Environmental Guide - Chapter 4 Auditinginfohouse.p2ric.org/ref/17/16240.pdf · 4.1 Introduction...

PART II

CHAPTER4 AUDITING

TABLE OF C 0 " l S

4.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2 Guiding Principles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

4.2.1 Building Consensus ....................................... 4-2 4.2.2 Completeness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 4.2.3 Accuracy.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 4.2.4 Credibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

4.3 General Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4 4.3.1 Pre-Audit Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4 4.3.2 On-Site Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 4.33 Post-Audit Activities ...................................... 4-9

4.2.5 Liability Minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

Appendix 4-A Environmental Audit Checklists

4.1 Introduction

This chapter discusses the use of internal audits to help ensure that compliance is maintained. Its scope includes environmental issues only, although some occupational safety issues are included in the checklist for spill and emergency planning and control. This chapter discusses auditing in general terms; checklists that can be used during an audit are also included (Appendix 4-A). The general auditing principles discussed are applicable to safety auditing as well.

In the discussion below, reference is made to an audit team and a team leader. It is generally recognized that although using a team approach to auditing is preferable, it is not absolutely required. In fact, because there are no standards established for environmental auditing, any approach a company wants to use is acceptable as long as it is effective at identifying environmental issues and measuring performance. The approach presented here is a summary of what the authors of this manual have found to be effective.

Auditing is one of the necessary elements of a comprehensive approach to successfully managing environmental issues and systems. To be effective, it is important to define the objectives and then the scope and content of any audit prior to commencement. Audits may be done to verify regulatory compliance; to identify, reduce

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AUDITING PART LI CHAPTER 4

or manage potential liabilities; and to ensure conformance with company or corporate policy.

An audit is most often defined as "a systematic process for reviewing facility operations, practices, and management systems to determine how well they are meeting the standards set by relevant laws and regulations and/or corporate policies."

It is important to recognize the difference between an inspection and a program audit. The use of the term "inspection" implies that a "wall-to-wall" or "fenceline-to-fenceline" visual overview of the facility is performed. That is, the focus of the work is the discovery of deficiencies that manifest themselves as visible problems or failures. The term inspection also implies that each and every instance of a mechanical or physical deficiency is sought and noted. The major drawback to the inspection approach, besides the amount of time required to perform a thorough job, is that the causes of deficiencies are often not identified.

I I A program audit, on the other hand, evaluates management programs and systems

that are (or should be) in place to prevent, mitigate, and remediate accidents, incidents, and regulatory compliance deficiencies. The program auditing process includes visual observations of equipment, processes, and procedures being used, but observed deficiencies are viewed and treated as symptoms (or manifestations) of program

paper") and in what manner and level of completeness they have been implemented ("in the real world"). Programs are first examined to determine if they will enable the facility to achieve compliance, if properly implemented. Their actual implementation is then evaluated to determine if they have enabled the facility to achieve compliance and achieve their objectives of reducing or eliminating emissions, incidents, and accidents to acceptable levels. An effective program audit can help detect "accidents waiting to happen" and situations where mere chance has been a major factor in incident and accident prevention.

i I deficiencies. This approach examines programs as they have been developed ("on 1

4.2 Guiding Principles

There are five general principles that should guide the development and implementation of program audits. The characteristics that all effective audit programs share is that they build consensus between auditors and the facility regarding the status of programs and are complete, accurate, credible, and do not unnecessarily increase the exposure of the audited company or facility to regulatory, civil, or criminal liability. Each of these characteristics is discussed in more detail below.

4-21 BuiIding Consensus

For an audit to have value, the audited organization must "buy in" to the team's findings. The goal of every team should be to resolve differences of opinion between it and the facility before the end of on-site activities. To achieve this, the team must be objective in their evaluations and start discussion about findings as early in the audit as

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AUDITING PART 11 CHAPTER 4

possible. Informative discussions between auditors and facility personnel should take place as frequently as possible. One way to encourage this is to have briefings, open to all facility personnel, at the end of each day. The team leader asks each auditor to verbally describe the progress made that day and potential findings that have been identified. Frank discussions are encouraged. By holding these discussions, facility personnel become accustomed to hearing about program deficiencies, have time to formulate strategies for addressing them, and have the opportunity to comment on the consensus reached. The team should also do everything it can to involve facility personnel in all phases of the audit. Meetings should be open and informal. Experience and knowledge should be shared.

This characteristic is best achieved by developing and using checklists or protocols that require the auditors to systematically determine the compliance status of the company or facility relative to all applicable laws, regulations, standards, and corporate policies. These checklists must then be implemented by the audit team to the fullest extent possible to ensure that a thorough audit is performed.

The progress of the auditors in completing checklists must be checked and verified on at least a daily basis. Auditors must keep the team leader informed of their progress and the problems they encounter in gathering information and assessing a program's compliance status. The team leader must be able to provide effective solutions to problems encountered, be able to assist the auditors in prioritizing their activities, and have the resources available to overcome mechanical and logistical pro b 1 ems .

4.23 Acxluacy

Quality assurance (QA) is an important element of an effective audit. A high level of accuracy is best achieved by subjecting the auditors' work-in-progress to review by both company and facility personnel and by their fellow audit team members. Although an expert is responsible for each of the subject areas under review, a matrix approach to auditing exposes all team members to each of the processes or operations being examined. A daily critical review of each auditor's work by fellow audit team members is the best way to incorporate a "checks and balances" approach to achieving accuracy. Facility personnel review of the auditors' understanding of the facility, its operations, and compliance programs is an approach that has been found to be effective. If discussions with facility personnel are limited to the gathering of information and confirmation of the auditors' opinions regarding their compliance status, they need not expose the company and facility to additional unnecessary liability. Accuracy is further ensured by careful selection of the audit team members. In selecting team members, you should be careful to audit a given subject area using only personnel having extensive experience in dealing with the relevant regulatory requirements and standards.

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Given that one of the objectives of program auditing is to communicate concerns to appropriate company operations personnel, it is essential that the audit and its reports be credible to those receiving the reports and those who may eventually be required to respond to audit findings. The most effective ways to achieve credibility are for the audit team to have an understanding of the facility and processes adequate to allow them to "speak the language" of the facility and to effectively communicate with the facility's personnel during the audit. Accuracy is essential if credibility is to be achieved. Audit team members must be willing to take the time to get to know the facility's operations and the people they interview and interact with. They must have a genuine interest in the facility and its people and effectively demonstrate their interest.

A good audit does not cause more problems than it helps solve. Confidentiality is a key aspect of " i n ' n g any liabilities that may be incurred by performing an audit. The language used in audit reports must be carefully chosen to ensure that it is accurate and noninflammatory. It may be desirable to keep communications between the audit team and company and facility personnel regarding compliance status to a minimum. Audits by extemal personnel (e.g., consultants) are sometimes performed under a contract with the company's internal or external counsel to provide "attorney client" privilege protection.

4 3 General Methodology

Most audit programs are based on the set of elements defined below. These elements or steps can be broadly grouped into pre-audit activities, on-site activities, and post-audit activities.

These generally include:

Determining the basis and type of the audit;

Selecting appropriate management and specialist positions in the company for interviews and information gathering;

Selecting audit team members;

Contacting the facility, and scheduling and planning the audit;

Gathering and reviewing site-specific information;

APMA/3M/AI(ZO NOBEL- mlouibt Aryurt 1994 44

I


0 Compiling of the standards against which the facilities will be judged (applicable regulations standards, corporate policies and guidelines, etc.) to ensure that all environmental, health, and safety requirements are covered; and

Developing checklists or protocols that ensure a complete audit of the facility.

The type of audit and the standards to be used to assess the facility's performance must be clearly defined prior to the audit. These factors have a direct bearing on the identification of an appropriate audit team and the successful completion of an audit of the facility.

Selection of the team is also an important step. It is very important that appropriate qualified and sufficiently senior personnel are available to conduct the audit so that they can make a realistic appraisal of what is observed, provide sound technical input, and be credible to local site management. This is especially true for management systems auditing. Team members may come from staff within the facility, staff from other facilities within the organization or from outside sources of expertise (consultants, attorneys, etc.). In some cases a peer review group may also be used to check audit results.

\

I

I A common approach to organizing an audit is to examine the facility by subject or

discipline, not by physical location of units or sub-units (i.e., the protocols developed and used over subjects such as water pollution control, air pollution control, solid and hazardous waste management). The team is staffed by experts in particular subjects who examine the entire facility from the perspective of their particular discipline. This matrix approach provides for checks and balances on each audit team member's area of responsibility and helps ensure against issues being overlooked or otherwise "falling through the cracks."

I

1,

Initial gathering and review of site-specific information is very important in preparing for the audit, and helps ensure the audit can be conducted in a timely and resourceefficient manner.

A generally followed approach to conducting an environmental audit is to systematically identify environmentally sensitive materials entering the facility (in fuel, raw materials, maintenance materials), or leaving the facility (products, by-products, wastes, emissions, and discharges); environmental results or corporate standards that apply to the materials emissions and operations should also be identified. This approach focuses on the opportunities for the environmentally sensitive material to enter the environment and/or to leave the facility (e.g., through wastes, emissions, or products, etc). The audit effort can then be targeted toward these emission points or points of exposure, to maximize the potential benefits of the audit.

