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2015 Analytical Services Program Workshop 2015 Analytical Services Program Workshop

2015 Analytical Services Program Workshop - PowerPoint Presentation

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2015 Analytical Services Program Workshop - PPT Presentation

Charleston South Carolina Thursday Afternoon September 17 2015 TSDF Checklist Changes Ms Susan Aderholdt TSDF Lead and Corrective Actions Coordinator DOECAP Operations Team Pro2Serve Oak Ridge Tennessee ID: 680907

1910 cfr 264 facility cfr 1910 facility 264 checklist waste 761 reference requirements program pcb reworded changed permit safety reflect compliance storage

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Slide1

2015 Analytical Services Program WorkshopCharleston, South CarolinaThursday Afternoon, September 17, 2015

TSDF Checklist ChangesMs. Susan AderholdtTSDF Lead and Corrective Actions Coordinator, DOECAP Operations Team,Pro2Serve, Oak Ridge, Tennessee

9/14/2015

1Slide2

TSDF Checklist Changes

Susan AderholdtASP WorkshopSeptember 14-17, 20152Slide3

TSDF Checklists 4, 6, and 1 Changed

The only changes to the TSDF Checklists this year were cosmetic, except for:Checklist 4: Environmental Compliance and PermittingChecklist 6: Industrial and Chemical SafetyChecklist 1: Quality Assurance Management Systems

3Slide4

TSDF Checklist 4: Environmental Compliance and Permitting

4Slide5

Checklist 4

ItemNumber

Lines

of Inquiry

Status

Auditor

Response

/

Comments

1.0

Resource Conservation and Recovery Act

(

RCRA)

This checklist cites federal requirements for ease of use. Findings must reference applicable State or facility permit requirements.1.1General Facility Requirements Facility Reviewer_____________________________RCRA-based requirements may be found in state and federal regulations and in a facility-specific permit or other authorization. Appropriate citations must be provided for any findings.1.1.1Does the facility have an EPA identification number for operating a permitted treatment, storage or disposal facility?40 CFR 262.12and/or 40 CFR 264.11  1.1.2Are RCRA-permitted units maintained in compliance with the permit, including labeling, aisle spacing, inspections, monitoring, leak detection, reporting and recordkeeping, emergency planning and preparedness, training, and financial assurance?40 CFR 264.175  

5Slide6

Checklist 4

1.1.4

Does facility ship hazardous waste to other TSDFs? If so, does the facility have a documented program to ensure that the other TSDFs manage hazardous waste in compliance with appropriate RCRA regulations?

(If facility ships DOE wastes or byproduct of DOE waste treatment to another contractor then they are required to flow down the DOE QA requirements.)

DOE QA Requirements

 

 

1.1.5

What is the date of the most recent RCRA agency inspection and results?

 

 

1.2

Permitted Facility Compliance.

Is facility in compliance with requirements?  1.2.1Waste Analysis PlanDoes the facility have a Waste Analysis Plan (WAP)?40 CFR 264.13  6Slide7

Checklist 4

1.2.8

Reporting

Has the facility submitted all regulatory reports on time including:

40

CFR

264.7

Biennial report

(or annual if required by State)

;

Removed first bullet

Un-manifested waste report;

Releases, fires and explosion;

Specific reports5, 264.76, 264.77, RCRA Permit  1.3Unit-Specific RequirementsIs facility in compliance with requirements?  1.3.1ContainersDoes the facility have a container management program in place that ensures waste is stored in good condition, compatible with the waste container, and all containers are closed unless waste is being added or removed? Do waste storage areas have an adequate containment system? 40 CFR 264.174  7Slide8

Checklist 4

1.4

Permitted Incinerators/ Thermal Burners

 

 

1.4.1

Does the facility burn only wastes authorized in the permit and under operating conditions specific in permit?

40 CFR

264.340

(a) through 264.340 (c) and 264.341 through 264.344(a), 264.345 and 264.347, and as approved in permit.

