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					                CAP101                                                                                                                                                                                                          Audit Protocol Questions / Checklist
                Revision Number: 4

                                                                                                                Country




                                                                                                                                                             State / Province
                                                                                                                                   Venezuela
                                                                                                                 Canada
                                                                                                                          Mexico
                                                                                                                                                                                   Citation                                 Media       Subcategory         Type of Req.                                                                                                                                                                           Evidence
                                                                                      SEB No. &                                                 Agency                                                   Related                                                                                                                         Requirement Description




                                                                                                         U.S.
   Number                 Audit Protocol Question / Checklist                                                                                                                    (sets ECAR                               (In ECAR       (In ECAR            (In ECAR                                                                                                                                                                        (Documents for auditor to               Comments
                                                                                       Section                                                 Category                                                Requirements                                                                                                                (either SEB or federal/state citation)
                                                                                                                                                                                   Priority)                              Database)      Database)           Database)                                                                                                                                                                               verify)


CAP101-US-001                                                                       SEB101 Section       x                                     Federal                                                 SEB 102        Waste            Solid & Hazardous Operating Criteria Facilities that generate solid wastes must determine if these wastes are hazardous waste per the definitions and exclusions of 40 CFR 261.2, and 40            Provide documentation that contains
                                                                                    5.2.1                                                                                                                                              Waste Identification                 CFR 261.3, and 40 CFR 261.4. Specific solid and hazardous waste identification and determination procedures are included in SEB 102. Also, if a                manufacturers data or engineering
                   Can the facility provide documentation that indicates how they                                                                                                                                                                                           waste is determined to be hazardous and will be land disposed, the generator must also determine if the waste must be treated for land disposal.               knowledge to properly classify the
                                                                                                                                                                                 40 CFR 262.11
                     have determined the proper classification of their waste?                                                                                                                                                                                              These requirements are more fully discussed in SEB 102, and SEB 103, and in 40 CFR 268.7 .                                                                     plant wastes.


CAP101-US-002 Can the facility provide shipping records and other supporting        SEB101 Section       x                                     Federal                          40 CFR                                Waste            Solid & Hazardous Reporting             Wastes determined to be hazardous based on the waste determinations made per the definitions of 40 CFR 261.2, 261.3,and 261.4 must be                       Review of the manifest log,
              documentation to support the facility generator status (LQG,          5.2.2                                                                                       261.5(c),(d),262.1                                     Waste Identification                    accounted for when determinining if the facility is a generator and then to establish the category of generator status. The quantity of waste onsite        WasteTRACK shipping records, and
              SQG, or CESQG)?                                                                                                                                                   0(b)                                                                                           never exceeds 6000 kg for SQG's or 1000 kg for CESQG's.                                                                                                     any inventory tracking reports.
CAP101-US-003 Does the facility have an EPA ID No.? Has a change occurred at SEB101 Section              x                                     Federal                          40 CFR 262.12                         Waste            Solid & Hazardous Reporting             Identification Numbers (EPA ID number - form 8700-12) - Notification of hazardous waste activity and subsequent notifications under certain                 Provide a copy of the last EPA/SE&E
              the facility that would require a subsequent notification? Has the 5.2.3.1                                                                                                                                               Waste Identification                    circumstances (facility moves to another location, facility contact changes, ownership of your facility changes, additional owner has been added or         notification.
              facility used the proper notification form?                                                                                                                                                                                                                      replaced since the facility's initial notification, or type of regulated waste activity you conduct changes). EPA requirement for LQG & SQG. DCC
                                                                                                                                                                                                                                                                               requirement for CESQG. Some states require that state specific forms be used in place of form 8700.


CAP101-US-004 Is the facility accumulating waste within the required                SEB 101 Section     x                                      Federal                          40 CFR                                Waste            Solid & Hazardous Record Keeping        Large Quantity Generators may accumulate hazardous waste on-site for 90 days or less. Small Quantity Generators may accumulate hazardous                    Review container labels within the
              accumulation time limits?                                             5.2.6.1 and 5.2.6.2                                                                         262.34(a),(d),(e),(f                                   Waste Identification                    waste on-site for 180 days or less. If the DCC facility must ship its waste to a TSD&R facility that is more than 200 miles from the DCC facility, the      accumulation areas. Review of the
                                                                                                                                                                                )                                                                                              SQG may accumulate hazardous waste on-site for 270 days or less.                                                                                            manifests, WasteTRACK shipping
                                                                                                                                                                                                                                                                                                                                                                                                                                           records, and any inventory tracking
                                                                                                                                                                                                                                                                                                                                                                                                                                           reports.
CAP101-US-005 Is the facility using and managing hazardous waste containers         SEB 101 Section                                            Federal                          40 CFR                                Waste            Waste Tank          Operating Criteria Containers must be marked with the words "Hazardous Waste". Container labels must be properly completed. Containers must be in good condition Review all 90 day and satellite
              per the regulatory and DCC environmental requirements?                5.2.7, 5.2.7.1                                                                              262.34(a),(d),and                                      Container                              and not leaking. Containers must be compatible with the materials collected in them. All containers must be closed except when waste is added or accumulation area containers as well
                                                                                                         x                                                                      40 CFR 265        ETI 501                              Management                             removed. Incompatible wastes must be segregated in the accumulation area according to waste type and characteristics. Adequate aisle space       as inspection logs.
                                                                                                                                                                                Subpart I                                                                                     must be maintained. Containers holding ignitable or reactive wastes must be located at least 50 feet from the property line.


CAP101-US-006 Does the facility store hazardous waste in a satellite                SEB 101 Section      x                                     Federal                          40 CFR 262.34                         Waste            Waste Tank          Operating Criteria A generator may accumulate up to 55 gallons of hazardous waste (total), or one quart of acutely hazardous waste, in containers at or near any point          Review containers in Satellite
              Accumulation area? If so, are the satellite accumulation area         5.2.9                                                                                       (c)                                                    Container                              of generation (satellite accumulation area). The container must be under the control of the operator of the process generating the waste and must            Accumulation areas and any facility
              requirements met?                                                                                                                                                                                                        Management                             be marked “hazardous waste” (or with other words accurately identifying its contents) in good condition, compatible with the waste to be                     inspection logs.
                                                                                                                                                                                                                                                                              accumulated, and kept closed except when waste is added or removed. When a total of 55 gallons of hazardous waste or one quart of acutely
                                                                                                                                                                                                                                                                              hazardous waste accumulates at a satellite accumulation area, the container(s) must be marked with the date the container became full. The
                                                                                                                                                                                                                                                                              generator then has three days to move the waste to the facility's 90 or 180 waste accumulation area (a.k.a. barrel yard).