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Pre-audit information needed to implement this approach includes the following:

e

0

0

e

0

0

e

e

e

e

e

Plant layout and facility diagrams;

Description of operation;

Process flow diagrams;

Unit operations used;

Typical job or task descriptions;

Summary information on typical employee exposures to physical and chemical agents;

List of hazardous materials (raw materials, intermediates, fuels, products, by-products, and wastes);

Material Safety Data Sheets (MSDSs) for key materials;

Environmental permits, and planning and applications licenses;

Typical emissions, effluent, and waste inventories and emission rates, if available;

Existing waste minimization programs; and

Relevant company policies and procedures.

The purposes of the site-specific information review is to characterize the processes, products, by-products, emissions and wastes to assist in the determination of applicable standards, to develop and tailor audit protocols, and to organize and priorithe the on-site activities.

In order to prepare for interviews and corporate management and specialist personnel, information on the facility‘s management structure is required before the start of the audit. This information includes: organization charts showing the people to be met and their roles and positions in the organization; role statements/job descriptions as appropriate; and sample environmental, health, and safety responsibility/authonty descriptions for those positions.

The actual performance of the audit involves a three step process: detailed information gathering, evaluation, and verification. The detailed information gathering step requires the auditors to gather information on the facility and its operations, the delegation of environmental and safety responsibilities and authorities, and the programs

AFMA/3M/AKZO NOBEL/Eavironmen WGUide A u y t 1994 4-6

that have been developed and implemented to achieve compliance with applicable requirements. Following the gathering of pertinent information (via interviews and review of written programs), the evaluation step determines if the programs developed are capable of ensuring compliance. That is, the "on paper" programs are evaluated to determine if they would enable the facility to achieve compliance with requirements, if fully implemented.

The verification step of the process is intended to determine whether a particular compliance program has been implemented as developed, and whether the program has been effective as implemented. This step requires the auditors to make visual observations of the facility and its practices, review samples of records to ensure that stated procedures have been followed and documented, and to test the effectiveness of established programs by asking "What If?" type questions of operational and staff managers.

The on-site activities needed to perform these steps include:

e Introduction; 0 Interviews; e Program reviews; 0 Records review; e

e Visual observations (for verification); and Compilation of audit notes and summary of results.

During the introductory on-site meeting, plant personnel should describe the current and planned operations of the plant and the organizational structure of the environmental and safety function.

Key managers, sta& and technicians are interviewed to determine:

0 Suitability of the organizational structure and staffing for ensuring adequate control of hazards and compliance with standards;

e Likelihood that procedures and programs will be effective in finding and correcting problems; and

e The interviewee$ level of understanding of their responsibilities and authorities in environmental and safety matters.

The above factors may also be used in discussions with corporate managers and specialists who are not located at a facility but who have broader corporate environmental responsibilities.

Program review activities involve the review of written compliance programs to determine their level of completeness. If a written program does not exist for a given

AUDITING PART 11 CHAP'JXR 4

requirement, the auditor will use the protocol to ensure that he or she receives a complete description of the facility's practices so that a thorough evaluation of the practices can be made.

Another element of the on-site visit is the review of records and documentation of performance. This includes a review of permit applications, permits, registrations, planning applications, selected data, etc. You should review, if available, any required reports or correspondence with regulatory agencies including discharge monitoring reports, manifests, consignment notes, notices of violation, complaints, and any environmental loss reports. Previous audit reports should also be reviewed if available.

When interviewing corporate managers and specialists, the records review is limited to reviewing improvement plans and other business plans to ascertain how they reflect corporate environmental policy and to determine if environmental improvements are included.

Another aspect of the on-site audit is a tour of the facility. During the tour with facility personnel, the audit team should visually observe:

0 Emissions/waste stream sources; 0

0 Monitoring systems; and 0 Operating procedures.

Performance and condition of pollution control devices;

For audits focusing only on broader management systems, the abovedetailed observations would not be required, but are a necessary part of more detailed compliance audits.

It has been many companies' experience that conducting the audit process by media or regulatory program is essential to ensuring a complete audit. As discussed previously, the staffing of the audit team and the drafting of protocols is best performed by function, not physical location or process operation. For example, an expert in air emissions regulations uses a protocol that addresses air emissions issues across the facility. This matrix approach to auditing has each of the facility's unit operations and processes examined by each of the auditors, in independent records and program reviews, visual observations, and verification steps. This matrix approach, then, gives the audit team several looks" at a process, all from different perspectives. If good communications are maintained between the audit team via the daily team debriefing sessions, an auditor can draw the attention of the entire team to unique situations being examined by their protocol and also pass on their observations regarding issues being addressed by other team members. For example, the team member addressing air emissions issues may come across information regarding a wet scrubber's solution discharge that is pertinent to the work of the team member addressing watewater issues. This would help prevent the wastewater auditor from missing an important, though relatively small-volume, watewater stream while they are looking at larger streams.

4-8


- Post-audit activities typically center around preparing the audit report and communicating audit findings to the facility, company, and/or their legal counsel. It is common to have all reports submitted directly to their legal counsel. Oral and/or written reports to facility or company management and/or their counsel can be submitted as desired.

Reports should be drafted considering the sensitivity of management and counsel regardmg the use of language in audit reports. Internal or external attorneys often perform an internal review of audit reports before their submission to management.

The nature and scope of audit reports are best determined by your needs. The type of report most often submitted is an exception report. Usually, exceptions to laws and regulations, company policies, or good practices are stated and applicable requirements are cited. If desired, recommendations or suggestions for corrective action can be included in the report.

4-9

AUDITING PART II CHAPIXR 4

APPENDIX A

SAMPLE ENVIRONMENTAL AUDIT CHECKLISTS'

e

e Water Pollution Control e

e Air Pollution Control 0 PCB Management

Solid and Hazardous Waste Management

Spill and Emergency Planning and Control

Note: Checklists should be adapted to site-specific conditions, and state regualtions and should be updated periodically to reflect changes in regualtions.

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SOLID AND HAZARDOUS WASTE MANAGEMENT ENVIRONMENTAL AUDIT CHECKLIST

Facility/Unit/Area Audited:

Date of Audit:

Period Audited:

Auditor:

Persons Contacted/Inteniewed:

Areas Toured:

Page: 1 Date: 5/94

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SOLD AND HAZARDOUS WASIE MANAGEMENT Page: 2 ENVIRONMENTALAUDITCHECKLIST Date: 5/94

~ ~ ~~

LO Waste Generator Adivities (NonSmd Ouantity Generators) (40 CFR, Parts 260-268)

1-1 Waste Dete.rminatioo

Based upon a review of the facility's operations and processes, develop a list of waste generation points and wastes generated. Use Form 1.

Test the facility's program for characterizing its wastes by completing the following:

- Verify that the facility has identified all potential points of waste generation by comparing your listing to facility information.

- C o n f i i that the facility's procedures for classifying its wastes as hazardous or nonhazardous are used or adequate knowledge is applied to classify waste streams.

'

- By observing practices, verify that the facility follows procedures for preventing the mixing of hazardous and nonhazardous wastes. (40 CFR 261, 262.11)

12 Re&erinp: as a Hazardous Waste Generator

Verify, by reviewing the facility's hazardous waste generator application and corresponding documents, that an EPA identification number has been obtained. (40 CFR 262.22)

*OK NA Comments

Note: OK - Appears to meet requircments NI - Needs improvement NA - Not applicable

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SOLID AND HAZARDOUS WASTE MANAGEMENT ENVIRONMENTAL AUDIT CHECKLIST

FORM 1 - WASTIE GENERATION INVENTORY

Page: 3 Date: 5/94

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L3 Recycling of Hazardous Wastes and Hazardous Wastes Fuels and Used Oil

If the faciIity engages in the marketing or burning of hazardous waste fuels or used oil, verify that appropriate authorities have been notified, analytical records are maintained for used oils burned for energy recovery, and appropriate storage and treatment practices are followed. (40 CFR 266)

(NOTE: Coordinate the above portion of the audit with the completion of the Air Pollution Control Protocol.)

L4 Waste Miimization Programs

Verify that the facility has a written waste minimization program and retains information which documents waste minimization activities. Conclude if facility actions are resulting in the reduction of hazardous wastes. (4 CFR 262.41(a)(6),(7))

15 Hazardous Waste Manifests and Periodic Generator Reports

Test the generator’s manifest program by completing the following:

- From a review of shipping records or +xher independent documents, verify that manifests were completed for all hazardous waste shipments transported off-site. (40 CFR 26220)

- Ver;fy, by documentation review, the accuracy and completeness of manifests (including the waste minimization ce&ication, proper waste characterization and proper DOT shipping names).

*OK

-

NA Comments

Note: OK - Appears to meet requircnents NI - Needs improvement NA - Not applicable

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- For aU (or, as appropriate, a sample of) waste types, confirm that the annual (or biennial or quarterly) generator waste report(s) accurately reflect waste shipments. (40 CFR 262.41)

- Verify that the facility notified EPA of its intent to export hazardous wastes, if applicable. This notification must be made 60 days prior to shipment, and EPA will notify the facility if consent has been obtained. (Notification may be for a period extending 12 months or less.) (40 CFR 26253)

- Determine by documentation reyiew that the signed TSDF copies of the manifest were returned within the required time limits (45 days domestically, 90 days internationally). Where appropriate, verify that exception reports were prepared and submitted in a timely fashion.

