OFFICIAL USE ONLY
U. S. Department of Energy
Consolidated Audit Program
Treatment, Storage and Disposal Facilities
Checklist 3
Waste Operations
Revision 1.5
September 2015
OFFICIAL USE ONLY
May be exempt from public release under the Freedom of Information Act
(5 U.S.C 552), exemption number and category: Exemption #4: Commercial Proprietary
Department of Energy review required before public release
Name/Org: TBD
Date: TBD
Guidance (if applicable) Memo dated October 30, 2008 from Charles B. Lewis III to Larry Kelly, DM No 419069
Audit ID:
Date:
OFFICIAL USE ONLY
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Revision 1.5
Page 2 of 17
TSDF: _______________________________________ Auditor: __________________________________
Areas Reviewed During Audit:
_____ Waste Acceptance
_____ Waste Storage
_____ Recordkeeping
_____Waste Tracking
_____Treatment
_____Waste Treatment
_____ Site Generated Waste
_____ Aged Waste
Training
_____ Treatability Studies
Disposal
Waste Management Methods Evaluated:
Management Method:
_____ Disposal/Landfill
_____ Waste Storage
_____ Waste Treatment
Recycling
Treatment Method:
_____ Macroencapsulation
_____ Neutralization
_____ Segregation/Repackage
_____ Thermal Desorption
_____ Aqueous treatment
_____ Fuels Blending
___ __ Compaction/Size Reduction
____ _ Stablilization/Vitrification
___ __ Metals Treatment
Incineration
Solvent Washing
_ ___ _ Deactivation
Other
__________
________
Treatment: ________ ________ __
Recycling
__ _____________
Method
______________
Acceptable Waste Types Received:
_____ Hazardous Only
_____ Radioactive Only
_____ Mixed Waste
_____ Sanitary Waste
Acceptable Waste Forms:
_____ Liquid
_____ Solid
_____ Sludge
_____ Gas
A = Acceptable
_____ TSCA Regulated Wastes
_____ Bulk Product/Remediation TSCA Waste
_____ Beryllium Contaminated/Containing
_____ Cylinders
Acceptable Conveyances:
_____ Highway _____ Rail
_____ Ship
NA = Not Applicable
_____ Biological/Infectious Waste
_____ CERCLA Generated Waste
_____ Asbestos (friable/nonfriable)
Storage Vessels:
_____Containers
_____Waste Piles
_____ Aboveground Storage Tanks
Underground Storage Tanks
F = Finding
O = Observation
Access to all referenced regulations is available at the following URLs: https://apps.oro.doe.gov/sites/DOECAP/SitePages/Home.aspx
http://www.access.gpo.gov/nara/cfr/cfr-table-search.html#page1
NOTE:
When audit findings are written against site-specific documents (i.e., SOPs, QA Plans, licenses, permits, etc.), a copy of the pertinent requirement text
from that document must be made available for review or attached to this checklist for retention in DOECAP files.
The references in this checklist are for guidance only. State regulations and permit conditions should be consulted.
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Item
Number
Line of
Inquiry
General
1.1
Does the facility have the necessary and applicable permits and licenses to
perform the operations for which they market?
1.3
1.4
1.5
1.6
Page 3 of 17
TSDF: _______________________________________ Auditor: __________________________________
1.0
1.2
Revision 1.5
Response/
Comments
Status
(RCRA, TSCA, Radioactive Material License)
Does the facility have an EPA identification number if treating, storing,
transporting, or disposing of hazardous waste?
40 CFR 264.11, 40 CFR 261.4(e) and (f)
Does the facility control entry to the active portion of the facility?
40 CFR 264.14 and 265.14
Access Control: Does the facility have a combination of adequate fencing,
natural barriers, guarded gates, and/or 24-hour surveillance systems to guard
against unknowing/unauthorized entry to the facility?
EC Primary
40 CFR 264.14 and 265.14
Danger Signs: Does the facility have “Danger – Unauthorized Personnel Keep
Out” (or similar wording) signs at each entrance and at any other locations
necessary to be visible from any approach, and are they legible from at least 25
feet away?
EC Primary
40 CFR 264.14 and 265.14
Do facility personnel who handle hazardous waste meet the appropriate
training requirements?
