ENVIRONMENTAL, SAFETY AND · Web viewThis document has been developed to assist the Defense Logistics Agency (DLA) Strategic Materials (SM) in conducting internal environmental

ENVIRONMENTAL COMPLIANCEAUDIT PROTOCOL

Defense Logistics Agency Strategic Materials

January 2017

Environmental ComplianceAudit Protocol

INTRODUCTION

This document has been developed to assist the Defense Logistics Agency (DLA) Strategic Materials (SM) in conducting internal environmental audits. This Environmental Compliance Audit Protocol consist of 15 audit protocols, based on specific environmental management topics, to evaluate the site’s compliance with environmental regulations under federal law. Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the federal laws affecting a particular environmental management area. Each protocol includes a checklist delineating the topics that should be evaluated during an audit. The checklists include the applicable regulatory citations. Not all checklist items will be applicable to a particular site.

This document also includes five separate state-specific audit protocols to align with the locations of the five DLA SM sites. These state-specific audit protocols are to be used along with the main audit protocol while conducting the audit. The state-specific audit protocols are formatted with the same 15 environmental management audit protocols to evaluate compliance with state and local environmental regulations. If no additional state requirements are applicable, it is indicated on the state-specific audit protocol summary page. Each state-specific protocol includes a checklist delineating the topics that should be evaluated during an audit. The checklists include the applicable regulatory citations. Not all checklist items will be applicable to a particular site.

AUDIT INFORMAITON

SITE INFORMATION

Site Name: Site Representative:

Address: Title:

City, State, Zip: Signature:

AUIDIT INFORMATION

Date of Audit: Auditor Name:

Title:

Signature:

OTHERS PRESENT

Name: Name:

Title: Title:

Signature: Signature:

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TABLE OF CONTENTS

PROTOCOL 1: NEPA Process...................................................................................................................................

PROTOCOL 2: Historical and Cultural Resources....................................................................................................PROTOCOL 3: Natural Resource Management.........................................................................................................

PROTOCOL 4: Air Emissions....................................................................................................................................PROTOCOL 5: CERCLA...........................................................................................................................................

PROTOCOL 6: Hazardous Materials.........................................................................................................................PROTOCOL 7: Hazardous and Universal Wastes......................................................................................................

PROTOCOL 8: Aboveground Storage Tanks...........................................................................................................14PROTOCOL 9: Oil Spill Prevention and Preparedness............................................................................................15

PROTOCOL 10: Water Discharges..........................................................................................................................17PROTOCOL 11: Drinking Water.............................................................................................................................19

PROTOCOL 12: Toxic Substances..........................................................................................................................20PROTOCOL 13: Pesticides.......................................................................................................................................22

PROTOCOL 14: Solid Waste and Recycling...........................................................................................................23PROTOCOL 15: Energy Conservation, Sustainability, and Other Occupational Health Programs........................25

Attachment 1: Indiana Environmental Compliance Audit ProtocolAttachment 2: New York Environmental Compliance Audit ProtocolAttachment 3: Nevada Environmental Compliance Audit ProtocolAttachment 4: Ohio Environmental Compliance Audit ProtocolAttachment 5: Environmental Compliance Audit Protocol Summary

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PROTOCOL 1: NEPA Process

The National Environmental Policy Act (NEPA) of 1970 requires federal agencies to assess the environmental effects of their proposed actions prior to making decisions. Using the NEPA process, agencies evaluate the environmental and related social and economic effects of their proposed actions.

The following federal and agency regulations apply to this protocol:

NEPA Process (40 Code of Federal Regulations [CFR] 1501-1508)

DLA Regulation, Environmental Considerations in DLA Actions, DLAR 1000.22

Yes No NA NEPA Process Citation

Does the site follow the DLA process to integrate NEPA review during new project development (i.e., DLA proposed actions)?

The DLA process to integrate NEPA review during new project development is provided in DLAR 1000.22.

40 CFR 1501; DLAR 1000.22

Does the site maintain documentation of the NEPA review process activities it has completed?

Where is the documentation located? ______________________________

40 CFR 1501; DLAR 1000.22

Does the site maintain documentation of its activities that qualify as Categorical Exclusions (CXs)?

40 CFR 1501; DLAR 1000.22

If a proposed action at the site does not qualify as a CX, was an Environmental Assessment (EA) completed to review the proposed action?

40 CFR 1501; DLAR 1000.22

If the result of the EA was a finding of no significant impact (FONSI), is this determination documented?

40 CFR 1501; DLAR 1000.22

If the result of the EA determined that the proposed action may significantly affect the human environment, was an Environmental Impact Statement (EIS) prepared?

40 CFR 1502; DLAR 1000.22

If an EIS was prepared for a proposed activity at the site, is there documentation of all completed steps in the EIS process and of the final disposition of the EIS (i.e., Final EIS, Record of Decision [ROD])?

40 CFR 1505; DLAR 1000.22

1


PROTOCOL 2: Historical and Cultural Resources

The ultimate goal is to preserve sites that have historic and cultural importance to our society while simultaneously being able to conduct government activities important to today’s economy.

The following federal regulation and guidance apply to this protocol:

Protection of Historic Properties (36 CFR 800)

Department of Defense (DoD) Instruction 4715.16, Cultural Resources Management (DoDI 4715.16)

Yes No NA Cultural Resource Assessment Citation

Are you aware of any cultural resources located on site? 36 CFR 800

If yes, do you have a plan for preservation and protection of the resource (e.g., an Integrated Cultural Resource Management Plan [ICRMP])?

DoDI 4715.16

If yes, has the ICRMP been externally reviewed in the past 5 years? DoDI 4715.16

If there are cultural resources located on site, are internal cultural resources self-assessments conducted annually?

DoDI 4715.16

Has there been a cultural resource assessment conducted? 36 CFR 800

If yes, where is this documented? 36 CFR 800

Yes No NA Historical Resource Assessment Citation

Are you aware of any historical properties located on site? 36 CFR 800

If yes, do you have a plan to determine whether an activity/project is within an area that has the potential to cause effects on historic properties?

36 CFR 800

If there are historical properties on the site, has there been an assessment of adverse effects to historic properties for any activities/projects that have the potential to cause effects on historic properties?

36 CFR 800

If yes, where is this documented? 36 CFR 800

2


PROTOCOL 3: Natural Resource Management

This protocol addresses natural resource conservation and management. The ultimate goal is to preserve significant natural resources while simultaneously being able to conduct mission-critical government activities.

The following federal laws, regulations, and guidance apply to this protocol:

Department of Defense Instruction 4715.03, Natural Resources Conservation Program (DoDI 4715.03) The Sikes Act (16 USC 670) Endangered Species Act (16 USC 1531-1544; 50 CFR 17) U.S. Migratory Bird Treaty Act (16 USC 703-712) Clean Water Act (33 USC 1251 et seq.; 40 CFR 30) Soil Conservation (16 USC 590) Executive Order 11988: Floodplain Management (EO 11988) Executive Order 11990: Protection of Wetlands (EO 11990)

Yes No NA Integrated Natural Resource Management Plan (INRMP) Citation

Are there any significant natural resources on the site?

If yes, continue with the following questions.

“Significant natural resources” are resources identified as having special importance to an installation or its ecosystem. Natural resources may be significant on a local, regional, national, or international scale. All threatened or endangered species, and species at-risk, are significant natural resources that normally will require an INRMP for the site. Installations that actively manage fish and wildlife, forestry, vegetation and erosion control, agricultural out-leasing or grazing, or wetlands protection should be evaluated for significance, but normally will require an INRMP. An evaluation for significance should also consider the degree of active management, special natural features, aesthetics, outdoor recreational opportunities, and the ecological context of the installation.

DoDI 4715.03

Does the site maintain an INRMP? 16 USC 670; DoDI 4715.03

Where is the INRMP documented? DoDI 4715.03

If there are significant natural resources on the site, are internal natural resources self-assessments conducted annually for the site?

DoDI 4715.03

Is the INRMP externally reviewed and renewed every five years? 16 USC 670; DoDI 4715.03

Yes No NA Endangered Species Citation

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Is the site located in a habitat area for endangered or threatened species? 50 CFR 17

If yes, does the INRMP include procedures to comply with federally listed threatened and endangered species management and recovery efforts?

DoDI 4715.03; 50 CFR 17

Yes No NA Migratory Birds Citation

Does the INRMP include procedures to implement appropriate conservation measures if a proposed action may have a significant adverse effect on a migratory bird population?

DoDI 4715.03; 16 USC 703-712

Yes No NA Wetlands and Surface Waters Citation

Does the INRMP include procedures to ensure no net loss of size, function, and value of wetlands at the property?

DoDI 4715.03; EO 11990

When avoidance of wetlands and other waters of the U.S. is not practicable, and impacts have been minimized, does the site participate in an approved off- or on-site mitigation bank or in-lieu fee instrument to meet applicable permit conditions?

DoDI 4715.03; 33 USC 1344

If the site plans to take an action that will discharge dredged or fill material into the waters of the U.S., has the site obtained a Section 404 permit from the United States Army Core of Engineers (USACE) prior to beginning the proposed action?

33 USC 1341, Section 404; 40 CFR 230, Section 404

If the site plans to take an action that will discharge dredged or fill material into the waters of the U.S., has the site obtained a Section 401 Water Quality Certification (WQC) from the applicable state environmental protection agency prior to beginning the proposed action?

33 USC 1341, Section 401; 40 CFR 230, Section 401

Yes No NA Floodplains and Soil Erosion Citation

Does the INRMP include procedures to avoid floodplain development where there is a practicable alternative?