(NOTE: Generators are required to initiate efforts to locate the wastes if the manifests are not returned within 30 to 35 days and fde exception reports after the 45 or 90 day limit is passed.) (40 CFR 262.42)

- If the generator disposes of wastes subject to land disposal restrictions under 40 CFR 268, confirm that the TSDF was notified (e.g., with each manifested shipment, a notification was submitted certifying that the waste meets or does not meet treatment standards under 40 CFR 268). (40 CFR 268.8)

- Verify that generator reports, manifests, and discrepancy reports are retained for the required time period (3 years). (40 CFR 262.40)

*OK Comments

Note: OK - Appears to meet requirements NI - Needs improvement NA - Not applicable

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Note: OK - Appears to meet requirements

M &Site Accumulation Pradices Training Programs and Drum Manzement Pradices

Verify that appropriate measures are being implemented by the facility with regard to hazardous waste accumulation requirements by performing the following:

- Tour the hazardous waste accumulation area(s) to verify that:

Wastes are properly marked with

Date of accumulation (40 CFR 26234(a)(2))

A label bearing the words. "hazardous waste" (40 CFR 26234(a)(3))

Clear and durable identification of which waste stream is being accumulated in each container during the accumulation period.

An 'EPA sticker" and DOT hazard labels prior to transporting (40 CFR 26232)

Aisle space is adequate (Le., so that leakin? drums can be removed easily). (40 CFR 265.35)

Containers or tanks are in good condition and compatible with the wastes accumulated. (40 CFR 265.171, -172; see 40 CFR 265 Subpart J for tank requirements)

Containers are kept closed unless adding or removing wastes. (40 CFR 265.173(a))

Containers are opened, handled, and stored in ways that do not pose an unnecessary risk of damage to the container. (40 CFR 265.173(b))

*OK - Comments

NI - Needs improvement NA - Not applicable

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Fire extinguishers and two way communications are present or in close proximity to the area. (40 CFR 2653534)

Spill control equipment is available. (40 CFR 26532 (c))

Containers holding wastes that are incompatible with other materials are provided with secondary containment (e.g., diking) adequate to prevent the contact of incompatible materials. (40 CFR 265.177)

- Verify that ignitable, reactive or incompatible wastes are being stored greater than 50 feet from the property line and away from other wastes. Confirm that effective steps are taken to keep ignition sowces away from ignitable wastes. (40 CFR 265.176)

- If satellite accumulation requirements are provided, verify faality compliance with applicable requirements (e.g., containers are labeled as hazardous waste, and each full quart container of acutely hazardous waste and each full 55 gallon drum is removed within 3 days). (40 CFR 26234(c))

- Document the period of time wastes are accumulated on-site to determine if wastes are stored for less than or greater than 90 days. If wastes are stored for more than 90 days, verify that all applicable %-day rule exemption criteria and management requirements are met. (40 CFR 262.34(b),(d),(e), or (9)

- Verify that hazardous waste accumulation areas are inspected weekly and that inspections are documented. (40 CFR 265.174)

'OK NA

- Comments

Note: OK - Appears to meet requirements NI - Needs improvement NA - Not-applicable

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- Verify the following:

Drums containing residues of materials are being managed to prevent and control releases to the environment. (40 CFR 265.17, 31)

Drums considered "empt)r by facility personnel have less than one inch of residue remaining in the drum or inner Iining, or less than 3 percent of total capaaty of container equal to or less than 110 gallons, or 03 percent for containers larger than 110 gallons. (40 CFR 261.7)

- Note and evaluate whether empty drums have any potential to impact the environment (e.g., are they cracked or located in direct contact with soil, or does the potential exist for them to contact storm water runoff?).

- Verify that the facility's hazardous waste training program is written, and contains a description of the scope of the training, who will be trained, and job descriptions for those people. (40 CFR 265.16)

- Verify that hazardous wastes are effectively segregated from - non-hazardous .wastes from their point of generation to their point of loading on transport vehicles for disposal.

L7 Hazardous Waste Contingency Plan (40 CFR 265 265)

(NOTE: Coordinate this portion of the audit with the completion of the Spill and Emergency Planning and Control protocol.)

*OK

-

-

Comments


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Verify the completeness and adequacy of the facility's hazardous waste contingency plan. (This plan may be part of the facility's emergency response plan or spill plan.) For example, the plan should include, at a minimum:

- Listing of emergency coordinators and telephone numbers. (40 CFR 26234(d)(5) or 26552(d))

- Listing of emergency equipment. (40 CFR 26552(e))

- Arrangements with local authorities (or listing of local authorities and range of assistance provided). (40 CFfL26537, 52(c))

- Evacuation plan. (40 CFR 26552(f))

- Description of emergency response procedures. (40 CFR 26234(d)(5)(iii) or 26552(a))

- Determine whether the contingency plan has been submitted to local and state emergency response teams. (40 CFR 26553)

L8 DisDosal and Tran..uortation Vendors

- Verify that the facility, for the treatment, storage, disposal and transportation of hazardous wastes, uses only vendors that are permitted by the US. EPA.

- Verify that the facility is not transporting its own hazardous waste unless it is specifically permitted to do so by the U.S. EPA.

*OK

-

NA

-

Comments


AFMA/~M/AKZO NOBEL/Environmcntal Guide August 1994


'OK NI NA Comments

20

21

i 2.2

&Site Hazardous Waste Stowe . Treatment, and D i s d PGidiceS (40 CFR 264,265)

Permit by Rule

Verify compliance with permit-by-rule provisions, if applicable.

(NOTE: 40 CFR 270.60 allows an owner/operator of certain facilities to dispose of hazardous waste without an actual RCRA permit if the fadlity complies with other applicable regulations. These facilities, while they do not have a permit specifically allowing them to dispose of hazardous waste, are "permitted-by- rule". The type of facilities to which this provision is limited are ocean disposal barges or vessels, injection wells, and publicly owned treatment works.

Consult 40 CFR 270.60 if the facility is operating under permit-by-rule provisions to determine the applicability of regulations.)

Conformance With TSDF Standards

Test the facility's hazardous waste treatment, storage, and disposal practices by completing the following:

- Develop a 1;:: of TSDF design requirements (Le., secondary containment, leachate removal, etc) by touring the site and evaluating practices in relation to regulatory requirements. Verify that the design of the treatment, storage, or disposal area meets interim status or established permit criteria. (40 CFR, Parts 264 and 265, Subparts 1 and J, as applicable)

Note: OK - Appears to meet requirements N1 . Needs improvement NA - Not applicable

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- Verifj by selecting a representative sample of hazardous wastes that they can be tracked from the time they enter the treatment, storage, or disposal system to their fmal disposition. (Alternatively, review the facility's operating record and confirm that it contains the required information.)

- Verify that the facility is managing ignitable, reactive or incompatible wastes in accordance with, governmental regulations (Le., preventing accidental explosions or reactions, etc. by segregating wastes, maintaining well ventilated areas, and minimizing spillage of materials). (40 CFR 264.17 or 265.17, as applicable)

- Verify, by selecting a representative sample of wastes destined for treatment, storage, or disposal, that the methods used to treat or dispose are consistent with operating methods set forth under interim status requirements or permit conditions. Confirm that only permitted liquid solvents are being landfilled or land-treated. (40 CFR Parts 264-268)

- Verify that the facility inspects treatment, storage, or disposal areas on a weekly or daily basis. Document whether or not these inspections are being documented routinely. (40 CFR 264.15, -174, -195 or 265.15, -174, -195, as applicable)

- Evaluate the security system in place for the treatment, storage, or disposal area by confirming that danger signs have been posted an/or access to the area is restricted. (40 CFR 264.14 or 265.14, as applicable)

*OK - Nl NA Comments


AFMA/3M/AKU3 NOBEL/Envhnmcntal Guide August 1994


- Verify the completeness and adequacy of the closure plan for the treatment, storage, or disposal area. (40 CFR Parts 264 or 265, Subpart G, as applicable)

- Verify that records relating to compliaice are readily a d a b l e and are being retained for the required time frame. (40 CFR Parts 264 or 265, Subpart E, as applicable)

- Test the facility's hazardous waste storage tank program by performing the following (40 CFR 264 or 265, Subpart J , as applicable):

Verify that an assessment of each existing tank system was performed by a registered professional engineer by January 12, 1988, or within one year of tank system becoming a hazardous waste tank system subsequent to July 14, 1986. (40 CFR 264 or 265, -191, as applicable)

Verify that daily inspections of tank systems are being conducted and documented. (40 CFR 264 or 265, .195, as applicable)

Evaluate the facility's program to install secondary containment for existing tanks. (40 CFR 264 or 265, .193(b), as applicable)

(NOTE. If any spills or leaks were noted during facility incr'ections, evaluate whether these spills need to be reported.) (40 CFR 264 or 265, -1%. as applicable).

3.0 Undernround Stowe Tank Wsr) Promans (40 CFR 280)

3.1 Management of Underground Tanks

Test the facility's management of USTs by performing the following

*OK Comments

*Note: OK - Appears to meet requirements NI - Needs improvement NA - Not applicable

AFMA/3M/AKZO NOBEL/Environmental Guide August 1994

I


- Tour the site and interview personnel to identify underground storage tanks and piping systems used by the facility. Verify that the facility has a complete list which specifies the location, size, age, materials of construction, and contents of each tank.

- Note any strong odors, presence of surface stains, stressed vegetation, evidence of spills, and damaged fill pipes in and around the area of the underground tank.

