Appendix H

Toolkit for Evaluating TSCA

This appendix provides a series of checklists intended to assist compliance managers and personnel performing certain inspections and assessments of some of the typical operations involving asbestos and PCB inspections governed by TSCA. These tools are provided for instructional purpose and guidance only and are not intended to represent an all-inclusive collection of TSCA regulatory requirements. The tools provided in this appendix are adapted from EPA checklists and guidance. The example checklists provided in this appendix are as follows.

TSCA Compliance Inspections:

  1. 1. Asbestos Management
  2. 2. PCB Storage

TABLE H.1
Asbestos Management Plan Checklist

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TABLE H.2
PCB Storage Checklist

Date: _______ Time: _______

Designated person: ________________ Signature: ________________

  1. 1. Was the last inspection conducted within the previous 30 days?      Yes___ No___
  2. 2. Date of last inspection
  3. 3. Are all containers marked with the large PCB mark?      Yes___ No___
  4. 4. Number of containers in storage area?
  5. 5. Are all entrances to the storage area marked with the large PCB mark?      Yes___ No___
  6. 6. Are nonradioactive PCBs in this area stored in containment with a continuous curb that is at least 6 inches in height, or are the containers stored within a salvage container?      Yes___ No___
  7. 7. Does the containment have a volume of at least two times the internal volume of the largest PCB article or PCB container, or 25% of the total volume of all PCB articles or PCB containers stored, whichever is greatest?      Yes___ No___
  8. 8. Have salvage containers been opened and inspected for leaks during this quarter (Le. Jan–Mar; Apr–Jun; Jul–Sep; Oct–Dec)?      Yes___ No___
  9. 9. Is the floor free from any openings such as drain valves, floor drains, expansion joints, lines, etc.?      Yes___ No___
  10. 10. Are the floor and containment curbing constructed of continuous smooth and impervious materials, such as Portland cement concrete or steel?      Yes___ No___
  11. 11. Are roof and walls adequate to prevent rainwater from reaching the stored PCBs and PCB items?      Yes___ No___
  12. 12. Are all containers in good condition?      Yes___ No___
  13. 13. Is the ‘Removal from Service for Disposal’ date recorded on the documentation for each PCB item in each container?      Yes___ No___
  14. 14. Are all PCBs being stored for less than nine months?      Yes___ No___

 

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