DoDI 4715.03; EO 11988

Does the INRMP include procedures to prevent and control soil erosion, and implement soil conservation measures?

DoDI 4715.03; 16 USC 590

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PROTOCOL 4: Air Emissions

The Clean Air Act includes regulations, responsibilities, and compliance requirements associated with air pollution emissions from stationary and mobile sources. The Clean Air Act is enforced through state air quality implementation plans and operating permits for sources of toxic and hazardous air pollutants.

The following federal law and regulation apply to this protocol:

Air Programs (40 CFR 50-99)

Clean Air Act (42 USC Chapter 85)

Yes No NA Criteria Air Pollutants Citation

Does the site emit criteria air pollutants?

Criteria air pollutants include ozone, carbon monoxide (CO), nitrous oxides (NOx), sulfur oxides (SOx), particulate matter (PM), and lead.

40 CFR 50

If yes, and the site is in a nonattainment area for a criteria air pollutant that it emits, does the site have an air quality permit?

A list of the nonattainment areas is provided on the U.S. Environmental Protection Agency (USEPA) website: https://www.epa.gov/green-book

40 CFR 50

Yes No NA Hazardous Air Pollutants Citation

Does the site emit or have the potential to emit 10 tons per year or more of a hazardous air pollutant (e.g., asbestos, benzene, heavy metals) or 25 tons per year or more of a combination of hazardous air pollutants?

The above criterion is the definition of a major source of hazardous air pollutants.

40 CFR 61

If yes, does the site have an air quality permit? 40 CFR 61

Yes No NA Ozone Depleting Substances Citation

Does the site use equipment that contains ozone depleting substances (ODSs)?

A list of ODSs is provided on the U.S. Environmental Protection Agency (USEPA) website: https://www.epa.gov/ozone-layer-protection/ozone-depleting-substances

40 CFR 82

If yes, is an inventory of ODS-containing equipment maintained? 40 CFR 82

Does any equipment at the site contain over 50 pounds of ODSs? If yes, are ODS leak rates checked annually for this equipment?

40 CFR 82

If an ODS leak that exceeds the annual leak rate for that type of equipment is identified, is the leak retested or repaired within 30 days?

40 CFR 82

5

https://www.epa.gov/ozone-layer-protection/ozone-depleting-substances

https://www.epa.gov/ozone-layer-protection/ozone-depleting-substances

https://www.epa.gov/green-book


PROTOCOL 5: CERCLA

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 provides for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and cleanup of inactive hazardous waste disposal sites. In addition to the federal requirements listed in this protocol, many states have additional release reporting requirements and cleanup requirements. Therefore, regulated entities that are not subject to the requirements of CERCLA may be subject to state or local regulations regarding release reporting and site evaluation and cleanup.

The following federal law and regulation apply to this protocol:

CERCLA (42 USC 9601 et seq.)

Hazardous Substance Responses (40 CFR 300 Subpart E)

Yes No NA CERCLA Citation

Has there been a release of a hazardous substance at the site that has required CERCLA action?

40 CFR 300

If yes proceed with the following questions:

Was a remedial site evaluation completed?

If yes, were follow up actions completed in accordance with the findings of the remedial site evaluation?

40 CFR 300

Did the site conduct a remedial investigation/feasibility study? 40 CFR 300

If yes, were the appropriate community relation activities conducted? 40 CFR 300

If yes, did the site develop a remedial design/remedial action consistent with the record of decision?

40 CFR 300

If yes, were operation and maintenance measures initiated and maintained? 40 CFR 300

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PROTOCOL 6: Hazardous Materials

This section addresses the proper storage and handling of chemicals and the training, reporting, spill contingency, and response requirements related to hazardous materials.

The following federal regulations apply to this protocol:

Emergency Planning Community Right to Know Act (EPCRA; 40 CFR 350-399)

Occupational Safety and Health Act (OSHA; 29 CFR 1910)

Hazardous Materials Transportation Act (HTMA; 49 CFR 105-180)

Yes No NA EPCRA Section 301 – Emergency Planning Citation

Does the site have any extremely hazardous substances equal to or greater than the threshold planning quantity (TPQ)?

A List of Lists showing the TPQs is provided on the USEPA website: https://www.epa.gov/epcra/epcracerclacaa-ss112r-consolidated-list-lists-march-2015-version

40 CFR 355

If yes, have you notified State Emergency Response Commission (SERC) and local emergency planning committees (LEPCs)?

40 CFR 355

If yes, does the site have a designated representative who will work with local emergency personnel?

40 CFR 355

Are Safety Data Sheets (SDSs) for every hazardous chemical stored and used on-site available upon request?

40 CFR 355

Have copies of SDSs been submitted to your SERC, LEPC, or local fire department?

40 CFR 355

Yes No NA EPCRA Section 304 – Emergency Notification Citation

Have there been releases of hazardous materials in amounts greater than the reportable quantity (RQ)?

A List of Lists showing the RQs is provided on the USEPA website: https://www.epa.gov/epcra/epcracerclacaa-ss112r-consolidated-list-lists-march-2015-version

40 CFR 355

If yes, were the appropriate SERC and LEPC notified? 40 CFR 355

7


Yes No NA EPCRA Section 301-312 – Tier II Citation

Is your site required to comply with hazardous chemical reporting requirements by submitting Tier II reports?

40 CFR 370

If yes, are the Tier II reports being submitting annually to your SERC, LEPC, and fire department?

40 CFR 370

If yes, is the site keeping documentation that Tier II reports are completed annually on or before March 1 for the preceding calendar year?

40 CFR 370

Yes No NA EPCRA Section 313 – Toxic Release Inventory (TRI) Citation

Is your site required to complete toxic chemical reporting by submitting TRI reports?

The TRI chemical list is provided on the USEPA website: https://www.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals

40 CFR 372

If yes, is the site keeping documentation that TRI reports are completed annually on or before July 1 for the previous calendar year?

40 CFR 372

Yes No NA OSHA Hazardous Communication Requirements Citation

Are all containers of chemicals labeled in accordance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) which is now aligned with Hazardous Communication Standard (HCS) (e.g., label includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category)?

29 CFR 1910

Are SDSs for every chemical/mixture readily accessible during each work shift to employees when they are in their work areas?

29 CFR 1910

Are employees provided information and training on hazardous chemicals in their work area?

29 CFR 1910

Yes No NA HMTA Requirements Citation

Do you ship hazardous materials? 49 CFR Subchapter C Part 171

If yes, are employees involved with shipping hazardous materials trained? 49 CFR Subchapter C Part 172

Does the site have proper shipping documentation including originals and receiving/accepting documentation from end site for 2 years as required?

49 CFR Subchapter C Part 172

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PROTOCOL 7: Hazardous and Universal Wastes

Defense Logistics Agency (DLA) Strategic Materials depots are usually conditionally exempt small-quantity generators (CESQG). That is, they generate less than 100 kilograms of hazardous waste a month. Regulated entities that generate hazardous waste are subject to waste accumulation, manifesting, and recordkeeping standards. Facilities generally must obtain a permit either from the USEPA or from a state agency that the USEPA has authorized to implement the permitting program if they store hazardous wastes for more than 90 days before treatment or disposal. The Resource Conservation and Recovery Act (RCRA) addresses nonhazardous and hazardous waste management activities.

Universal wastes are defined in 40 CFR 273 as batteries, fluorescent light bulbs, mercury-containing equipment, and pesticides. Universal wastes are considered hazardous wastes but have fewer requirements than other hazardous wastes due the common nature of the items.


Hazardous Wastes (40 CFR 260-272)

Standards for the Management of Used Oil (40 CFR 279)

Standards for Universal Waste Management (40 CFR 273)

Yes No NA Verification of Generator Status Citation

Does the site generate hazardous waste as defined by 40 CFR 261.3? 40 CFR 261

Is the site registered as a generator of hazardous waste and/or waste oil? 40 CFR 261

If yes, provide Generator ID Number: ______________________________40 CFR 261

If yes, provide Waste Generator Status (i.e., CESQG, Small Quantity Generator [SQG] and Large Quantity Generator [LQG])?

_____________________________

40 CFR 261

Yes No NA Verification of the Accumulation limits Citation

If the site is a CESQG, is there less than 1,000 kilograms (kg) or 2,200 pounds (lbs) of hazardous waste accumulated on-site?

If CESQG, continue with audit question below (excluding SQG and LQG section).

40 CFR 261

If the site is a SQG, is there less than 6,000 kg of hazardous waste accumulated on-site?

If SQG, see additional questions SQG section below.

40 CFR 261

If the site is a LQG, there is no limit to the volume of hazardous waste stored on-site.

If LQG, see additional questions in LQG section below.

40 CFR 261

9


Yes No NA Waste Container Management Citation

Are all waste containers stored in the designated accumulation area? 40 CFR 265

Are all waste containers in good condition, not leaking, and closed at all times expect when adding/removing waste?

40 CFR 265

Are containers labeled, including the name of the waste and the words “Hazardous Waste”?

40 CFR 262

Are containers compatible with the waste being accumulated? 40 CFR 265

Are containers of highly flammable wastes electrically grounded? 40 CFR 265

Is there at least 3 feet of aisle space provided between rows of containers? 40 CFR 265

Yes No NA Satellite Accumulation Area Citation

If the site maintains a Satellite Accumulation Area:

Is there only one drum/container of each waste type (limit one container up to 55 gallons)?

40 CFR 262, 265

Is the satellite accumulation area at or near the waste’s point of generation? 40 CFR 262, 265

Is the satellite accumulation managed by the person responsible for the area/operation generating the waste?