- Verify that the construction material/design of USTs is compatible with the material being stored. (40 CFR 28032)

- Verify that recently installed steel USTs have cathodic protection and are thereby protected from corrosion. Verify that non- steel USTs are constructed of corrosion- resistent materials. Verify that all USTs are designed to prevent any releases. (40 CFR 28020,21)

- Verify that the facility has implemented (if applicable) a program to test the integrity of USTs and piping integrity testing programs and that the type and frequency of testing is appropriate for the age and location of the tanks. (40 CFR 280.40)

- Document that leak detection systems or procedures are in place. (40 CFR 280.40)

32 Notification Reauirements

- Verify that each underground tank currently in use or taken out of service since January 1, 1974 was reported to the proper governmental agency by May8, 1986. (40 cm 280.22)

'OK

-

NI - NA Comments


AFMA/3M fAKZ0 NOBELfEovimnmcntaI Guide August 1994

SOLID AND HAZARDOUS WASTE MANAGEMENT Page: 1d ENVIRONMENTAL AUDIT CHECKLIST Date: 5/96.

- Verify that the facility notified the appropriate agency within 30 days of bringing into use any USTs installed after Mays, 1986. (40 CFR 280.22)

- Verify that if a release fro= a UST or UST system has been discovered, the release was reported, investigated, and confirmed in accordance with applicable requirements. (40 CFR 280, Subpart E)

33 Release Response Rwuiremcnts

- Verify that all UST or UST system releases have been corrected or are being corrected in accordance with applicable requirements. (40 CFX 280, Subpart F)

(NOTE: The scope of this audit does not include an exhaustive or comprehensive review of corrective adions.)

4.0 PastDisposai and Omrational Practices

4.1 Past D- Pradices

- Determine through interviews with facility personnel and review of aerial photographs or other documents, if wastes have been disposed of on-site since the facility started operations. If wastes were disposed of on- site, gather information on how and where disposal occurred and what types of waste remain on-site.

- Verify that the facility has fded notification of past on-site hazardous waste treatment, storage or disposal activities as required under CERCLA Section 103(c).

Comments




- Review and evaluate the above information in conjunction with current waste management and empty drum management practices, information regarding the condition of underground tanks, and soil analysis; and develop a list of potential or actual areas of subsurface contamination.

(NOTE The scope of this audit does not include an exhaustive or comprehensive review of corrective actions.)

5.0 Condition* Exempt Small Quantity Generator Comdiane Ad)vities (40 CFR 2615)

(NOTE: Some states do not recognize Conditionally Exempt Small Quantity Generator Status. Check the requirements of the state in which the facility is located before completing this section.)

- Interview facility personnel and/or review relevant documents (waste analyses) to verify that the generator has determined if its wastes are hazardous or nonhazardous. (40 CFR 26211)

- Verify, by reviewing shipping and/or accumulation logs, that the facility has not exceeded the small quantity generator limitation. (40 CFR 261J(a),(e)

- Verify, by reviewing shipping records or other information, that the hazardous wastes are transported, treated, stored, or disposed of by a facility permitted to do so by the U.S. EPA. (40 CFR %15(f)(3) or (d(3))

- Verify that the facility has an emergency plan that includes hazardous waste emergencies as part of its scope.

- Verify that the facility is not transporting its own hazardous waste unless it is specifically permitted to do so by the U.S. EPA.


.OK NA Comments

"I - Needs improvement NA - Not applicable

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SOLID AND HAZARDOUS WASTE MANAGEMENT Page: 16 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/9;

i

613 Adivities of Generat:-s Generab ;3etweea 1 ~ ~ o o o Kilogram s c Waste Pc: ic~onth (40 CFR 26234(d))

61 Waste Determination

Test the facility's program for characterizing its wastes by completing the following

- Based upon a review of faality operations and processes, determine whether the facility has identified all potential points of waste generation.

- Verify that the facility's procedures for classifying its wastes as hazardous or nonhazardous are used. Assess whether the results are reliable.

- Ascertain whether thL iaality follows procedures for preventing the mixing of hazardous and nonhazardous wastes. (40 CFR 261,26211)

Rcniaeriw as a Hazardous Waste Genera! .-

ierify, by reviewing the facility's hazardous waste permit application and corresponding documents, that an EPA identification number has been obtained. (40 CFR 262.12)

63 Read ing of Hazardous Wastes

If the facility recycles hazardous waste, verify that proper procedures are being -mplemented. (40 CFR 266)

6.4 Hazardous Waste Accumulation P r a d i ~ s

Verify that appropriate measures are being implemented by the facility with regard to hazardous waste satellite and accumulation area requirements t- performing the following:

*OK NI - NA Comments


AFMA/3M/AKZO NOBEL/Envimnmcntal Guide A i i m i r t lood


- Tour the hazardous waste accumulation area(s) to verify that wastes are properly marked with date of accumulation and labeled with the words "hazardous waste," marked with an EPA sticker prior to transport, aisle space is adequate, and containers or tanks are in good condition and kept closed unless adding or removing wastes. Ve@ that ignitable, reactive or incompatible wastes are being stored away from other wastes. Identify evidence of leaks. (See Section 1.6, "On-Site Accumulation Practi ces..." for appropriate citations.)

- Document the period of time wastes are accumulated on-site to determine if wastes are stored for less than or greater than 180 days. Verify that the facility conducts and documents inspections of the accumulation area(s) regularly. (40 CFR 26234(d), (e), or (0; as applicable)

- Verify that hazardous wastes are accumulated at the point of generation in a manner that complies with the satellite requirements under 40 CFR 26234. That is, tour the satellite areas and note that full 55-gallon drums of hazardous waste or one- quart containers of acutely hazardous waste are removed within 72 hours and are marked with the words hazardous waste or other words that identify the contents of container. (40 CFR 26234(c))

6 5 Disposal and Transportation Vendors

Verify that the facility uses only U.S. EPA permitted transport, treatment, storage, and disposal vendors.

- Verify that the facility does not transport its own hazardous waste unless it is specifically permitted to do so by the U.S. EPA.


*OK NI - NA Comments




6.6 Hazardous Waste Manifests

Test the generator’s manifest program by completing the following

- From a review of shipping records or other independent documents, verify that manifests were completed for all hazardous waste transported off-site. (40 CFR 26220)

- Verify the accuracy and completeness of manifests (including the waste minim-ation certification and proper waste characterization etc).

- For all (or, as appropriate, a sample of) waste types, verify that the generator waste report accurately reflects waste shipments. (40 CFR 262.41)

- Verify that the facility notified EPA of its intent to export hazardous wastes. This notification must be made 60 days prior to shipment, and EPA will notify the facility if consent has been obtained. (Notification may be for a period extending 12 months or less.) (40 CFR 26253)

- Verify that the TSDF copies of the manifest were returned within 60 days after the waste was accepted by initial transporter. If not, confirm that the generator notified the EPA (effective March 23,1988). (40 CFR 262.42(b))

- Verify that manifests and waste analyses are retained for the required time period. (40 CFR 262.40)

NI NA Comments




6.7 Traininn and Emergency Preparednw

Verify, by reviewing training documents and interviewing key personnel, that employees associated with hazardous waste handling procedures are thoroughly familiar with proper waste handling and emergency procedures. emergency coordinator. (40 CFR 26234(d)Qiii))

Document the name of the

- Verify that the facility has a preparedness and prevention program that includes:

- Having a person responsible for coordinating all emergency response measures on the premises or on call at all times. (40 CFR 26234(d)(S)(i))

- The posting of the following information near the telephone used to summon emergency aid:

The name and telephone number of the emergency coordinator,

The location of fire elbinguishers, spill control equipment and fire alarms.

The telephone number of the local fire department (unless a direct alarm has been installed). (4 CFR ~ 2 W u 5 ) C i i ) )

- Procedures for reporting releases that could threaten human health outside the facility or reach surface water to the National Response Center. (40 CFR 26234(d)(S)(iii))

The provision of communication equipment that allows for the alerting of facility personnel and summoning external emergency aid. (40 CFR 26532(a), (b))

-

'OK NI Comments


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- The provision of fire and spill control equipment (including firefighting water) appropriate in type and amount for hazardous wastes generated and accumulated by the facility. (40 CFR 26532(c),(d))

- Procedures for testing and maintaining alarm systems; and spill.control, fire control and decontamination equipment. (Verify that these procedures have been implemented adequately to allow proper operation in the event of an emergency) (40 CFR 26533)

- The provision of immediate access to means of communication with other faality personnel by persons handling hazardous waste. (40 CFR 26534)

- Arrangements with external emergency responders (e.g. fire department, police department, cleanup contractors, local hospitals) to familiarize them with the facility's hazards and emergency plan(s) and to provide for the appropriate delegation of authority in the event of an emergency. (40 CFR 26537)

70 Solid Waste Pr-

7J Non-Hazardous Non-Sveaar - Waste Manwment Promans

- Verify that vendors (or municipal services) used for disposal of sanitary wastes, constrxtion and demolition debris, are permitted to do so.

- Verify that all noo-hazardous waste accumulation containers are properly managed and that wastes in these containers are properly segregated.

*OK NA Comments

*Note: OK - Appears to meet requirements Ni - Needs improvement NA - Not applicable


SOLID A N D HAzkRDOUS WASTE MANAGEMENT Page: 21 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/94

- Check sanitary waste containers for inappropriate items (e.g. empty drums, tire, potentially-hazardous items, items for which recycling programs are in place). Check for spillage on the ground.

72 Non-Hazardous 5- Waste Manwemeat Progams

- Verify that vendors used for disposal of speaal wastes are permitted to do so.

- Ve+ that the facility accounts for and documents the proper disposal of all its special wastes.

