Auto Body Compliance Assessment

Appendix B

SV Pilot Phone Survey Instructions

Introduction:

Hi, my name is [interviewer name]. I’m calling on behalf of the U.S. Environmental Protection Agency. We are conducting a brief survey related to environmental practices at autobody shops. Are you the person I should speak to about environmental issues in your shop?

(If no, ask to speak with appropriate person and repeat above introduction. If target respondent not available, schedule a callback date and time. The ideal target respondent (in survey research this is called the “most knowledgeable person” -- MKP). is the person from the shop who keeps up with environmental requirements, is familiar with shop set up and operations, and perhaps receives information through training or attending workshops or manages the operations of the shop.)

The survey will help EPA improve the assistance it provides to shops in complying with environmental regulations.

Great. The survey should take only about 10 minutes, and your responses will remain anonymous.

PROPOSED TELEPHONE SURVEY INSTRUMENT

KEY:

Boldface Font – Spoken question

Normal Font – Response options

Italics – Instruction for questionnaire administrator (not spoken)

Date of Survey: ________________________________

Agency/Regional Office: ___________________

Assistance Provider:__________________________________________

Tel.______________________

Facility Name:___________________________________________________________________________

Facility Address:_________________________________________________________________________

Name and Title of Facility Contact Person: ____________________________________________________________________________________

Telephone number of Facility Contact Person:

____________________________________________________________________________________

SECTION A: INTRODUCTION

A1. Which of the following categories best describes your role at this shop? (read categories):

___ Owner

___ Manager

­­­___ Technician who applies spray coatings

___ Another role (specify)__________________________________________

A2. Do the operations at your shop include the application of surface coatings to vehicles or parts?

___ Yes

___ No  End survey

A3. Is this shop part of a corporate chain?

___ Yes (specify which one)_____________________________________________

___ No

SECTION B: AIR POLLUTANTS

B1. What type of spray guns do you use to apply coatings in your shop?

___ HVLP (High Volume Low Pressure)

___ Electrostatic

___ Airless spray gun

___ Air assisted airless

___ Don’t know

___ Other (specify) ___________________________________________

Note for surveyor: If flow is 15-26 cubic feet per minute and PSI at orifice is less than 10 lb per square inch, then likely to be an HVLP spray gun.

Now I have a few questions about where in your shop coatings are applied to vehicles:

B2. a. Does your shop have a spray booth?

___ Yes

___ No  Skip to B4

b. Are ALL spray coatings applied in the spray booth?

___ Yes

___ No

___ Don’t know

c. When did your shop first begin using this spray booth to apply coatings? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

4. Is the spray booth enclosed with a full roof and four complete walls or side curtains?

___ Yes, spray booth is enclosed

___ No, spray booth is NOT enclosed

___ Don’t know

B3. a. Is the spray booth ventilated with an exhaust fan?

___ Yes, spray booth is ventilated

___ No, spray booth is NOT ventilated  Skip to B4

___ Don’t know  Skip to B4

b. When was this booth exhaust system first used at your shop? (read responses)

___ Less than 2 years ago

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

c. What is the capture efficiency of your booth exhaust system?

If respondent is unsure, note that this information would typically be found on the filter package

or provided by the distributor.

___ % Capture efficiency (list numerical value)

___ Don’t know

d. Is there a particle filter on the spray booth exhaust?

___ Yes, the station has a particle filter

___ No, the station does not have a particle filter

___ Not sure

B4. a. . Do you have a separate paint mixing room?

___ Yes

___ No  Skip to B5

b. When did your shop first begin using this mixing room? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

c. Is the mixing room enclosed with a full roof and at least three complete walls or side curtains?

___ Yes, mixing room is enclosed

___ No, mixing room is NOT enclosed

___ Don’t know

d. Is the mixing room ventilated with an exhaust fan?

___ Yes, mixing room is ventilated

___ No, mixing room is NOT ventilated

___ Don’t know

B5. a. Do you have a prep station where coatings are applied on vehicle components?

___ Yes

___ No  Skip to B6

b. When did your shop first begin using this prep station? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

3. Is the prep station enclosed with a full roof and at least three complete walls or side curtains?

___ Yes, prep station is enclosed

___ No, prep station is NOT enclosed

___ Don’t know

d. Is the prep station ventilated with an exhaust fan?

___ Yes, prep station is ventilated

___ No, prep station is NOT ventilated

___ Don’t know

B6. Do you use waterborne paints?