 

 

1.4.2

Are adequate waste analyses performed to verify permitted waste feed amounts are within permit limits?40 CFR 264.340 (a) through 264.340 (c) and 264.341 through 264.344(a), 264.345 and 264.347, and as approved in permit.  1.4.3If EPA Hazardous Waste Number F020 through F023, F026, or F027 is incinerated, does the facility verify that DRE of 99.9999% is achieved and the regulatory agency is notified of the intent to burn? Otherwise verify DRE of four nines.40 CFR 264.340 (a) through 264.340 (c) and 264.341 through 264.344(a), 264.345 and 264.347, and as approved in permit.  8Slide9

Checklist 4

1.4.9

Describe the number and type of permit exceedances

in the past three years.

 

 

1.5

Corrective Actions Facility Reviewer

_____________________________________________

1.5.1

Is the facility operating under any Consent Orders or Agency agreements? If so, describe.

 

 

1.5.2Is the facility operating under any Corrective Actions for Solid Waste Management Units? If so, describe. 40 CFR 264.552  1.6Air Emissions1.6.1Is the facility regulated under Subpart AA, BB, CC, DD, or EE? If so, describe the compliance status of the program. 40 CFR 264.1030, 264.1050, 264.1080, 264.1100, 264.1200  9Slide10

Checklist 4

2.0

COORDINATE WITH EC

Toxic Substances Control Act (TSCA/

PCB

)

Facility Reviewer

_________________________

2.1

Does the facility accept, store and/or treat TSCA regulated material?

40 CFR 761.

65

 

 2.2Are TSCA permitted units maintained in compliance with TSCA approval or RCRA Permit requirements for including aisle spacing, inspections, labeling, and marking reporting and recordkeeping? 40 CFR 761.40, 761.65, RCRA Permit  2.3Is the facility in compliance with disposal requirements outlined in their TSCA approval? 40 CFR 761.60, RCRA Permit  2.4When shipping PCB Bulk Product Waste to an offsite facilities, does the Company provide appropriate notifications to receiving solid waste landfill facilities?40 CFR 761.62  

2.5

If the facility is using an independent transporter to transport PCB waste, is confirmation of receipt documented?

40 CFR 761.

208(4)

 

 

10Slide11

Checklist 4

2.6

Has all PCB waste been disposed

of within

one year

from the date it was determined to be PCB waste?

40 CFR 761.65(a)(1)

 

 

2.7

Does the PCB storage area meet the following

requirements

:

Adequate roof and wall to prevent rainwater from reaching the stored PCBs and PCB items;Adequate curbing to contain the greater of 2x the largest container or 25% of all containers. In addition, curbing must be 6” minimum for areas storing PCB items (but may be less than 6” for areas storing combined PCB/radioactive wastes).No drains or structures to permit flow of liquids from curbed areas,Floors and curbing are Portland cement or continuous smooth, non-porous surface andNot located on site within the 100-year floodplain.OR,• Is RCRA permitted or has interim status, or;• Has a TSCA Coordinated Approval, or;• Has a TSCA waste management approval?40 CFR 761.65(b)(1)(ii), 40 CFR 761.77, 40 CFR 761.61(c), 40 CFR 761.62(c).  11Slide12

Checklist 4

2.8

If PCB storage areas do not meet any of the above requirements, is the PCB waste being stored in a 30-day temporary storage area?

40 CFR 761.65(c) (1)

 

 

2.9

Does the facility haves a container management program in place that ensures waste is stored in good condition, compatible with the waste container, and all containers are closed unless waste is being added or removed?

Do the waste storage areas have an adequate containment system?

40 CFR 761.65, BMP

 

 

2.10

Are PCB items in storage dated with the date removed from service and managed such that PCB items can be located by this date? 40 CFR 761.65  2.11Are the landfills used to dispose of TSCA regulated wastes operating in compliance with regulatory requirements?40 CFR 761.75 (a)  2.12Does the facility have a process to address PCB Spill Cleanup which is compliant with regulatory requirements? Removed second question and the reference to it.40 CFR 761.125  

12Slide13

Checklist 4

2.13

Has the facility prepared the Annual Document Log and are the reports readil

y available for review?