CAP101-US-007 Does the facility inspect 90 or 180 day storage areas on a weekly SEB 101 Section          x                                     Federal/DCC                      40 CFR 265.174                        Waste            Waste Tank          Inspection          90 and 180 day accumulation areas must be inspected weekly (every 7 days). Applies to LQG, SQG, and CESQG's, and inspections must be                        Review all 90 and 180 day
              basis (every 7 days)?                                             5.2.7, 5.2.7.1                                                                                  Subpart I                                              Container                               documented.                                                                                                                                                 accumulation area inspection logs.
                                                                                                                                                                                                                                       Management
CAP101-US-008 Does the facility inspect all Satellite Accumulation areas at a       SEB 101 Section      x                                     DCC                              N/A                                   Waste            Waste Tank          Inspection          It is a DCC environmental requirement, to at a minimum, inspect satellite accumulation areas on a monthly basis (every 30 days). Inspections must           Review all Satellite Accumulation area
              minimum once per month (every 30 days)?                               5.2.9                                                                                                                                              Container                               be documented.                                                                                                                                              inspection logs.
                                                                                                                                                                                                                                       Management
CAP101-US-009 Is the facility using and managing hazardous waste tanks per the SEB 101 Section           x                                     Federal/DCC                      40 CFR                                Waste            Waste Tank          Operating Criteria ###################################################################################################################### Review all hazardous waste tanks as
              regulatory and DCC environmental requirements?                   5.2.8                                                                                            262.34(a),(d),40                                       Container                                                                                                                                                     well as inspection logs. Review the
                                                                                                                                                                                CFR 265 Subpart                                        Management                                                                                                                                                    facility tank manual.
                                                                                                                                                                                J
CAP101-US-010 Does the facility inspect hazardous waste tanks on a daily basis? SEB 101 Section          x                                     Federal                          40 CFR 265.195                        Waste            Waste Tank          Inspection          Tank systems must be inspected daily in accordance with 40 CFR 265.195 for LQGs and 40 CFR 265.201 for SQGs and CESQGs. Inspections                         Review the hazardous waste tank
                                                                                5.2.8                                                                                           (for LQG's) and                                        Container                               must be documented.                                                                                                                                         inspection logs and the facility tank
                                                                                                                                                                                40 CFR 265.201                                         Management                                                                                                                                                                                          manual for inspection requirements.
                                                                                                                                                                                (for SQG and
                                                                                                                                                                                CESQG's)
CAP101-US-011 Is the facility completely empting hazardous waste tanks and          SEB 101 Section      x                                     Federal                          40 CFR 262.34(a)                      Waste            Waste Tank          Operating Criteria All hazardous waste tanks used for accumulation purposes must be emptied completely and the waste transported offsite within 90 or 180 days                  Review of the manifest log,
              transporting the waste offsite within 90 days?                        5.2.8                                                                                                                                              Container                              depending on generator status. Documentation of tank draining is required. Number of gallons in tank prior to removal and amount removed should              WasteTRACK shipping records, and
                                                                                                                                                                                                                                       Management                             be documented.                                                                                                                                               any inventory tracking reports.
CAP101-US-012 Has the facility installed any new hazardous waste tanks, or is the SEB 101 Section        x                                     Federal                          40 CFR 265.192         SEB 612        Waste            Waste Tank          Operating Criteria SE&E must be consulted prior to any new tank system installation. When installing new tanks, an assessment must be performed in accordance                   Review Facility Tank Manual and any
              facility using an existing tank for hazardous waste that previously 5.2.8                                                                                                                                                Container                              with 40 CFR 265.192 to determine that the integrity and installation of the tank are acceptable for storage of hazardous waste.                              tank inventoriest. Ask facility for
              did not contain hazardous waste?                                                                                                                                                                                         Management                                                                                                                                                                                          documentation that SE&E was notified
                                                                                                                                                                                                                                                                                                                                                                                                                                           of the installation or reuse of an
                                                                                                                                                                                                                                                                                                                                                                                                                                           existing tank.
CAP101-US-013 Do all tanks used for the accumulation of hazardous waste have        SEB 101 Section      x                                     Federal                          40 CFR 265.191         SEB 612        Waste            Waste Tank          Operating Criteria All tanks must have an integrity assessment either meeting the requirements of 40 CFR 265.191 for tanks installed prior to July 14. 1986 or meeting Review facility files for integrety
              complete integrity assessments certified by a Professional            5.2.8                                                                                       & 40 CFR                                               Container                              the requirements at 40 CFR 265.192 for tanks installed after July 14, 1986. A file containing the written integrity assessment, design, tightness, and assessments of tanks. Verify that
              Engineer (by the state in which the facility operates)?                                                                                                           265.192                                                Management                             installation certifications must be maintained at the facility, with copies sent to SE&E.                                                              assessments were certified by a PE
                                                                                                                                                                                                                                                                                                                                                                                                                                     within the state that the facility
                                                                                                                                                                                                                                                                                                                                                                                                                                     operates.
CAP101-US-014 Has the facility installed Corporate approved signs at hazardous      SEB 101 Section      x      x         x                    DCC                              N/A                                   Waste            Waste Tank          Operating Criteria SE&E approved standard signs have been designed for hazardous waste satellite stations and hazardous waste accumulation areas. Use of these                  Review waste accumulation areas for
              waste 90, 180, & Satellite Accumulation areas?                        5.2.10;5.3.7;5.4.7                                                                                                                                 Container                              signs facilitates area control and clearly communicates requirements for plant personnel preparing/accumulating waste for shipment.                          proper signage.
                                                                                                                                                                                                                                       Management
CAP101-US-015 If the facility is a SQG or CESQG is the appropriate emergency        SEB 101 Section      x                                     Federal/DCC                      40 CFR 262.34                         Waste            Waste Tank          Operating Criteria SQGs are legally required (40 CFR 262.34(d)(5)) and it is a DCC environmental requirement for CESQG's to post emergency response information                 Review waste accumulation areas for
              response information posted at the 180 day waste accumulation         5.2.10                                                                                      (d)(5)                                                 Container                              next to the telephone at the 180 day waste accumulation area. Corporate signage has been created to satisfy this requirement and its use is                  proper signage.
              area?                                                                                                                                                                                                                    Management                             recommended as the best means of satisfying this rule.
CAP101-US-016 Is the facility using TSD&R facilities that have been approved by     SEB 101 Section      x      x                              DCC                              N/A                    SEB 611        Waste            Waste Tank          Operating Criteria All DCC facilities must use TSD&R facilities that have been pre-approved by SE&E. All destinations where hazardous waste is to be managed must Review of the manifest log,
              SE&E for all waste streams leaving the facility?                      5.2.11 & 5.3.8                                                                                                                                     Container                              be verified. Specifically, the ultimate disposal location must be documented, if different than the facility to which the waste is first manifested (i.e. for WasteTRACK shipping records, and
                                                                                                                                                                                                                                       Management                             consolidation, treatment, storage, etc.). All TSD&R destination sites must be approved per SEB 611.                                                           any inventory tracking reports that
                                                                                                                                                                                                                                                                                                                                                                                                                                            identify destination sites that can be
                                                                                                                                                                                                                                                                                                                                                                                                                                            compared to the SE&E approved list.




                                                                                                                                                                                                                                                 1 of 20                                                                                                                                                                                                               July 2006
                CAP101                                                                                                                                                                                                             Audit Protocol Questions / Checklist
                Revision Number: 4

                                                                                                                Country




                                                                                                                                                                  State / Province
                                                                                                                                   Venezuela
                                                                                                                 Canada
                                                                                                                          Mexico
                                                                                                                                                                                        Citation                               Media       Subcategory       Type of Req.                                                                                                                                                                     Evidence
                                                                                       SEB No. &                                                Agency                                                    Related                                                                                                                         Requirement Description




                                                                                                         U.S.
   Number                  Audit Protocol Question / Checklist                                                                                                                        (sets ECAR                             (In ECAR       (In ECAR          (In ECAR                                                                                                                                                                  (Documents for auditor to                Comments
                                                                                        Section                                                Category                                                 Requirements                                                                                                                (either SEB or federal/state citation)
                                                                                                                                                                                        Priority)                            Database)      Database)         Database)                                                                                                                                                                         verify)


CAP101-US-017 Has the facility completed and submitted a Biennial report to the     SEB 101 Section      x                                     Federal                               40 CFR 262.41                       Waste            Waste Tank         Reporting          Biennial reports must be submitted by LQGs to EPA on Form 8700-13A (this form changes based on the reporting year) or to the State on a state-        Provide a copy of the Biennial report
              state or Federal agency by March 1 of each even numbered              5.2.14                                                                                                                                                Container                             equivalent form by March 1 of each even numbered year. The report covers activities during the previous year for all hazardous waste shipments to     with evidence that it was submitted to
              year? Has the facility submitted a copy of the report to SE&E?                                                                                                                                                              Management                            TSD&R facilities within the United States. A copy of the report must also be sent to SE&E by the same date.                                           the agency by March 1(eg. Certified
                                                                                                                                                                                                                                                                                SQGs and CESQGs are not required to prepare Biennial Reports, although some reporting requirements may be mandated by state law.                      mail receipt) and a copy was
                                                                                                                                                                                                                                                                                                                                                                                                                                      submitted to SE&E.



CAP101-US-018 Has the facility maintained all records with respect to waste         SEB 101 Section      x                                     Federal/DCC                           40 CFR 262.40                       Waste            Record Retention   Record Keeping      U.S. EPA and the states require that copies of manifests, Biennial Reports, LDR notices and certifications, Exception Reports, test results,         Review facility records on file and
              management within the time limits set in the DCC record               5.2.16                                                                                                                                                Requirements                          inspection reports, training records and waste analyses/determinations be maintained on-site for certain periods of time in the case of any           determine if they are within the DCC
              retention database?                                                                                                                                                                                                                                               enforcement action or request from EPA. DCC record retention requirements meet or exceed these requirements and are specified in the DCC              record retention requirements.
                                                                                                                                                                                                                                                                                record retention database.


CAP101-US-019 Does the facility have an EPA ID No.? Has a change occurred at SEB 101 Section             x                                     State /       AL                      335-14-3-          CAP101-US-002    Waste            Solid & Hazardous Reporting           Alabama requires that ADEM Form 8700-12 be completed and submitted for notifying the State of hazardous waste activity, changes in activity,          Check when the last notification was
              the facility that would require a subsequent notification? Has the 5.2.17                                                        Province                              .01(3),(4)                                           Waste Identification                  change in location, and requesting an EPA ID number. A generator must submit a correct and complete form annually; the due date varies                made. Has there been any changes in
              facility used the proper Alabama state notification form?                                                                                                                                                                                                         depending upon the county where the site is located.                                                                                                  the facility that would require a new
                                                                                                                                                                                                                                                                                                                                                                                                                                      notification (list any changes)


CAP101-US-020 Is the facility using and managing hazardous waste containers         SEB 101 Section      x                                     State /       AL                      335-14-5-.9        CAP101-US-004    Waste            Waste Tank         Inspection         In Alabama, each container should be marked with the appropriate EPA waste code as well as the words “Hazardous Waste”.                               Review all 90 day and satellite
              per the regulatory requirements in the state of Alabama?              5.2.17                                                     Province                                                                                   Container                             In Alabama, containers larger than 30 gallons cannot be stacked more than two high.                                                                   accumulation area containers as well
                                                                                                                                                                                                                                          Management                                                                                                                                                                                  as inspection logs.