40 CFR 262, 265

When the satellite accumulation container is full, is the container labeled with the date and moved to the 90-day storage area or off-site within 3 days?

40 CFR 262, 265

Are satellite accumulation areas inspected weekly and inspections documented?

40 CFR 262, 265

Yes No NA Recordkeeping Citation

Does the site have at least one emergency coordinator on-site or on call? 40 CFR 262, 265

Are analytical records and waste determination records maintained on-site for a period of 3 years and available for each waste?

40 CFR 262, 265

Are training records for all staff who manage hazardous waste retained for 3 years after employment at the site?

40 CFR 262-265

Are hazardous waste manifests used when shipping hazardous waste? 40 CFR 265

If yes, are hazardous waste manifest records maintained for 3 years? 40 CFR 265

10


Yes No NA Small Quantity Generators Citation

For Small Quantity Generators:

Does the site have a USEPA ID Number? 40 CFR 262

Does the site have at least one personnel who has completed applicable RCRA basic training requirements?

40 CFR 262

SQG may accumulate hazardous waste on-site for 180 days or less. Do all accumulation start dates on full containers meet accumulation time limits?

40 CFR 262

Does the site have a signed copy of all manifest from the owner of the treatment, storage, and disposal facility (TSDF) within 60 days?

40 CFR 262

Yes No NA Large Quantity Generators Citation

For Large Quantity Generators:

Does the site have a USEPA ID Number? 40 CFR 262

Does the site have at least one personnel member who has completed applicable RCRA training requirements?

40 CFR 262

LQG may accumulate hazardous waste on-site for 90 days or less. Do all accumulation start dates on full containers meet accumulation time limits?

40 CFR 262

Does the site have a Hazardous Waste Contingency Plan or an Integrated Contingency Plan?

40 CFR 265

Does the site have documentation that biennial hazardous waste reports have been submitted by March 1 of every even-numbered year?

40 CFR 265

Does the site have a signed copy of all manifests from the owner of the TSDF within 45 days?

40 CFR 265

Yes No NA Used Oil Management Citation

Does the site generate used oil? 40 CFR 249

Are all used oil containers in good condition, with no visible leaks, and labeled “Used Oil”?

40 CFR 249

Is the used oil being shipped off-site? If yes, does the transporter have an USEPA ID #?

40 CFR 249

11


Yes No NA Universal Waste Citation

Does the site store universal waste on-site? 40 CFR 273

Does the site store more than 5,000 kg or 11,000 lbs of universal waste at any one time?

If yes, has the site notified the USEPA and followed other requirements for a large-quantity generator?

If no, the site shall comply with small-quantity generator requirements.

40 CFR 273

Does the site dispose, treat, or dilute universal waste on-site? 40 CFR 273

Are all site personnel who manage universal waste informed/training on proper handling and emergency procedures?

40 CFR 273

Is universal waste disposed of within 1 year of generation? 40 CFR 273

Yes No NA Universal Waste – Batteries Citation

Are waste batteries managed in a way that prevents leaks, spillage, or damage that could cause leakage?

40 CFR 273

If waste batteries show visible leaks, are they placed in a container to contain leaks?

40 CFR 273

If waste batteries are containerized, is the container labeled with the words “Universal Waste Batteries”?

40 CFR 273

Yes No NA Universal Waste – Fluorescent Light Bulbs Citation

Are waste fluorescent bulbs stored in a container that is structurally sound, closed, compatible with material, and that lacks evidence of leakage, spillage, or damage?

40 CFR 273

Are containers labeled with the words “Universal Waste Lamps, Waste Lamps, or Used Lamps”?

40 CFR 273

12


Yes No NA Universal Waste – Mercury Containing Equipment Citation

Is mercury-containing equipment with non-contained elemental mercury stored in a container that is structurally sound, closed, compatible with material, and lacks evidence of leakage, spillage, or damage?

40 CFR 273

Are containers labeled with the words “Universal Mercury-Containing Equipment” or “Used Mercury-Containing Equipment”?

40 CFR 273

Yes No NA Universal Waste – Pesticides Citation

Is waste pesticide stored in a container that is structurally sound, closed, compatible with material, and lacks evidence of leakage, spillage, or damage?

40 CFR 273

Are containers labeled with the words “Universal Waste Pesticides or Waste Pesticides”?

40 CFR 273

13


PROTOCOL 8: Aboveground Storage Tanks

Most aboveground storage tanks (ASTs) need to meet the requirements in 40 CFR 112. Some ASTs may also need to meet additional state or local regulatory requirements that safeguard human health and the environment from potential threats posed by ASTs.


Oil Pollution Prevention (40 CFR 112)

Occupational Safety and Health Act (29 CFR 1910)

Yes No NA ASTs Citation

Are ASTs labeled? 29 CFR 1910

Are ASTs in good condition (no evidence of cracks, corrosion on tank, piping, valves, or pumps, leaks, drips, or spills)?

40 CFR 112

Are ASTs double walled? 40 CFR 112

If ASTs are single walled, are they within secondary containment? 40 CFR 112

If yes, are plugs in place? 40 CFR 112

If yes, is secondary containment area free of standing water and materials? 40 CFR 112

Has integrity testing been conducted on ASTs that require it?

Integrity testing is required for all ASTs with capacity of 55 gallons or more. Oil filled equipment is not subject to integrity testing. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Records or inspections and/o test must be kept for three years.

40 CFR 112

Are required inspections conducted and documented? 40 CFR 112

Have there been any discharges in the past year from an AST? If yes, were the proper notifications made?

Provide location of documentation: _______________________________

40 CFR 112

14


PROTOCOL 9: Oil Spill Prevention and Preparedness

Facilities that store, transport, dispose of, or use oil are required to have procedures and organizational mechanisms designed to prevent or limit oil from reaching navigable waters and adjoining shorelines, and to contain discharge of oil.

Oil means oil of any kind or in any form, including, but not limited to, the following: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

Oil storage containers are defined as containers used to store oil that are greater than or equal to 55 gallons in volume.


Oil Pollution Prevention (40 CFR 112)

Yes No NA Spill Prevention, Control, and Countermeasure (SPCC) Plan Citation

Does the site store oil in aboveground storage containers (55 gallons or greater) in quantities equal or greater than 1,320 gallons?

40 CFR 112

If yes, continue with the following questions:

Does the site have an SPCC Plan? 40 CFR 112

Does the site qualify as a Tier I facility?Tier I requirements are as follows:

Aggregate aboveground oil storage capacity is 10,000 gallons or less; AND

The capacity of each individual aboveground oil storage container is 5,000 gallons or less; AND

The facility has NOT had a single discharge exceeding 1,000 gallons, OR two discharges each exceeding 42 gallons within any 12-month period.

40 CFR 112

If site does not meet Tier I requirements, is the SPCC Plan certified by a licensed Professional Engineer?

40 CFR 112

Does the SPCC Plan accurately reflect quantities and location of oil storage containers at the site?

40 CFR 112

Has the SPCC Plan been reviewed and evaluated at least once every 5 years?

40 CFR 112

Following plan review, was the SPCC Plan amended? 40 CFR 112

Do oil storage containers have appropriate secondary containment? If yes, is secondary containment in good condition?

40 CFR 112

15


Yes No NA Spill Prevention, Control, and Countermeasure (SPCC) Plan Citation

Does the site maintain inventory of spill sorbent materials? 40 CFR 112

Are required inspections conducted, documented, and kept with the SPCC Plan for 3 years?

40 CFR 112

Are oil-handling personnel at the site trained annually on discharge prevention and on the contents of the SPCC Plan?

40 CFR 112

Does the site have a designated person who is accountable for discharge prevention and reports to management?

40 CFR 112

Are best management practices for oil storage, handling, and transfer being followed?

40 CFR 112

Have there been any oil discharges in the past year? If so, were the proper notifications made and documented?

40 CFR 112

16


PROTOCOL 10: Water Discharges

The Clean Water Act governs the control of water pollution in the nation. The act’s primary objective is to restore and maintain the chemical, physical, and biological integrity of the nation’s surface waters. The Clean Water Act made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained. The USEPA National Pollutant Discharge Elimination System (NPDES) permit program controls discharges of wastewater and stormwater. In addition to the federal requirements listed in this protocol, many state (or local) regulations may be applicable if discharges are permitted by a local, state, or tribal authority. In addition, many facilities qualify for Multi-Sector General Permits (MSGPs) for their stormwater discharges.


Clean Water Act (40 CFR 125–136)

NPDES (40 CFR 122)

Yes No NA Wastewater Discharges – Applicable to NPDES Citation

What is the type of sewer system at the site (public, septic, other)?

__________________________________________

Probe Question

Does the site need an NPDES permit for wastewater?

NPDES Permit Requirements: If you discharge from a point source into the waters of the United States, you need an NPDES permit. If you discharge pollutants into a municipal sanitary sewer system, you do not need an NPDES permit, but you should ask the municipality about their permit requirements. If you discharge pollutants into a municipal storm sewer system, you may need a permit depending on what you discharge.

40 CFR 122

If site is permitted, continue with following questions:

Does the site have an individual NPDES permit for wastewater?

An NPDES individual permit is written to reflect site-specific conditions of a single discharger (or in rare instances to multiple co-permittees) based on information submitted by that discharger in a permit application and is unique to that discharger. Individual permits are issued directly to an individual discharger.

40 CFR 122

Does the site qualify under an NPDES general permit?