40 CFR 761.180

 

 

2.14

Are records retained at least 20 years after the waste landfill is no longer used?

40 CFR 761.180

 

 

2.15Has the facility submitted any PCB manifest discrepancy reports to the Agency for DOE PCB waste?40 CFR 761.210  2.16Has the facility submitted any PCB un-manifested reports to the Agency for DOE PCB waste?40 CFR 761.211  2.17Does the facility submit Certificates of Disposal (CDs) back to the generator within 30 days of disposal?40 CFR 761.218  2.18Does the facility have a Risk Based Disposal Approval?

40 CFR 761.62 (c)

 

 

2.19

COORDINATE WITH EC

Facility Reviewer

_____________________________________

2.19.1

The facility has adequate liability insurance for both sudden and non-sudden liability coverage. Describe the General Liability limits and the company affording coverage.

40 CFR 264 Subpart H

 

 

13Slide14

TSDF Checklist 6: Industrial and Chemical Safety

14Slide15

Checklist 6

ItemNumber

Lines of Inquiry

Status

Auditor

Response

/ Comments

1.0

Occupational Safety

Facility Reviewer

______________________________________________

 

Facility has a documented Health & Safety program with necessary plans and SOPS in place and current

See Section 1.6 below  1.1Housekeeping1.2Floor and Wall Openings1.2.1Is every open-sided floor or platform 4 feet or more above adjacent floor or ground level guarded by a standard railing (or equivalent) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder? Does the railing have a toe board?29 CFR 1910.23(c)(1) 

 

Changed reference and reworded to more accurately reflect the reference

15Slide16

Checklist 6

1.2.2

Are stairways adequately illuminated and have stair treads that are slip resistant? Are any of the treads wearing down?

29 CFR 1926.56; 20

CFR 1910.24(f)

 

 

Changed reference

1.3

Means of Egress

1.3.1

Are all existing exit routes clearly marked and equipped with emergency lighting?

29 CFR 1910.37(b)(1)(2)

  1.3.2Are any exits obstructed and are all exits unlocked when employees are in the building? 29 CFR 1910.37(a)(3)  1.4 Medical and First Aid1.4.1Are adequate first-aid supplies readily available? 29 CFR 1910.151(b)

 

Reworded to more accurately reflect the reference

1.4.2

Are there facility personnel identified and adequately trained to render first aid in the absence of an infirmary, clinic, or hospital in near proximity to the workplace?

29 CFR 1910.151(b)

 

Reworded to more accurately reflect the reference

1.4.3

Are suitable facilities for quick drenching or flushing of the eyes or body provided for immediate emergency use in work areas where a person may be exposed to injurious corrosive material?

29 CFR 1910.151

(c)

 

Changed reference and reworded to more accurately reflect the reference

16Slide17

Checklist 6

1.5

Fire Protection

1.5.1

Fire extinguishers are conspicuously marked, properly mounted, and accessible.

29 CFR 1910.157(c)(l)

 

 

1.5.2

Fire extinguishers are inspected monthly, are fully charged and operable.

29 CFR 1910.157(e)(2) and Compressed Gas Association Pamphlet P-1, Rev 2000.

 

 

1.5.3Are “No Smoking” signs conspicuously posted were hazard from flammable liquid vapors are normally present? (Open flames and smoking shall not be permitted in flammable liquid storage area.). 29 CFR 1910.106 (d)(7)(iii) and (f)(6) Changed reference and reworded to more accurately reflect the reference1.5.4If fire extinguishers are available and intended for employee use, are personnel provided instructions for the proper use of fire extinguishers and applicability of when to use them?29 CFR 1910.157 (g) Changed reference17Slide18

Checklist 6

1.6

Facility Health and Safety Program

1.6.1

The facility has an occupational health and safety plan that addresses the following OSHA requirements:

Floor and Wall Openings (29 CFR 1910.23)

Means of Egress (29 CFR 1910.37)

Signage (29 CFR 1910.36)

Equipment Guarding (29 CFR 1910.212)

Electrical (29 CFR 1910.332)