CAP101-US-021 Is the facility making proper notification to the state of Alabama    SEB 101 Section      x                                     State /       AL                      335-14-3-.08       CAP101-US-0015   Waste            Waste Tank         Operating Criteria Generators of waste destined for disposal at a commercial site in Alabama must submit an adequate notification to the ADEM prior to disposal of any Review of the manifest log,
              for wastes destined to a commercial site within the state prior to    5.2.17                                                     Province                                                                                   Container                             waste. ADEM must have notification at least 5 working days before disposal is allowed. If ADEM fails to respond to the generator within the 5 days WasteTRACK shipping records, and
              disposal?                                                                                                                                                                                                                   Management                            after notification, the waste may be disposed. The generator must complete form ADEM Form 278 01/96.                                                any inventory tracking reports that
                                                                                                                                                                                                                                                                                                                                                                                                                                    identify destination sites within the
                                                                                                                                                                                                                                                                                                                                                                                                                                    state of AL and ensure proper
                                                                                                                                                                                                                                                                                                                                                                                                                                    notification was made by reviewing
                                                                                                                                                                                                                                                                                                                                                                                                                                    facility records.
CAP101-US-022 Has the facility obtained the Biennial report form from the state     SEB 101 Section      x                                     State /       AL                      335-14-3-.04(2)(a) CAP101-US-0016   Waste            Waste Tank         Reporting          The facility must use the federal biennial report form which can be obtained from ADEM. Complete the report and submit to ADEM.                       Review facility files for a copy of the
              for submittal by March 1 of each even numbered year? Has the          5.2.17                                                     Province                                                                                   Container                                                                                                                                                                                   Biennial report with evidence that it
              facility submitted a copy of the report to SE&E?                                                                                                                                                                            Management                                                                                                                                                                                  was submitted to the agency by March
                                                                                                                                                                                                                                                                                                                                                                                                                                      1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                      was submitted to SE&E.


CAP101-US-023 Does the facility inspect container storage areas on a weekly         SEB 101 Section      x                                     State /       AL                      335-14-5-.9(5) &   CAP101-US-006    Waste            Waste Tank         Inspection         In Alabama, it is required that container storage areas be inspected at least every 7 days. These inspections must be documented and the records      Review all accumulation area
              basis (every 7 days)?                                                 5.2.17                                                     Province                              335-14-5-.2(6)                                       Container                             kept for 3 years. Documentation must include the date of the inspection, the inspector’s name, notes of observations, and date and nature of any      inspection logs.
                                                                                                                                                                                                                                          Management                            repairs or remedial actions.
CAP101-US-024 If the facility is a LQG in the state of Arizona has it completed and SEB 101 Section      x                                     State /       AZ                      R18-8-262.41       CAP101-US-0016   Waste            Waste Tank         Reporting          In Arizona, LQGs are required to prepare and submit a single copy of an annual report to the ADEQ by March 1st of each year for the previous year’s Review facility files for a copy of the
              submitted a report of it's hazardous waste activities to the state    5.2.18                                                     Province                                                                                   Container                             hazardous waste activities.                                                                                                                         annual report with evidence that it was
              agency by March 1 of each year? Has the facility submitted a                                                                                                                                                                Management                                                                                                                                                                                submitted to the agency by March
              copy of the report to SE&E?                                                                                                                                                                                                                                                                                                                                                                                           1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                    was submitted to SE&E.


CAP101-US-025 Does the facility have an EPA ID No.? Has a change occurred at SEB 101 Section             x                                     State /       DE                      Rule 262.12        CAP101-US-002    Waste            Solid & Hazardous Reporting           A facility in the state of Delaware must submit the State form that is numbered and titled the same as federal form for notification of regulated     Check when the last notification was
              the facility that would require a subsequent notification? Has the 5.2.19                                                        Province                                                                                   Waste Identification                  activity.                                                                                                                                             made. Has there been any changes in
              facility used the proper Delaware state notification form?                                                                                                                                                                                                                                                                                                                                                              the facility that would require a new
                                                                                                                                                                                                                                                                                                                                                                                                                                      notification (list any changes)


CAP101-US-026 If the facility is a generator in the state of Delaware has it  SEB 101 Section            x                                     State /       DE                      Rule 262.41 and    CAP101-US-0016   Waste            Waste Tank         Reporting          A facility in the state of Delaware must submit an annual report summarizing hazardous waste activities and submit that report to DNREC by March 1 Review facility files for a copy of the
              completed and submitted a report summarizing hazardous waste 5.2.19                                                              Province                              Rule 262.40                                          Container                             of each year. This form is available from the Solid and Hazardous Waste Management Branch of DNREC.                                                annual report with evidence that it was
              activities to the state agency by March 1 of each year? Has the                                                                                                                                                             Management                                                                                                                                                                               submitted to the agency by March
              facility submitted a copy of the report to SE&E?                                                                                                                                                                                                                                                                                                                                                                     1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                   was submitted to SE&E.


CAP101-US-027 If the facility is a generator in the state of Illinois has it completed SEB 101 Section   x                                     State /       IL                      35 IAC 722.141     CAP101-US-0016   Waste            Waste Tank         Reporting          A hazardous waste generator in the state of Illinois must submit an annual report summarizing hazardous waste activities and submit that report to    Review facility files for a copy of the
              and submitted a report summarizing hazardous waste activities to 5.2.20                                                          Province                                                                                   Container                             DNREC by March 1 of each year. This form is supplied by the Illinois EPA.                                                                             annual report with evidence that it was
              the state agency by March 1 of each year? Has the facility                                                                                                                                                                  Management                                                                                                                                                                                  submitted to the agency by March
              submitted a copy of the report to SE&E?                                                                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                      was submitted to SE&E.


CAP101-US-028 If the facility is a SQG, LQG, or CESQG generator in the state of SEB 101 Section          x                                     State /       IN                      Senate Enrolled    CAP101-US-0016   Waste            Waste Tank         Reporting          The annual manifest reporting requirements took effect January 1, 2002. The annual manifest report must be submitted to IDEM, on forms provided       Review facility files for a copy of the
              Indiana has it completed either the annual IDEM annual manifest 5.2.21                                                           Province                              Act 511 (P.L. 143-                                   Container                             by IDEM, for all Indiana SQGs, and LQGs. CESQGs that for any one calendar month generate more than 100 kilograms (220 pounds) or accumulate           annual and biennial reports with
              report or the EPA Biennial Report by March 1 of the reporting                                                                                                          2000) (IC 13-22-4-                                   Management                            on-site at any time more than 1,000 kilograms (2,200 pounds) of hazardous waste will also be required to complete and submit the annual manifest      evidence that it was submitted to the
              year? Has the facility submitted a copy of the report to SE&E?                                                                                                         3.1) and 329 IAC                                                                           report to IDEM.                                                                                                                                       agency by March 1(eg. Certified mail
                                                                                                                                                                                     3.1-7-14                                                                                   The annual manifest report will summarize a company’s hazardous waste manifest shipments that are sent and/or received. SQGs (also CESQGs             receipt) and a copy was submitted to
                                                                                                                                                                                                                                                                                over their generation or accumulation limits) will be required to submit the annual report by March 1st of each year, beginning March 1, 2002. LQGs   SE&E.
                                                                                                                                                                                                                                                                                will be required to submit the Hazardous Waste Biennial Report, required by the US EPA, on the years they are due and the IDEM annual manifest
                                                                                                                                                                                                                                                                                report on the other years. The reporting schedule with due dates for LQGs is as follows:
                                                                                                                                                                                                                                                                                March 1, 2002 Hazardous Waste Biennial Report
                                                                                                                                                                                                                                                                                March 1, 2003 IDEM annual manifest report
                                                                                                                                                                                                                                                                                March 1, 2004 Hazardous Waste Biennial Report
                                                                                                                                                                                                                                                                                March 1, 2005 IDEM annual manifest report




                                                                                                                                                                                                                                                   2 of 20                                                                                                                                                                                                        July 2006
                CAP101                                                                                                                                                                                                          Audit Protocol Questions / Checklist
                Revision Number: 4

                                                                                                              Country




                                                                                                                                                             State / Province
                                                                                                                                 Venezuela
                                                                                                               Canada
                                                                                                                        Mexico
                                                                                                                                                                                   Citation                                 Media       Subcategory       Type of Req.                                                                                                                                                                           Evidence
                                                                                      SEB No. &                                               Agency                                                   Related                                                                                                                         Requirement Description




