Information
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Client, Site and/ or Location:
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Date Conducted:
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Evaluated By:
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Facility Manager:
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Facility Location:
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Personnel Affiliated; if Applicable:
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Expectations of this audit is to ensure that the facility is operating with in the guidelines of the regulating agencies as well as the specifically assigned permits. The goal of completing this audit is to avoid any potential environmental impacts by enforcing the requirements set forth by Ecoserv and the regulating agencies.
DIVISION DETAILS
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Environmental Services Division – [Check which operation that is applicable]:
- Collection Operations
- Processing Operations
- Injection Operations
- NORM Injection Operations
- Industrial Disposal Facility Operations
- Permian Basin Operations
APPLICABLE REGULATORY
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Environmental Regulatory – [Click on all that apply]:
- Railroad Commission of Texas
- Spill Prevention Control, and Countermeasure
- Waste Management Operations Plan
- Louisiana Department of Natural Resources
- United States Coast Guard
- Louisiana Department of Environment Quality
- Texas Department of State Health Services
- United States Environmental Protection Agency
- Texas General Land Office
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Reference Page #1
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Reference Page #2
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Reference Page #3
1.0 DOCUMENT VERIFICATION
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Is there an updated map of the facility
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Is there an Emergency Contact listing posted (i.e. Louisiana Emergency Contacts for LA Facilities & Texas Emergency Contacts for TX Facilities)
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Is the previous year's Tier II Report available.
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Is there an up to date SDS packet for products found on-site
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Is the facility permitted/regulated by Louisiana Department of Natural Resources
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Are the following documents available:<br>- WMOP<br>- UIC 28 Manifest (3 years)<br>- Samples (30 days)<br>- Louisiana Emergency Contacts
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Which of the following documents are missing
- WMOP
- UIC 28 Manifest (30) Days
- Samples (30) Days
- Louisiana Emergency Contacts
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Is this facility permitted/regulated by Louisiana Department of Environmental Quality
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Which of the following are conducted at this facility
- Storm water/Sanitary Discharge
- D-Listed Area (i.e. Hazardous Waste Transfer, NORM Transfer/work, Non E&P Waste Transfer)
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Is the Stormwater/Sanitary Discharge Permit available
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Select which of the following operations are conducted on the D-Listed Area
- Hazardous Waste Transfer/Non E&P Non-Hazardous Waste Transfer
- NORM contaminated Waste/Equipment Transfer
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Are the following documents available: <br>- EPA ID Number <br>- D-Listed Area waste log (log of accepted and shipped)<br>- Waste Manifest from D-Listed Area (3 years- Copies)<br>- Training Records ( Advanced & Basic Hazardous Waste, Hazardous Waste Contingency Plan)<br>- LDR Notices (Hazardous waste requirement only)<br>- Regulatory Agency Inspection (EPA/LDEQ)<br>- Internal Facility Inspections (Weekly)<br>- Inspection Log (3 Years)<br>- Copy of Inspection Plan<br>- Emergency Coordinator List<br>- Contingency Plan<br>- List and Locations of Emergency Response Equipment<br>- Evacuation Plan
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Which of the following documents are not available
- EPA ID Number
- D-Listed Waste Log (log of accepted and shipped)
- Waste Manifest (3 years- Copies)
- LDR Notices (Hazardous Waste Only- copies)
- Training Records (Advanced & Basic Hazardous Waste, Hazardous Waste Contingency Plan
- Regulatory Inspection records
- Internal Facility Inspections (Weekly)
- Emergency Coordinator List
- Contingency Plan
- List and Locations of Emergency Response Equipment
- Evacuation Plan
- Inspection Log (3 years)
- Copy of the Inspection Plan
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Are the following documents available: <br>- NORM Manifest<br>- NORM Training (NORM Worker, RSO)<br>- Records of Transfer<br>- Inventory Log (Accepted, Shipped, Current)<br>- DRC- 3 Posting (CDF)<br>- LDEQ Radiological License (CDF)
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Which of the following documents are not available
- NORM Manifest
- NORM Training (NORM Worker, RSO)
- Records of Transfer
- Inventory Log (Brought in, shipped, and current)
- DRC-3 Posting (CDF)
- LDEQ Radiological License (CDF)
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Is the facility permitted/regulated by Texas Railroad Commission
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Is there a permitted pit at this facility?
