Environmental Audit

  • Prepared by: HRP Associates Inc.

  • This checklist is intended to assist companies in achieving compliance with environmental regulations. HRP does not make any warranty or representation, either expressed or implied, that using this checklist will satisfy all environmental requirements. In addition, HRP does not assume any liability of any kind whatsoever resulting from the use of or reliance upon this checklist.

  • Facility Name:

  • Address:

  • City:

  • Zip:

  • Date of Inspection:

  • Site contact (name/title):

  • Site contact (name/title):

  • * please note, this is not a state specific checklist. Additional information may need to be collected depending on the state's environmental regulations

  • State:

  • Inspector(s):

  • Telephone:

  • Is Waste Water Compliance Necessary?

  • Is there documented proof that a permit is not needed (either from POTW or state)?

  • Other? (Notes)

  • Is there documented proof that a permit is not needed (either from POTW or state)?

  • Other? (Notes)

  • Discharge name(s), Generation Rate(s) (gdp), Discharge Point(s)

  • What Type of Permit(s) does the facility hold (i.e. NDPES, pretreatment, general or other?)

  • What is the permit number?

  • What is the permit expiration date?

  • What pollutants are required to be sampled in the permit?

  • What is the required sampling frequency?

  • Identify the required operator level stated in the permit.

  • Briefly describe the treatment mechanisms employed.

  • Does the current treatment system employed match that which was described in the permit application?

  • Does the facility have a wastewater operations and maintenance manual? (note the revision date in the comments section)

  • Is the facility meeting its required sampling frequency?

  • Is the facility meeting its required reporting frequency?

  • Has the facility received any NOVs or warnings relative to its discharge?

  • Is the facility maintaining its required calibration logs? (reference permit for frequency)

  • If utilizing wastewater basins, are the banks and areas around the basins well maintained (i.e. no cat tails, trees, etc. growing out of the banks?

  • Can the operator show you proof of his certification?

  • Other? (Notes)

  • Is Stormwater Compliance Necessary?

  • Is the facility covered by the state's industrial general permit? ( Note the Registration/ NOI Submittal Date) (Note the Coverage Number)

  • Was "No Exposure" claimed?

  • Is the facility covered by the state's industrial general permit? ( Note the Registration/ NOI Submittal Date) (Note the Coverage Number)

  • Was "No Exposure" claimed?

  • Other? (Notes)

  • Is the facility covered by the state's industrial general permit? ( Note the Registration/ NOI Submittal Date) (Note the Coverage Number)

  • Was "No Exposure" claimed?

  • Are raw materials, intermediate products, wastes, etc. stored outside? (If yes, list types and quantities)

  • Has a Stormwater Pollution Prevention Plan (SPPP) been prepared? (Note revision date in the comments box)

  • Has the SPPP been certified by a registered Professional Engineer? (If required by state)

  • Has SWPPP Training been conducted annually?

  • Are SWPPP Training records maintained on-site?

  • Are stormwater sampling results maintained on-site? (if required by state)

  • Are stormwater samples reported to the state (if required)?

  • Are inspection results required under the SPPP maintained on-site?

  • Description and number of conveyance systems on-site (e.g. pipe, channel, conduit, tunnel, catch basin, etc.) for storm water discharge.

  • Other? (Notes)

  • Is UST Compliance Necessary?

  • UST location(s) and identification(s), Contents, volume, Installation Date, Usage, Construction, Containment

  • Does the facility have an SPCC plan? (If yes, get a copy) (A SPCC Plan is required, if the total U/G storage volume for petroleum products is >42,000 gallons.)

  • Are underground tanks registered with the State? If yes, what are the registration date and numbers?

  • Is there a trained A/B and C operator on site? (Verify copy of license)

  • What is the material of construction for the piping?

  • Is the piping double walled or otherwise contained?

  • Is the piping leak tested, at what frequency?

  • Is the piping cathodically tested?

  • How is cathodic protection addressed?

  • Is cathodic protection tested or inspected?

  • How is leak detection addressed?

  • is leak detection (i.e. a passing result) monitored monthly?

  • How is spill and overflow addressed?

  • Is the spill bucket clean and empty of material?

  • Is the overfill system tested periodically?

  • Other? (Notes)

  • Is AST Compliance Necessary?

  • AST location(s) and identification(s), Contents, volume, Installation Date, Usage, Construction, Containment

  • Does the facility have an SPCC plan? (If yes, get a copy) (A SPCC Plan is required, if the total A/G storage volume for petroleum products is >1,320 gallons total.)

  • Are all SPCC inspections and reporting requirements being completed and maintain on-site for previous 3 years?

  • Does it appear that all oils are appropriately included within the SPCC Plan?

  • Date of Plan. (Plan must be revised within 6 months of change or 5 years, which is less.)