___ Yes

___ No Skip to B8

___ Don’t know Skip to B8

B7. What do you use waterborne paints for? (read responses)

___ Basecoat

___ Primer

___ Another use (Specify) ___________________________________________

B8. On average, about how many gallons of each of the following coatings are applied (not purchased) in your shop each week? (read responses)

Basecoat: _______ gallons _______ don’t know

Primer: _______ gallons _______ don’t know

Topcoat: _______ gallons _______ don’t know

Total Estimate: ______ gallons _______ don’t know

B9. Who is your supplier of paint coating products?

Supplier: ________________________________________________________________

Would you please provide contact information for that supplier? We are asking because we would like to partner with the suppliers to provide compliance assistance in the future.

Contact Information: _______________________________________________________

B10. a. Have ALL spray technicians been trained regarding spray equipment?

___ Yes (all)

___ Yes (some)

___ No  Skip to B11

___ Not sure  Skip to B11

b. Has the training addressed and/or included the following regarding spray equipment? (read responses; check all that apply)

___ Selection

___ Set-up

___ Use

___ Maintenance

___ Hands on with equipment

___ Classroom

B11. Have you heard of EPA regulations related to spray painting operations and paint stripping?

___ Yes

___ No  Skip to C1

B12. When did you first hear of these new regulations?

___ Year

___ Month

___ Don’t know

B12. How did you first hear about the regulations, from a... (Read list of sources)

Sources: Circle all that apply	For each circled source, ask: Who provided this information? Then check off provider from list below for that source. Do not read the list of providers.
	EPA	State	Supplier/vendor	Other auto body shops	Trade Ass’n	Local Gov’t	OSHA	Don’t Know
Shop Visit
DVD
CD
Post Card
Fact Sheet
Website
Workshop
Another source

If another source, specify: ________________________________________________________

SECTION C: RCRA GENERATOR AND WASTE DETERMINATION

Now I have a few questions about how you manage your hazardous waste.

C1. About how much hazardous waste does your shop generate each month? (read options)

___ 0 - 26 gal/mo (VSQG or equivalent)

___ 27-270 gal/mo (SQG)

___ >270 gal/mo (LQG)

___ Don't know or your waste hauler handles that for you

C2. Are all hazardous waste containers properly labeled?

___ Yes

___ No

___ Don’t know

If interviewee asks, explain that all hazardous waste containers should be labeled with the words “hazardous waste” and clearly marked with the date on which accumulation began.

C3. Does your shop send all hazardous waste to a permitted or state authorized hazardous waste treatment, storage, or disposal facility, or a state authorized facility? (Example: Clean Harbors in Braintree)

___ Yes

___ No

___ Don’t know

___ Recycled

C4. Are used absorbent paint applicators such as shop rags and towels stored in closed containers?

___ Yes, containers are closed

___ No, containers are not closed

___ Don’t know

___ Don’t use

C5. Do you treat the following as hazardous wastes: (read list of waste streams)

Waste streams:	For each waste stream, check off relevant response:
	Yes	No	Don’t Know	Not Applicable (i.e., this waste stream isn’t generated at all)
Solvents
Paints
Sand blast debris
Use rags
Spray booth filters
Antifreeze
Waste oil
Another hazardous waste stream

If other, specify: ____________________________________________________

C6. Have your employees taken a training program that covers proper hazardous waste management procedures?

___ Yes

___ No

___ Don't know

SECTION D: COMPLIANCE ASSURANCE

D1. How do you obtain information about how to comply with federal and state environmental regulations? (do not read responses; check all that apply)

­___ Coating manufacturers or suppliers

___ Corporate environmental division

___ Educational institutions (vocational technical school, community college, specialized training center, etc.)

___ Environmental consultant

___ Other autobody shops

___ Local government (town, city, or county)

___ OSHA

___ State environmental agencies

___ Suppliers

___ Trade association

___ U.S. EPA

___ Other (Specify)_______________________________________________

___ Don’t know

D2. Has your shop been inspected or visited by a government environmental, health and or safety official within the last six months?

____ Yes

____ No  End survey

____ Don’t know  End survey

D3. What type of government official inspected or visited your shop? (do not read responses, check all that apply)

___ EPA

___ State

___ Local government (environmental, health or fire department)

___ OSHA

___ Other (specify) ___________________________________________________

___ Don’t know/Can’t recall

Thank you for your time.