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Are the following documents available:<br>- Pit Permit<br>- Pit Inspections
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Which of the following documents are not available
- Pit Permit
- Pit Inspections
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Do disposal operations occur at this facility?
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Are the following documents available:<br>- Well Permits<br>- H-5 Reports
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Which of the following documents are not available
- Well Permits
- H-5 Reports (Most Recent: 1 yr/ 5 yr)
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Is the facility permitted/regulated by Texas Commission on Environmental Quality
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Which of the following does TCEQ regulate at this facility
- Stormwater Discharge
- Waste Processing and Disposal
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Are the following documents available:<br>- Permit Application<br>- Facility Permit (Solid Waste Permit)<br>- Well Permits<br>- Waste Analysis Plan<br>- Waste Manifest<br>- Waste Profiles<br>- Scale Certificate<br>- Safety Survey of Waste Management Units (Every day of month)<br>- Waste Analysis Plan <br>- Well Pressure Chart (Every day of month)<br>- Employee Training (SEMS)
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Which of the following documents are not available
- Permit Application
- Facility Permit (Solid Waste Permit)
- Well Permits
- Waste Analysis Plan
- Waste Manifest
- Waste Profiles
- Scale Certificate
- Safety Survey of Waste Management Units (Every day of Month)
- Waste Acceptance Reports
- Well Pressure Charts (Every day of Month)
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Are the following documents available:<br>- Storm Water MSGP<br>- Storm Water Pollution Prevention Plan (SWPPP)<br> or<br>- No-Exposure Certificate (must have if above two are not available)<br>
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Which of the following documents are not available
- Stormwater MSGP
- No-Exposure Certificate
- Stormwater Pollution Prevention Plan (SWPPP)
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Is the facility permitted/regulated by Texas Department of State Health Services
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Are the following documents available:<br>- TDSHS License<br>- Quarterly Reports<br>- Dosemitry Badge Reports<br>- Monthly Audits/Surveys<br>- Employee Training (SEMS)<br>- NORM Employee Awareness Posting<br>- Ambient Air Reports<br>- Past TDSHS Audits<br>- Gamma Spec Daily Response Checks (Big Hill only)
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Which of the following documents are not available
- TDSHS License
- Quarterly Reports
- Dosemitry Badge Reports
- Monthly Audits/Surveys
- Employee Training Documents (NORM Worker, RSO)
- NORM Employee Awareness Posting
- Ambient Air Reports
- Past TDSHS Audits
- Gamma Spec Daily Response Check
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Is the facility permitted/regulated by United States Coast Guard
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Are the following documents available:<br>- Facility Operation Manual<br>- Facility Response Plan<br>- Tabletop Drill (3 years)<br>- OSRO Letters (3 years)<br>- Past Inspections<br>- PIC List<br>- PIC Training<br>- Quarterly Phone Drills (3 years)<br>- Declaration of Inspection (DoI)<br>- Transfer Hose Pressure Reports<br>- Site Diagram<br>- Spill Notification List<br>- Hose Log<br>
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Which of the following documents are not available
- Facility Operations Manual
- Facility Response Plan
- Tabletop Drill (3 years)
- OSRO Letters (3 years)
- Past Inspections (3 years)
- PIC List
- PIC Training
- Quarterly Phone Drills
- Declaration of Inspection (DoI)
- Transfer Hose Pressure Reports
- Site Diagram
- Spill Notification List/Emergency Contact List
- Hose Log
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Are all items above up to date.
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Is the facility permitted/regulated by the Environmental Protection Agency. (i.e. Oil or oily material onsite)
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Is there an SPCC for the facility.
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Is employee training up to date
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Are permanent ASTs (i.e. Water plant tanks, slurry tanks, waste storage tanks) in compliance with tank inspection program.
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Are equipment inspection sheets available.
Equipment Inspection Sheets
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Were issues that were noted with equipment corrected
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Which piece of equipment is there an issue with.