  • Date of last training. (Require Annually)

  • Description of inspection schedule.

  • Note any discrepancies to the standard with regard to containment, overfill protection, or emergency response.

  • Does facility have proof of financial responsibility for tanks? (state-specific)

  • Do tanks have adequate secondary containment? (state-specific)

  • Do tanks have spill containment at fill ports? (state-specific)

  • Do tanks have release detection methods in place? (state-specific)

  • Are inspection, release detection monitoring and testing records maintained? (state-specific)

  • Other? (Notes)

  • Is Air Compliance Necessary

  • If no, is there documentation of exempt status on site?

  • Other? (Notes)

  • If no, is there documentation of exempt status on site?

  • Other? (Notes)

  • Inventory of Air Emissions Source(s), Permitted?, Pollutant. Process Description, Controls, Emission Rate

  • Are these air pollution sources permitted? If yes, obtain a copy of the permit.

  • Is the facility abiding by all conditions and limitations within the air permit?

  • Is your facility considered a Title V "major source"?

  • Does your facility emit any toxic or hazardous air pollutants?

  • Is your facility covered under any Maximum Achievable Control Technology (MACT) source categories? (see NSPS and NESHAP Listings)

  • Has your facility submitted an annual emission statement to the appropriate state agency?

  • Does your facility have applicable accidental release substances (112n of CAAA) on-site? If yes, get copy of RMP Program and Filing.

  • Does your facility use any ozone depleting substances?

  • Does facility personnel service equipment that normally maintains 50 pounds or more of refrigerant?

  • Who conducts the service on the 50 pounds or more of refrigerant equipment? (Employee or Contractor)

  • Are logs maintained on the 50 pounds or more of refrigerant equipment?

  • Are certifications of operators maintained on the 50 pounds or more of refrigerant equipment?

  • List all applicable NSPS and MACT standard(s), Notification Date, Notification Submitted

  • Other? (Notes)

  • Is SARA Reporting Compliance Necessary?

  • If N/A is proof of N/A available?

  • Other? (Notes)

  • If no, is proof of no available?

  • Other? (Notes)

  • If EHS, have local authorities been notified of Emergency Coordinator?

  • Have fire marshal notifications (MSDS submissions or list) been made?

  • Have Tier Two Forms been submitted? (If yes, get a copy)

  • Have Form R's applicability been documented?

  • If Form Rs are required, are proof of submissions available for review?

  • Tier II Chemical(s), Max inventory on site, TPQ, EHS or OSHA, Reported (yes/no).

  • Form R Chemical(s), Otherwise Used (lbs), Processed (lbs), Manufactured (lbs), Threshold.

  • Did you observe any chemicals that may have been left off of the Tier II or Form R reports?

  • Other? (Notes)

  • Is PCB Compliance Necessary?

  • Do the ballasts contain PCBs?

  • Are used PCB Ballasts dated?

  • Are used PCB Ballasts labeled?

  • Are used PCB Ballasts contained?

  • Are used PCB Ballasts Disposed within one month or registered with EPA to allow for longer storage up to one year.

  • Are any transformers on site?

  • Are transformers on site owned by facility or utility company?

  • If owned by the facility, are the transformers PCB containing?

  • Are PCB transformers registered with the EPA?

  • Are PCB transformers labeled?

  • Are PCB transformers inspected monthly?

  • Other? (Notes)

  • Is Asbestos Compliance Necessary?

  • If no, is there an asbestos inspection showing no asbestos in the facility?

  • Other? (Notes)

  • If N/A, is there an asbestos inspection showing no asbestos in the facility?

  • Other? (Notes)

  • Have any renovation or demolition projects occurred in the last 3 years?

  • Was an asbestos survey conducted prior to any renovation/demolition?

  • If asbestos identified Was a notice of abatement filed with the State?

  • If asbestos identified were air monitoring conducted and records maintained?

  • If asbestos identified were manifests for asbestos disposal maintained?

  • Renovation / Demolition Project(s), Date, Description, Asbestos Identified

  • Other? (Notes)

  • Is Miscellaneous Compliance Necessary

  • Any mining or quarry work on site?

  • Any wetland or bank management work on site (i.e. Army Corp of Engineers Nationwide Permit work)

  • Facility own any target housing?

  • If yes, date houses were built and description of use.

  • If pre 1978, have LBP disclosures been performed?

  • Does facility treat its own water for consumption? If yes, acquire licenses, permits, and check compliance.

  • Does facility synthesize new chemicals? If yes, ask for a copy of PMN program.

  • Other? (Notes)

  • General Comments

  • Additional Photos (If Necessary)

  • Client Representative

  • Inspectors Signature

  • Date and Time Audit was Completed

  • Audit findings reflect the current findings of the auditor/inspector at the time of the audit to best of the auditors/inspectors knowledge.

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