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Why is an Environmental Audit Important to You?
Ed Callahan
Agenda• Why perform an environmental audit?• Process of performing an audit.• What things need to be addressed during
audit?• What to do after the audit is completed?
• To determine compliance status
Why Perform an Environmental Audit?
Why Perform an Environmental Audit?
• Avoidance of regulatory violations and monetary fines
Why Perform an Environmental Audit?
• Preventative Maintenance
Why Perform an Environmental Audit?
• Complex Regulations
Why Perform an Environmental Audit?
• Environmental compliance is given a low priority
• Complacency
Why Perform an Environmental Audit?
• Good business practice
Why Perform an Environmental Audit?
• Reduce major risk
Why Perform an Environmental Audit?
• Peace of mind
When Should you Perform an Environmental Audit?
• Changes have occurred (internal or external) – Processes– Chemicals– Personnel– Regulations
• Events have occurred– Purchased a new facility– Opening a new facility– Facility or company has received a violation
When Should you Perform an Environmental Audit?
• Change in personnel
When Should you Perform an Environmental Audit?
• Violations– At your facility or sister facility
When Should you Perform an Environmental Audit?
• As matter of routine
Elements of a Good System
• Audit standards• Satisfy your individual needs• Detailed, but functional and understandable• Confirm what you are doing correctly• Provide solutions to problem areas
Elements of a Good System
• Compliance Calendar– Reminder System
• Good File Organization– Documentation of Methodologies
• Good Housekeeping• Transferable Understanding of System
– Duplicity of Knowledge
Process of Performing an Environmental Audit
• Preparation• Site Walk / Inspection (Floor Practices)• Records & Data Review (Paperwork)• Findings, Actions Required, and Priorities
Preparation
• Attorney-Client privilege• www.epa.gov/echo/ • Any industry-specific or area-specific rules• Audit checklist (regulations)• Create a list of permits and plans to be
reviewed • Know the safety requirements• Pre-Audit questionnaire
Site Walk / Inspection
• Try to tour operations in the sequence of the process (not required)
Site Walk / Inspection
• Think and ask questions
Site Walk / Inspection
• Note information on site/facility map
Site Walk / Inspection
• Look everywhere: roof, outfalls, maintenance rooms, basement, etc…
• Note “Floor Practices”
Floor Practices
• Labeled drums and secured lids• Pressure drop readings• Working communication device• Permit requirements (e.g. closed doors on
paint booth; pH of the wastewater effluent)• Visible emissions
Records & Data Review
• Reports• Plans• Applications• Safety Data Sheets (SDSs)• Recordkeeping and Inspection Documentation• Corrective Action Documentation• Support Documentation • Training Records
Records & Data Review
• Manifests• Waste Characterization Information• Lab Results• Regulatory Agency Correspondence• Purchase Records• Proof of Submittals• Old Files ???• Documenting Non-Issues
Paperwork and Floor Practices
What Things Need to be Reviewed During Audit?
• Air– Are they fulfilling the permit requirements?– Look at all permitted equipment and processes (air
emissions inventory)– Look at equipment and processes that are not
permitted. Should they be permitted?– Are all reports being submitted on-time and
correctly?
What Things Need to be Reviewed During Audit?
• Air– Are all plans developed that are required in
the permit (CAM, ERP, OM&M, etc.)? Are they following and updating plans as necessary?
– Is record keeping being completed as required?
– Review SDS’s of any coatings, paints, etc.– Inspect the roof and look at all stacks
What Things Need to be Reviewed During Audit?
• Air– Have stack tests been completed?– When are the permits due to be renewed?– Are there any planned expansions?– MACT?
What Things Need to be Reviewed During Audit?
• Wastewater (NPDES or Industrial)– Are they fulfilling the permit requirements?– Look at all permitted discharges and processes.– Look at discharges that are not permitted. Should
they be permitted?– Are all reports being submitted on-time and
correctly?
What Things Need to be Reviewed During Audit?
• Wastewater– Are all plans developed that are required in
the permit (Slug Control Plan, etc.)? Are they following and updating plans, as necessary?
– Is record keeping being completed as required?
– Review the analytical results, DMR’s, etc.– When are the permits due to be renewed?– Categorical pretreatment standards
What Things Need to be Reviewed During Audit?
• Storm Water– Do they have or do they need a storm water
permit?– Review the Storm Water Pollution Prevention Plan
(SWPPP). • Is it updated? Are they following it? Does the plan have
all of the necessary elements?
– Any sampling requirements?
What Things Need to be Reviewed During Audit?
• Storm Water– Review all record keeping and reports– Where are spill kits located?– Look at “high risk” areas– Look at housekeeping
What Things Need to be Reviewed During Audit?
• Spill Prevention, Control, and Countermeasures (SPCC) Plan – Oil Storage– Do they have or do they need a SPCC Plan?– Review the SPCC Plan. Is it updated? Are
they following it? Does the plan have all of the necessary elements and fulfill requirements?
What Things Need to be Reviewed During Audit?
• Spill Prevention, Control, and Countermeasures (SPCC) Plan – Oil Storage– Review all record keeping – Where are spill kits located?– Look at all oil storage areas– Look at housekeeping
What Things Need to be Reviewed During Audit?
• Waste– What is their hazardous waste generator status
(CESQG, SQG, LQG, or TSDF)? This will determine the requirements they must adhere to.
– Tanks: “a potentially burdensome task”– Is all waste properly characterized (sludges, dust,
etc.)?
What Things Need to be Reviewed During Audit?
• Waste– Review all record keeping, manifests, and
reports– Inspect all satellite accumulation and
hazardous waste storage areas– Review Universal Waste program
What Things Need to be Reviewed During Audit?
• Chemical Reporting – Tier II’s– Hazardous substances – very vague– Extremely hazardous substances (EHS’s)– For emergency planning purposes– Review submitted Tier II’s– Review SDS’s– Look for chemicals stored in large quantities – Review purchase records
What Things Need to be Reviewed During Audit?
• Chemical Reporting – Form R’s (TRI)– Chemical or compound specific (EPA’s List of
Lists)– Manufactured, processed, or otherwise used– Review submitted Form R’s and supporting
documentation– Ask about methodology to determine if Form
R’s are applicable
What Things Need to be Reviewed During Audit?
• Other Compliance Issues– Compliance (not Phase I)– State-specific or local requirements– Tanks– Drinking water– Used oil– Refrigerants– Risk Management Plans / Process Safety
Management
What To Do After the Audit is Completed?
• Prioritize findings
• Best Management Practice vs. Regulatory Requirement
What To Do After the Audit is Completed?
• Self-Disclosure
What To Do After the Audit is Completed?
• Take Action & Correct Deficiencies!