Hand Tools and Portable Power tools (29 CFR 1910.242)

Ladder Safety (29 CFR 1910.26)

Fixed Ladder Safety (29 CFR 1910.27)

Hoisting and Lifting (29 CFR 1910.179)Compressed Gases (29 CFR 1910.101)Powered Industrial Truck (29 CFR 1910.178)Lockout/Tagout (29 CFR 1910.147(c)(1))Confined Space (29 CFR 1910.146(c))Hazwoper (29 CFR 1910.120(p)Other (list)  1.7Accident Prevention Signs and Tags1.7.1Are danger signs posted to warn of specific dangers and are caution signs posted to warn against potential hazards or to caution against unsafe practice, and do these signs conform in design with requirements? 29 CFR 1910.145(c) and (d)  Changed reference and reworded to more accurately reflect the reference18Slide19

Checklist 6

1.7.2

Are general safety instruction signs posted relative to safety measures?

29 CFR 1910.145(c)(3)

 

 

1.7.3

Are accident prevention signs and tags adequate?

29 CFR 1910.145

 

Changed reference and reworded to more accurately reflect the reference

1.8

Machine Guarding

1.8.1Are machine guards affixed to the applicable machines where possible and secured elsewhere if for any reason attachment to the machine is not possible? The guard shall be such that it does not offer an accident hazard in itself.29 CFR 1910.212(a)(2)  1.8.2Are point-of-operation guards in place on all operating equipment and are spinning parts guarded? 29 CFR 1910.212(a)(3)(ii)  1.8.3Are belts and pulleys less than 7 feet from the floor guarded? 29 CFR 1910.219(d) and (e) 

Changed reference

1.9

Material Handling and Storage

1.9.1

Is adequate clearance allowed in aisles where material must be moved?

29 CFR 1910.176(a)

 

 

19Slide20

Checklist 6

1.10

Hoisting and Lifting

1.10.1

Is equipment identified with load capacity and is legible from the ground or floor?

29 CFR 1910.179(b)(5)

 

 

1.10.2

Are trolley

limit stops working?

29 CFR 1910.179(e)(l)(

i

) Reworded to more accurately reflect the reference 1.11Compressed Gases1.11.1Are gases segregated, away from heat sources, stored upright and chained to prevent the container from falling? (Compressed gases should be segregated and stored to ensure co-located gases are of suitable compatibility.) Compressed Gas Association Pamphlet P-1, 1965 Changed reference 1.11.2Are compressed gas cylinder valve covers in place when cylinders are not in use? 29 CFR 1910.101and Compressed Gas Association Pamphlet P-1, 1965 Changed reference and reworded to more accurately reflect the reference

1.11.3

Are cylinder storage areas prominently posted with the names of the gases to be stored?

Compressed Gas Association Pamphlet P-1, 1965

 

This is a new LOI

20Slide21

Checklist 6

1.12

Lockout/Tagout

Systems

1.12.1

Are only authorized personnel

who are performing the servicing or maintenance allowed to perform lockout/

tagout

?

29 CFR 1910.147(c)(8)

 

Changed reference and reworded to more accurately reflect the reference

1.12.2

Have procedures been developed, documented and utilized for the control of potentially hazardous energy?29 CFR 1910.147(c)(4) Reworded to better define requirement.1.12.3Are tagout devices, where used, affixed in such a manner as will clearly indicate that the operation or movement of energy isolating devices from the “safe” or “off” position is prohibited? Are the tagout devices fastened at the same point at which the lock would have been attached?29 CFR 1910.147(d)(4) (ii) and (iii) Reworded to better define requirement1.12.4If there is a possibility of reaccumulation of stored energy to a hazardous level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility of such accumulation no longer exists. 29 CFR 1910.147(d)(5)(ii) Reworded to better define requirement.1.13

Confined Space Entry

1.13.1

Are confined spaces (both permit and non-permit) clearly identified by posting?

29 CFR 1910.146(c)(2)

 

Reworded to better define requirement.

