Is the storage container/s and/or tanks in good condition and free of leaks?
____
____
____
3. Are storage container/s and/or tanks clearly labeled “Used Oil?
____
____
____
4. Upon discovering a leak does the generator perform the following?
a. Stop the leak
____
____
____
b. Contain the leak
____
____
____
c. Clean up the leak
____
____
____
d. Repair the container or tank
____
____
____
____
____
____
5. Does the generator have waste oil transported by a vendor that has obtained
an EPA ID number?
USC EHS Office of Hazardous Waste
(EHS-M-027) Environmental Audit Program
Page 31 of 31
Destroy Previous Revisions
Issue Date: 6/18/07
Reviewed:______