An NPDES general permit is written to cover multiple dischargers with similar operations and types of discharges based on the permit writer’s professional knowledge of those types of activities and discharges. A general permit is issued to no one in particular with multiple dischargers obtaining coverage under that general permit after it is issued, consistent with the permit eligibility and authorization provisions.

40 CFR 122

17



Is the site completing monitoring/sampling events? 40 CFR 122

Have any discharge permit violations occurred? 40 CFR 122

Is the permit expired? 40 CFR 122

Yes No NA Stormwater Discharges – Applicable to NPDES Citation

Does the site have an individual NPDES permit to discharge stormwater associated with industrial materials or activity from point sources through a stormwater system that is not a municipal separate stormwater sewer?

40 CFR 122

If no, did the site complete and sign a certification for “No Exposure,” indicating that there a no discharges of stormwater contaminated by exposure to industrial materials and activities from the entire site property?

40 CFR 122

If yes, continue with following questions:

Does the site have a Stormwater Pollution Prevention Plan (SWPPP)? 40 CFR 122

Is the site completing monitoring/sampling events? 40 CFR 122

Is the site completing annual inspections? 40 CFR 122

Are monitoring and inspection records kept for 3 years? 40 CFR 122

Is the permit expired? 40 CFR 122

Yes No NA Stormwater Requirements for Construction Activities Citation

Has the site conducted a construction activity that disturbed 1 or more acres of land?

40 CFR 122

If yes, did the site prepare and implement a SWPPP? 40 CFR 122

Did the site complete and document inspection records? 40 CFR 122

18


PROTOCOL 11: Drinking Water

The Safe Drinking Water Act identifies and regulates facilities that have a public water supply system. A public water system is defined as a system for providing piped water for human consumption. To qualify, the system must have at least 15 service connections or an average of 25 individuals for at least 60 days out of the year.


Safe Drinking Water (40 CFR 141–143)

Yes No NA Drinking Water Supply Citation

What is the site’s water supply source (private well, municipal water supply, bottled water, other)?

__________________________________________

If the site does not operate a public water system, then this protocol does not apply to the site. A “public water system” is defined as a system for providing piped water for human consumption and must have at least 15 service connections or an average of 25 individuals for at least 60 days out of the year.

If the site operates a public water system, then proceed with the following protocol questions.

Probe Question

Yes No NA Public Water System Citation

Is the site required to sample for total coliform? If so, verify samples are collected at regular intervals at the frequency required based on population.

40 CFR 141

Has the site completed monitoring requirements for lead and copper in tap water?

40 CFR 141

Are records maintained (sampling analysis, records of actions taken, public notices, monitoring plans)?

40 CFR 141

19


PROTOCOL 12: Toxic Substances

This section addresses management activities associated with toxic substances, including asbestos, lead-based paint, and polychlorinated biphenyls (PCBs).


Toxic Substances Control Act (40 CFR 700-766)

Occupational Safety and Health Standards (29 CFR 1910)

DLA Safety & Occupational Health (SOH) Policies

Yes No NA Asbestos Citation

Does the site contain any known or presumed asbestos-containing materials (ACMs)? If yes, is there an inventory of all ACM and presumed ACM (PACM) at the site?

29 CFR 1910

Are all installed and stored ACM and PACM clearly identified by label or sign?

29 CFR 1910

Are employees who perform housekeeping and other activities in areas that contain ACM and PACM provided an annual asbestos awareness training course?

29 CFR 1910

Are accredited asbestos management contractors utilized when renovations or other construction projects are performed in areas with ACM and PACM?

29 CFR 1910

Is the Operations Division at each site completing an annual survey documenting the location and condition of asbestos containing material and subsequently submitting survey to the DLA Safety & Health Manager by the 15th of January each year?

DLA SOH Policies

Yes No NA Lead-based Paint Citation

Are there any lead-based paints at the site? If yes, is there an inventory of the lead-based paints?

40 CFR 745

Are accredited lead-based paint contractors utilized for all renovations or other construction projects that involve disturbing lead-based paint?

40 CFR 745

20


Yes No NA PCBs Citation

Does the site contain greater than 45 kg (99 pounds) of PCBs, or one or more PCB transformers, or 50 or more PCB large high or low voltage capacitors?

40 CFR 761

If yes, does the site maintain all annual records (e.g., manifests and certificates of disposal) and the written annual document log of the disposition of PCBs and PCB items?

40 CFR 761

Are the annual records and the annual document log maintained for at least 3 years after the site ceases using or storing PCBs and PCB items in the quantities prescribed above?

40 CFR 761

Does the site store for disposal PCBs or PCB items with concentrations of 50 parts per million (ppm) or greater?

40 CFR 761

If yes, is the stored PCB waste disposed of within 1 year from the date it was determined to be PCB waste and the decision was made to dispose of it?

40 CFR 761

21


PROTOCOL 13: Pesticides

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulates the sale, distribution, and use of pesticides. Pesticides include insecticides, herbicides, fungicides, rodenticides, and antimicrobials.

Pesticides are strictly prohibited at DLA Strategic Materials depots.


Herbicides and Pesticides (40 CFR 150–186)

Recordkeeping on restricted use pesticides by certified applicators (7 CFR 110)

Yes

No NA

Pesticide Management Citation

Does the site use, distribute, or sell pesticide in the United States?

If no, this protocol is not applicable for the site. If yes, proceed with the following protocol questions.

Probe Question

Does the site distribute or sell pesticide in the United States? 40 CFR 152

If yes, does site have documentation of USEPA registration license? 40 CFR 152

Are all pesticides labeled? 40 CFR 156

Yes

No NA

Pesticide Application Citation

Do site personnel use or apply pesticides or restricted-use pesticides? 40 CFR 171

If no, are pesticides applied at the site by commercial or private contractors?

40 CFR 171

If yes, are the contractors who apply pesticides certified to do so? 40 CFR 171

If noncertified personnel apply pesticides, are they directly supervised by a certified applicator?

40 CFR 171

If restricted use pesticides are applied, are records retained for at least 2 years from the date of use?

7 CFR 110

22


PROTOCOL 14: Solid Waste and Recycling

Solid waste is nonhazardous trash, including recyclable materials, and bulky wastes, liquids, or sludge generated by any operations and activities. This section addresses the collection, storage, and disposal of solid waste.


Guidelines for the storage and collection of residential, commercial, and institutional solid waste (40 CFR 243)

Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257)

Executive Order 13514: Focused on Federal Leadership in Environmental, Energy, and Economic Performance (EO 13514)

Yes No NA Solid Waste Management Citation

Are the solid wastes present at the site stored in secured, covered receptacles?

40 CFR 243

Are the solid wastes located in designated accumulation areas that are clean and safe for employees?

40 CFR 243

Are solid waste and recyclables removed at regular frequency? 40 CFR 243

Are there any active or inactive landfill or dumping grounds at the site? 40 CFR 257

Is there evidence of improper disposal in the solid waste receptacles (batteries, lamps, waste oil, etc.)?

40 CFR 261 and 40 CFR 273

Yes No NA Solid Waste Recycling and Diversion Citation

Does the site recycle, recover, or divert to waste-to-energy facilities at least 50 percent (%) of non-hazardous solid waste?

EO 13514

Does the site divert from the solid waste stream (e.g., facilitate the reuse of) at least 50% of non-hazardous construction and demolition materials and debris?

EO 13514

Does the site divert compostable and organic material from the waste stream?

EO 13514

23


Are the following recycling projects implemented and maintained where at the site?

Office Paper – Purchase recycled paper products when available, and place a container in the main office area as a collection point to be used to recycle used office paper.

Aluminum Cans – Place a container labeled “Recycling Aluminum Cans” in the break room or a designated area.

Ink Cartridges – Designate a collection point that is centrally located in the main office area.

Plastic – Place a container labeled “Plastic Recycling” in the break room or a designated area.

Universal Wastes – Designate an area for used batteries, mercury-containing equipment, and lamps.

DLA Environmental Policies

Does the site maintain a continuing record, by weight, of all non-hazardous solid waste and construction and demolition debris that is disposed of and diverted?

DLA Environmental Policies

24


PROTOCOL 15: Energy Conservation, Sustainability, and Other Occupational Health Programs

The federal government has several policies in place to reduce their energy intensity, reduce greenhouse gas emissions, reduce water consumption, and procure environmentally sustainable materials.

The following federal regulations and executive order apply to this protocol:

Federal Energy Management and Planning Program (10 CFR 436)

Comprehensive Procurement Guideline for Product Containing Recovered Materials (40 CFR 247)

Executive Order 13693: Planning for Federal Sustainability in the Next Decade (EO 13693)

Yes No NA Energy Management and Planning Citation

Does the site have a general operations 10-year plan? 10 CFR 436

Does the site input its data in an appropriate location so that it can be easily recalled for submittals related to the “Annual Report on Energy Management?”

10 CFR 436

Does the site meet all energy conservation goals established by the agency? 10 CFR 436

Is the site monitoring progress toward achieving the energy conservation goals?

10 CFR 436

Yes No NA Energy Awareness Program Citation

Have employees received annual training on energy conservation awareness and the DLA Strategic Materials 2016 Energy Awareness Program?

10 CFR 436; DLA 2016 Energy Awareness Program

Are the following percentages of the total amount of building electric energy and thermal energy at the site considered clean energy?

Not less than 10% in fiscal year (FY) 2016 and 2017; Not less than 13% in FY 2018 and 2019; Not less than 16% in FY 2020 and 2021; Not less than 20% in FY 2022 and 2023; and Not less than 30% in FY 2025 and each year thereafter.