Appendix C

Proposed Survey Instrument for On-Site Inspections

KEY:

Boldface Font – Spoken question

Normal Font – Site visit record/contacts and response options

Italics – Instruction for compliance assistance provider (not spoken)

Date of Visit: ________________________________

Agency/Regional Office: ____________________

Assistance Provider:__________________________________________

Tel.______________________

Facility Name:___________________________________________________________________________

Facility Address:_________________________________________________________________________

Name and Title of Facility Contact Person: ____________________________________________________________________________________

Telephone number of Facility Contact Person:

____________________________________________________________________________________

Introduction

Hi, my name is [interviewer name]. I am here on behalf of the U.S. Environmental Protection Agency. We are conducting a survey related to environmental practices at autobody shops. The survey will help EPA improve the assistance it provides to shops in complying with environmental regulations. Are you the person I should speak to about environmental issues in your shop?

(If no, ask to speak with appropriate person and repeat above introduction The ideal respondent (in survey research this is called the “most knowledgeable person” -- MKP) is the person from the shop who keeps up with environmental requirements, is familiar with shop set up and operations, and perhaps receives information through training or attending workshops or manages the operations of the shop.)

Great. It will take us about 1 hr to walk through the shop and complete the survey, and your responses will remain anonymous. Is there an office, or a place where we can sit to go over some of the basic questions first?

Based on our observations and experience testing the survey out in shops, it works best to go through all interview questions up front in a quiet office area and then ask to be shown through the shop for observations

SECTION A: INTRODUCTION

A1. Which of the following categories best describes your role at this shop? (read categories):

___ Owner

___ Manager

­­­___ Technician who applies spray coatings

___ Another role (specify)__________________________________________

A2. Do the operations at your shop include the application of surface coatings to vehicles or parts?

___ Yes

___ No  End survey

A3. Is this shop part of a corporate chain?

___ Yes (specify which one)_____________________________________________

___ No

SECTION B: TRAINING

B1. a. Have your employees taken a training program that covers proper hazardous waste management procedures?

___ Yes

___ No Skip to B 2

___ Don't know  Skip to B 2

b. Is the documentation related to the hazardous waste management training program present and available for review?

___ Yes

___ No

___ Don't know

CA provider may examine documentation to determine whether or not shop has program. The CA provider will not evaluate the quality of the training program.

___ Shop has training program

___ Shop does not have training program

___ Not sure

B2. a. Have ALL spray technicians been trained regarding spray equipment?

___ Yes (all)

___ Yes (some)

___ No  Skip to C 1

___ Not sure  Skip to C 1

b. Has the training addressed and/or included the following regarding spray equipment? (read responses; check all that apply)

___ Selection

___ Set-up

___ Use

___ Maintenance

___ Hands on with equipment

___ Classroom

c. Are the training records present and available for review?

CA provider may examine documentation (certificates, dates, places) to determine whether or not the spray technicians have been properly trained (meaning they have been trained in all 6 areas listed in question B2(b) above).

___ All technicians have been properly trained.

___ Some (but not all) technicians have been properly trained

___ None of the technicians has been properly trained

___ Records not available

SECTION C: AIR POLLUTANTS

When we walk through the shop, it would be helpful if you could show me your spray guns.

C1. a. Does your shop have a spray booth?

___ Yes

___ No  Skip to C2

b. Are ALL spray coatings applied in the spray booth?

___ Yes

___ No

___ Don’t know

c. When did your shop first begin using this spray booth to apply coatings? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

C2. a. Is the spray booth ventilated with an exhaust fan?

___ Yes, spray booth is ventilated

___ No, spray booth is NOT ventilated  Skip to C3

___ Don’t know  Skip to C3

b. Do you know the capture efficiency rating of your booth exhaust system?

___ % Capture efficiency (list numerical value)

___ Don’t know

c. Is the documentation related to the capture efficiency of your booth exhaust system present and available for review?

If respondent is unsure, note that this information would typically be found on the filter package or provided by the distributor. CA provider may review documentation to determine the capture efficiency:

___ % Capture efficiency (list numerical value)

___ Cannot find it

d. When was this booth exhaust system first used at your shop? (read responses)

___ Less than 2 years ago

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

When we walk through the shop, it would be helpful if you could show me your spray booth and exhaust system.

C3. a. Do you have a separate paint mixing room?

___ Yes

___ No  Skip to C4

b. When did your shop first begin using this mixing room? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

C4. a. Do you have a prep station where coatings are applied on vehicle components?