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Coaching Comments and/or Category Recognition:
Sampling/Waste Screening
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Is sampling/waste screening equipment located on site
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Which of the following sampling equipment can be found on site
- Retort
- Chloride test
- pH
- Flashpoint
- EC/Resistivity Meter
- Centrifuge
- LEL- 4 Gas Meters
- VOC- PID Meters
- Confirmation Analysis (Drager Tubes)
- NORM Screening Device (Ludlum Model 3/3000)
- NORM Confirmatory Device (Ludlum Model 2200)
- Scales
- Gamma Spec
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Does sampling/screening equipment meet requirements of what the permit/regulatory agency require and what is required from the safety department (Employee Education, Protection, and Exposure Application).
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Which of the following required sampling/screening equipment, cannot be found at the site.
- Retort
- Chloride test
- pH
- Flashpoint
- EC/Resistivity Meter
- Centrifuge
- LEL- 4 Gas Meters
- VOC- PID Meters
- Confirmation Analysis (Drager Tubes)
- NORM Screening Device (Ludlum Model 3/3000)
- NORM Confirmatory Device (Ludlum Model 2200)
- Scales
- Gamma Spec
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Where is the sampling/screening equipment stored
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Is all sampling/screening equipment properly maintained and stored (i.e. properly Calibrated, properly working, properly stored)
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Can calibration logs be verified
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Are any pieces of equipment being used passed it's calibration date.
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Which pieces of equipment are past the calibration date.
- Retort
- Chloride test
- pH
- Flashpoint
- EC/Resistivity Meter
- Centrifuge
- LEL- 4 Gas Meters
- VOC- PID Meters
- Confirmation Analysis (Drager Tubes)
- NORM Screening Device (Ludlum Model 3/3000)
- NORM Confirmatory Device (Ludlum Model 2200)
- Scales
- Gamma Spec
Demonstration of sampling/screening procedure.
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Who demonstrated sampling/screening procedure; Name and Title.
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Was sampling/screening of waste demonstrated by qualified individual. (i.e. Knowledgeable on Sampling/screening)
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Was sampling/screening completed properly
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What problems were encountered?
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Add media
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Was waste properly collected in order to demonstrate a representative sample of the contents being collected. i.e.: homogeneous mixture; top, middle, and bottom.
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Which of the following equipment was used for this demonstration.
- Retort
- Chloride test
- pH
- Flashpoint
- EC/Resistivity Meter
- Centrifuge
- LEL- 4 Gas Meters
- VOC- PID Meters
- Confirmation Analysis (Drager Tubes)
- NORM Screening Device (Ludlum Model 3/3000)
- NORM Confirmatory Device (Ludlum Model 2200)
- Scales
- Gamma Spec
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Was equipment used in sampling/screening demonstration used properly.
3.0 Observation
3.1 General Facility
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Is there a Muster Station with proper signage.
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Location:
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Is there a smoking area with proper signage.
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Location:
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Is there a "Transfer Communication System" used (i.e. Two Way Radio)
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What type of system is being used
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Is the "Transfer Communication System" being used intrinsically safe (this is noted on the systems)
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Does the Facility Manager have the capability of being notified via this form of communication
3.2 Facility Entrance
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Is there a sign(s) posted at the entrance of the facility
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Take picture of entrance- including all sign(s)
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What is the condition of the sign(s)
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Is there a lockable gate
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What is the condition of the gate and lock
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Is there a security fence or a barrier of entry located around the entire facility.
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What is the condition of the security fence or barrier of entry
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Add media
3.3 Facility Housekeeping
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Are there any spills/leaks or signs of spills/leaks. (soil/gravel stains)
Spills
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Spill Location/Description:
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Add media
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Is there permanent/portable Secondary Containment present at this facility
Secondary Containment
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Location:
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What type of secondary containment is present
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Is containment sufficient for total storage capacity
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What is the condition of the secondary containment
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Add media
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Is there any trash/junk located throughout the facility. (i.e.: Junk piles, trash on ground, overflowing trashcans, empty drums)
Trash/Junk
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Location/Description:
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Add media
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Are there spill kits located throughout the facility (i.e. oil absorbent)
3.4 Facility Equipment
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Is there a washwater plant at this facility
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Is the plant in good condition and properly functioning
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Are there any odors present
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Is there sufficient/adequate containment. Does the containment meet regulatory requirements (i.e.: 100 year flood, if required).