                                                                                                       U.S.
   Number                 Audit Protocol Question / Checklist                                                                                                                    (sets ECAR                               (In ECAR       (In ECAR          (In ECAR                                                                                                                                                                        (Documents for auditor to                Comments
                                                                                       Section                                               Category                                                Requirements                                                                                                                (either SEB or federal/state citation)
                                                                                                                                                                                   Priority)                              Database)      Database)         Database)                                                                                                                                                                               verify)


CAP101-US-029 Does the facility have an EPA ID No.? Has a change occurred at SEB 101 Section           x                                     State /    MI                      R 299.9304           CAP101-US-002    Waste            Solid & Hazardous Reporting           The state of Michigan requires that State Form EQP5150 be completed and submitted for notifying the State of Hazardous Waste Activity, changes              Check when the last notification was
              the facility that would require a subsequent notification? Has the 5.2.22                                                      Province                                                                                  Waste Identification                  in activity, and requesting an EPA Identification Number.                                                                                                   made. Has there been any changes in
              facility used the proper notification form?                                                                                                                                                                                                                                                                                                                                                                                the facility that would require a new
                                                                                                                                                                                                                                                                                                                                                                                                                                         notification (list any changes)


CAP101-US-030 Is the facility using and managing hazardous waste containers         SEB 101 Section                                          State /    MI                      R299.9614            CAP101-US-004    Waste            Waste Tank         Operating Criteria The state of Michigan requires that containers with less than 110 gallons of waste be marked with the hazardous waste number in addition to the             Review all 90 day and satellite
              per the regulatory and corporate requirements?                        5.2.22             x                                     Province                                                                                  Container                             federal requirement of marking the container with the words “Hazardous Waste” and the accumulation start date .                                             accumulation area containers as well
                                                                                                                                                                                                                                       Management                                                                                                                                                                                        as inspection logs.
CAP101-US-031 Do the facility's accumulation areas comply with the requirements SEB 101 Section                                              State /    MI                      R299.9614            CAP101-US-004    Waste            Waste Tank         Operating Criteria The state of Michigan requires hazardous waste generators to comply with secondary containment requirements found at 40 CFR 264.175.                Review all 90 day and satellite
              set forth in 40 CFR 264.175?                                      5.2.22                                                       Province                                                                                  Container                             Containment systems (accumulation areas) must be sufficiently impervious to leaks, sloped to remove liquids, and contain 10% of the total volume of accumulation area containers as well
                                                                                                       x                                                                                                                               Management                            all containers or 100% of the largest container, whichever is greater.                                                                              as inspection logs.

CAP101-US-032 Has the facility obtained the Biennial report form from the state     SEB 101 Section                                          State /    MI                      R299.9308            CAP101-US-0016   Waste            Waste Tank         Reporting          The state of Michigan requires LQG's to submitt a Hazardous Waste Report in a form and format specified by the director. In Michigan, pre-                  Review facility files for a copy of the
              for submittal by March 1 of each even numbered year? Has the          5.2.22                                                   Province                                                                                  Container                             populated forms will be mailed to each site. Facilities are to submit completed forms that are signed and dated by March 1 of each even numbered            Biennial report with evidence that it
              facility submitted a copy of the report to SE&E?                                                                                                                                                                         Management                            year.                                                                                                                                                       was submitted to the agency by March
                                                                                                       x                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                         was submitted to SE&E.


CAP101-US-033 Does the facility store hazardous waste in a Satellite                SEB 101 Section                                          State /    MO                      10 CSR 25-           CAP101-US-005    Waste            Waste Tank         Operating Criteria In the state of Missouri, waste in a Satellite Accumulation area cannot remain there for more than a year from the date the waste first began               Review containers in satellite
              Accumulation area? If so, are the satellite accumulation area         5.2.23                                                   Province                           5.262(2)(C)3                                           Container                             accumulating. The date that hazardous waste is first placed in the satellite accumulation container must be recorded on the container.                      accumulation areas and inspection
              requirements met?                                                                        x                                                                                                                               Management                                                                                                                                                                                        logs.

CAP101-US-034 If the facility is a generator in the state of Missouri (generating SEB 101 Section                                            State /    MO                      10 CSR 25-           CAP101-US-0016   Waste            Waste Tank         Reporting          In the state of Missouri generators of more than 100 kg per month are to report quarterly on their hazardous waste activity.                                Review facility files for a copy of the
              more than 100 kg per month) has it completed and submitted a        5.2.23                                                     Province                           5.262(2)(D)1                                           Container                                                                                                                                                                                         quarterly reports with evidence that it
              quarterly hazardous waste activity report to the agency? Has the                                                                                                                                                         Management                                                                                                                                                                                        was submitted to the agency by March
              facility submitted a copy of the report to SE&E?                                         x                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                         was submitted to SE&E.


CAP101-US-035 If the facility is a generator in the state of New York has it        SEB 101 Section                                          State /    NY                      6 NYCRR              CAP101-US-0016   Waste            Waste Tank         Reporting          In the state of New York any generators who ships any hazardous waste off site to a TSD facility located within the U.S. must submit an annual              Review facility files for a copy of the
              completed and submitted an annual hazardous waste activity            5.2.24                                                   Province                           372.2(c)(2)                                            Container                             report to the New York State DEC by March 1 for the previous year.                                                                                          annual reports with evidence that it
              report to the agency? Has the facility submitted a copy of the                                                                                                                                                           Management                                                                                                                                                                                        was submitted to the agency by March
              report to SE&E?                                                                          x                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                         was submitted to SE&E.


CAP101-US-036 If the facility is a generator in the state of Ohio has it completed SEB 101 Section                                           State /    OH                      3745-52-41           CAP101-US-0016   Waste            Waste Tank         Reporting          The state of Ohio requires annual reports containing information on the types and quantities of hazardous waste generated. The report is due on             Review facility files for a copy of the
              and submitted an annual hazardous waste activity report to the       5.2.25                                                    Province                                                                                  Container                             March 1 for the previous year.                                                                                                                              annual reports with evidence that it
              agency? Has the facility submitted a copy of the report to SE&E?                                                                                                                                                         Management                                                                                                                                                                                        was submitted to the agency by March
                                                                                                       x                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                         was submitted to SE&E.


CAP101-US-037 Does the facility store hazardous waste in a Satellite                SEB 101 Section                                          State /    WI                      NR 610.08(2)         CAP101-US-005    Waste            Waste Tank         Operating Criteria For SQGs, Wisconsin requires that an individual be assigned or designated to be in charge of a satellite accumulation area.                                 Review satellite accumulation areas,
              Accumulation area? If so, are the satellite accumulation area         5.2.26                                                   Province                                                                                  Container                                                                                                                                                                                         inspection logs, and training records of
              Wisconsin regulatory requirements met?                                                   x                                                                                                                               Management                                                                                                                                                                                        individual assigned to the satellite
                                                                                                                                                                                                                                                                                                                                                                                                                                         area.
CAP101-US-038 Does the facility know the location and identity of all stored        SEB 101 Section                                          State /    WI                      NR                                    Waste            Waste Tank         Operating Criteria Wisconsin requires that the location and identity of all stored hazardous waste be known at all times by the generator.                                     Review documentation that identifies
              hazardous waste?                                                      5.2.26                                                   Province                           610.05(4),(7);610.                                     Container                                                                                                                                                                                         all waste locations throughout the
                                                                                                       x                                                                        08(1)( r)                                              Management                                                                                                                                                                                        facility (ie site plan) and the
                                                                                                                                                                                                                                                                                                                                                                                                                                         identification of the hazardous waste.


CAP101-US-039 If the facility is a generator in the state of Wisconsin has it       SEB 101 Section                                          State /    WI                      NR 610.08 (1)(g)     CAP101-US-0016   Waste            Waste Tank         Reporting          In Wisconsin, generators must submit an annual activity report summarizing hazardous waste generation and disposal to the Wisconsin DNR by                  Review facility files for a copy of the
              completed and submitted an annual hazardous waste activity            5.2.26                                                   Province                           & NR 615.11                                            Container                             March 1 for the previous year’s activity. The form is available from and will be distributed by the Wisconsin DNR. Note that Wisconsin charges fees         annual reports with evidence that it
              report to the agency? Has the facility submitted a copy of the                                                                                                                                                           Management                            based on the amount of waste reported. NR 685.09(2)(b).                                                                                                     was submitted to the agency by March
              report to SE&E?                                                                          x                                                                                                                                                                                                                                                                                                                                 1(eg. Certified mail receipt) and a copy
                                                                                                                                                                                                                                                                                                                                                                                                                                         was submitted to SE&E.