___ Yes

___ No  Skip to C5

b. When did your shop first begin using this prep station? (read responses)

___ Less than 2 years

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

When we walk through the shop, it would be helpful if you could show me the mixing room and/or the prep station.

C5. a. How do technicians at your shop typically clean the spray guns?

___ Use a fully enclosed spray gun washer

___ Use a fully enclosed spray gun washer and occasionally disassemble and clean by

hands

___ Flush with solvent (but don’t spray)

___ Spray coatings and/or solvent through the gun

___ Clean disassembled gun by hand or through mechanical methods

___ Other (specify) ____________________________________________________

b. When was this spray gun cleaning approach first used at your shop?

___ Less than 2 years ago

___ 2-5 years ago

___ More than 5 years ago

___ Don’t know

When we walk through the shop, it would be helpful if you could show me the gun cleaning area and operations.

C6. Do you use waterborne paints?

___ Yes

___ No Skip C8

___ Don’t know Skip C8

C7. Do you use waterborne paints for your: (read responses)

___ Basecoat

___ Primer

___ Other (specify) ____________________________________________________

C8. On average, about how many gallons of each of the following coatings are applied in your shop each week?

Basecoat: _______ gallons _______ don’t know

Primer: _______ gallons _______ don’t know

Topcoat: _______ gallons _______ don’t know

Total Estimate: ________gallons _______don’t know

C9. Who is your primary supplier of paint coating products?

Supplier: ________________________________________________________________

Would you please provide contact information for that supplier? We are asking because we would like to partner with the suppliers to provide compliance assistance in the future.

Contact Information: _______________________________________________________

C10. Does your shop have Material Safety Data Sheets (MSDS) and coating formulation data supplied by the manufacturer for the solvents and coatings that you use? Is this documentation present and available for review?

CA provider observes documentation and records whether or not it is sufficient. If no physical documentation is available, CA provider will confirm if shop uses a color matching computer technology on-site that has formulation data in it, and if so, ask to see data.

___ Yes, documentation available for all solvents and coatings

___ Documentation available for some solvents and coatings, but not all

___ Documentation not available for any solvents or coatings

___ Don’t know

C11. Do the coatings used by your shop contain any of the following hazardous air pollutants: chromium, lead, cadmium, nickel, or manganese (includes compounds of these metals)?

___ Yes

___ No

___ Don’t know

C12. a. Do you use chemical products for paint stripping tasks?

___ Yes

___ No  Skip C13

___ Don’t Know

b. What chemical products do you use for paint stripping?

List Products: ________________________________________________________________

c. Have you checked these products for the presence of Methylene Chloride?

___ Yes

___ No

___ Don’t know

[e.g. StripRDry, Booth Floor Stripper both made by CMA Philadelphia, both contain MeCl]

When we walk through the shop, it would be helpful if you could show me the products.

C13. May I please see records related to your shop’s methylene chloride usage?

CA provider examines documentation and records annual usage:

______ Gallons per year (as supported by documentation)

______ Don’t know; no documentation

C14. Does your shop have a minimization plan for use of MeCl? Could I take a look at it?

CA provider examines documentation and determines whether or not a plan exists:

___ Yes, shop has minimization plan

___ No, shop does not have minimization plan

C15. Have you heard of EPA regulations related to spray painting operations or paint stripping?

___ Yes

___ No  Skip to D1

C16. When did you first hear of these regulations?

_____________ Year

_____________ Month

_____________ Don’t know

C17. How did you first hear about the regulations, from a... (Read list of sources)

Sources: Circle all that apply	For each circled source, ask: Who provided this information? Then check off provider from list below for that source. Do not read the list of providers.
	EPA	State	Supplier/vendor	Other auto body shops	Trade Ass’n	Local Gov’t	OSHA	Don’t Know
Shop Visit
DVD
CD
Post Card
Fact Sheet
Website
Workshop
Another source

If another source, specify: ________________________________________________________

SECTION D: RCRA GENERATOR AND WASTE DETERMINATION

D1. About how much hazardous waste does your shop generate each month? (read options)

___ 0 - 26 gal/mo (VSQG or equivalent)

___ 27-270 gal/mo (SQG)

___ >270 gal/mo (LQG)

___ Don't know or your waste hauler handles that for you

When we walk through the shop, it would be helpful if you could show me the hazardous waste storage area.

