Small Quantity Generator
Campus:
Audit Date:
Auditor:
yes / no / n/a / comments
Generator Size Determination
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?
Hazardous Waste Determination
1 / Has an accurate hazardous waste determination been made on all solid wastes by utilizing the following criteria:
· Is it excluded under 261.4?
· Is it excluded in subpart D of 261 or appendix XI of 261?
· Has the waste been analyzed?
· Has generator knowledge of the hazard characteristics of the waste in light of the materials used been applied?
2 / Have other regulatory exclusions and/or restrictions been applied?
Documentation
1 / Does the generator have an EPA ID number?
2 / Has the generator filed a new form 2701 upon generation of a new waste stream at his site?
3 / Have wastes that have been newly classified or listed hazardous been reported on form 2701?
4 / Has a new form 2701 been filed each time its contents becomes outdated?
5 / If company no longer produces hazardous waste has DHEC been notified through submission of a 2701?
6 / Is a copy of the manifests maintained onsite for three years?
7 / Are test results, waste analysis or other waste determination documentation maintained onsite for three years?
8 / If a signed copy of a manifest has not been received within 60 days has an exception report been filed with DHEC?
9 / Has generator status been declared annually on or before January 31 using DHEC form 2701?
10 / Are land disposal requirements met as outlined in R.268?
11 / Are LDRs maintained onsite for three years?
12 / Does the generator us a uniform manifest when shipping hazardous waste offsite?
13 / Does generator designate on the manifest one facility which is permitted to handle the waste?
14 / If necessary, does generator designate an alternate facility?
15 / Does the generator use a permitted transporter to ship waste off-site?
16 / Is the manifest completed as required by the instructions printed on back:
· Generator’s name, address, phone number, and ID number?
· Name and ID number of each transporter
· Name, address and ID number of designated facility and, if any, alternate facility?
· DOT description of waste
· Total quantity if each waste by units of weight and the type and number of containers as loaded onto the transport vehicle?
· 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.
· Have items A-K and L-T been completed?
· Does the SC generator’s certification appear on the manifest?
· Does the generator sign the manifest certification by hand?
· Obtain handwritten signature from the initial transporter and date of
· acceptance?
17 / Does generator retain one copy?
Note: The manifest requirements do not apply to small quantity generators if the following requirements are met:
· their waste is reclaimed under a contractual agreement,
· 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,
· there is a copy of the agreement available onsite.
Note: Manifests do not have to be used to transport waste on public or private rights of way within or along the border of contiguous property
Storage
1 / Before transporting, or offering for transport, does generator mark each container of 110 gallons or less with the following:
· “HAZARDOUS WASTE – federal law prohibits improper disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
· Generator’s name and address
· Manifest document number
· Accumulation start date
2 / Has hazardous waste been accumulated onsite for greater than 180 days?
3 / Has greater than 13,200 pounds of hazardous waste been accumulated onsite at any time?
4 / Does generator comply with subparts I and J of 265 (management of containers)?
5
6 / Is each storage container marked with an accumulation start date and EPA hazardous waste number?
7 / Is there always at least one person on the premises or on call to act as emergency coordinator?
8 / 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
9 / Are all employees trained in waste handling and emergency procedures relevant to their responsibilities during normal and emergency operations?
Are all containers in good condition?
10 / Are all containers compatible with the waste they contain?
11 / Are all containers closed except when adding or removing waste?
12 / Are containers handled in a way that prevents rupture or leaking?
13 / Is each container marked with the following or equivalent statement: “Hazardous waste – federal laws prohibit improper disposal.”
14 / Is each container marked with an EPA waste number
15 / Is each container marked with an accumulation start date?
16 / Are incompatible waste separated by a physical barrier?
Satellite accumulation
1 / 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?
2 / Are containers in good condition?
3 / Are containers compatible with the waste that they hold?
4 / Is the container kept closed except when adding or removing waste?
5 / Is the container marked either as “hazardous waste” or other words that identify its contents?
6 / Do facility personnel complete classroom or on the job training that teaches them to perform their duties in a way that ensures compliance?
7 / Is the training program designed to ensure that personnel are able to respond effectively to emergencies, including the following:
· Procedures for using, inspecting, repairing and replacing emergency and monitoring equipment
· Communications or alarms systems
· Response to fires or explosions
· Response to groundwater contamination Shutdown of operations
8 / Are records of training maintained onsite for three years?
Inspections
1 / Are all areas where containers are stored being inspected at least weekly for compliance with regulatory requirements?
2 / Are inspections documented and maintained onsite?
USC EHS Office of Environmental Management Destroy Previous Revisions
EHS-F-175 Issue Date: 6/18/07
Page 1 of 4 Reviewed: ______