- Ve+ that special waste accumulation containers are properly managed and that these wastes are adequately segregated from other wastes and each other.

- Verify that specid wastes are not being commingled with hazardous and other wastes.

73 Solid Waste Recvcliw Program S

- Verify.that materials accumulated for recycling are properly stored and segregated from other wastes. Confirm that cutting and/or lubricating oils that may drip or leak from scrap metal containers are contained, kept from entering soils or water, and are disposed of properly.

'OK NI - Comments



WATER POLLUTION CONTROL ENVIRONMENTAL AUDIT CHECKLIST

Facility/Unit/Area Audited:

Date of Audit:

Period Audited:

Auditor:

Persons Contacted/Interviewed:

Areas Toured:

Page: 1 Date: 5/94


WATER POLLUTION CONTROL Page: 7 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/5

11) Dischamc Identification (40 CFR l2226(a))

Test the facility's program for identifying its wastewater sources (ie., where the wastewater comes from) and discharge points (Le., locations where wastewater leaves the site). Assess effediveness by performing the following:

- Prepare a listing of sources and discharge points by

Reviewing process flow diagrams, piping diagrams, sewer maps, note whether drawings are "as-built" or "proposed design", and whether older maps or diagrams have been regularly revised to reflect facility modifications. If "proposed design" or "design" drawings are used, verify that they reflect actual flows and equipment.

Touring facility process operations and noting wastewater sources. Note destination (Le. on-site (pre)treatment facilities, off-site treatment, direct discharge, etc);

Touring the facility (and satellite facilities) and noting all places where normal or unusual discharges of wastewater or contaminated surface water leave or may leave the facility boundary;

Noting all discharges where there is visual evidence of impact on or near receiving waters (e.& oil, foam, discoloration, and/or floating solids); and

Identifying points where flow from adjacent property, or surface water runoff may influence facility effluent quality.

*OK NA Comments

AFMA/3M/AKzo NOBEL/Environmental Guide August 1994

I .


- Compare your listing with facility records and note any points and sources contributing to the wastewater discharge(s) which have not been identified and accurately described.

Re6tration and Discharge Permits (40 CFR lu, 404 et seq)

Permit A~pEcrations

If the facility is required to submit permit or registration applications for wastewater discharges, verify that these applications are accurate and complete.

Stormwater Discharge Permits

Ver;fy that the facility determined the need (or lack thereof) for a stormwater permit(s). If a permit is required, confirm that an appropriate and accurate permit application(s) has been fded in a timely manner. (See 40 CFR 122-26(c) for permitting requirements.) (e.g., Part 1 of group permits should be submitted by May 18,1992, individual permits for discharge associated with industrial activities are due October 1,1995 etc) Verify completion of required sampling, flow measurement, and appropriate permit application forms. (40 CFR 12226(c))

- Veri& that the facility determined the need for a Best Management Practice Plan (BMP) under the stormwater permit rules. (NOTE: Coordinate the review of the plan with the completion of the Spill and Emergency Planning and Control Protocol.)

- Examine the applications for completeness of data, compliance with required filing dates, and accuracy (Le., whether listed effluent constituents and loading reflect current operations, whether there have been any process/chemical modifications to affected operations since the application was filed, etc.).


'OK NI - NA Comments



WATER POLLUTION CONTROL Page: ENVIRONMENTALAUDITCHECKLIST Date: 5 / !

*OK NI NA Comments - Confirm that the applications were signed

by the person specified in applicable requirements or that person's duly authorized representative. (40 CFR 122.22)

- Review a site map showing topography of stormwater drainage areas. Compare with observations from facility tour(s). Review sample collection activities/documentation associated with storm events. Note date(s) and duration.

- Through a review of capital and major expense project documentation, confirm that changes in raw materials, volume, or processes are properly reflected in permit applications.

- Conf i i that all wastewater discharge points or sources noted in Section 1.0 above are properly permitted. List any discharges which are not properly permitted.

- Note permit renewal dates. Are all permits current? What system is in place to ensure permits are maintained and/or renewed so that permitted status does not lapse?

3.0 Conformance with "DES or POTW Standards (Applicable regulatory requirements)

- Verify facility conformance with permit conditions, sewer ordinances, P O W regulations, or pretreatment standards by performing the following

- Develop a schedule of all permit requirements, sewer use regulations and/or pretreatment standards currently in effect. (This may have been done during Step 20.)


AFMA/3M/AKZO NOBEL/Environmcntal Guide -.

t

WATER POLLUTION CONTROL Page: 5 ENVIRONMENTAL AUDIT CHECKLAST Date: 5/94

*OK NI NA Comments - Verify that operating procedures or

installed systems are capable of providing information substantiating compliance with these requirements by performing the .

following:

Review calibration and maintenance records for water pollution control equipment to verify conformance with permit or regulatory requirements.

Confirm that the sampling location and sampling method used results in representative samples, and that sampling frequency agrees with permit or established guidelines.

Review the facility's intemal procedures to ensure that unauthorized materials are not put down the sanitary sewer.

Review the laboratory analytical procedures used by the facility to analyze wastewater and verify compliance with best management practices or with the guidelines and test procedures set forth under 40 CFR 136. Determine whether proper sample containers, preservation techniques, holding times, and quality control procedures are used. (Note any significant discrepancies between procedures used and those approved.)

Veri@ laboratory certification to perform wastewater analyses required for routine reporting. Have intemal/extemal audits been performed?

- Review a representative sample of monitoring records (e.g., recorder charts and laboratory results) and note the type and frequency of effluent exceedances.

'Note: OK - Appears to meet requirements NI - Needs improvement NA - Not applicable

.4FMA/3M/AKZO NOBEL/Envimnmental Guide August 1994

WATER POLLUTION CONTROL Page: 6 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/9.

Review internal records for proposed corrective actions for equipment malfunctions, breakdowns, or effluent exceedances. Determine whether corrective action was effected promptly (Le., revision of operating procedures, repair of equipment, installation of new equipment, etc).

- If the facility is under a compliance schedule, confirm that all requirements have been met.

41) Manwment of Wastewater Treatment Units (Applicable federal and state regulatory requirements)

Review and test the facility's management of wastewater treatment units by performing the following

- Verify that the waste treatment unit is beiig regularly inspected and maintained under a0 established preventive maintenance schedule.

- Verify that any operational or maintenance procedures spedfically required by the facility's POTW, NFDES permit, and/or pre-treatment standard are comptied with by the facilities.

- Verify that wastewater treatment procedures are defined and compliance with them is documented.

- Confirm by reviewing documents that wastewater treatment operators have training and licenses as required by state or local authorities.

- Confirm that wastewater sludges are being handled and disposed of properly (Le., sent to facilities having the necessary permits or approvals for treatment or disposal). (NOTE. Coordinate this portion of the audit with the completion of the Solid and Hazardous Waste Management checklist.)


*OK NI - Comments


AFMA/3M/AKZO NOBEL/Environmental Guide


5.0 RecordkeeDing and Rerxlrtinn Svstems (40 CFR 122,404 et seq)

C o d i the implementation of water pollution control recordkeeping and reporting procedures by carrying out the following steps:

- Review facility files to verify that accurate records on sampling (Le., date, place, time, person taking the sample) and analysis, equipment maintenance and any required reports (e.g., unanticipated batch dischargers, emergencies) are being maintained for the required 3 years.

- Coof i i that discharge monitoring reports have been submitted to the appropriate regulatory agencies in accordance with the required frequency and contain the required information (This may have been done above.)

- Review reporting procedures. Compare information from routine recordkeeping activities with generated reports and verify that data transcription practices result in accurate reports.

- Confirm that discharge exceedances were properly reported to regulatory agencies. (Under federal and state regulations, exceedances must be reported within 24 hours of discovery or knowledge of the exceedance and followed up with a written notification letter no more than 5 days later, unless a waiver is granted.) (40 CFR 122)

6.0 Minimization Prop~ams

- Confirm that systematic efforts are being made to reduce wastewater volume and/or level of contamination. Comparisons should be made based on a product

increased/decreased production volumes. , quantity basis to account for

NI NA Comments


AFh4A/3M/AKZO NOBEL/Environmcntal Guide August 1994

WATER POLLUTION CONTROL Page: P ENVIRONMENTAL AUDIT CHECKLIST Date: 5/!

- Verify segregation of hazardous materials and hazardous wastes from wastewater streams. Note potential means of contamination.

711 Past Operational Practices

Determine, through interviews with facility personnel and review of aerial photographs or other documents, whether or not the facility used retention ponds or sumps for wastewater discharges in conjunction with release to surface waters or a P O W . Document whether or not these ponds were lined and if any soil analyses have been conducted in the %<unity of the ponds. Determine whether sumps or "u-drains" are periodically inspected for structural integrity. Verify that appropriate follow up activities have been performed if structural defects have been identified. Review and evaluate this information in conjunction with current wastewater discharge management practice: and develop a list of potential or actual areas of subsurface contamination.

*OK NI NA Comments



I

SPILL AND EMERGENCY PLANNING AND CONTROL Page: 1 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/94

Facility/Uni t/Area Audited:

Date of Audit:

Period Audited:

Auditor:

Persons Contacted/InteMewed:

Areas Toured:


!

SPILL AND EMERGENCY PLANNING AND CONTROL Page: 3 ENVIRONMENTAL AUDlT CHECKLIST Date: 5/ !

to Oil and Chemical S d l Plan (40 CFR 112)

(NOTE: The regulation cited above applies only if the facility has storage capacity for petroleum products exceeding

0 42,000 gallons below ground (buried);

0 l,320 gallons above ground (not buried); or

0 660 gallons in a single container.