DLA 2016 Energy Awareness Program

Yes No NA Sustainability Programs Citation

Does the site have an affirmative procurement program in place? 40 CFR 247

If so, does the site procure such items containing recovered materials to the maximum extent possible?

40 CFR 247

25


Is the site implementing the agency plan to achieve sustainability goals included in EO 13693? The EO 13693 sustainability goals include promoting:

Energy conservation; Utilizing renewable or thermal energy; Water conservation; Separating compostable and recyclable materials from the solid

waste stream; Disposing of electronic products in an environmentally sound

manner; Purchasing and utilizing ENERGY STAR products; and Incorporating climate-resilient design and management elements

into the operation, repair, and renovation of existing agency buildings and the design of new agency buildings.

EO 13693

Yes No NA Ergonomics Program Citation

Does the DLA Safety Manager have a minimum of 40 hours of formal ergonomics training?

DLA Safety and Occupational Health (SOH) Policies

Is the ergonomics program evaluated biennially? DLA SOH Policies

Do all DLA employees receive ergonomics training? DLA SOH Policies

Yes No NA Hearing Conservation Program Citation

Are all potential employees who could be exposed to hazardous noise in their employment with the DLA receiving a baseline audiogram as part of their pre-placement medical examinations and annually thereafter?

DLA SOH Policies

Are employees who are exposed to noise above the action level of 85 decibels based on the 8-hour time-weighted average issued hearing protectors?

DLA SOH Policies

Are affected employees trained annually on hearing conservation and the purpose of audiometric testing?

DLA SOH Policies

Are hearing monitoring records maintained at the site for two years? DLA SOH Policies

26


Attachment 1

Indiana Environmental Compliance Audit Protocol


Table of Contents INDIANA ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY............................................PROTOCOL 1: NEPA Process (State Environmental Review Process) – NA..........................................................

PROTOCOL 2: Historical and Cultural Resources....................................................................................................PROTOCOL 3: Natural Resource Management.........................................................................................................

PROTOCOL 4: Air Emissions....................................................................................................................................PROTOCOL 5: CERCLA (State Remediation Programs).........................................................................................

PROTOCOL 6: Hazardous Materials – NA................................................................................................................PROTOCOL 7: Hazardous and Universal Wastes......................................................................................................

PROTOCOL 8: Aboveground Storage Tanks (ASTs)................................................................................................PROTOCOL 9: Oil Spill Prevention and Preparedness – NA....................................................................................

PROTOCOL 10: Water Discharges............................................................................................................................PROTOCOL 11: Drinking Water...............................................................................................................................

PROTOCOL 12: Toxic Substances............................................................................................................................PROTOCOL 13: Pesticides.........................................................................................................................................

PROTOCOL 14: Solid Waste – NA...........................................................................................................................PROTOCOL 15: Energy Conservation and Sustainability Programs – NA...............................................................


INDIANA ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY

Protocol Compliance Topic Findings Recommendation

1

National Environmental Policy Act (NEPA) Process

(State Environmental Review Process)

No additional state requirements

2 Historical and Cultural Resources

3 Natural Resource Management

4 Air Emissions

5

Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA) (State Remediation Programs)

6 Hazardous Materials No additional state requirements

7 Hazardous and Universal Wastes

8 Aboveground Storage Tanks

9 Oil Spill Prevention and Preparedness


10 Water Discharges

11 Drinking Water

12 Toxic Substances

13 Pesticides

14 Solid Waste No additional state requirements

15 Energy Conservation and Sustainability Programs



PROTOCOL 1: NEPA Process (State Environmental Review Process) – NA

PROTOCOL 2: Historical and Cultural Resources

Yes No NA Historic and Cultural Resources Citation

Are you aware of any historic or cultural resources located on-site that are listed on the Indiana Register of Historic Places and Structures?

An online inventory of Indiana Register of Historic Places and Structures can be viewed at: http://www.ulib.iupui.edu/collections/IHSSI

Indiana Administrative Code (IAC) 14-21-1

If yes, and a project is planned that may disturb the state-listed resource, and the project includes state funding, has the site received a certificate of approval from the Indiana Historic Preservation Review Board?

IAC 14-21-1


Yes No NA Endangered and Threatened Species Citation

Is the site located in a habitat area for state-listed endangered species?

An inventory of state-listed endangered species can be viewed at: https://secure.in.gov/dnr/naturepreserve/4666.htm.

IAC 14-22-34

If the site plans to take an action that may impact a state-listed endangered species, has the site obtained a permit from the Indiana Department of Natural Resources (IDNR) prior to beginning the proposed action?

IAC 14-22-34

Yes No NA Wetlands and Surface Waters Citation

If the site plans to take an action that will disturb isolated wetlands, has the site obtained an Isolated Wetland Permit from the Indiana Department of Environmental Management (IDEM) prior to beginning the proposed action?

Isolated wetlands are not connected to other surface waters. Therefore, they are not classified as waters of the United States by the U.S. Army Corps of Engineers (USACE). However, they are waters of the State of Indiana and are regulated by the IDEM.

IAC 13-18-22



Yes No NA Air Permitting and Reporting Citation

Does the facility have an air quality permit issued by IDEM? 326 IAC 2-6

If your facility is a Title V source (a source that emits 25 tons or more of nitrogen oxide (NOx) in Lake or Porter Counties, or a source that emits 5 tons or more of lead [Section 1]), you are required to complete annual emission reporting to the IDEM by July 1.

If you meet the above requirements, does the facility report emissions annually to the IDEM?

326 IAC 2-6

Yes No NA Hazardous Air Pollutants (HAPs) Citation

The state of Indiana adheres to all federal emission standards for HAPs. The state of Indiana uses the federal HAPs list for emission inventory. The IDEM requests companies that report emissions of criteria pollutants under the emissions reporting rule, 326 IAC 2-6, to voluntarily report emissions of HAPs. The data is used to compile statewide emissions inventories for HAPs.

If the facility is required to report HAPs based on federal regulations, does it voluntarily report emissions to the IDEM?

326 IAC 2-6

PROTOCOL 5: CERCLA (State Remediation Programs)

Yes No NA Remediation Guide Citation

Are there any areas of the site that are contaminated, potentially contaminated, or perceived to be contaminated by hazardous substances or petroleum?

IDEM, Remediation Program Guide March 2012

If yes, was a site assessment or investigation activities based on the IDEM remediation program (Indiana Brownfields Program, Leaking Underground Storage Tank Program, Voluntary Remediation Program, etc.) completed?


If yes, does the site have closure documentation issued by the IDEM? IDEM, Remediation Program Guide March 2012

If remediation requires long-term maintenance or contaminants are not removed that require institutional controls, are periodic monitoring and/or inspections being completed?



PROTOCOL 6: Hazardous Materials – NA


Yes No NA Permitting and Reporting Citation

If the site is a small quantity generator (SQG), was a U.S. Environmental Protection Agency (USEPA) Form 8700-12 “Notification of Regulated Waste Activity” application submitted to the IDEM as generators of hazardous waste?

329 IAC 3.1

If the site is an SQC, does the facility submit an Annual Manifest Report by March 1 to the IDEM?

329 IAC 3.1

If the site is a large quantity generator (LQG), was a USEPA Form 8700-12 “Notification of Regulated Waste Activity” application submitted to the IDEM as generators of hazardous waste?

329 IAC 3.1

If the site is an LQG, does the facility submit an Annual Manifest Report or a Hazardous Waste Biennial Report, depending on the year?

329 IAC 3.1

PROTOCOL 8: Aboveground Storage Tanks (ASTs)

Yes No NA Tanks Citation

Does the site have ASTs with a capacity of more than 660 gallons of hazardous materials that are located in a Critical Zone of Concern?

To verify that the site is within the Critical Zone of Concern, use the following: http://www.in.gov/idem/cleanwater/pages/ast/

Indiana Code (IC) 13-18-5.5

All ASTs that are presently addressed in accordance with a state law or administrative rule under an existing state program are not required to report. Those not exempt must report to the IDEM utilizing State Form 55906.

If applicable, has the site submitted State Form 55906 before January 1, 2016?

IC 13-18-5.5


Yes No NA Flammable and Combustible Liquids Citation

Does the site use ASTs to store flammable and combustible liquids and gases?

Indiana Department of Homeland Security (IDHS) 3712

If yes, did the site complete an application for Storage Facilities for Flammable and Combustible Liquids and Gases (State Form 8451)?

IDHS 3712

Do the ASTs have secondary containment (i.e., double walled, dikes, berms)?

IDHS 3712

Do you have a “Site” plan showing AST locations along with a spill response plan?

IDHS 3712

PROTOCOL 9: Oil Spill Prevention and Preparedness – NA


Yes No NA Wastewater Permitting Citation

Does the site have a National Pollutant Discharge Elimination System (NPDES) Permit to discharge wastewater issued by the IDEM?

327 IAC 15-1 through 15-4


Is the site completing monitoring/sampling events? 327 IAC 15-1 through 15-4

Have any discharge permit violations occurred? 327 IAC 15-1 through 15-4

Is the permit expired? 327 IAC 15-1 through 15-4


Yes No NA Industrial Stormwater Permitting Citation

Does the site have stormwater that is exposed to industrial activity and the Standard Industrial Classification (SIC) Code requiring a NPDES General Permit issued by the IDEM?

If yes, skip to questions below.

327 IAC 15-6

If the site requires a NPDES General Permit, but stormwater is not exposed to industrial activities, was a Conditional No Exposure Certification Form (USEPA NPDES Form 3510-11) completed?