EC Primary
EC Primary
EC Primary
EC Primary
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Item
Number
1.7
Revision 1.5
Page 4 of 17
TSDF: _______________________________________ Auditor: __________________________________
Line of
Inquiry
Response/
Comments
Status
40 CFR 264.16 (a) and 40CFR265.16 (a)
Are facility personnel trained in hazardous waste management and emergency
response procedures, (Note if annual refreshers are current?)
EC Primary
Does the facility have 40 hour OSHA training or 24 hour OSHA training? Do
the facility procedures document this requirement?
( Note: 40CFR 264/265.1(a)(4) states employees with OSHA emergency
response training are not required to have separate emergency response
training)
EC Primary
40 CFR 264.16 (b) and 40CFR265.16 (b)
Item
Number
1.8
1.9
Line of
Inquiry
Are training records maintained for all TSDF staff who manages hazardous
waste?
EC Primary; coordinate with QA
40 CFR 264.16(d,e) and 40 CFR 265(d,e)
Does the facility keep a written operating record at the facility?
EC Primary
40 CFR 264.73 through 264.74 and 265.73 through 265.74
Response/
Comments
Status
EC Primary; coordinate with QA
EC Primary
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Waste Acceptance
2.1
Are there any limitations to waste acceptance per environmental permits or
radioactive licenses (rad facilities only)?
If so, how does the facility monitor/control these limitations?
RCRA, Radioactive Materials License
Does the facility have a designated person responsible for waste acceptance
who has the appropriate skills and training to perform the work?
2.3
40 CFR 264.16 (d) (4)
Does the program establish waste profiles and acceptance ranges for customer
wastes?
Coordinate with QA
2.4
40 CFR 264.73 (b) (2); Operational Permits; NQA-1
Does the facility have a written waste analysis plan (WAP) in place for upfront evaluation of customer wastes, establishes waste profiles and defines
acceptance ranges for selected parameters of the waste that is shipped?
2.5
2.6
Page 5 of 17
TSDF: _______________________________________ Auditor: __________________________________
2.0
2.2
Revision 1.5
40 CFR 264.13 (b)
Does the WAP defines procedures for inspection and verification against the
manifest?
40 CFR 264.13 (a) (4)
Prior to receipt, are wastes inspected/sampled to verify acceptability and
sampling meets applicable regulations and QA requirements?
40 CFR 264.13 (b); SW-846, Chapter 9
Coordinate with QA
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
2.7
2.8
2.9
2.10
2.11
Revision 1.5
Page 6 of 17
TSDF: _______________________________________ Auditor: __________________________________
Is routine testing performed to ensure that the waste is authorized under
permits/licenses and matches the waste profile within established acceptable
ranges?
Does testing meet analytical QA requirements?
40 CFR 264.13 (b); SW-846, Chapter 9
For Radiological TSDFs,
Is a process in place to track compliance with radiological limits?
Can the facility document the quantity of radionuclides onsite per license
category?
RC Primary
Radioactive Materials License
For Non-Radiological TSDFs,
Is a process in place to verify and document that no radioactive contaminated
waste is accepted at the TSDF?
RCRA Permit, NRC Regulations
Does the facility operating record include types/quantities of waste received,
results of analyses, inspection results, and results of implementation of all
incidents regarding implementation of the Contingency Plan?
EC Primary
40 CFR 264.73 (b)
Does the facility take precautions to prevent waste reactions by conducting
compatibility reviews of waste and containers prior to mixing or
commingling?
40 CFR 264.17 (b); 40 CFR 264.172
RC Primary
EC Primary
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
2.12
Revision 1.5
Page 7 of 17
TSDF: _______________________________________ Auditor: __________________________________
Does the facility have a written plan and schedule for inspection and
monitoring requirements for containers?
• Are inspections documented? Show date of last inspection and findings.
• Are areas subject to spills inspected daily when in use?
• Are records at inspections kept for at least 3 years?
Coordinate with EC
40 CFR 264.15; 40 CFR 264.1086 (c)(4) and (d)(4); 40 CFR 264.1088 (b); 40
CFR 265.15; 40 CFR 265.1086 (c)(4) and (d)(4); 40 CFR 265.1088 (b)
Coordinate with WO
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.0
3.1
3.1.1
3.1.2
3.1.3
3.1.4
3.1.5
Revision 1.5
Page 8 of 17
TSDF: _______________________________________ Auditor: __________________________________
Waste Treatment
Treatability Studies
Are wastes received for treatability studies <10,000 kg of media contaminated
wastes, 2400 kg of media contaminated with acutely hazardous waste,
<1000kg of non-acute hazardous waste or <1 kg of acutely hazardous waste?