Auditors should refer to 40 CFR 112 for this section and d o n 3.0 only if these storage capacities exist at the facility. Some states and municipalities also have spill control and countermeasure requirements for lesser volumes or materials other than petroleum products. If the facility does not have a spill plan, go to Section 2.0; however, note whether or not the fadlity is required to have a spill plan based on the volume of oil or other materials regulated by state or local regulations stored on-site.)

.

Test the adequacy of the facility's oil and hazardous substance spill prevention and control plan by performing the following:

- V e W that the plan has been certified by a registered professional engineer and reviewed by the facility within the past three years. (40 CFR 1123(d))

- Verify that the plan contains the required elements and is based on good management practices. For example, verify that the plan includes a discussion on:

Past spill events, enforcement actions, and fmes. (40 CFR 112.7(a))

'OK NA Comments

Note: OK - Appears to meet 'requirements M - Needs improvement NA - Not applicable

AFMA/3M/AKZO NOBEL/Envimnmcntal Guide August 1994


Location and volume of oil and hazardous substances stored, including drum storage areas. (40 CFR 112.7(b))

Recent facility changes in design or operations which may affect spill potential. (40 CFR 1125)

Containment and diversionary structures or equipment used to prevent and/or control

(40 CFR 1127(c)) spills.

Provisions for the management and prevention of hazardous waste and/or PCB spills.

Spill response measures, if containment or diversionary structures are not used where oil or hazardous substances are stored. (40 CFR 112.7(d))

Procedures for reporting CERCIA hazardous substance releases, EPCRA extremely hazardous substance releases, or other spill events.

Responsible personnel for spill response activities. (40 CFR 112.7(e)(10))

Spill response procedures. (40 CFR 112.7(e))

Management commitment statement. (40 CFR 112,7(d)(2))

2 0 Spill Plan Imulementation or Spill Prevention hdQS

Test that the facility has implemented its spill plan as designed, and review and evaluate facility control practices (if a spill plan does not exist). Comment on conformance with good management practices by performing the following:

NA Comments


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SPILL AND EMERGENCY PLANMNG AND CONTROL Page: 4 ENVIRONMENTAL AUDITCHECKLIST Date: 5 / 9

- Tour the facility to confirm that spill control activities stipulated (Le., location of dikes or warning signals, drum management practices) in the plan have been implemented. Note any areas of spillage and assess the potential for spills in these areas to reach waterways.

- Tour the facility and note the location and quantity of spill control materials and equipment. Evaluate whether the location and quantity of these ma?enals and equipment provide the faaiity with adequate spill response potential.

- Through inquiry and review of facility records, veriry whether or not aboveground storage tanks, piping, and raw material storage areas are routinely inspected and whether these inspections are being documented.

- Ver;fy by reviewing engineering designs or observation that storage tank secondary containment volumes are adequate.

- Verify that underground portions of steel tank systems (Le., tank bottoms and piping) are under cathodic protection. Are cathodic protection settings recorded at least monthly? Is the system reviewed at least annually by a qualified cathodic protection speaalist (e.g. NACE-cerGfied specialist, qualified PE, etc) (40 CFR 1127(e))

- For storage tanks or storage areas with no secondary containment, evaluate the feasibility of such systems. Conclude whether secondary containment would be a good management practice and feasible.

NI NA Comments



I .


- Verify whether, when not in service, a representative sample of master flow and drain valves on tanks and dikes are locked in a closed position, starter controls for pumps are locked in off position, and loading and unloading connections of pipelines are capped or blank flanged. Also evaluate site security measures. (40 CFR 1l2.7(e)(9))

- Verify that all inspections performed under the plan are conducted in accordance with schedules specified in the plan and inspection log sheets are retained for the time period specified in the plan. Also verify that problems noted in the inspection log sheets are addressed in a timely fashion and the corrective actions noted in the records. (40 CFR 112.7(e)(8))

3-0 Oil and Hazardous Substance Unloadiw and Loading PraCiiQs

. (40 CFR 1l2.7)

Inspect loading and unloading areas on-site and assess adequacy in relation to the facility’s unloading or loading practices and ability to control spills.

4-0 SD~U and Release Reporting

Test the implementation of the facility’s program for reporting oil, hazardous substances, or hazardous waste spills and releases, etc, by completing the following:

- Interview facility personnel and review a sample of incident reports to determine if any releases which threaten human health or the environment (e.g., a discharge of oil in violation of Section 311@)(3) of the Federal Water Pollution Control Act (see 33 CFR l53.203) or reportable quantities of hazardous substances) have occurred during the review period).

‘OK

-

-

Comments



S P U A N D EMERGENCY PLANNING AND CONTROL Page: f

ENVIRONMENTAL AUDIT CHECKLIST Date: 5/9-

. Note: OK - Appears to meet requirements

- Review facility procedures for reporting sudden releases of SARA 304 and CERCLA 302.4 listed chemicals in excess of their specifred reportable quantity ( R O ' S ) .

- Review the facility's declamation and reporting of any S A R A 304 and CERCLA 302.4 listed chemical that is released continuously and that such a release is related to the process and meets the requirements of 40 CFR 3028 and 40 CFR 355.4(2)@)

- Veri&, by reviewing documents and interviewing key personnel, that the appropriate levels of management and/or the proper authorities were notified of the releases. For example:

National Response Center (NRC) for discharges and releases of materials exceeding the CERCLA reportable quantities. (NOTE. Some state response centers notify NRC for the der-check the spedfic procedure needed for each state.) (40 CFR 302.6)

State water poi:;ltion agencies for releases which reach waters of the state (including groundwater).

Regional EPA offices for hazardous waste spills from tanks or secondary containment systems which exceed one pounc: or are not contained within diversionary structure. (40 CFR 264 or 265, Subpart J).

Local emergency planning committee coordinator of any discharge/release of extremely hazardous substances (SARA reportable quantity) or hazardous substances that results in exposure outside a location's boundaries. (40 CFR 355.40)

*OK - NI - NA Comments





51) SARA Notitication and Rem& Program

Test the facility's SARA (SARA 111) notification reporting program. By reviewing agency correspondence or interviewing key personnel, verify that:

- As of May 17, 1987, the facility notified the state emergency response commission of extremely hazardous substances (see listing under 40 CFR 355) on-site in amounts greater than the designated "threshold planning quantity." (40 CFR 35530(b))

- As of September 17, 1987, or 30 days after, whichever is sooner, the establishment of a local emergency planning committee or state emergency response commission, that the facility notified state and local authorities of its selection of an emergency response coordinator. (40 CFR 35530(c))

- As of October 17,1987, the facility has submitted to the local emergency planning committee, state emergency response commission, and local fire department, a list of hazardous chemicals (Le., any chemical substance as defined by OSHA's hazard communication standard) handled on-site or their respective material safety data sheets (MSDSs) subject to Title I11 regulations and updates. (If a list is submitted, verify that MSDSs are available if requested by the local emergency planning committee.) ( S A R A Section 311, 40 CFR 370.20)

- Verify that procedures are in place to provide updated information to the groups mentioned above if new non-reported substances or a hazardous chemical exceeds its threshold for the first time.

Comments



SPILL AND EMERGENCY PLANNING AND CONTROL Page: 8 ENVIRONMENTAL AUDIT CHECKLIST Date: 5 / 9

- By March 1, 1988, and annually thereafter, that the facility submitted an emergency and hazardous chemical inventory (Le., Tier 1 or 2) form to the groups mentioned above. (SARA Section 312,40 CFR 370.20)

- By July 1, 1988, and annually thereafter, that a Form R was submitted providing information on releases of toxic chemicals to the environment. (NOTE: Backup data pertaining to threshold determinations and release calculations must be retained at the facility.) (SARA Section 313,40 CFX 372)

- By January 1, 1989, product labels contain information stating that materials in the product are subject to S A R A 313 provisions (if applicable).

- Submitted Form R reports are complete and accurate. Complete the following for a sample of data submitted.

Review threshold determinations for reporting:

Spot check inventory, accounting, purchasing OF production records thz were used to determine reportable chemicals.

Is facility aware of lowering thresholds from 1987 to 1989 (75,000 Ibs; 50,OOO lbs; 25,OOO Ibs) for materials manufactured or produced?

Did facility correctly determine materiais that are "otherwise used" and subject to the 10,ooO Ib threshold?

'OK NA Comments

*Note: OK - Appears to meet requirements NI - Needs improvement NA - Not applicable

k%AA/3M/AKZO NOBEL/Environmental Guide August 1994

SPILL AND EMERGENCY P L A N " G AND CONTROL Page: 9 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/94

- Did facility inventory as part of the Form R submittals the quantities of regulated chemicals entering waste streams prior to treatment, recycling or disposal? Did facility determine- the proportions of the same that were treated, recycled, or disposed on-site vs. off-site? Did facility prepare a 2-year projection of the same information? (This will be codified in 1992 or 1993 under 40 CFR 272 as the "Source Reduction and Recycling Report")

- Review approach to release calculations:

If mass balance approach was used for estimating releases were all possible inputs and outputs considered?

Were all fugitive air emission sources included? (e.g. equipment leaks, on-site wastewater treatment processes, material handling and transfer, storage piles)

Did facility correctly report releases directly to surface water (Section 53 of Form R) vs. releases to a P O W (Section 6.1 of Form R)?