327 IAC 15-6

If the site is covered under the NPDES General Permit:

Does the site have a Storm Water Pollution Prevention Plan (SWP3)? 327 IAC 15-6

Is the site completing, at a minimum, quarterly inspections? 327 IAC 15-6

Is the site completing annual stormwater monitoring? 327 IAC 15-6

Is the site submitting annual a Storm Water Discharge Monitoring Report Form (State Form 53590)?

327 IAC 15-6

Is the permit expired? 327 IAC 15-6

Yes No NA Construction/Land Disturbance Stormwater Permitting Citation


3217 IAC 15-5

If yes, was Construction Plan including the SWP3 developed? 3217 IAC 15-5

Was the Notice of Intent (NOI) State Form 47487 submitted to the IDEM? 3217 IAC 15-5


PROTOCOL 11: Drinking Water

Yes No NA Public Water Systems Citation

If the site meets requirements of a Public Water System (transient, non-transient non-community, and community), does it have an IDEM-approved Site Sampling Plan?

327 IAC 8

On April 1, 2016, the Revised Total Coliform Rule (RTCR) went into effect.

If the site is required to sample for total coliform, are sample results in compliance with the RTCR?

327 IAC 8


Yes No NA Lead-Based Paint Citation

The Indiana State Department of Health (ISDH) implements state and federal regulations concerning lead-based paint. Are ISDH-certified contractors utilized for lead abatement activities?

410 IAC 32

Are lead abatement notification procedures followed and documented? 410 IAC 32

Yes No NA Asbestos Citation

The IDEM Asbestos Program requires that all facilities scheduled for renovation or demolition be inspected by an Indiana licensed asbestos inspector prior to the start any activities for the presence of asbestos.

Prior to asbestos abatement activities, are notification procedures followed and documented using State Form 44593?

326 IAC 14-10


Pesticide Use and Application

The Office of Indiana State Chemist (OISC) regulates the distribution and application of pesticides in the State of Indiana.

If pesticides are applied at the site by a commercial or private contractor, are they using an OISC-licensed applicator?

355 IAC 4-0.5-1 Article 4


PROTOCOL 14: Solid Waste – NA

PROTOCOL 15: Energy Conservation and Sustainability Programs – NA


Attachment 2

NEW YORK ENVIRONMENTAL COMPLIANCE

AUDIT PROTOCOL


TABLE OF CONTENTS

NEW YORK ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY..........................................................

PROTOCOL 1: NEPA Process (State Environmental Review Process) – NA.............................................................................

PROTOCOL 2: Historic and Cultural Resources..........................................................................................................................

PROTOCOL 3: Natural Resource Management...........................................................................................................................

PROTOCOL 4: Air Emissions......................................................................................................................................................

PROTOCOL 5: CERCLA (State Remediation Programs)............................................................................................................

PROTOCOL 6: Hazardous Materials – NA..................................................................................................................................

PROTOCOL 7: Hazardous and Universal Waste.........................................................................................................................

PROTOCOL 8: Aboveground Storage Tanks...............................................................................................................................

PROTOCOL 9: Oil Spill Prevention and Preparedness – NA......................................................................................................

PROTOCOL 10: Water Discharges..............................................................................................................................................

PROTOCOL 11: Drinking Water – NA........................................................................................................................................

PROTOCOL 12: Toxic Substances...............................................................................................................................................

PROTOCOL 13: Pesticides.........................................................................................................................................................10

PROTOCOL 14: Solid Waste – NA............................................................................................................................................10

PROTOCOL 15: Energy Conservation and Sustainability Programs – NA...............................................................................10


NEW YORK ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY


1National Environmental Policy

Act (NEPA) Process (State Environmental Review Process)




4 Air Emissions

5








10 Water Discharges

11 Drinking Water No additional state requirements

12 Toxic Substances

13 Pesticides






PROTOCOL 2: Historic and Cultural Resources

Yes No NA Historic and Cultural Resource Assessment Citation

Are you aware of any historic or cultural resources located on-site that are listed on the New York Register of Historic Places?

The New York Register of Historic Places can be viewed on the Cultural Resource Information System: https://cris.parks.ny.gov/Login.aspx?ReturnUrl=%2f

9 New York Codes, Rules and Regulations (NYCRR) 426.1

If yes, do you have a plan for preservation and protection of the historic or cultural resource?

9 NYCRR 426.1


Yes No NA Endangered Species Citation

Is the site located in a habitat area for endangered species, threatened species, or species of special concern listed by the state of New York?

The list of endangered species, threatened species, or species of special concern can be viewed at: http://www.dec.ny.gov/animals/7494.html

6 NYCRR 182.5

If yes, and the site plans to take an action that may impact an endangered species, threatened species, or species of special concern, has the site obtained an incidental take permit?

6 NYCRR 182.8

Yes No NA Wetlands Citation

Are there wetland areas with an area of 12.4 acres or larger, or wetland areas that are of unusual local significance at the site?

A wetland of unusual local significance is defined as a Class I wetland in 6 NYCRR 664.5: https://govt.westlaw.com/nycrr/Document/I4ece2eaecd1711dda432a117e6e0f345?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default)

6 NYCRR 664.7

If yes, and the site plans to take an action that may impact the wetland area, has the site obtained a state permit or letter of permission from the New York State Department of Environmental Conservation (NYSDEC)?

6 NYCRR 663.4



Yes

No NA Minor Source Facility Registration Citation

Is the site registered with the NYSDEC air program based on the site’s air pollutant emissions (i.e., the site emits air pollutants that are not considered exempt or trivial under 6 NYCRR 201-3)?

6 NYCRR 201-4.1

If yes, has the site renewed its registration with the NYSDEC within the last 10 years?

6 NYCRR 201-4.2

Yes

No NA State Facility Air Quality Permit Citation

Does the site have a State Facility Air Quality Permit under the NYSDEC? 6 NYCRR 201-5.1

Does the site follow the operating conditions set forth in the State Facility Air Quality Permit?

6 NYCRR 201-5

Does the site follow the reporting conditions set forth in the State Facility Air Quality Permit?

6 NYCRR 201-5

Does the site maintain records of all monitoring data and support information for at least 5 years?

6 NYCRR 201-6.4

Yes

No NA Title V Air Quality Permit Citation

Does the site have a Title V Facility Permit under the NYSDEC? 6 NYCRR 201-6

Are reports of any required monitoring and support information (as specified in the Title V Facility Permit) submitted electronically to the NYSDEC at least every 6 months?

6 NYCRR 201-6.4


6 NYCRR 201-6.4




Are there any areas of the site that are contaminated or potentially contaminated by hazardous substances or petroleum?

NYSDEC, Division of Environmental Remediation (DER)-10 Technical Guidance for Site Investigation and Remediation, May 2010

If yes, has the site performed environmental investigation or remediation activities to address the contamination in accordance with the NYSDEC remediation program guidance?

NYSDEC remediation programs include the Inactive Hazardous Waste Disposal Site Remedial Program (aka State Superfund Program); Brownfield Cleanup Program (BCP); Environmental Restoration Program (ERP); and Voluntary Cleanup Program (VCP).

NYSDEC, DER-10 Technical Guidance for Site Investigation and Remediation, May 2010

If yes, has the NYSDEC granted site closure for contaminant investigation and cleanup at the site?

NYSDEC, DER-10 Technical Guidance for Site Investigation and Remediation, May 2010


PROTOCOL 7: Hazardous and Universal Waste


If the site is a large quantity generator (LQG), was a U.S. Environmental Protection Agency (USEPA) Form 8700-12 “Notification of Regulated Waste Activity” application submitted to the NYSDEC as generators of hazardous waste?

6 NYCRR Part 370 series

If the site is an LQG, does the facility submit a Hazardous Waste Report annually by March 1 of each year?

6 NYCRR Part 370 series



Yes No NA Aboveground Storage Tanks (ASTs) General Regulations Citation

Are all ASTs at the site registered with the NYSDEC?

Note: All ASTs must be re-registered with the NYSDEC every 5 years.

6 NYCRR 613-1.9

Does the site maintain an NYSDEC facility registration certificate? 6 NYCRR 613-1.9

Are all ASTs marked (for example, with stenciled letters) with the tank registration identification number, tank design type, and working capacities?

6 NYCRR 613-4.1

Are all AST systems color coded in accordance with American Petroleum Institute (API) RP 1637 at or near the fill port?

If an AST contains petroleum that does not have a corresponding API color code, the facility must otherwise mark the AST (for example, with stenciled letters) to identify the petroleum currently in the AST.

6 NYCRR 613-4.1

Are all ASTs at the site equipped with a gauge which accurately shows the level of petroleum in the AST?

The gauge must be accessible to the carrier and be installed so it can be conveniently read. Note that a high-level warning alarm, a high-level liquid pump cut-off controller, or equivalent device may be used in lieu of a gauge.

6 NYCRR 613-4.1

Are the AST level gauges accessible to the carrier and installed so it can be conveniently read?

6 NYCRR 613-4.1

Are all ASTs at the site that contain used oil labeled “Used Oil” and with the tank capacity?

6 NYCRR 360-14

For ASTs with secondary containment, is stormwater that collects within the secondary containment system controlled by a manually operated pump or siphon, or a gravity drain pipe that has a manually controlled dike valve on the outside of the dike?

6 NYCRR 613-4.2


Yes No NA Spill Prevention and Leak Detection Citation

Are all AST gauges, valves, and other equipment for spill prevention in good working order?

6 NYCRR 613-4.1

Does the site perform monthly leak detection inspections of the AST systems?