40 CFR 261.4(e) and (f)
Has the facility notified EPA or State agency personnel 45 days prior to
conducting treatability studies?
40 CFR 261.4(f)
Have no more than 90 days elapsed since a treatability study was completed or
no more than one (1) year elapsed since the generator shipped the sample?
40 CFR 261.4(f)
Does the facility maintain a copy of the treatability study contract and shipping
papers for 3 years?
40 CFR 261.4(e) and (f)
Does the facility submit an annual treatability study report (by March 15)?
40 CFR 261.4(f)
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Waste Sampling DQ Primary if DQ auditor on the team
3.2.1
Are samples collected in a way that ensures that the samples are
fully representative of the sampled waste and that there is
maximum protection from inadvertent cross-contamination?
EPA SW-846 – Chapter Nine
Do sampling SOPs exist that are well written and can be
understood and implemented by the technician?
EPA SW-846 Chapter Nine, Section 9.2.2.5
3.2.3
Are sampling technician training programs in place to ensure that
sampling is performed in a consistent and representative manner?
EPA SW-846 Chapter One, Section 2.7
3.2.4
Are samples collected for shipment to off-site analytical
laboratories appropriately containerized, preserved, and
packaged?
EPA SW-846 Chapter Nine
3.2.5
Page 9 of 17
TSDF: _______________________________________ Auditor: __________________________________
3.2
3.2.2
Revision 1.5
For samples collected and sent to the analytical laboratory, is
sample custody maintained and documented at all times from
collection to disposition or return from the outside laboratory?
EPA SW-846 Chapter Nine, Section 9.2.2.7
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.2.6
For samples collected and sent to the analytical laboratory, is
sampling documentation complete and of sufficient detail to
permit reconstruction of the sampling event?
For samples collected and sent to the analytical laboratory, are
records independently reviewed to provide early detection and
corrective action of sampling problems and concerns?
EPA SW-846 Chapter One, Section 2.7.4.1
3.2.8
For samples and standards requiring temperature preservation, is
the temperature in refrigerators and freezers monitored and
documented daily using a calibrated temperature measuring
device?
EPA SW-846 Chapter One and NQA-1, Requirement 12
3.2.9
Page 10 of 17
TSDF: _______________________________________ Auditor: __________________________________
EPA SW-846 Chapter Nine, Section 9.2.2.7
3.2.7
Revision 1.5
Are subsamples taken for analysis representative of the entire
sample that is in the sample container (i.e. sample
homogenization may be required before subsampling)?
EPA SW-846 Chapter Nine, Section9.2.4
3.3
Waste Tracking
3.3.1
Is the waste tracking system documented in a procedure?
Coordinate with QA
40 CFR 264.73 (b) (2); Operational Permits; NQA-1
Coordinate with QA
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.3.2
Does the facility have a formal program in place to document the
description and quantity of waste received and the method and
date of treatment, storage and disposal or offsite shipment?
Does the facility have a formal waste tracking program that
documents the location of each hazardous waste within the
facility and are contemporaneous with waste receipt and
processing?
40 CFR 264.73(b)
3.3.4
Is waste tracked from receipt, through treatment/disposal or
offsite shipment?
 Where is waste stored?
 Where is waste sampled?
 Where is waste treated?
 What process batch is a given container treated in?
 What container number is the treated waste placed in?
 What manifest is the treated waste container shipped out
on?
40 CFR 264.73(b)
3.3.5
Does the waste tracking system document a unique identification
of each treatment batch and the associated waste containers that
are in the batch (e.g., demonstrate the specific batches that DOE
waste containers are treated and shipped offsite in)?
40 CFR 264.73(b)
Page 11 of 17
TSDF: _______________________________________ Auditor: __________________________________
40 CFR 264.73(b)
3.3.3
Revision 1.5
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.3.6
Is the waste tracking system protected in the event of a system
crash or disaster (routine backups) and/or there is an alternative
manual means for tracking waste within the facility?
Is access to the waste tracking system restricted to qualified and
authorized users and all changes to the system are documented
and made by qualified and authorized users?
