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Top 10 Audit Issues. Don Gansert Managing Consultant February 19, 2009. trinityconsultants.com. Multi-Media Audits . Housekeeping Matters The typical compliance issues per media: Air Water Waste Right to Know Risk Management Program Process Safety Management . Air . - PowerPoint PPT Presentation
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Top 10 Audit Issues
Don GansertManaging Consultant
February 19, 2009
trinityconsultants.com
Multi-Media Audits
Housekeeping Matters The typical compliance issues per media:
Air Water Waste Right to Know Risk Management Program Process Safety Management
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
Water
NPDES permits Storm water pollution prevention
plans Spill prevention control and
countermearsure plan
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
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
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
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
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
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)
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
Questions?