Preparing for and Surviving Inspections

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www.kdheks.gov
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Preparing for and Surviving Inspections

• Bureau of Environmental Field Services

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The Facilitys Perspective
Only in cases where you arent prepared!
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District Office Locations
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Inspections Performed
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The Importance of Compliance

• Maintain safe conditions for workers and visitors
• Protect the environment
• Reduce long-term care and maintenance
• Selling tool for customers
• Avoid compliance problems and penalties.

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Inspection Preparation

• Has to be diligent and constant.
• Keep a single file of all the required
  information
• Permits
• Correspondence (including e-mails)
• Inspections
• Shipment records
• Laboratory analyses
• Make sure at least one additional person has
  access to the information.

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Inspection Preparation

• For facilities that have permits
• READ YOUR PERMIT!
• Your Permit Contains
• Sampling Requirements
• Sampling parameters
• Inspection requirements
• Personnel training requirements

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Lets Talk Specifics

• Hazardous Waste
• Storage Tanks
• Air
• Waste Water
• Public Water Supplies
• Solid Waste

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Hazardous Waste
Program does not require a generator to hold a
permit.
Notification of hazardous waste generator status
is a requirement.
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Hazardous Waste

• Three Classifications of Hazardous Waste
  Generators in Kansas
• EPA Generator
• Kansas Generator
• Small Quantity Generator
• Kansas and EPA Generators are required to notify.

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Hazardous Waste

• Be Prepared for an Inspection
• Perform a waste determination on each potentially
  hazardous waste stream.
• Knowledge of process
• Document your findings
• Analysis by certified laboratory
• Keep records until the waste stream changes
• Ask for assistance from respective district
  office staff if there are questions.
• Keep all documents in a single file.

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Hazardous Waste

• Sign up for one of the ten hazardous waste
  generator workshops that will be held across the
  State in November 2006!
• Sign up information is available on KDHEs Bureau
  of Waste Management web site!

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Storage Tanks

• Aboveground Storage Tanks (ASTs)
• Sizes that must register with KDHE
• 660 gallons or larger
• 1100 gallons or greater if farm or residential

Check with Kansas State Fire Marshalls office
for additional requirements for your AST.
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AST Requirements

• KDHE
• Pay annual registration fee of 10 per tank.
• Keep operating permits posted.
• Fire Marshall
• Approval of Plans
• Inspections
• EPA
• Spill Control Rule (SPCC)

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Storage Tanks

• Underground Storage Tanks (USTs)
• Sizes that must register with KDHE
• Greater than 110 gallons
• Greater than 1100 gallons for farm or residential

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UST Requirements

• Pay annual registration fee of 10 per tank
• Post operating permits
• Meet performance standards
• Demonstrate financial responsibility
• Licensed contractor program

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Storage Tank Inspections

• Inspections are performed once every three years
  (more often if complaints are received.)
• Assure that your permit is current.

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Storage Tank Inspections

• What we will ask for
• Inventory Control
• Release Detection
• Release Prevention

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Storage Tank Inspections

• How to Prepare for an Inspection
• Understand and follow all the requirements of
  your current permit.
• Have all information documented and available at
  the site.
• Train your employees as to the proper protocol in
  the case of an inspection.

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Permit Specific Inspections

• Air Inspections
• Water Inspections
• Solid Waste Inspections

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Preparation

• Find your permit
• Read the permit.
• Pay special attention to specific requirements,
  such as sampling, and reporting.
• If modifications are being considered, contact
  the Department early in the process.

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Preparation

• Ask the Department for a copy of the appropriate
  inspection form used at your facility.
• Perform mock inspections.
• Correct deficiencies prior to KDHE showing up and
  finding them for you!

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www.kdheks.gov
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