Top 10 Audit Issues

1. Top 10 Audit Issues Don Gansert Managing Consultant February 19, 2009 trinityconsultants.com

2. Multi-Media Audits • Housekeeping Matters • The typical compliance issues per media: • Air • Water • Waste • Right to Know • Risk Management Program • Process Safety Management

3. Air • Non-compliance with operating and construction permit requirements • Monthly emissions calculations missing • i.e. tracking VOC emissions on a 12-month rolling average • Pollution control equipment – operating & maintenance logs missing • Emissions calculations missing for new equipment not permitted • Construction and operating permit applications signed by someone other than the responsible official • Operating permit applications submitted late • Less than six months from expiration date or past the expiration date • CFC or HCFC chemicals • Leak rate calculations missing • 3 years of service records missing • Training certificates of contractors missing • Asbestos • Record of agency notification for demolition projects missing • Semi-annual deviation and monitoring reports missing or late • Annual Compliance Certification Report signed by someone other than the responsible official or submitted late

4. Water • NPDES permits • Storm water pollution prevention plans • Spill prevention control and countermearsure plan

5. NPDES Permits • DMR reports • Reports periodically submitted late • Lack of timely verbal and written notification for exceedances • Action plan missing for a pollutant(s) exceeding a limit on a periodic bases • Reports signed by someone other than the responsible official • Testing • pH test results not performed immediately • pH buffers out dated • Chlorine test results not performed immediately • Permit applications • Signed by someone other than the responsible official • Do not reflect actual backup water system(s) discharged to surface waters • Many city water systems contain chlorine • Non permitted discharges not captured • Facility discharge from A/C units or air compressor blow down

6. Storm Water Construction • Construction permit applications missing • New construction impact area greater than 1 acre, not including the storage pile, contractor parking, temporary drive ways • If construction permit issued, the following items missing: • Training records of contractors, truck drivers, etc. who will pass through area • Periodic inspection records missing • Inspection records do not reflect the condition of the area inspected • Silt fences missing or damaged • Site map not kept up to date as the location of erosion controls change • The plan is not readily available for review • Erosion evident and not controlled • Permit application signed by someone other than the responsible official • Notice of Termination (NOT) missing even though project completed more than a year ago

7. SPCC • Documentation of the facility-wide oil storage capacity for the facility missing • Facility contacts not updated • Agency contact list not updated • Containers with a capacity of 55-gallons missing • i.e. Maintenance shop drums of lube oil, motor oil, used oil • Operational equipment with a capacity of 55-gallons or more missing • i.e. Oil-filled electrical transformers, hydraulic equipment on presses, etc. • Site map • Overhead piping and loading/unloading areas missing • 55-gallon drums, full, partially full and empty missing • Inspection records • Signature of the inspector (usually see initials) • 3 years of inspection records incomplete or missing • Substantial Harm Determination Certification missing

8. Waste • Hazardous Waste • Satellite containers • Bungs loose • Containers not closed • Containers missing hazardous waste label • Less than 90 day storage area • 3 years of weekly inspection records incomplete or missing • Bungs loose on drums • Date missing • Manifests not legible on all copies &/or incomplete • Training • Type and amount of training information missing in the employees file • Training records older than 3 years missing • Job Description • Job description of hazardous waste duties missing, the amount and type of initial and annual training • Universal Waste • Training records missing • Proper container labeling missing • Date on container missing • Container not closed

9. Right to Know • Tier II • Chemical inventory missing • Threshold determination missing • i.e. during walk thru, discovered chemicals exceeding 10,000 lbs not on the Tier II • Extremely Hazardous Substances (EHS) in mixtures not totaled and compared to the threshold planning quantity (TPQ) • A new EHS added to the Tier II but an initial notification report missing • The incorrect number of days on site carried over from previous years • i.e. in 2006, new chemical (A) brought on site for 279 days. The 279 days is carried over and reported in the 2007 and 2008 reports. • Storage areas and type of container change but not updated on the site map • Toxic Release Inventory (TRI) • Threshold determination(s) missing • Air emissions calculations used are different than the calculations used for the annual air emissions report • The calculations used to determine the release to each media missing or incomplete • The annual reports for the past three years missing

10. RMP (Risk Management Program) • Evaluating program level • Review, update, and certify sections of RMProgram • Report most recent dates of: • Hazard review (Program 2) • Required to review, and document, every 5 yrs • Process Hazard Analysis (Program 3) • Operating procedure training • Refresher training every three years • Required to certify annually that current and accurate (Program 3) • Compliance audits • Required to audit every three years • Maintenance/Mechanical Integrity Program Review • Management of Change Review (Program 3) • Emergency Response Program Training • 5 year review of RMP Plan • Online Submittal - RMP*eSubmit (available soon)

11. PSM • Each process hazard analysis (PHA) not updated and revalidated at least every five years • Team findings and recommendations not promptly addressed, resolved in a timely manner and documented • Operating procedures are not developed or incomplete for every process • Training • New employees or transferred employees not provided initial process safety management training • Records showing the date of training missing • Means to verify employee understanding lacking • Contractor training verification missing • Pre-Startup Safety Reviews for new and modified facility records incomplete • Inspection records incomplete • Incident investigation records incomplete • Form not completed • Five years of incidents missing • Hot Work Permits not completed • Compliance audits not performed at least every three years

12. Questions?