V e W that off-site shipments of waste for recyde/reclamation are fi included on Form R. (It may have been necessary to calculate this as part of mass balance even though not reported).

6.0 Emerpenw Resmnse Teams

(NOTE: Per OSHA's defuzition of emergency response (29 CFR 1910.120(a)(3)), the OSHA requirements cited below apply only to personnel responding to emergencies from outside the immediate release area and to designated emergency responders.)

If emergency response teams are expected to respond to situations involving hazardous substances or waste, verify that:


*OK NA Comments



I

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SPILL AND EMERGENCY PLANNING AND CONTROL Page: 10 ENVIRONh4ENTALAUDITCEECKLIST Date: 5 / 9

- An emergency response plan contains the elements required by OSHA standard 29 CFR 1910.12O(q)(l), and (2).

- On-site emergency response team personnel receive initial and annual training commensurate with the emergency role(s) called for them in the facility's emergency response plan for spills/releases of hazardous materials or waste. For specific training/experience requirements for hazardous material spill/release responders, see 29 CFR 1910.120(q)(6), and complete the following steps:

Fist, determine which of the five duty (function) categories each facility person or job category, named in the plan, is expected to perform.

Second, determine the level of training, experience or competency demonstration (initially and annually) that must be documented for that person or job category.

Third, confirm that the facility has adequately documented that each person, and/or person in each job category, has received training or experience or demonstrated competency in the skills required (initially and annually).

71) Past Operational Radices

Determine, through interviews with senior personnel and review of aerial photographs or other documents, how and where 05 or hazardous substances were stored on-site in aboveground containers, whether these have been released in the past, and the locations of oil pump compressors. Note whether these materials were stored on concrete surfaces or other types of protective barriers. Determine whether or not any soil analysis has been conducted on-site. Review and evaluate this information in conjunction with current spill prevention practices and develop a list of potential or actual areas of subsurface contamination.

*Note: OK - Appears to meet requirements

NA Comments



AIR POLLUTION CQNTROL ENVIRONMENTAL AUDIT CHECKLIST

Page: 1 Date: 5/94

FacilitylUnitlArea Audited:

Date of Audit:

Period Audited:

Auditor:


i

Areas Toured:

AFMA/3M/AI(ZO NOBEL/Environmcntal Guide August 19p4

AIR POLLUTION CONTROL Page: 2 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/94

*OK

11) Emission Source Identification

Test the facility's programs for identifying its emission points (locations where air emissions enter the atmosphere) and sci.-ces (Le., where are the emissions coming from) by performing the following:

- Locate and note all (or, as appropriate, a sample of) points of continuous and periodic emissions (stacks, ventilators, wall fans, exhaust ports, large VOC storage tanks (e.&, >2O,OOO gallons) etc.), on a

noted during the faality tour, but a thorough inspection of the facility's roof top(s) should be conducted ig order to locate all points.)

. facility map. (Some emission points can be

- Identify the location of all emission control and monitoring facilities, and cross reference to em'ksion list (if available).

- Note any likely sources of emissions not included above (Le., open burning, fugitive dust, smoke generation, solvent storage and use, coatings storage and use, etc).

- Compare the points identified above with the most recent emissions inventory. Note any discrepancies. If an emissions inventory does not exist evaluate the need for suc6 a document from a management control perspective.

20 Re&tration and Permits

If the facility is required to submit permit or registration applications for air emission sources or pollution control equipment, verify that these applications are accurate and complete by performing the followiiig:

(NOTE: Review copies of construction and new source permit applications submitted since 1975.)

.

NI NA Comments



AIR POLLUTION CONTROL Page: 3 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/94

'OK NI NA Comments ~~

- Examine the applications for completeness of data, accuracy, and compliance with required filing dates.

(NOTE: Ensure that applications for both "permits to construct (or install)" and "permits to operate" have been submitted as required.)

- C o n f i i that the applications were signed by the person specified in applicable requirements or that person's duly authorized representative.

- Conf i i that all emission sources and equipment noted in Section 1.0 (above) are properly permitted.

- For new or recently installed equipment, check compliance with prevention of signifcant deterioration and nonattainment rules, if applicable.

3.0 Conformance with Air Emission Standards

- Verify facility conformance with permit conditions or regulatory standards by performing the following:

- Determine the regional air quality status for the facility's location (;.e-, %on- attainment" for NO,? SO,?, CO?, PM,,?, VOC?, lead?).

- Develop a schedule of all permit and regulatory requirements, compliance order schedules, and state agreements currently in effect (e.g., emission limitations, equipment maintenance frequency provisions). Requirements may include, as applicable, New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) Standards, State Implementation Plan rules, and also State Hazardous Air Pollutant requirements. Extra requirements for non-attainment areas must also be determined.

*Note: OK - Appears to meet requirements NI - Needs hprovement NA - Not applicable


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AIT; POLLUTION CONTROL ENVIRONMENTAL AUDIT CHECKLIST

- Veri@ that written operating procedures, written maintenance programs, and installed systems (e.g., monitoring devices) are capable of providing information substantiating compliance with these requirements. For example:

Review calibration and maintenance records for emission control equipment to verify that the equipment is maintained as specified by applicable regulations, pennit conditions, and manufacturers' recommendations. Note the actual frequency of the calibration and maintenance.

If continuous emissions monitoring is used to demonstrate compliance, verify that written calibrxion and QA/QC procedures have been developed and implemented.

If emissions are limited by opacity standards, verify that plant personnel are properly trained to determine opacity, or alternately, that opacity monitoring devices are utilized.

Observe the equipment to confim that it is in the condition stated by maintenance records and connected to the sources specified in the permit application.

- Review operational data and, if available, monitoring records to verify that all applicable permit standards have been met and that any uperational malfunctions have been recorded, reported (if required), and corrected.

- Determine whether any process changes have been implemented that are not reflected in the permit application data or permit updates.

'OK NA

Page: 4 Date: 5/94

Comments



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AIR POLLUTION CONTROL ENVIRONMENTAL AUDIT CHECKLIST

- Review documents on air emission episodes and interview plant personnel (e.g., maintenance, security, others) to verify that episode reports are accurate, complete, and (if required) have been submitted to regulatory agencies.

- For any permit or regulatory deviations, equipment malfunctions, and emission complaints noted, review internal records for proposed and completed corrective actions. Note &y instances where appropriate and effective corrective actions were not taken. (Reporting of these situations is covered under Section 7.0)

4.0 Gasoline DisDensing Operations

Verify facility compliance with federal fuel requirements by completing the following:

- Confirm that appropriate vapor control systems or submerged fill pipes have been installed on gasoline storage tanks.

- By checking the labels and nozzles on gasoline dispensing pumps, and reviewing purchasing records for fuel deliveries, determine whether the gasoline dispensed for motor vehicles conforms with federal regulations (e.g., unleaded gasoline, dispensed using unleaded dispensing nozzles for vehicles requiring unleaded gasoline).

5.0 Fuel Burning EQ uiDment

- Confirm that the sulfur content of fuel oil used for fuel burning equipment (e.g., boilers) conforms with that prescribed in applicable regulations or best management practices by reviewing purchasing records and other available documentation (e.g., fuel analyses).

*OK - NI - NA

Note: OK - Appears to meet requirements NI - Needs improvement

Page: 5 Date: 5/94

Comments

NA - Not applicable

AFMA/3M/AKZO NOBEL/Envixunmcntal Guide August 1994

AIR POLLUTION CONTROL ENVIRONMENTAL AUDITCHECKLIST

- If the facility burns hazardous waste fuel, above the a p $ a b l e exemption limits, in a boiler or industrial furnace, confirm that a pre-compliance certification was fded by August 21, 1991. (40 CFR Part 266, Subpart H)

- If an air pollution alert or emergency plan is required, review the facility's plan to verify that it conforms with regulatory requirements.

71) Recordkeerting and R e m " Systems

Veri@ the implementation of regulatory and permit driven recordkeeping and reporting procedures by carrying out the following steps:

- Develop a list of recordkeeping requirements outlined in air permits or state requirements (e.g., record retention).

- Review facility files to veri@ that required records, such as monitoring and equipment calibration documents, are b e i i maintained (may be done in conjunction with Step 2.0).

- If applicable, confirm that required monitoring or equipment malfunction reports, etc, have been submitted to the appropriate regulatory agencies and that these agencies have been notifed of emission exceedances or equipment malfunctions in accordance with the permit provisions and state air regulations.

8.0 Past Operational Practices

- Verify that facility programs and procedures relating to responding to community complaints of odors, dust, etc, have been -mplemented when appropriate and that the response activities were documented and reviewed.

'OK NA

Note: OK - Appears to meet requirements NI - Needs *mprovement

Page: 6 Date: 5/94

Comments

NA - Not applicable

AFMA/3M/AKZO NOBEL/Environmcntal Guidc August 1994

AIR POLLUTION CONTROL ENVIRONMENTAL AUDIT CHECKLJST

*OK NI - Determine through interviews with facility

personnel and review of aerial photographs or other documents whether or not the facility disposed of air pollution control equipment fdters or captured materials on- site and the location of boiler blowdown areas. Review and evaluate this information in conjunction with current air pollution control activities and develop a list of potential or actual areas of surface or subsurface contamination.

9-0 Air Pollution Prevention

- Ve- that the facility has taken a systematic approach to identifying and implementing opportunities to reduce the volume and toxicity of its air emissions.

