Outline the typical components of a thorough compliance audit for a hazardous waste facility, specifying the key areas of evaluation.

A thorough compliance audit for a hazardous waste facility is a systematic and detailed assessment designed to verify adherence to all applicable environmental regulations, permits, and best management practices. The goal of the audit is not only to identify areas of non-compliance but also to promote continuous improvement in a facility’s environmental management system. It involves a meticulous review of numerous operational aspects, record-keeping procedures, and site-specific conditions. Such an audit typically includes several key components and areas of evaluation, which are interconnected and aim to ensure that the facility is operating responsibly and legally.

One of the fundamental areas of evaluation is the facility’s adherence to regulatory requirements related to waste characterization and classification. This involves verifying the processes used to identify, classify, and code all hazardous waste streams. Auditors examine documentation for testing and analysis conducted to determine if a waste exhibits hazardous characteristics such as ignitability, corrosivity, reactivity, or toxicity, and if the necessary testing is being performed using appropriate methods and accredited laboratories. For instance, if a facility generates used solvents, the auditors would review the analytical results for flash point, corrosivity and any other tests required to classify the specific waste stream as a hazardous waste and assign the proper EPA waste codes based on the properties and source of the waste stream. They will also check to see if the facility has material safety data sheets (MSDS) for all chemicals on site and if those MSDSs are up to date. This stage ensures that hazardous waste is accurately classified and managed according to applicable regulations such as the Resource Conservation and Recovery Act (RCRA).

The facility's waste management practices are also evaluated, covering all aspects of hazardous waste handling, storage, and transportation. Auditors inspect storage areas for compliance with regulatory requirements on container selection, labeling, and storage conditions. This includes verifying that containers are properly labeled with the contents, accumulation start dates, and hazard warnings. They will check that containers are in good condition, compatible with the waste they hold, and kept closed when not in active use, and stored within the prescribed time limits. The audit assesses if proper segregation of incompatible wastes is in place and if appropriate secondary containment structures are used to prevent spills from reaching the environment. They would also look at emergency equipment like spill kits and fire extinguishers to determine if they are readily accessible and well maintained. For example, containers storing flammable liquids should be located away from any ignition sources and should be properly grounded to prevent static build-up.

Another important area of evaluation is the facility's manifest system. Auditors verify if the facility uses hazardous waste manifests correctly to track the movement of waste from the generator to the final treatment, storage, or disposal facility (TSDF). This includes ensuring that all required information is documented accurately, such as the waste description, quantity, EPA identification numbers for the generator, transporter, and receiving facility, and any special handling instructions. Auditors check if the facility is retaining copies of the signed manifest from the TSDF, and that these records are properly maintained. They would also review any discrepancy reports or exception reports and how the facility addressed those incidents. This verification ensures that hazardous waste is being sent to permitted facilities and that there is a "cradle to grave" tracking system in place to hold all parties accountable for the safe management of hazardous waste.

The personnel training program at the facility is also carefully reviewed. Auditors assess if all employees who handle hazardous waste have received the necessary training, including waste management procedures, emergency response protocols, and safety practices. They verify the training content and ensure that it’s appropriate for their specific job functions, and that records of this training are complete and up to date. For example, employees involved in loading hazardous waste onto trucks would need to have documented training that addresses DOT regulations concerning hazardous material transportation and how to handle manifests, and those employees must receive refresher training annually.

The facility’s emergency preparedness and response capabilities are another critical area to assess. Auditors examine the site’s emergency response plan, ensuring that it identifies potential emergencies, provides clear procedures for response actions, establishes emergency contacts and evacuation routes, and details the availability of emergency equipment. They look for the presence of spill control equipment, safety equipment, and communication devices to use in case of a spill, and they review documentation of emergency response training exercises or drills. They would verify if those drills were appropriate and comprehensive, and that all employees are trained on procedures during emergencies.

Record-keeping and documentation are a fundamental part of the compliance audit. Auditors verify if the facility has the required documentation for all its operations, and if the records are accurate and complete, and if all documents are readily available for regulatory agency review. The review includes waste characterization data, training records, waste manifests, hazardous waste storage records, inspection logs, equipment maintenance logs, as well as permits, licenses and registrations. They would verify if the records are organized, well-maintained, and easily accessible for review, and also check how records are archived to ensure compliance with record retention regulations.

Finally, a compliance audit may assess any site remediation activities that have been conducted or are ongoing. This includes reviewing documentation of site investigations, cleanup plans, and monitoring data for any contaminated areas. Auditors check if the remediation efforts were effective and followed regulatory requirements. This area of the audit is especially pertinent to facilities that have previously experienced contamination issues and must comply with specific remediation plans. Overall, the audit involves a thorough examination of all facets of a hazardous waste facility’s operation to ensure full compliance and to promote continuous improvement in its environmental management practices. The aim is to verify that the facility is managing waste safely and responsibly to protect human health and the environment.