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Are all AST's in good condition, no signs of age/wear and tear or leaks.
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Is there a transfer pit/tank present at this facility.
Transfer pit/tank
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Is the "Pit Permit Number" posted, if applicable. (Required by RRC)
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Does the freeboard meet the requirement found in permit, if applicable.
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What is freeboard
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What condition is the truck ramp in, if applicable
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What is the condition of the pit/tank
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Add media
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Is there a washrack/ cleaning slab present at this facility (i.e.: area where cleaning jobs occur)
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What is the condition of the washrack/cleaning slab. (i.e.: cracks, not draining properly, releases outside of area)
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Add media
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Are there above ground storage tanks (ASTs) present at this facility
ASTs
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Location/I.D. of ASTs
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What are the contents of the ASTs
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What is the condition of the ASTs
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Is there any signs of leaks or spills around ASTs
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Add media
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Are there any portable tanks present at this facility (i.e. MPTs, Frac Tanks, Cutting boxes)
Portable tanks
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Location of portable tanks
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What are the contents of the portable tanks
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Is there any signs of leaks or spills around portable tanks
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Add media
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Is there mobile equipment present at this facility (i.e. Forklift, Cranes, Excavator)
Mobile Equipment (i.e. Forklift, Cranes, Excavator)
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Mobile Equipment I.D. (i.e. Forklift, Crane, Excavator)
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Is there any visible signs of faulty, leaking, or damaged parts (i.e. damaged hydraulic hose, oil leak, leaking seal)
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Add media
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Is there permanent lighting at this facility
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Is work conducted during non-daylight hours
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Do the lights put off sufficient illumination
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What is the condition of the lighting
3.5 Dockside Facility (USCG regulated)
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Is this a dockside facility (USCG regulated)
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Are there warning signs on the dock
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Total number on dock
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Do they face Downstream and Upstream
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Do they face Seaward and Landward
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Are the signs in good condition
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Add media
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Are there Fire Extinguishers on the dock
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Total number on dock
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Are the extinguishers in good condition
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Are the extinguishers fully charged
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When were the extinguishers last inspected
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Is there proper signage indicating location of extinguishers
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Are the extinguishers properly mounted
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Add media
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Are there Life Rings on the dock
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Total number on the dock
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Is there retrieval rope on all Life Rings
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Are the Life Rings mounted properly (i.e. on rack with retrieval rope properly coiled)
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Are the Life Rings in good condition
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Add media
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Are there Work Vest located on the dock
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Total number of Work Vest
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Are the Work Vest in good condition.
3.6 Transfer Hoses/Transfer piping (i.e. Hoses used to transfer waste)
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Are there transfer hoses/Transfer piping present at this facility
Transfer Hoses
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Hose I.D./Location
Hose Markings
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is there a Hose Marking indicating OIL SERVICE
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Is there a Hose Marking stating the "Maximum Allowable Working Pressure" (MAWP)
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Is there a Hose Marking idicating the "Hose I.D." (Hose I.D. should match information in hose log book)
Hose Defects (i.e. Wear and Tear of hoses)
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Is the hosed mashed
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Are there any cuts
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Are there any kinks
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Does the hose show any signs of peeling/deteriorating
Spill Control
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Are all connections properly secured (i.e. Camlocks secured with pins, diapered)
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If not being used are ends properly capped (i.e. Camlocks secured with pins, diapered)
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Drip pans placed under connections
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Is drip pan empty of any fluids and clean
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Add media
Transfer Piping
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Pipe I.D./Location:
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What is condition of the piping
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Do all flanges, have sufficient number of bolts
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Are Nuts and Bolts in good condition
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Add media
3.7 Over the top transfers
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Are over the top transfers being conducted at this facility
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Does the Transfer Manifold Equipment being used meet the requirements of the SOP "Marine Liquid Bulk Transfer Procedure" Section D
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Do the hoses being used meet the requirements of the SOP "Marine Liquid Bulk Transfer Procedure" Section E.