NQA-1 Subpart 2.7, Section 405(b)
3.4
Aged Waste
3.4.1
Does the facility currently have any waste onsite greater than one
(1) year old?
RC Primary for Rad Waste
RC Primary for Rad Waste
40 CFR 268.50, Radioactive Materials License
3.4.2
For any hazardous waste stored greater than one (1) year, can the
facility demonstrate that storage is solely for the purpose of
accumulation of such quantities to facilitate proper recovery,
treatment and disposal?
40 CFR 268.50
3.5
Waste Storage
3.5.1
Are only wastes authorized under regulatory documents stored
onsite and do not exceed permitted capacities?
RCRA Permit, Radioactive Materials License
3.5.2
Page 12 of 17
TSDF: _______________________________________ Auditor: __________________________________
NQA-1 Subpart 2.7, Section 203(a)(2)
3.3.7
Revision 1.5
During the physical walk down of the facility:
• Were waste containers observed to be in good condition
Coordinate with EC
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Coordinate with EC
40 CFR 264.171, 40 CFR 264.175, 40 CFR 264.190
Does the facility take precautions to prevent the accidental
ignition or reaction of ignitable or reactive wastes?
40 CFR 264.17(a) and (b)
3.5.4
Are containment buildings operated according to specific
standards?
40 CFR 264.1101(a)(3), 40 CFR 264.1101(c)(1), 40 CFR
264.1101(c)(4)
3.6
Treatment
3.6.1
Are controlled procedures in place that specify the required
process for treating waste?
10 CFR 830.122
3.6.2
Are the procedures of sufficient detail to conduct the operation
consistently from batch to batch?
10 CFR 830.122
Page 13 of 17
TSDF: _______________________________________ Auditor: __________________________________
and closed except when necessary to add or remove
waste?
• Do container storage areas have secondary containment
that is designed and operated in compliance with
regulatory and permit conditions?
• Are tank systems located within secondary containment
that has no free liquids and are situated in a permitted
storage area with impermeable floors?
3.5.3
Revision 1.5
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.6.3
Are wastes are treated to established standards (e.g., LDR
standards) or receiving facility acceptance criteria?
Are treatment activities performed in compliance with applicable
regulatory requirements and permit and license requirements?
RCRA Permit; Radioactive Materials License; TSCA
authorization
3.7
Site Generated Waste
3.7.1
For site generated waste treated in accumulation areas to meet
LDRs, does a Waste Analysis Plan describe procedures to be
followed to ensure compliance with LDRs is in place?
40 CFR 268.7(a)(5)
3.7.2
Does the facility ship all hazardous and/or mixed waste on a
hazardous waste manifest compliant with governing
requirements?
TR primary
40 CFR 262.20 (NA for Non-Rad Facilities)
3.7.3
Are site generated wastes stored in permitted areas, 90-day areas
or satellite accumulation areas compliant with governing
requirements?
40 CFR 262.34
3.7.4
Page 14 of 17
TSDF: _______________________________________ Auditor: __________________________________
40 CFR 268.
3.6.4
Revision 1.5
Does the facility manage universal waste in compliance with
requirements?
40CFR273.2; 40CFR273.13(a); 40CFR273.33(a)
TR primary
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
3.7.5
Page 15 of 17
TSDF: _______________________________________ Auditor: __________________________________
Do recyclers comply with applicable requirements for handlers of
universal waste?
40CFR273.2; 40CFR273.13(a); 40CFR273.33(a)
4.0
Waste Disposal
4.1
Hazardous Waste Landfills
4.1.1
Does the landfill have a run-on control system, a runoff
management system and control of wind dispersal of particulate
matter?
40 CFR 264.301(g) through (k) and 40 CFR 265.301 (f) through
(i)
4.1.2
Revision 1.5
Does the landfill have a liner and a leachate collection and
removal system?
40 CFR 264.301 (a) and (b)
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Notes:
Revision 1.5
Page 16 of 17
TSDF: _______________________________________ Auditor: __________________________________
U.S. Department of Energy Consolidated Audit Program
DOECAP TSDF Audit Checklist: 3
Waste Operations
Effective Date: September 2015
Audit ID: ________________
Notes:
Revision 1.5
Page 17 of 17
TSDF: _______________________________________ Auditor: __________________________________