CAP101-CAN-      Has the facility registered with the Ministry of the Environment   SEB 101 Section                                          State /    ON                      R.R.O. 1990, Reg.                     Waste            Waste Tank         Reporting          All generators of Subject Waste in Ontario are required to register annually with the MOE as a waste generator by submitting an annual Generator            Review the on line HWIN system with
040              (MOE) before February 15 of each year?                             5.3.2                                                    Province                           347 18 (1)(a)(b)                                       Container                             Registration Report before February 15th of each year. Generator Registration and manifesting can be done online through the Hazardous Waste                the designated administrator at the
                                                                                                              x                                                                                                                        Management                            Information Network (HWIN) located on the MOE’s website at: http//www.hwin.ca.                                                                              facility. Review the date the
                                                                                                                                                                                                                                                                                                                                                                                                                                         registration process was completed.


CAP101-CAN-      Has the facility transferred any Subject Waste off site without the SEB 101 Section                                         State /    ON                      R.R.O. 1990, Reg.                     Waste            Waste Tank         Reporting          Subject Waste cannot be transferred by the facility until the annual Generator Registration Document has been posted along with the specific                Review the on line HWIN system with
041              Generator Registration Document and the specific information on 5.3.2                                                       Province                           347 18 (7.1)                                           Container                             information for the Subject Waste being transferred.                                                                                                        the designated administrator at the
                 the Subject Waste being posted on HWIN (Hazardous Waste                                      x                                                                                                                        Management                                                                                                                                                                                        facility. Review all subject waste
                 Information Network)?                                                                                                                                                                                                                                                                                                                                                                                                   which has been registered.
CAP101-CAN-      Have any changes occurred at the facility that would require a     SEB 101 Section                                          State /    ON                      R.R.O. 1990, Reg.                     Waste            Waste Tank         Reporting          The facility HWIN Administrator must advise the MOE through HWIN of any of the following changes:                                                           Check when the last notification was
042              supplementary report to the MOE?                                   5.3.2.1                                                  Province                           347 18 (6)                                             Container                             Generator's name, address, or telephone number; or                                                                                                          made. Has there been any changes in
                                                                                                                                                                                                                                       Management                            If the facility moves to another location; or                                                                                                               the facility that would require a new
                                                                                                                                                                                                                                                                             If the facility HWIN Administrator (i.e. contact) changes; or                                                                                               notification (list any changes)
                                                                                                                                                                                                                                                                             If ownership of the facility changes; or
                                                                                                              x                                                                                                                                                              If an additional owner has been added or replaced since the facility's initial notification; or
                                                                                                                                                                                                                                                                             If the facility generates a new waste or waste changes (i.e. significant change to physical or chemical characteristics) from that originally declared or
                                                                                                                                                                                                                                                                             described in a supplementary report..
                                                                                                                                                                                                                                                                             The supplementary report must be submitted to the MOE Director within fifteen days after the change at the facility




                                                                                                                                                                                                                                                3 of 20                                                                                                                                                                                                             July 2006
              CAP101                                                                                                                                                                                                  Audit Protocol Questions / Checklist
              Revision Number: 4

                                                                                                           Country




                                                                                                                                                      State / Province
                                                                                                                              Venezuela
                                                                                                            Canada
                                                                                                                     Mexico
                                                                                                                                                                            Citation                              Media       Subcategory         Type of Req.                                                                                                                                                                            Evidence
                                                                                    SEB No. &                                              Agency                                              Related                                                                                                                         Requirement Description




                                                                                                    U.S.
  Number                Audit Protocol Question / Checklist                                                                                                               (sets ECAR                            (In ECAR       (In ECAR            (In ECAR                                                                                                                                                                         (Documents for auditor to              Comments
                                                                                     Section                                              Category                                           Requirements                                                                                                                (either SEB or federal/state citation)
                                                                                                                                                                            Priority)                           Database)      Database)           Database)                                                                                                                                                                                verify)


CAP101-CAN-    Is the facility managing Hazardous Waste Accumulation Stations     SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria Hazardous Waste Accumulation Stations are locations at or near the point of waste generation where collection and accumulation of waste can                   Review all Hazardous Waste
043            per the DCC corporate environmental requirements?                  5.3.3.1                                                                                                                                    Container                              begin. It is a DCC environmental requirement that a generator may accumulate up to 55 gallons (208 litres) of each hazardous waste (i.e Subject               Accumulation Stations, containers
                                                                                                                                                                                                                             Management                             Waste), or one quart (1 litre) of acutely hazardous waste, in containers at or near any point of generation. The container for each must be under the         within these areas, as well as
                                                                                                           x                                                                                                                                                        control of the operator of the process generating the waste. Once the drum or container is full it must be moved to the designated 90-day hazardous           inspection logs.
                                                                                                                                                                                                                                                                    waste accumulation area within three days. In addition, the container management standards detailed must be followed.


CAP101-CAN-    Is the facility managing 90-day Hazardous Waste Accumulation       SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria 90-day accumulation areas are locations where DCC generators may collect or accumulate hazardous waste (i.e Subject Waste) on site prior to off Review the 90-day Hazardous Waste
044            Areas per the DCC corporate environmental requirements?            5.3.3.2                                                                                                                                    Container                              site shipment. DCC 90-day accumulation areas are designated with “Hazardous Waste Station” signs. Access to 90-day accumulation areas must be Accumulation Areas, containers within
                                                                                                           x                                                                                                                 Management                             limited or controlled. In addition, the container management standards detailed must be followed.                                               these areas, as well as inspection
                                                                                                                                                                                                                                                                                                                                                                                                                    logs.
CAP101-CAN-    Is the facility accumulating waste within the required             SEB 101 Section                                         State /    ON                  R.R.O. 1990, Reg.                  Waste            Waste Tank          Reporting          Regulatory requirements state that a generator who retains hazardous waste (i.e. Subject Waste) for more than three months must submit a report to            Review all containers within the
045            accumulation time limits? If waste is stored more than 90 days     5.3.3.2                                                 Province                       347 18 (10)                                         Container                              the Regional Director of the MOE within five business days after the three month period. The report shall include the name and waste number of the            Hazardous Waste Accumulation
               has the facility submitted a Notification Report to the MOE?                                                                                                                                                  Management                             waste, the quantity of waste, the manner in which it is stored, the reasons for the retention and the anticipated time and manner of disposal of the          Stations and 90-day Hazardous Waste
                                                                                                                                                                                                                                                                    waste (O. Reg. 347, s. 18 (10)).                                                                                                                              Accumulation area and their labels.
                                                                                                           x                                                                                                                                                                                                                                                                                                                      Review of the manifest log,
                                                                                                                                                                                                                                                                                                                                                                                                                                  WasteTRACK shipping records.
                                                                                                                                                                                                                                                                                                                                                                                                                                  Request a copy of any notification
                                                                                                                                                                                                                                                                                                                                                                                                                                  reports submitted to the MOE.

CAP101-CAN-    Is the facility compling with the DCC corporate environmental      SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria Containers must be marked “Hazardous Waste” using SE&E required labels. Once a container is placed in the Waste Accumulation Station or Area,                 Review the 90-day Hazardous Waste
046            container management standards for both hazardous waste            5.3.4                                                                                                                                      Container                              it must be marked with the accumulation start date. Containers must be in good condition and not leaking. Containers must be compatible with the              Accumulation Areas and Hazardous
               accumulation stations and 90-day accumulation areas?                                                                                                                                                          Management                             materials collected in them. All containers must be kept closed except when waste is added or removed. Spill containment must be provided and                 Waste Accumulation stations,
                                                                                                           x                                                                                                                                                        maintained for containers of liquid hazardous waste per the requirements of DCC ETI-501. It is a DCC environmental requirement to inspect                     containers within these areas, as well
                                                                                                                                                                                                                                                                    containers every 7 days. Containers must be inspected for leaks and/or deterioration, and appropriate action taken if a problem is found. These               as inspection logs.
                                                                                                                                                                                                                                                                    inspections must be documented.
CAP101-CAN-    Is the facility complying with the DCC environmental container     SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria Fire and spill control equipment must be functional and available. Episode plans developed in accordance with SEB 601 must also be implemented,               Review the 90-day Hazardous Waste
047            management standards for both hazardous waste accumulation         5.3.4                                                                                                                                      Container                              maintained, and accessible to deal with emergencies and contingencies in the event of spill or fire associated with hazardous waste. Incompatible             Accumulation Areas and Hazardous
               stations and 90-day accumulation areas?                                                                                                                                                                       Management                             wastes must be segregated in the accumulation area according to waste type and characteristics. Adequate aisle space must be maintained.                      Waste Accumulation stations,
                                                                                                           x                                                                                                                                                        Containers holding ignitable or reactive wastes must be located at least 50 feet from the property line. A container must be labeled with the                 containers within these areas, as well
                                                                                                                                                                                                                                                                    applicable Transportation of Dangerous Goods Act (TDGA) label that is to be used for transporting the waste prior to off site shipment. Examples of           as inspection logs.
                                                                                                                                                                                                                                                                    transportation labels include labels for flammable, corrosive, reactive, biohazards and toxic substances.