21Slide22

Checklist 6

2.0

Industrial Hygiene

Facility Reviewer

___________________________________________________

2.1

Hazard Communication

2.1.1

There is evidence of effective implementation of a Hazard Communication Program:

Written hazard communication program, (e)

Hazard Classification, (d)

Container labeling and other forms of warning program, (f)

Accessible Safety Data Sheets (g)

Hazardous material listing (e)(1)(i)Training (h)29 CFR 1910.1200 Reworded to better define requirement.2.2Exposure Monitoring2.2.1The facility has a monitoring program to determine employee exposure to chemicals. Monitoring is performed for those chemicals that have a potential for exceedance of an OSHA Permissible exposure level?29 CFR 1910.1000  

2.2.2

Employees are notified of exposure monitoring results in accordance with OSHA requirements.

29 CFR 1910.1000

 

 

22Slide23

Checklist 6

2.3

Personal Protective Equipment

2.3.1

Appropriate required equipment is identified, readily available, maintained, and used properly?

29 CFR 1910.132

 

 

2.3.2

All equipment meets specific requirements and is reliable?

29 CFR 1910.132(a)

 

 

2.3.3SOPs governing the selection and use of respirators are in place and current? 29 CFR 1910.132(d) and (f), 29 CFR 1910.134(a) and (c)  2.3.4Are personnel are required to wear personal protective equipment and trained in the use? Is PPE is appropriate for tasks being performed?29 CFR 1910.132 Reworded to better define requirement.2.3.5Has a Hazard Assessment been prepared for tasks requiring PPE?29 CFR 1910.132(d) 

2.3.5 LOI deleted and numbering changed to reflect correct sequence

2.4

Respiratory Protection

2.4.1

Is written program in place to administer all aspects of the program?

29 CFR 1910.134(c)

 

 

2.4.2

Personnel required to wear respirators have been trained, had a medical evaluation and have been fit tested?

29 CFR 1910.134(c)(1)

 

 

23Slide24

Checklist 6

3.0

Chemical Hygiene Program

Facility Reviewer

__________________________________________

3.1

Laboratory Chemical Hygiene Plan

3.1.1

Note: Laboratory meets the following definition

: “Laboratory” means a facility where the “laboratory use of hazardous chemicals” occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis. “Laboratory scale” means work with substances in which the containers used for reactions, transfers, and other handling of substances is designed to be easily and safety manipulated by one person. “Laboratory scale” excludes those workplaces whose function is to produce commercial quantities of materials.

29 CFR 1910.1450

(b)

 

Changed reference3.1.3Does the chemical hygiene plan designate the required control measures to reduce employee exposure to hazardous chemicals including engineering controls, the use of PPE and hygiene practices? Do observations indicate that control measures are being used when required? Are laboratory personnel required to wear appropriate PPE when handling samples and chemicals? 29 CFR 1910.1450 (e)(3)(ii) Reworded to better define requirement.3.1.4Is chemical container labeling adequate to convey hazard information?29 CFR 1910.1450(h) Removed an incorrect reference. Added corrected reference24Slide25

Checklist 6

6.0

Safety Training

Facility Reviewer

___________________________________________________

6.1

Has the employer implemented a hazard communication program meeting the requirements of 29 CFR 1910.1200 as part of the employer's safety and program?

29 CFR 1910.120 (p) (2)

 

Changed to better reflect the wording in the requirement

6.2

Has the employer developed and implemented a training program which is part of the employer's safety and health program, for employees exposed to health hazards or hazardous substances to enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees?

 

29 CFR 1910.120 (p) (7) Changed to better reflect the wording in the requirement6.3Has an emergency response plan been developed and implemented by the employer?29 CFR 1910.120(p)(8)(i) New LOI25Slide26

TSDF Checklist 1: Quality Assurance Management Systems

26Slide27

TSDF Checklist 1

Mike

Nicol’s

presentation at this workshop covered t

he key changes to TSDF Checklist 1 from the

changes in

NQA-1-2015.

The revised Checklist 1 will be sent to the TSDF quality auditors as soon as it’s ready.

27Slide28

28