Top Non-Compliance Issues Noted During Multimedia Environmental Compliance Audits
- Satellite Accumulation Areas are not properly identified and maintained (e.g. no appropriate signage, secondary containment, labels, waste determinations made, or proper training provided).
- Hazardous Waste labels do not identify the hazardous constituents contained therein (e.g., Methanol, toluene, acetone) and the hazards posed (e.g., corrosive, ignitable, toxic and/or reactive).
- No documentation of formal waste determination for regularly generated hazardous waste streams.
- Failure to provide adequate secondary containment for all bulk oil storage containers with a capacity of 55-gallons or greater.
- Drain disposal of chemicals. (e.g., solvents, laboratory chemicals).
- Failure to keep hazardous waste containers closed at all times unless adding or removing wastes (e.g., open funnel in waste container).
- Failure to prevent the potential pollution of stormwater runoff from various operations (e.g., vehicle washing, materials storage, construction activities).
- Spent mercury containing fluorescent lamps not stored in closed boxes labeled with the words “UNIVERSAL WASTE – MERCURY CONTAINING LAMPS.
- Improper operation of the solvent cleaning process (e.g., the lid on a degreasing station is left open when not in use, a summary of operating procedures are not posted on or near the station, and/or records of solvent consumption are not being maintained).
- Failure to comply with training, inspection, reporting and record keeping requirements for one or more of the following:
- Clean Air Act (e.g., failure to apply for a permit/license or include all sources on the permit)
- Clean Water Act (e.g., failure to prepare a Stormwater Pollution Prevention Plan)
- Emergency Planning Community Right-to-Know (e.g., failure to report all chemicals stored in quantities above the threshold planning quantity)
- Oil Spill Control and Countermeasure (e.g., failure to implement a plan, conduct necessary training, inspections, and maintain records)
- Resource Conservation Recovery Act (e.g., failure to clarify generator status, provide adequate training, document inspections, or maintain all required manifest, exception reports, and LDR records).