CAP101-CAN-    Is the facility complying with the DCC environmental container     SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria As soon as a container begins accepting hazardous waste, it must be marked with the SE&E approved label. All of the information on the label                  Review the 90-day Hazardous Waste
048            marking requirements?                                              5.3.4.1                                                                                                                                    Container                              should be completed as soon as the container begins accepting waste except for the accumulation end dates. The start date should be completed                 Accumulation Areas and Hazardous
                                                                                                           x                                                                                                                 Management                             as soon as the waste container begins accepting waste, and the end date is completed once the container becomes full. Once the container is                   Waste Accumulation stations,
                                                                                                                                                                                                                                                                    moved to the main waste accumulation area it must be shipped off site for disposal within 90 days from the end date.                                          containers within these areas, as well
                                                                                                                                                                                                                                                                                                                                                                                                                                  as inspection logs.
CAP101-CAN-    Is the facility using and managing hazardous waste tanks per the SEB 101 Section                                           DCC        ON                  N/A                                Waste            Waste Tank          Operating Criteria Tanks must be identified as containing hazardous waste. Signs, labels, or painted stencils with the words “Hazardous Waste” can be used to identify Review all hazardous waste tank
049            regulatory and DCC environmental requirements?                   5.3.6                                                                                                                                        Container                              tank contents. Tanks must be corrosion-resistant and compatible with the waste they contain. Tanks and ancillary equipment must be equipped with systems, as well as inspection logs.
                                                                                                                                                                                                                             Management                             secondary containment that meets the requirements outlined in DCC ETI-501. Tanks must be equipped with spill prevention controls such as check
                                                                                                                                                                                                                                                                    valves. Tank systems must be equipped with overfill prevention controls such as level sensing devices and high-level alarms. Tanks must be
                                                                                                                                                                                                                                                                    equipped with leak detection systems. Tank systems must be inspected daily. Tanks containing hazardous wastes with VOC emissions must be kept
                                                                                                                                                                                                                                                                    closed at all times, except when removing or adding waste. All facility operators must examine provincial and local regulations for any additional
                                                                                                           x                                                                                                                                                        requirements governing hazardous waste tank systems. All facilities must inspect the tank system components daily. Inspections must be
                                                                                                                                                                                                                                                                    documented in writing. The inspector must report any problems to facility environmental staff and ensure these problems are corrected immediately.
                                                                                                                                                                                                                                                                    All facilities must integrate the appropriate
                                                                                                                                                                                                                                                                    hazardous waste release/spill mitigation measures into their Episode Plan. The Episode Plan must be amended whenever there is a
                                                                                                                                                                                                                                                                    change in hazardous waste tank systems that affect the likelihood of a release (i.e., tank installation or removal).



CAP101-CAN-    Does the facility use approved hazardous waste signage?            SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Labeling      Operating Criteria It is a DCC environmental requirement that all facilities use signage available through the on-line IRIS or NPICS systems. Corporate standard signs           Review signage.
050                                                                               5.3.7                    x                                                                                                                                                        have been designed for hazardous waste satellite stations, hazardous waste accumulation areas, non-hazardous waste accumulation, recycling,
                                                                                                                                                                                                                                                                    PCB storage and other applications.
CAP101-CAN-    Have all employees that handle or manage waste been trained        SEB 101 Section                                         DCC        ON                  N/A                 SEB 105        Waste            Waste Management Training              Employees are required to participate in an annual review of the initial training. Documentation of this training must be maintained at the facility. It is   Review training records.
051            within the last 365 days?                                          5.3.9                    x                                                                                                                 Training                               a DCC environmental requirement that employees be trained every 365 days.

CAP101-CAN-    Does the facility use approved disposal sites?                     SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste               Operating Criteria All DCC facilities must only use hazardous waste (i.e. Subject Waste) TSD&R facilities that have been pre-approved by SE&E.                                   Review Manifests.
052                                                                               5.3.8                                                                                                                                      Shipping/Manifestin
                                                                                                           x                                                                                                                 g & Transportation

CAP101-CAN-    Has the facility performed inspections weekly at 90 day            SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Inspection         Inspections must be documented in an inspection logbook or other record, including records of the area inspected, the date and time of the                    Review all inspection records.
053            accumulation areas (every 7 days), daily for the tank system and   5.3.10                                                                                                                                     Container                              inspection, the inspector’s name, conditions and recommendations and the date and type of corrective actions.
               monthly (every 30 days) at waste accumulation stations?                                     x                                                                                                                 Management
                                                                                                                                                                                                                                                                    Inspections should ensure that the requirements as outlined in Sections 5.3.4, 5.3.5, 5.3.6, 5.3.7 and 5.2.8 are being maintained.


CAP101-CAN-    Is the plant keeping records such as :reports, test results,       SEB 101 Section                                         DCC        ON                  N/A                                Waste            Waste Tank          Record Keeping     Reports, test results, manifests and waste analyses/determinations must be maintained on-site for certain periods of time in the case of any                  Review record retention timeframes
054            manifests and waste analyses/determinations on-site per the        5.3.11                   x                                                                                                                 Container                              enforcement action or request from MOE. DCC record retention requirements meet or exceed these requirements and are specified in the record                   and have plant point to record
               DCC record retention requirements ?                                                                                                                                                                           Management                             retention database.                                                                                                                                           retention database.
CAP101-MEX-    Does the facility keep a daily storage log for hazardous waste?    SEB 101 Section                                         Federal    MEX                 NOM-052                            Waste            Waste Tank          Reporting          Hazardous waste generators are required to keep a daily storage log.                                                                                          Review all daily storage logs kept in
055                                                                               5.4.2                              x                                                                                                       Container                                                                                                                                                                                            the plant file.
                                                                                                                                                                                                                             Management
CAP101-MEX-    Has the facility submitted a biannual report to SEMARNAT on        SEB 101 Section                                         Federal    MEX                 NOM-052                            Waste            Waste Tank          Reporting          Hazardous waste generators are required to submit a biannual report to SEMARNAT on where the used oil has been sent to recycling or final                     Review the biannual report submitted
056            where the used oil has been sent to recycling or final disposal?   5.4.2                                                                                                                                      Container                              disposal.                                                                                                                                                     to SEMARNAT.
                                                                                                                     x                                                                                                       Management




                                                                                                                                                                                                                                       4 of 20                                                                                                                                                                                                               July 2006
              CAP101                                                                                                                                                                                              Audit Protocol Questions / Checklist
              Revision Number: 4

                                                                                                            Country




                                                                                                                                                       State / Province
                                                                                                                               Venezuela
                                                                                                             Canada
                                                                                                                      Mexico
                                                                                                                                                                             Citation                         Media       Subcategory     Type of Req.                                                                                                                                                                          Evidence
                                                                                     SEB No. &                                              Agency                                         Related                                                                                                                     Requirement Description




                                                                                                     U.S.
  Number                Audit Protocol Question / Checklist                                                                                                                (sets ECAR                       (In ECAR       (In ECAR        (In ECAR                                                                                                                                                                       (Documents for auditor to           Comments
                                                                                      Section                                              Category                                      Requirements                                                                                                            (either SEB or federal/state citation)
                                                                                                                                                                             Priority)                      Database)      Database)       Database)                                                                                                                                                                              verify)


CAP101-MEX-    Are all hazardous waste containers stored in appropriate areas?     SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria Hazardous waste must be stored in areas that must be kept separate from offices, raw material storage (even if hazardous materials are stored              Review hazardous storage areas at
057                                                                                5.4.3                              x                                                                                                  Container                           therein) production and finished product areas                                                                                                             the facility.
                                                                                                                                                                                                                         Management
CAP101-MEX-    Do all hazardous waste storage areas meet the requirements in       SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria Hazardous waste storage areas must have the following features: a containment wall and retention ditch capable of holding the waste and its               Review hazardous storage areas at
058            the bulletin?                                                       5.4.3                                                                                                                                 Container                           leachate; trenches or channels on the floor so that the waste or its leachate may flow to the retention ditch. Trenches or ditches must be capable of     the facility.
                                                                                                                                                                                                                         Management                          holding up to one fifth of what is stored; passageways sufficiently wide, allowing forklifts and safety personnel or firemen to enter the storage area in
                                                                                                                      x                                                                                                                                      case of an emergency; fire fighting equipment such as extinguishers. In the case of fire hydrants, these must be kept at a 6kg/cm² pressure during
                                                                                                                                                                                                                                                             15 minutes; signs describing the waste being stored; natural or forced ventilation and explosion-proof lighting (in the case of enclosed storage
                                                                                                                                                                                                                                                             areas); lighting rods, and hazardous gas or vapor detectors with an audible and visible alarm system.