D2. Is the documentation related to shipping these wastes off site present and available for review?

CA provider should review documentation if the answer to D1 above is “don’t know.”

___ Yes

___ No

___ Don’t know

When we walk through the shop, it would be helpful if you could show me where used rags and towels are stored.

D3. Do you treat the following as hazardous wastes: (read list of waste streams)

Waste streams:	For each waste stream, check off relevant response:
	Yes	No	Don’t Know	Not Applicable (i.e., this waste stream isn’t generated at all)
Solvents
Paints
Sand blast debris
Use rags
Spray booth filters
Antifreeze
Waste oil
Another hazardous waste stream

If other, specify: ____________________________________________________

Note: Spent/used booth filters are typically being treated as solid waste. Advise shops that the only definitive way to know if those are non-hazardous is by testing (TCLP) to determine whether they are characteristic of hazardous waste.

SECTION E: EMERGENCY PROCEDURES (EPCRA)

E1. Have you implemented emergency procedures in your shop?

___ Yes

___ No

___ Don't Know

E2. Is the documentation related to your emergency procedures present and available for review?

CA provider reviews documentation and determines whether or not emergency procedures are in place:

___ Shop has emergency procedures in place

___ Shop does not have emergency procedures in place

___ Don’t know

Note to CA provider: Emergency procedures can include: The shop posting the current name and telephone number of the emergency coordinator; posting the location of fire extinguishers and spill control material, and if present, fire alarm; posting the telephone number of the fire department, unless the shop has a direct alarm.

SECTION F: COMPLIANCE ASSURANCE

F1. How do you obtain information on how to comply with federal and state environmental regulations? (do not read responses; check all that apply)

­___ Coating manufacturers or suppliers

___ Corporate environmental division

___ Educational institutions (vocational technical school, community college, specialized training center, etc.)

___ Environmental consultant

___ Other auto body shops

___ Local government (town, city, or county)

___ OSHA

___ State environmental agencies

___ Suppliers

___ Trade association

___ U.S. EPA

___ Other (Specify)________________________________________________

___ Don’t know

F2. Has your shop been inspected or visited by a government environmental or health and safety official within the last six months?

____ Yes

____ No  Skip to F 4

____ Don’t know  Skip to F 4

F3. What type of government official inspected or visited your shop? (check all that apply)

___ EPA

___ State

___ Local government (environmental, health or fire department)

___ OSHA

___ Other (specify) ___________________________________________________

___ Don’t know/Cannot recall

F4. a. Have you made any changes in the last year in your shop operations (e.g., the type of equipment you use, techniques you use, or training you provide)?

____ Yes

____ No  Skip to F 5

____ Don’t know  Skip to F 5

b. What changed?

Comment:______________________________________________________________________

______________________________________________________________________________

c. Why did this change happen?

Comment:______________________________________________________________________

______________________________________________________________________________

F5. Is there any other information about your shop's operations that you'd like to share before we walk through the shop together? Is there anything that you would like EPA to know or to do related to assistance or inspections or other activities that impact your operations?

Comment:______________________________________________________________________

______________________________________________________________________________

SECTION G: Walk Through (The order of these questions may have to be rearranged based on the set up of the shop.)

G1. May I see the spray guns you use? (Check all that apply)

____ HVLP (High Volume Low Pressure)

____ Electrostatic

____ Airless spray gun

____ Air assisted airless

____ Other (specify) ___________________________________________

____ Don’t know

Note for CA provider: If flow is 15-26 cubic feet per minute and PSI at orifice is less than 10 lb per square inch, then likely to be an HVLP spray gun. Other equivalent high transfer efficiency technology examples include: electrostatic application, airless spray gun, and air-assisted airless guns.

G2. Verify the Manufacturer of the Spray guns:

_____________________________________________ Manufacturer

______________________________________________Manufacturer

______________________________________________ Manufacturer

___ Don’t know

G3. May I see the gun cleaning area, operations?

CA provider observes cleaning procedures and categorizes cleaning technique:

___ Use a fully enclosed spray gun washer

___ Use a fully enclosed spray gun washer and occasionally disassemble and clean by

hands

___ Flush with solvent (but don’t spray)

___ Spray coatings and/or solvent through the gun

___ Clean disassembled gun by hand or through mechanical methods

___ Other (specify) ____________________________________________________

G4. May I see your spray booth?