The leak detection inspection must cover the tank, any leak detection system, cathodic protection monitoring equipment, or other monitoring or warning system that may be in place. The inspection must include, as applicable, identification of leaks, cracks, areas of wear, corrosion and thinning, poor maintenance and operating practices, excessive settlement of structures, separation or swelling of tank insulation, malfunctioning equipment, and structural and foundational weaknesses.

6 NYCRR 613-4.3

Does the site maintain records of the monthly leak detection inspections for at least 3 years?

6 NYCRR 613-4.3

Is a tightness test performed by a qualified tester on each AST and associated underground piping at least every 10 years?

Note: The tightness test report must be submitted to the NYSDEC within 30 days of the test.

6 NYCRR 613-4.3

Does the site maintain records of all AST tightness tests for at least 10 years?

6 NYCRR 613-4.3

Are known or suspected petroleum spills (i.e., product releases of any manner) at the site reported to the New York Spill Hotline (1-800-457-7362) within 2 hours of discovering the release?

All petroleum spills must be reported to the spill hotline, unless the spill meets all of the following criteria:

The quantity is known to be less than 5 gallons; The spill is contained and under the control of the spiller; The spill has not and will not reach the State's water or any land;

and The spill is cleaned up within two hours of discovery.

6 NYCRR 613-4.4

Yes No NA ASTs with Cathodic Protection Citation

If the site has metal ASTs with cathodic corrosion protection, is testing performed annually by a qualified tester to ensure that the cathodic protection system is working properly?

6 NYCRR 613-4.2

Does the site maintain records of annual cathodic protection tests for at least 3 years?

6 NYCRR 613-4.2

For metal ASTs with impressed current cathodic protection, are records of 6 NYCRR 613-4.2


impressed current inspections maintained for at least 3 years?

Yes No NA Higher Risk ASTs Citation

Does the site have ASTs with a capacity of 10,000 gallons or greater, or ASTs that could reasonably be expected to discharge petroleum to groundwater or surface waters?

Any AST located within 500 feet of a storm drain, public or private water well, or surface waters, is considered likely to discharge to groundwater or surface water in the event of a release.

6 NYCRR 613.3

If yes, is there secondary containment around these ASTs that is constructed of a material so that petroleum spills will not permeate, drain, or otherwise escape to the groundwater or surface waters?

6 NYCRR 613.1 and 613.3

Are these ASTs structurally inspected every 10 years to ensure that they are in sound condition?

This requirement does not apply to ASTs that are entirely aboveground, such as tanks on skids or cradles, or ASTs containing No. 5/6 fuel oil.

6 NYCRR 613-4.3

Does the site maintain records of the AST structural inspection for at least 10 years?

6 NYCRR 613-4.3

Yes No NA Out-of-Service and Closed ASTs Citation

Note: Out-of-service AST systems that contain petroleum products must still comply with all of the leak detection inspections and AST system operation and maintenance activities outlined in this protocol as if the tanks were in service.

However, empty out-of-service AST systems do not need to comply with the leak detection inspections and AST system operation and maintenance activities. An AST system is considered empty when all materials have been removed using commonly employed practices so that no more than 1 inch of residue remains in the system.

6 NYCRR 613-4.5

If an AST system is out of service for more than 3 months, are all vent lines open and functioning and all other piping, ancillary equipment, and manways capped and/or secured?

6 NYCRR 613-4.5

Are all closed ASTs either removed from the site or emptied, cleaned, and secured in place with the date of permanent closure stenciled on the tank?

6 NYCRR 613-4.5

Has the site submitted a copy of the AST closure records to the NYSDEC within 30 days of permanent closure of the AST system?

6 NYCRR 613-4.5


Does the site maintain AST permanent closure records for 3 years? 6 NYCRR 613-4.5



Yes No NA Wastewater Permitting Citation

Does the site have a State Pollutant Discharge Elimination System (SPDES) Private/Commercial/Industrial (PCI) General Permit to discharge wastewater issued by the NYSDEC?

6 NYCRR Section 750-1.11 and SPDES GP-0-15-001

If the site is permitted, continue with the following questions:

Is the site completing monitoring/sampling events? 6 NYCRR Section 750-1.11 and SPDES GP-0-15-001

Have any discharge permit violations occurred? 6 NYCRR Section 750-1.11 and SPDES GP-0-15-001

Is the permit expired? 6 NYCRR Section 750-1.11 and SPDES GP-0-15-001


Does the site have stormwater that is exposed to industrial activity and Standard Industrial Classification (SIC) Code requiring a SPDES Multi Sector General Permit (MSGP) for Stormwater Discharges from Industrial Activity (GP-0-12-001) issued by the NYSDEC?


SPDES GP-0-12-001

If the site requires an SPDES MSGP, but stormwater is not exposed to industrial activities, was a No Exposure Certification for Exclusion from SPDES Storm Water Permitting Form (2005) completed?

SPDES GP-0-12-001

If the site is covered under the SPDES General Permit:

Does the site have a Stormwater Pollution Prevention Plan (SWPPP)? SPDES GP-0-12-001

Is the site completing the Quarterly Visual Monitoring Form? SPDES GP-0-12-001

Is the site completing the annual dry weather flow monitoring? SPDES GP-0-12-001


Is the site completing benchmark monitoring and submitting Discharge Monitoring Reports?

SPDES GP-0-12-001

Is the site submitting the Annual Certification Report Form, due by February 28 of each year?

SPDES GP-0-12-001

Yes No NA Stormwater Permit for Construction Activity Citation

Has the site conducted a construction activity that disturbed 1 acre or more of land?

SPDES GP-0-15-002

If yes, was a Construction Plan including the SWPPP completed? SPDES GP-0-15-002

Was the Notice of Intent (NOI) submitted to the NYSDEC? SPDES GP-0-15-002

PROTOCOL 11: Drinking Water – NA


Yes No NA Toxic Substances – Asbestos Citation

Does the site utilize state-licensed asbestos abatement contractors for all asbestos abatement projects?

12 NYCRR 56-3.2

Is a written notice provided to occupants of the building/structure, including visitors to the building/structure, 10 days prior to beginning work on any asbestos project within the building/structure?

The written notice must be given to those business and residential occupants of a building/structure, or portion thereof, who are located on the floor or floors where the actual asbestos project is to be conducted, and one floor above and one floor below the floor or floors containing the project. In addition, such written notice must also be given to those occupants of adjacent building/structures who have direct horizontal access to these floors. Posted notice must be provided at all direct means of access to the floor, such as but not limited to stairways, ramps, emergency ingress or egress, elevators, escalators, ladders, hallways, corridors, and trapdoors.

If an emergency makes it impossible to provide the 10-day notice required by the above rule, the site must post or otherwise provide for written notice to occupants of the building/structure, as soon as practicable after identification of the project, in the manner set forth by the above rule.

Rule 12 NYCRR 56-3.6 provides the information that must be included in the written notice.

12 NYCRR 56-3.6


Is a project record maintained at the site for all ongoing asbestos abatement projects?

Note: Regulation 12 NYCRR 56-3.4 provides the information that must be included in the asbestos project report. The asbestos project record is typically prepared by the abatement contractor.

12 NYCRR 56-3.4


Yes No NA Pesticide Use and Application Citation

Are personnel and contractors who apply pesticides at the site certified by the state of New York?

New York state regulations generally follow federal FIFRA regulations (40 CFR 150–186).

6 NYCRR 325.2




Attachment 3

Nevada Environmental Compliance Audit Protocol


TABLE OF CONTENTS

NEVADA ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY............................................

PROTOCOL 1: NEPA Process (State Environmental Review Process) – NA..........................................................PROTOCOL 2: Historical and Cultural Resources – NA...........................................................................................

PROTOCOL 3: Natural Resource Management – NA...............................................................................................PROTOCOL 4: Air Emissions....................................................................................................................................

PROTOCOL 5: CERCLA (State Remediation Programs).........................................................................................PROTOCOL 6: Hazardous Materials – NA................................................................................................................

PROTOCOL 7: Hazardous and Universal Wastes......................................................................................................PROTOCOL 8: Aboveground Storage Tanks – NA...................................................................................................

PROTOCOL 9: Oil Spill Prevention and Preparedness – NA....................................................................................PROTOCOL 10: Water Discharges............................................................................................................................

PROTOCOL 11: Drinking Water – NA......................................................................................................................PROTOCOL 12: Toxic Substances – NA...................................................................................................................

PROTOCOL 13: Pesticides.........................................................................................................................................PROTOCOL 14: Solid Waste – NA...........................................................................................................................

PROTOCOL 15: Energy Conservation and Sustainability Programs – NA...............................................................


NEVADA ENVIRONMENTAL COMPLIANCE AUDIT PROTOCOL SUMMARY


1

National Environmental Policy Act (NEPA) Process

(State Environmental Review Process)


2 Historical and Cultural Resources State requirements not applicable

3 Natural Resource Management State requirements not applicable

4 Air Emissions

5





8 Aboveground Storage Tanks No additional state requirements



10 Water Discharges


12 Toxic Substances No additional state requirements

13 Pesticides






PROTOCOL 2: Historical and Cultural Resources – NA

PROTOCOL 3: Natural Resource Management – NA


Yes No NA Air Quality Permit Citation

Does the site require an air permit issued by the NDEP Air Quality Permitting Program?

Permit types include: Class 1, Class 2, Class 3, Class 4, and Surface Area Disturbance.

Nevada Administrative Code (NAC) 445B

Does the site follow the reporting conditions set forth in the permit and submit annual Emission Inventory forms by March 1?