CAP101-MEX-    Is the facility compling with container management standards for    SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria ###################################################################################################################### Review hazardous storage areas at
069            all hazardous waste storage areas?                                  5.4.4                                                                                                                                 Container                                                                                                                                                  the facility.
                                                                                                                                                                                                                         Management

                                                                                                                      x




CAP101-MEX-    Is the facility compling with container management standards for    SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria Generators must comply with the following container management standards: containers of hazardous waste must always be closed except when it Review hazardous storage areas at
060            all hazardous waste storage areas?                                  5.4.4                                                                                                                                 Container                           is necessary to add or remove waste from the container. The lid or cover of a container must be securely attached. Drums that previously contained the facility.
                                                                                                                                                                                                                         Management                          hazardous waste should not be used for collecting used oil or other non hazardous waste unless all of the hazardous waste has been removed and
                                                                                                                                                                                                                                                             the drum has been decontaminated. Only containers that are known to be compatible with a waste should be selected for use with wastes.
                                                                                                                      x                                                                                                                                      Containers are compatible if they are made of or lined with materials that will not react with the hazardous waste that will be contained in that
                                                                                                                                                                                                                                                             container either by the physical or chemical characteristics of that waste. Segregate hazardous and nonhazardous wastes to prevent accidental
                                                                                                                                                                                                                                                             mixing. Segregate hazardous wastes that are incompatible.


CAP101-MEX-    Are all hazardous waste labels on containers completely filled      SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria A completed hazardous waste label has the following information: correct Waste Transportation Regulation shipping name and the UN or NA            Review hazardous storage areas at
061            out?                                                                5.4.4                                                                                                                                 Container                           number; manifest number; official facility name; facility address; generator Registration Number for the facility; SEMARNAT Waste Code;            the facility. Review all labels on
                                                                                                                      x                                                                                                  Management                          accumulation start date and the date the container became full; hazardous waste generators are required to package, label, and mark the waste in   containers.
                                                                                                                                                                                                                                                             accordance with applicable Waste Transportation Regulation requirements; a transportation label may be required in addition to the hazardous waste
                                                                                                                                                                                                                                                             label
CAP101-MEX-    Are all hazardous wastes separated by their physical states         SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Design             Wastes must be stored in locations that are compatible with both the waste characteristics and the container. Ignitable wastes should not be placed        Review hazardous storage areas at
062            (hazardous characteristics and compatibility)?                      5.4.4.1                                                                                                                               Container                           next to combustible materials. Containers holding hazardous waste that may be incompatible with other waste/waste containers must be separated             the facility.
                                                                                                                      x                                                                                                  Management                          by a dike, berm, wall, or other device. Containers holding ignitable or reactive waste must be located at least 15 meters or 50 feet from the facility’s
                                                                                                                                                                                                                                                             property line or from another building.
CAP101-MEX-    Has the facility received a signed copy of the Manifest from from   SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Reporting          If the facility has not received the signed copy of the manifest from the TSDF within 30 days of waste shipment an exception report must be filed with Review the manifest logs at the
063            the TSDF within 30 days of shipping for all waste shipments?        5.4.5                              x                                                                                                  Container                           the agency.                                                                                                                                            facility.
                                                                                                                                                                                                                         Management
CAP101-MEX-    Are tanks used for hazardous waste storage properly marked?         SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Design             Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and                    Review all hazardous waste storage
064            Are they in good condition? Are they compatible with the waste      5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC             tanks at the facility.
               they contain?                                                                                          x                                                                                                  Management                          environmental requirements governing hazardous waste tank systems: Tanks must be identified as containing hazardous waste with the words
                                                                                                                                                                                                                                                             “Hazardous Waste”; Wastes must not be placed in a tank if they could cause rupture, leakage, corrosion, or tank failure; Tanks must be corrosion-
                                                                                                                                                                                                                                                             resistant and compatible with the waste they contain;
CAP101-MEX-    Are tanks used for hazardous waste storage designed to meet         SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Design             Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and                    Review all hazardous waste storage
065            the secondary containment requirements of ETI 501? Are the          5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC             tanks at the facility.
               tanks equipped with spill and overfill prevention controls and leak                                                                                                                                       Management                          environmental requirements governing hazardous waste tank systems: Tanks and ancillary equipment must be equipped with secondary
               detection systems?                                                                                     x                                                                                                                                      containment that meets the requirements outlined in DCC ETI-501; Tanks must be equipped with spill prevention controls such as check valves;
                                                                                                                                                                                                                                                             Tank systems must be equipped with overfill prevention controls such as level sensing devices and high-level alarms; Tanks must be equipped with
                                                                                                                                                                                                                                                             leak detection systems;
CAP101-MEX-    Are tanks used for hazardous waste storage kept closed at all       SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and             Review all hazardous waste storage
066            times except to add or remove wastes?                               5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC tanks at the facility.
                                                                                                                      x                                                                                                  Management                          environmental requirements governing hazardous waste tank systems: Tanks containing hazardous wastes with VOC emissions must be kept closed
                                                                                                                                                                                                                                                             at all times, except when removing or adding waste; All facility operators must examine state and local regulations for any additional requirements
                                                                                                                                                                                                                                                             governing hazardous waste tank systems;
CAP101-MEX-    Are tanks used for hazardous waste storage kept closed at all       SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Operating Criteria Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and                    Review all hazardous waste storage
067            times except to add or remove wastes?                               5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC             tanks at the facility.
                                                                                                                                                                                                                         Management                          environmental requirements governing hazardous waste tank systems: SE&E must be consulted prior to any new tank system installation. When
                                                                                                                      x                                                                                                                                      installing new tanks, an assessment must be performed to determine that the integrity and installation of the tank are acceptable for storage of
                                                                                                                                                                                                                                                             hazardous waste. A file containing the written integrity assessment, design and installation certifications must be maintained at the facility, with
                                                                                                                                                                                                                                                             copies sent to SE&E; Existing tanks must be retrofitted with secondary containment systems.


CAP101-MEX-    Are hazardous waste tanks addressed in the facilities episode       SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Reporting          Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and                    Review the facility episode plan to
068            plan?                                                               5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC             ensure all hazardous waste storage
                                                                                                                      x                                                                                                  Management                          environmental requirements governing hazardous waste tank systems: All facilities must integrate the appropriate hazardous waste release/spill             tanks are included.
                                                                                                                                                                                                                                                             mitigation measures into their Episode Plan. The Episode Plan must be amended whenever there is a change in hazardous waste tank systems that
                                                                                                                                                                                                                                                             affect the likelihood of a release (i.e., tank installation or removal);
CAP101-MEX-    Are all hazardous waste tank systems inspected daily?               SEB 101 Section                                         Federal    MEX                 NOM-052                       Waste            Waste Tank       Inspection         Tank systems include the hazardous waste tank plus ancillary equipment (such as pumps, valves, and piping) associated with the tank and           Review all hazardous waste storage
069                                                                                5.4.6                                                                                                                                 Container                           containment system. Tank systems containing hazardous waste must satisfy the following in order to comply with regulatory requirements and DCC tank inspection logs.
                                                                                                                                                                                                                         Management                          environmental requirements governing hazardous waste tank systems: All facilities must inspect the tank system components daily. Inspections must
                                                                                                                      x                                                                                                                                      be documented in writing. The inspector must report any problems to facility environmental staff and ensure these problems are corrected
                                                                                                                                                                                                                                                             immediately;




                                                                                                                                                                                                                                5 of 20                                                                                                                                                                                                           July 2006
              CAP101                                                                                                                                                                                            Audit Protocol Questions / Checklist
              Revision Number: 4

                                                                                                          Country




                                                                                                                                                     State / Province
                                                                                                                             Venezuela
                                                                                                           Canada
                                                                                                                    Mexico
                                                                                                                                                                           Citation                         Media       Subcategory     Type of Req.                                                                                                           Evidence
                                                                                   SEB No. &                                              Agency                                         Related                                                                                                             Requirement Description




                                                                                                   U.S.
  Number                Audit Protocol Question / Checklist                                                                                                              (sets ECAR                       (In ECAR       (In ECAR        (In ECAR                                                                                                        (Documents for auditor to         Comments
                                                                                    Section                                              Category                                      Requirements                                                                                                    (either SEB or federal/state citation)
                                                                                                                                                                           Priority)                      Database)      Database)       Database)                                                                                                               verify)


CAP101-VEN-    Does the facility follow the requirements of Decree 2635 in the   SEB 101 Section                                         Federal    VEN                 Decree 2635                   Waste            Waste Tank       Inspection     Have the plant show the requirements of Decree 2635 and how they are in compliance with them.   Review compliance requirements
070            generation, handling, storage and activity?                       5.5.1                                       x                                                                                         Container
                                                                                                                                                                                                                       Management