___If no spray booth present, check here and skip to G7.

CA provider performs visual inspection to confirm that spray booths, where coatings are applied to full vehicles, are fully enclosed and ventilated. Check all that apply:

___ Spray booth is fully enclosed with a full roof, four complete walls or side curtains

___ Spray booth is not fully enclosed

___ Spray booth is ventilated with an exhaust fan

___ Spray booth is not ventilated with an exhaust fan

___ There is evidence that at least some spray coating occurs outside of a spray booth

G5. May I see the particle filter on the spray booth exhaust?

CA provider performs visual inspection of pipe and filter and determines whether or not there is a particle filter on the exhaust:

___ Yes, the station has a particle filter

___ No, the station does not have a particle filter

___ Not sure

Note to CA provider: you may see a wall fan and small box with filter.

G6. Is the particulate filter in good condition? Look for rips or gaps in the particulate filters; check to see if the filters appear to be clogged with paint residue or dust.

CA provider records condition of particulate filters:

­­___ Good condition

___ Fair condition

___ Poor condition

___ Don’t know

If the filters are not in good condition, CA Provider should ask the shop to revisit manufacturer’s recommendation.

G7. May I see your mixing room?

___If no mixing room present, check here and skip to G8.

CA provider performs visual inspection to confirm that mixing room is enclosed and ventilated. Check all that apply:

___ Mixing room is enclosed with a full roof and at least three complete walls or side curtains

___ Mixing room is not enclosed as described above

___ Can’t tell if mixing room is enclosed

___ Mixing room is ventilated with an exhaust fan

___ Mixing room is not ventilated with an exhaust fan

___ Can’t tell if mixing room is ventilated

G8. May I see your prep station?

___If no prep station present, check here and skip to G9.

CA provider performs visual inspection to confirm that prep station is enclosed and ventilated. Check all that apply:

___ Prep station is enclosed with a full roof and at least three complete walls or side curtains

___ Prep station is not enclosed

___ Can’t tell if prep station is enclosed

___ Prep station is ventilated with an exhaust fan

___ Prep station is not ventilated

___ Can’t tell if prep station is ventilated

G9. May I see the products you use for paint stripping?

Examine products for ingredients with methylene chloride.

___ Yes, products with methylene chloride are used

___ No, products with methylene chloride are not used

___ Don't know/can’t tell

G10. May I see your hazardous waste storage area?

CA Provider: Are all hazardous waste containers properly labeled with the words “hazardous waste” and clearly marked with the date on which accumulation began?

___ Yes

___ No

___ Don’t know

Note: CA provider will use best professional judgment to determine what is “clear” and “legible” and whether the shop made a “genuine and complete effort” to meet this requirement.

G11. CA Provider: What is the earliest date that accumulation began in any of the drums?

__________________ Month/year of earliest beginning accumulation date

__________________ Not sure / Drums poorly labeled

Note to CA provider: No storage limits for VSQGs; SQGs has a <4400lbs & 180 day limit, body shops are not expected to be LQGs.

G12. CA Provider: Are all hazardous waste containers closed unless waste is being added or removed?

___ Yes

___ No

___ Don’t know

Note: “closed” means that if the containers were tipped, nothing would spill. “Funnels” are acceptable if they are closed.

G13. CA Provider: Approximately how much hazardous waste is currently on site ( excluding waste in satellite accumulation areas)?

_________________ Gallons of hazardous waste (approximate)

_________________ Not sure / Drums poorly labeled

G14. Can you please show me where you store used absorbent paint applicators such as shop rags and towels?

CA provider: are the containers closed when not in use?

____ Yes, containers are closed

____ No, containers are not closed

____ Don’t use rags, towels

____ Don’t know

G15. Is there any indication of spills in or near the shop? CA provider will check for stains on the ground and in and around manholes, leaking tanks and containers and/or pooled liquids.

___ Yes

___ No

___ Comment _____________________________________________________________

G16. Does the shop appear to be operating in such a way as to violate the CAA 112(r)(1) general duty clause – namely: “The owners and operators of stationary sources producing, processing, handling or storing [a chemical in 40 CFR Part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as he general duty clause in the Occupational Safety and Health Act (OSHA)], to identify hazards which may result from... releases using appropriate hazard assessment techniques, to design and maintain a safe shop taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”

___ Yes, shop appears to violate clause

___ No, shop does not appear to violate clause

___ Undetermined

Thank you for your time.

Provide site visit debrief and compliance assistance

Appendix B, Page 9