NAC 445B


NAC 445B

Yes No NA Chemical Accident Prevention Program (CAPP) Citation

Does the site use, store, produce, or otherwise handle any highly hazardous substance in excess of the listed threshold quantity?

The list of substances can be found online at: http://ndep.nv.gov/bapc/capp/caprsi.html

NAC 459

If yes, does the site have a CAPP? NAC 459

Does the site have documentation of Annual CAPP Registration, which is due by June 21 of each year and completed online through CAPPTrack?

NAC 459

Has the site developed and implemented each of the CAPP policies, procedures, and program elements; including Management Plan and Document Control?

The checklist of program elements can be found online at: http://ndep.nv.gov/bapc/capp/capguid.html

NAC 459

Employee refresher training is required at least once every 3 years. Was the latest training completed within the past 3 years?

NAC 459




Are there any areas of the site that are contaminated, potentially contaminated, or perceived to be contaminated by hazardous substances or petroleum products?

NAC 445A

If yes, were site assessment or investigation activities completed based on the Bureau of Corrective Actions (BCA), a division of the NDEP, cleanup requirements (Nevada Brownfields Program, Superfund Program, or Voluntary Cleanup Program, etc.)?

NAC 445A

If yes, does the site have documentation issued by NDEP determining “No Further Action” or “Certificate of Completion” for the site.

NAC 459




If the site is a large quantity generator (LQG), was a U.S. Environmental Protection Agency (USEPA) Form 8700-12 “Notification of Regulated Waste Activity” application submitted to the NDEP to obtain a USEPA Identification Number?

NAC 459

If yes, is the site submitting their Biennial Hazardous Waste Report electronically using Easitrak software?

NAC 459

PROTOCOL 8: Aboveground Storage Tanks – NA





Does the site have stormwater that is exposed to industrial activity and under 1 of 11 categories requiring a National Pollutant Discharge Elimination System (NPDES) General Permit issued by the NDEP?


NAC 445A

If the site requires a NPDES General Permit, but stormwater is not exposed to industrial activities, did the site complete the Conditional No Exposure Certification Form (USEPA NPDES Form 3510-11)?

NAC 445A

If the site is covered under the NPDES General Permit:

Does the site have a Stormwater Pollution Prevention Plan (SWPPP)? NAC 445A

Are employees who are responsible for implementing or maintaining activities identified in the SWPPP receiving annual training? And if so, are training records maintained in the SWPPP?

NAC 445A

Is the site completing, at a minimum, quarterly inspections? NAC 445A

Is the site completing quarterly visual monitoring? NAC 445A

Is the site completing an annual comprehensive site compliance evaluation? NAC 445A

Is the permit expired? NAC 445A

Yes No NA Construction Stormwater Permitting Citation


NAC 445A

If yes, did the site complete a Notice of Intent (NOI) for coverage under the Construction Stormwater General Permit NVR100000?

NAC 445A

If yes, was a Construction Plan including the SWPPP developed? NAC 445A


PROTOCOL 12: Toxic Substances – NA



Pesticide Use and Application

The Nevada Department of Agriculture (NDA) regulates the distribution and application of pesticides in the State of Nevada.

If pesticides are applied at the site by commercial or private contractors, is a Nevada-certified applicator being used?

NAC 555




Attachment 4

Ohio Environmental Compliance Audit Protocol


TABLE OF CONTENTS

OHIO ENVIRONMENTAL COMPLIANCE............................................................................................................

AUDIT PROTOCOL SUMMARY.............................................................................................................................PROTOCOL 1: NEPA Process (State Environmental Review Process) – NA..........................................................

PROTOCOL 2: Historic and Cultural Resources – NA..............................................................................................PROTOCOL 3: Natural Resource Management – NA...............................................................................................

PROTOCOL 4: Air Emissions – NA..........................................................................................................................PROTOCOL 5: CERCLA (State Remediation Programs) – NA ................................................................................

PROTOCOL 6: Hazardous Materials – NA................................................................................................................PROTOCOL 7: Hazardous and Universal Waste.......................................................................................................

PROTOCOL 8: Aboveground Storage Tanks.............................................................................................................PROTOCOL 9: Oil Spill Prevention and Preparedness – NA....................................................................................

PROTOCOL 10: Water Discharges – NA..................................................................................................................PROTOCOL 11: Drinking Water – NA......................................................................................................................

PROTOCOL 12: Toxic Substances – NA...................................................................................................................PROTOCOL 13: Pesticides – NA...............................................................................................................................

PROTOCOL 14: Solid Waste – NA...........................................................................................................................PROTOCOL 15: Energy Conservation and Sustainability Programs – NA...............................................................


OHIO ENVIRONMENTAL COMPLIANCE

AUDIT PROTOCOL SUMMARY


1

National Environmental Policy Act (NEPA) Process (State Environmental Review

Process)



State requirements not applicable



4 Air Emissions State requirements not applicable

5

Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA)

(State Remediation Programs)







10 Water Discharges State requirements not applicable


12 Toxic Substances State requirements not applicable

13 Pesticides State requirements not applicable


15 Energy Conservation and No additional state


Sustainability Programs requirements


PROTOCOL 2: Historic and Cultural Resources – NA

PROTOCOL 3: Natural Resource Management – NA

PROTOCOL 4: Air Emissions – NA

PROTOCOL 5: CERCLA (State Remediation Programs) – NA


PROTOCOL 7: Hazardous and Universal Waste


If the facility is a Small Quantity Generator (SQG) or a Large Quantity Generator (LQG), was a USEPA Form 9029 “RCRA Subtitle C Site Identification” submitted to the Ohio EPA to obtain a USEPA Identification Number?

OAC 3745-52-12

If the facility is an LQG, does the facility submit a Hazardous Waste Biennial Report by March 1 of each even year?

OAC 3745-52-41

Conditional Exempt Small Quantity Generators of hazardous waste in Ohio are required to document hazardous waste determination through process knowledge or analysis. Does the facility have records of waste evaluation?

OAC 3745-52-11


Yes No NA Aboveground Storage Tank (AST) Registrations and Permits Citation

Are all ASTs at the site registered with the Ohio State Fire Marshall BUSTR?

OAC 1301:7-7-3401

Does the site maintain documentation of AST registrations and permits? OAC 1301:7-7-3401

Has the site obtained a permit from BUSTR prior to making alterations to the ASTs and associated piping or components?

OAC 1301:7-7-3401

Has the site obtained a permit from BUSTR prior to abandoning, removing, or placing an AST temporarily out of service?

OAC 1301:7-7-3401


Yes No NA AST Security and Safety Citation

Are the AST system areas protected from public access? OAC 1301:7-7-3404

If the ASTs are not enclosed in vaults, are they surrounded by a chain link fence at least 6 feet high with a secured entry?

OAC 1301:7-7-3404

Are there guard posts or other approved means installed to protect the AST, piping, valves, and fittings from vehicular damage?

OAC 1301:7-7-3403

Are there signs posted surrounding the AST areas prohibiting open flames and smoking?

OAC 1301:7-7-3404

Are ASTs with a capacity greater than 100 gallons labeled to identify the tank product?

OAC 1301:7-7-3404

Is a permanent sign that documents the AST filling procedure and the tank calibration chart located at the AST fill point?

OAC 1301:7-7-3404

Are ASTs only filled to a maximum of 95 percent (%) of tank capacity? OAC 1301:7-7-3404


Yes No NA AST System Requirements Citation

Is a spill container with a capacity of at least 5 gallons provided at each AST fill connection point?

OAC 1301:7-7-3404

Is the area surrounding an AST or group of ASTs provided with drainage control or diked to prevent accidental discharge of liquid from impacting adjoining properties or reaching waterways?

OAC 1301:7-7-3404

Do all ASTs have normal vents and emergency vents (to relieve excess internal pressure caused by exposure to fires)?

OAC 1301:7-7-3404

Do AST normal vents have flame arresters or pressure vacuum breather valves?

OAC 1301:7-7-3404

Do ASTs with capacity greater than 1,320 gallons have an overfill prevention mechanism?

OAC 1301:7-7-3404

Are the AST systems fitted with check valves or block valves for automatic protection against backflow during filling?

OAC 1301:7-7-3403

Are all piping-related fluid-handling components and supports that are subject to external corrosion made from noncorrosive materials and coated or provided with corrosive protection?

OAC 1301:7-7-3403

Are all AST connections that are located below a normal liquid level provided with internal or external isolation valves located as close as practical to the shell of the tank?

OAC 1301:7-7-3403

Are ASTs, piping, and ancillary equipment maintained in a safe operating condition in accordance with the manufacturer specifications?

OAC 1301:7-7-3404


PROTOCOL 10: Water Discharges – NA


PROTOCOL 12: Toxic Substances – NA

PROTOCOL 13: Pesticides – NA




Attachment 5

Environmental Compliance Audit Protocol Summary


ENVIRONMENTAL COMPLIANCE AUDIT FINDINGS SUMMARYSITE AUDIT INFORMATION

Site Name and Location: Auditor Name:

Audit Date: Title:

Signature:

Protocol No. and Topic

Non-Compliance Finding and Root Cause

Recommended Corrective Action

Person Responsible for Resolving Non-

Compliance Finding

Resolution of Non-Compliance Finding


Protocol No. and Topic

Non-Compliance Finding and Root Cause

Recommended Corrective Action

Person Responsible for Resolving Non-

Compliance Finding

Resolution of Non-Compliance Finding

Documents

ENVIRONMENTAL, SAFETY AND · Web viewThis document has been developed to assist the Defense Logistics Agency (DLA) Strategic Materials (SM) in conducting internal environmental