                                                                                                                                                                                                                              6 of 20                                                                                                                                          July 2006
Country     Media
Canada      Air
Canada      Air
Canada      Air
Canada      Air
Canada      Air
Canada      Air
Canada      Construction\Deactivation\Remediaion
Canada      Emergency Preparedness & Response
Canada      Emergency Preparedness & Response
Canada      Emergency Preparedness & Response
Canada      Emergency Preparedness & Response
Canada      Emergency Preparedness & Response
Canada      EPCRA_NPRI
Canada      EPCRA_NPRI
Canada      EPCRA_NPRI
Canada      NPM Standards
Canada      NPM Standards
Canada      Pollution Prevention
Canada      Pollution Prevention
Canada      Pollution Prevention
Canada      Pollution Prevention
Canada      Storage Tanks
Canada      Storage Tanks
Canada      Storage Tanks
Canada      Storage Tanks
Canada      Storage Tanks
Canada      Storage Tanks
Canada      TSCA
Canada      TSCA
Canada      TSCA
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Waste
Canada      Water
Canada      Water
Canada      Water
Canada      Water
Canada      Water
Canada      Water
Canada      Water
Canada      Water


CAP 101 Rev. 4 July 2006                           7
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Air
Mexico      Construction\Deactivation\Remediaion
Mexico      Emergency Preparedness & Response
Mexico      Emergency Preparedness & Response
Mexico      Emergency Preparedness & Response
Mexico      Emergency Preparedness & Response
Mexico      NPM Standards
Mexico      NPM Standards
Mexico      Pollution Prevention
Mexico      Pollution Prevention
Mexico      Pollution Prevention
Mexico      Storage Tanks
Mexico      Storage Tanks
Mexico      Storage Tanks
Mexico      TSCA
Mexico      TSCA
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Waste
Mexico      Water
Mexico      Water
Mexico      Water
Mexico      Water
Mexico      Water
Mexico      Water
Mexico      Water
Mexico      Water
USA         Air
USA         Air
USA         Air
USA         Air
USA         Air
USA         Air


CAP 101 Rev. 4 July 2006                           8
USA         Air
USA         CERCLA
USA         Construction\Deactivation\Remediaion
USA         Emergency Preparedness & Response
USA         Emergency Preparedness & Response
USA         Emergency Preparedness & Response
USA         Emergency Preparedness & Response
USA         Emergency Preparedness & Response
USA         EPCRA _NPRI
USA         EPCRA _NPRI
USA         EPCRA _NPRI
USA         EPCRA _NPRI
USA         EPCRA _NPRI
USA         EPCRA _NPRI
USA         NPM Standards
USA         NPM Standards
USA         Pollution Prevention
USA         Pollution Prevention
USA         Pollution Prevention
USA         Storage Tanks
USA         Storage Tanks
USA         Storage Tanks
USA         Storage Tanks
USA         TSCA
USA         TSCA
USA         TSCA
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Waste
USA         Water
USA         Water
USA         Water
USA         Water
USA         Water
USA         Water
USA         Water




CAP 101 Rev. 4 July 2006                           9
Subcategory
Certificate of Approval
CFCs
Miscellaneous
ONT Environmental Protection Act
ONT Memo of Understanding
ONT Regulation #346 - General Air Pollution
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Incident Commander Training
Miscellaneous
Miscellaneous
National Pollutant Release Inventory
ONT Regulation #127/01: Airborne Contaminants Monitoring & Discharge Reporting
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
ONT Reduce/Reuse & Recycle Act
Pollution Prevention Plan
ASTs
Miscellaneous
ONT Gasoline Handling Act
ONT Liquid Fuels Handling Act
Tank Manuals
USTs
Asbestos
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
Liquid Industrial Waste (Used Oil)
Miscellaneous
Record Retention Requirements
Solid & Hazardous Waste Identification
Special Waste
Surplus Machinery
TSDF Program
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank/Container Management
IWTP Cost Report
Miscellaneous
Monthly Reports (WWTP)
Municipal Permits/By-laws
Municipal Wastewater Permit
ONT Municipal Industrial Strategy Abatement (MISA)
ONT Water Resources Act - Certificate of Approval
Surface Wastewater Permit


CAP 101 Rev. 4 July 2006                                                         10
Air Emission Inventory & Measurement (NOM 085#615)
Air Operating/Emission Permits
CFCs
Functional/Operational License
Incident Commander Training
Miscellaneous
Noise Compliance (NOM 081 ECOL)
Records of Coated Vehicles (NOM 121)
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Miscellaneous
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
Pollution Prevention Plan
ASTs
Miscellaneous
USTs
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
Miscellaneous
Record Retention Requirements
Registration & Operating License
Solid & Hazardous Waste Identification
Special Waste
Surplus Machinery
TSDF Program
Used Oil
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank Container Management
Waste (Six Month) Reporting
IWTP Cost Report
Miscellaneous
Monthly Reports (WWTP)
Municipal Wastewater Permit
Operations and Cost Data
Outfall Discharge Permits & Application
Outfall Parameters Measurement & Analysis
Surface Wastewater Permit
CFCs
Miscellaneous
NSPS
NSR Permits
State Regulations
Sythetic Minor/FESOP Permit


CAP 101 Rev. 4 July 2006                             11
Title V Permit
Miscellaneous
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Incident Commander Training
Miscellaneous
Miscellaneous
SARA 302 - Facility Registration
SARA 303 - Incident Notification
SARA 311 - Hazardous Material Notifications
SARA 312 - Hazardous Material Annual Report
SARA 313 - Toxic Chemical Release
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
Pollution Prevention Plan
ASTs
Miscellaneous
Tank Manuals
USTs
Asbestos
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
LDRs
Miscellaneous
RCRA BB/CC
Record Retention Requirements
Solid & Hazardous Waste Identification
Surplus Machinery
TSDF Program
Universal & Special Waste
Used Oil
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank/Container Management
IWTP Cost Report
Miscellaneous
Monthly Reports (Surface Water)
Monthly Reports (WWTP)
Municipal Wastewater Permit
Stormwater Pollution Prevention Plan
Surface Wastewater Permit




CAP 101 Rev. 4 July 2006                      12
                           Agency Category    Type of Requirement
                           Federal            Emission Limit
                           State / Province   Operating Criteria
                           Local Agency       Design
                           Facility Permit    Reporting
                           Coporate           Record Keeping
                                              Inspection
                                              Preventative Maintenance
                                              Training




CAP 101 Rev. 4 July 2006                                                 13
CAP 101 Rev. 4 July 2006   14
CAP 101 Rev. 4 July 2006   15
CAP 101 Rev. 4 July 2006   16
CAP 101 Rev. 4 July 2006   17
CAP 101 Rev. 4 July 2006   18
Subcategory
Air Emission Inventory & Measurement (NOM 085#615)
Air Operating/Emission Permits
Asbestos
ASTs
Certificate of Approval
CFCs
Containment
Emergency Equipment
Episode Plan
ETI - 103
ETI - 104
Functional/Operational License
Incident Commander Training
Infectious Waste
IWTP Cost Report
LDRs
Liquid Industrial Waste (Used Oil)
Miscellaneous
Monthly Reports (Surface Water)
Monthly Reports (WWTP)
Municipal Permits/By-laws
Municipal Wastewater Permit
National Pollutant Release Inventory
Noise Compliance (NOM 081 ECOL)
NSPS
NSR Permits
ONT Environmental Protection Act
ONT Gasoline Handling Act
ONT Liquid Fuels Handling Act
ONT Memo of Understanding
ONT Municipal Industrial Strategy Abatement (MISA)
ONT Reduce/Reuse & Recycle Act
ONT Regulation #127/01: Airborne Contaminants Monitoring & Discharge Reporting
ONT Regulation #346 - General Air Pollution
ONT Water Resources Act - Certificate of Approval
Operations and Cost Data
Outfall Discharge Permits & Application
Outfall Parameters Measurement & Analysis
PCB Recordkeeping/Documentation
PCBs
Pollution Prevention Plan
RCRA BB/CC
Record Retention Requirements
Records of Coated Vehicles (NOM 121)
Registration & Operating License
SARA 302 - Facility Registration
SARA 303 - Incident Notification
SARA 311 - Hazardous Material Notifications
SARA 312 - Hazardous Material Annual Report
SARA 313 - Toxic Chemical Release
Solid & Hazardous Waste Identification


CAP 101 Rev. 4 July 2006                                                         19
Special Waste
State Regulations
Stormwater Pollution Prevention Plan
Surface Wastewater Permit
Surplus Machinery
Sythetic Minor/FESOP Permit
Tank Manuals
Title V Permit
TSDF Program
Universal & Special Waste
Used Oil
USTs
Waste (Six Month) Reporting
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank Container Management




CAP 101 Rev. 4 July 2006                      20

				
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