NA

-

Page: 7 Date: 5/94

Comments



PCB MANAGEMENT ENVIRONMENTAL AUDIT CHECKLIST

FacilitylUnitlArea Audited:

Date of Audit:

Period Audited:

Auditor:


Areas Toured:

Federal Regulatory References: 40 CFR, Part 761

Page: 1 Date: 5/94

AFh4A/3M/AKZO NOBEL/Environmental Guide August 1994

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I

t

* Note: OK - Appears to meet requirements

d k d W

-~

LO Idenr.fication rtnd Management of PCJ3 Eauipment

Test the facility‘s program for identifying and managing PCB equipment by performing the following:

- Through a review of records and tour(s) of the facility, identify PCB items in storage and in use (i.e., transformers and their enclosures, capacitors, contaminated equipment, voltage regulators).

- Note all pieces of equipment which have been reclassified as PCB contaminated or non-PCB equipment. Note how the PCB concentration was determined.

- Verify that each PCB transformer identified above is accurately labeled, anc [hat all PCB items are completely documented in facility fdes. Note any disaepanaes with the most recent inventory, including any equipment which is not labeled or identified in facility records. In addition, examine vault doors or other means of access to a PCB transformer to confirm that they are marked and that the markings can be easily read by fire fighters responding to a fire involving the PCB transformzr. (40 CFR 761.40)

- C o d i that combustibles/fla”ables are not stored near PCB items and that each PCB item and storage area is appropriately labeled. Note any locations where PCB items are located near flammable materials. (40 CFR 76130(a)(l)(vG))

- Confirm that PCB transformers are not used or stored such that a risk to food or feed is posed. (40 CFR 76130(a)(l)(i))

‘OK Comments


I


~~ ~

- Confirm that any PCB transformers in or near commercial buildings have been removed/retrofitted or fitted with new fault protection, depending on classification, as of October 1, 1990. (40 CFR 76130(a)(l)(u)

- Note and evaluate the appropriateness of secondary containment practices around PCB transformers and other equipment containing PCBs (e.g., is equipment containing PCBs, with or without secondary containment, located near sewers or bodies of water). Confirm secondary containment volume requirements are met. (40 CFR 76130(a)(xG))

- Verify by reviewing inspection records and interviewing key personnel whether PCB items are regularly inspected. Note appropriateness of inspedion schedule (e.g., transformers in use or stored for reuse must be inspected at least once every three months) and codm that these inspections are documented. Note the disposition of PCB items during the audit and compare with most recent inspection documentation. Record discrepancies. In addition, verify that any required repairs or maintenance of PCB items are made and documented in an appropriate and timely manner. (40 C~(a)(l)C%x),(xv)Xv>)

2 0 StowePradices (40 CFR 761.65)

Test the facility's PCB storage practices by performing the following:

- Inspect PCB equipment and PCB items in storage and 'review storage and disposal records to confum that PCB equipment and PCB items are disposed of within one year from the date when they were frrst placed into storage. (40 CFR 761.65(a))

NA

- Comments


AFUA/3M/AKZO NOBEL/Envimnmcntal Guide August 1994

PCB MANAGEMENT Page: 4 ENVIRONMENTAL AUDIT CHECKLIST Date: 5/'

- Inspect the storage area to confirm that one-year storage facilities meet federal requirements (40 CFR 761.65@)) including

Roof and walls prevent rainwater from reaching PCB equipment and PCB items.

Adequate floor and continuous curbing (minimum height of 6 inches) are provided. Containment volume must equal or exceed the volume equal to twice the internal volume of the largest PCB article or container, or 25 percent of the total internal volume of all PCB artides or containers, whichever is greater.

No openings are present which would permit liquids to flow from the curbed area.

Floors and curbing are continuous, smooth, and impervious.

Storage area is located above 100-year flood plain.

- If PCB items are stored in areas not meeting the requirements referenced above, inspect these areas to conlirm that: (40 CFR 761.65(c))

PCB items are non-leaking or leaking items are placed in non-leaking containers, PCB items and containers have a notation which indicates the date they were taken out of service.

PCB items and containers have not been in storage greater than 30 days.

Limitations on the types of PCB items which may be stored are followed.

An SPCC Plan has been developed €or liquid PCBs in containers.


*OK Comments




PCB container labels include a notation indicating that the concentration of PCBs does not exceed 500 ppm.

- Inspect temporary and long-term PCB storage areas to confirm that these areas are properly marked.

- Review relevant documents to confirm that PCB articles and containers in temporary and long-term PCB storage are inspected every 30 days for leaks. (4 CFR 761.65(~)(5))

- Review federal requirements and then confirm by observation that liquid PCBs are stored in US. DOT-approved containers. (40 CFR 761.65(~)(6))

- If liquid PCBs are stored in containers larger than 110 gallons, confirm that the facility complies with OSHA standards found in 29 CFR 1910.106, which addresses flammable and combustible liquids. Additionally, confirm that the facility reviewed the design of storage containers used to ensure that they are structurally safe. (40 CFR 761.65(~)(7))

3-0 Fire Risk Redudion Adivities (40 CFR 76130)

Test the facility's PCB frre risk reduction activities by reviewing facility records to confirm that:

- All PCB transformers (including those in storage for reuse) have been registered with fire response personnel with primary jurisdiction by 12/1/85 Note any which have not been registered. (40 CFR 76130(a)(l)(vi))

*OK

-

-

NA Comments



PCB MANAGEMENT Page: f:

ENVIRONMENT~AUDIT CHECKLIST Date: 5/!

- PCB transformers involved in a fue related incident have been reported to the National Response Center (NRC). Note any which have not been reported. (40 CFR 76130(a)(l)(Xi))

- Verify that a plant contact name and telephone number is available in the event of a fire incident involving PCB items. (40 CFR 76130(a)(v))

- Plans have been developed to move PCB equipment off-site or to take it out of service.

Review the facility's current PCB spill cleanup and reporting procedures. Confinn compliance with EPA's PCB spill Cleanup and reporting policy guidelines. (4 cm 761.125(a),@),(c))

Verify appropriate cleanup/decontamination procedures from required documentation. Note any cleanup procedures or reporting systems which did not conform with EPA guidelines. (40 CFR 761.125(a)(5))

Confi i that PCB spills to navigable waters have been reported to the NRC. Note any which have not been reported. (40 CFR 117.2)

Conf i i that employees involved in PCB spill cleanup activities have been trained. (40 CFR 191O.l20)(q))

Verify that required postcleanup sampling measures were taken after each PCB spill. (40 CFR 761.130)

51) Rem& Retentioa and Remrtinrz Pr-

Test the facility's PCB recordkeeping and reporting programs by completing in the following:


Comments




‘OK NI NA Comments

Review annual reports for completeness. Review how the facility assembled the data used to compile the report. If there is any question regarding the report’s completeness or accuracy, select daily inventory records and manifests to confirm that the report represents PCB activities during that year. (40 CFR 761.180)

Confi that previous reports are being retained for the required Iyear time frame. Confirm that annual reports/records are available for review during normal business hours.

Confirm that the annual records contain the following:

All signed manifests generated by the facility during the calendar year.

All Certificates of Disposal that were received by the facility during the calendar Y e a r -

Verify tYat the facility maintains an annual document log (and retains each log for 3 years) and that it includes:

- The facility’s name, address, and EPA I.D. number.

- A list of the manifests generated by the facility during the year.

- Total weight, in kilograms, of any PCBs and PCB items in PCB containers, including the identification of container contents, such as liquids and capacitors.

- Total number of PCB transformers and total weight in kilograms of any PCBs contained in the transformers.

Note: OK - Appears to meet requirements NI - Needs -mprovement NA - Not applicable


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PCB MANAGEMENT Page: 9 ENVIRONMENTALAUDITCHECKIJST Date: 5/9

- Total number of PCB high or low voltage capacitors.

- For PCBs and PCB items removed from service, the location of the initial disposal or storage facility and the name of the owner or operator of the facility.

- The total quantities of PCBs and PCB items remaining in service at the end of the calendar year, indicated using the foliowing breakdown:

Total weight, in kilograms, of any PCBs and PCB items in PCB containers, including the identification of container contents, such 3s liquids and capacitors; and

Total number of PCB transformers and total weight in kilograms c.” any PCBs contained in the transformcrb and capacitors.

Review signed manifests (or shipping papers). Verify the PCB waste/container number, the facility EPA identification number, the dates when PCBs and PCB items were removed from service, the off-site commercial storage/disposal facility, date of transport, signature of transporter, and total number and weight of PCB items. ‘40 CFR 761.207).

Ve+ that inspection and maintenance records for PCB transformers are being retained for the required >year time period. (40 CFR 76130(a)(l))

Ascertain/ver;fy method used to confirm that manifested PCB waste was received by commercial store/disposer.

Verify that exception reporting is documented, if applicable. (40 CFR 761215)

~~


Comments

M - Needs improvement NA - Not applicable

AFMA/3M/AKu3 NOBEL/Environmental Guide August 1994


64 Past Omrational Practices

Determine, through interviews with facility personnel or review of other documents, whether or not the facility experienced any PCB spiIIs and reIeases to the environment in the past. Note whether any soil analyses had been conducted to determine the presence of PCBs in the soil. Evaluate this information in the context of current PCB management practices and deve1op.a list of potential or actual areas of subsurface contamination.

- Identify and note any evidence of spills around items containing PCBs.

*OK

-

NA

-

Comments


AFMA/3M/AKZO NOBEL/Ennronmental Guide August 1994

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