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Do the hoses connections being used meet the requirements of the SOP "Marine Liquid Bulk Transfer Procedure" Section F
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Does the Grounding/Bonding mechanisms being used meet the requirements of the SOP "Marine Liquid Bulk Transfer Procedure" Section G
3.8 Hopper Barges
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Are Hopper Barges present at this facility.
Hopper Barges
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Barge Name:
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Number of mooring lines
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Condition of lines
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Percent loading
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Is an oil sheen present
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Add media
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Are the following documents available:<br>- Vessel Response Plan/USCG Letter<br>- Stability Letter<br>- Certification of Financial Responsibility <br>- COI <br>- USCG Documents:<br> o Interim Period to Operate<br> o Security Exemption<br>- Manifest (If in transit/fleet area; or has been transited)<br>
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Select which of the following documents can not be found in the barge
- Vessel Response Plan/ USCG Letter
- Stability Letter
- Certificate of Financial Responsibility (Barge Specific)
- CoI
- COD
- USCG Document: Interim Period to Operate
- USCG Document: Security Exemption
- Manifest (If in transit/fleet area; or has been transitted)
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Are all documents up to date (i.e. not expired)
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If free oil is present, is the oil being skimmed prior to navigation
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Does the oil skimming operations being conducted meet the requirements of the SOP "Marine Liquid Bulk Transfer Procedure" Section J
3.9 Disposal Wells
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Are there disposal wells located at this facility
Disposal Wells
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Well Number:
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Is there a sign located at the well head
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Can the following information be found on the well sign:<br>- Operator (Ecoserv)<br>- Lease Name <br>- Lease Number<br>- Well Number<br>- Well Permit Number
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Select the following information that can not be found on the well sign
- Operator
- Well Number
- Lease Number
- Lease Name
- Well Permit Number
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Is the sign legible
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Is the sign big enough
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Add media
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Is this well currently being used for disposal
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Is the well's pressure within the permitted limits set in disposal permit
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Is there a pressure gauge on the well head
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Is the gauge working
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Can the pressure gauge be read
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Is there a pressure observation valve on the tubing and for each annulus
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Is the wellhead in good condition
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Was an H-5/MIT completed on this well within the last year, or if applicable (Fannett only) 5 years
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Is there any signs of releases around the wellhead
3.10 D-Listed Area
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Does this facility have a "D-Listed" Area (i.e. Areas of the dock non-LDNR permitted)
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Are there items/waste present in the D-Listed area
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Do the items found on the Inventory log of the D-listed area match what is located on the site.
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Are containers within storage limits (i.e. Hazardous Waste: Manifested Offshore- 10 days/ Classified onshore- 90 days; All other waste: 90 days (Ecoserv Policy)
Waste Containers being used
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Are Waste Containers closed
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Are containers in good condition
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Are containers leaking or show evidence of a leak
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If applicable, is the container stored in adequate secondary containment
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Are containers marked with accumulation start date (i.e. Date accepted on Ecoserv's facility)
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Are containers labeled with contents
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If applicable, is the container marked with "Hazardous Waste"
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If applicable, are ignitable Hazardous Waste stored >50 feet from the property line
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Are containers DOT approved
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Is there appropriate aisle space between containers being stored (i.e. Enough room to navigate to each container if necessary)
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Is there a water source near by with sufficient flow rate and pressure
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What is the source
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Is facility security system adequate to minimize unauthorized entry
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Is an Emergency Number Posted
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Are "NO SMOKING" signs posed in the area
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Is "No Unauthorized Entry" sign posted
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Is a "Hazardous Waste" sign posted, if applicable (i.e. if hazardous waste is present)
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Are signs posted and legible for 25 feet
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Are there spill kits located throughout the D-Listed area (i.e. oil absorbent)
4.0 COMMENTS
EVALUATOR ACKNOWLEDGMENT
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Name of (PIC) Person In Charge:
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(PIC) Person In Charge Signature:
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Name of Reviewer/ Evaluator:
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Evaluator Signature:
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Date: