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GROWMARK Wisconsin Environmental Compliance Audit
GROWMARK Wisconsin Environmental Compliance Audit
Chad Baxley

GROWMARK Wisconsin Environmental Compliance Audit

Environmental compliance audit for Wisconsin retail locations.

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Free GROWMARK Wisconsin Environmental Compliance Audit Checklist

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Title Page

  • Company Name:

  • Location:

  • Conducted on:

  • Audit Performed by:

I. CROP NUTRIENTS

  • This facility handles bulk liquid fertilizer.

A. Fertilizer Bulk Storage Areas

i. Containers, Appurtenances, & Security

  • 1. Containers are properly labeled and labeling is visible from outside containment areas.

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  • 2. Containers are equipped with an appropriate product level measuring device.

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  • 3. Product containers and appurtenances show no signs of chemical breakdown.

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  • 4. All piping and appurtenances are properly supported.

  • 5. When not in use, valves on containers are closed and locked or handles are removed.

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  • 6. Adequate security provisions have been implemented for those instances when responsible personnel are not present at the facility.

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  • 7. Filled mobile containers that are parked overnight have closed and locked valves or other security measures have been implemented to prevent tampering or theft.

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  • 8. Tanks are anchored to prevent flotation.

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ii. Secondary Containment & Site Information

  • 1. Tanks, seams, and other openings in floors, curbs, and walls of containment areas have been properly sealed.

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  • 2. Discharges or spills inside secondary containment are promptly recovered.

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  • 3. Containment areas are washed down at least annually and residue from discharges is not evident.

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  • 4. Rainwater accumulations are not allowed to exceed 20% of the containment dike capacity.

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iii. Discharge Response Plans, Inspections, & Records

  • 1. Discharge Response Plan is up to date and all required elements are complete. Required elements include emergency contact information, type(s) of bulk liquid fertilizer being stored, identification of storage areas, discharge response procedures, procedures to control and recover each bulk liquid fertilizer, & procedures for disposing of spilled materials.

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  • 2. Records of discharges are available for the past five (5) years. Records should include date & time of discharge, type of fertilizer discharged, amount, actions taken to control or recover the discharge, and method of disposal.

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  • 3. Records of weekly inventory levels of each container are available. Records are not required for the months of April and May on those liquid fertilizer containers being filled or emptied regularly, provided the containers are visually inspected twice weekly and the levels recorded at the end of the month.

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  • 4. Semi-annual inventory reconcilliation records for liquid fertilizer are available.

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  • 5. Records of weekly valve and appurtenance inspections for the past three (3) years are available.

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  • 6. Records of monthly vent inspections for the past three (3) years are available.

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  • 7. Records of annual secondary containment inspections for the past three (3) years are available.

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  • 8. Records of all maintenance performed on the valves, appurtenances, vents, and secondary containment over the past three (3) years are available.

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iv. Liquid Fertilizer Loading Areas

  • 1. Liquid fertilizer loading areas are paved or contained.

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  • 2. Discharges or spills at loading areas are promptly recovered.

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  • 3. Cracks, seams, and other openings at the loading pad are properly sealed.

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  • 4. The water supply has a back-siphon device or other means to prevent back flow to the water supply system.

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  • This facility handles bulk dry fertilizer.

v. Dry Fertilizer Loading Areas

  • 1. Dry fertilizer is mixed or loaded over a spill containment surface.

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  • 2. Spills of dry fertilizer are promptly recovered.

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  • This facility handles anhydrous ammonia.

vi. Anhydrous Ammonia

  • 1. All filling connections have a positive shutoff valve in conjunction with either a back-pressure check valve or excess flow valve and piping is sized so as not to restrict flow rates such that the protective devices will not function.

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  • 2. Vapor piping is equipped with an excess flow valve and piping is sized so as not to restrict flow rates such that the protective devices will not function. An approved, quick-closing internal valve which remains open during operating periods may be used in lieu of the excess flow valve.

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  • 3. Manually controlled valves and other appurtenances are closed and locked when the installation is unattended. Valve locks are not required if the facility is protected against tampering by fencing or other means.

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  • 4. Each storage tank is labeled on at least two (2) sides with the words "ANHYDROUS AMMONIA" or "CAUTION - AMMONIA" in sharply contrasting letters not less than 4-inches in height and one-half (1/2) inch in stoke. Additionally, a sign must be displayed in a conspicuous place stating the name, address, and phone number of the nearest representative, agent, or owner of the storage system.

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  • This facility has 10,000 pounds or more of anhydrous ammonia stored in bulk storage tanks and/or nurse tanks.

  • 5. A copy of the most recent Risk Management Plan (RMP) submittal is available at the facility. The submittal date should be within the past five (5) years.

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  • 6. The Emergency Contact information is current.

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  • 7. The facility has copies (or the ability to access online) of the Safety Data Sheets (SDS) from the location's anhydrous ammonia supllier(s).

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  • 8. A Hazard Review has been completed within the last five (5) years and documentation is available.

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  • 9. Any deficiencies noted in the Hazard Review have been corrected or a timeline for correction has been established. Documentation of corrections is available.

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  • 10. The facility has copies of the two (2) most recent Compliance Audits. A compliance audit is required to be completed at least every three (3) years.

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  • 11. The facility has prepared written Operating Procedures for the covered process(es) and the procedures have been updated whenever a major change occurs. The existing procedures address initial startup, normal operations, temporary operations, emergency shutdown, normal shutdown, startup following a shutdown or major change, consequences of deviation and steps to correct or avoid deviations, and equipment inspections.

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  • 12. The facility has investigated each incident that resulted in (or could reasonably have resulted in) a catastrophic release within 48 hours of the incident.Corrective actions have been documented, implemented, and reviewed with affected employees. A summary of the investigation has been prepared and includes the date of the incident, date the investigation began, a description of the incident, contributing factors, and recommendations resulting from the investigation. Records are available for the past five (5) years. NOTE - Not all incidents are reportable accidents.

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  • 13. The facility maintains a five-year accident history for those releases that meet the criteria of an EPA-reportable release. A reportable release is one that reulted in death, injury, or significant property damage on-site or death, injury, evacuations, shelter-in-place, property damage, or environmental damage off-site. The RMP has been re-submitted within 6 months of a reportable relase and records are available for the past five (5) years.

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  • 14. This facility is a non-responding facility for an uncontrolled release of anhydrous ammonia and an Emergency Action Plan has been implemented in accordance with 29 CFR 1910.38(a). The plan states that employees will report the release to local authorities and evacuate the area immediately. A copy of this plan and other planning information has been communicated to the Local Emergency Planning Committee (LEPC) and the local fire department.

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  • 15. Each newly-assigned employee has been trained in the operating procedures for the covered process(es) and refresher training has been completed at least every three (3) years thereafter.

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  • 16. The facility has implemented maintenance and inspection procedures for process equipment and applicable employees have been trained in the procedures. Inspections and tests are consistent with manufacturer's recommendations, industry standards or codes, good engineering practices, or prior operating experience.

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  • 17. The facility maintains documentation of maintenance and inspections. Documentation is also available for the repair of deficiencies noted during inspections and for the normal replacement of parts.

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  • 18. Process equipment is in compliance with the most current industry standard. Additionally, vehicle barriers, emergency shutoff devices, emergency breakaways at the riser(s), proper paint on the tanks and piping, hose and relief valves that have not passed their end-of-service date, safe fill charts on the storage tank, clean and accessible emergency water, and bleed-off water are available.

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II. CROP PROTECTION

  • This location handles Crop Protection products.

A. Pesticide Storage Areas

i. Containers, Appurtenances, & Security

  • 1. Product containers are properly labeled and labels are visible from outside the containment area.

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  • 2. Containers are equipped with an appropriate product level measuring device.

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  • 3. Product containers and appurtenances show no signs of chemical breakdown.

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  • 4. All piping and appurtenances are properly supported.

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  • 5. When not in use, valves on containers are closed and locked or handles are removed.

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  • 6. Adequate security provisions have been implemented for those instances when responsible personnel are not present at the facility.

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  • 7. Filled mobile containers that are parked overnight have closed and locked valves or other security measures have been implemented to prevent tampering or theft.

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  • 8. Tanks are anchored to prevent flotation.

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ii. Secondary Containment & Site Information

  • 1. Tanks, seams, and other openings in floors, curbs, and walls of containment areas have been properly sealed.

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  • 2. Discharges or spills inside secondary containment are promptly recovered.

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  • 3. Containment areas are washed down at least annually and residue from discharges is not evident.

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  • 4. Rainwater accumulations are not allowed to exceed 20% of the containment dike capacity.

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  • 5. Bulk pesticide and rinsate are segregated from other product storage.

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iii. Discharge Response Plan, Inspections, & Recordkeeping

  • 1. Discharge Response Plan is up to date and all required elements are complete. Required elements include identification of storage areas, discharge response procedures, use and disposal options, & name and number of at least two (2) local excavation contractors.

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  • 2. Documentation of annual pressure-testing of underground piping and appurtenances was available.

  • 3. Documentation of semi-annual inspection and maintenance of containers and appurtenances was available.

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  • 4. Documentation of semi-annual inspection and maintenance of loading pads was available.

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  • 5. Documentation of inspections and maintenance of loading pad sumps was available.

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  • 6. Documentation of annual pressure testing of underground piping connected to a sump was available.

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  • 7. Documentation of routine inspection and maintenance of secondary containment structures was available.

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  • 8. Documentation of rainwater sampling test results were available for the months of April, June, August, and October. The rainwater samples should be tested by a WDNR-certified laboratory and analyzed for nitrate/nitrite-nitrogen and ammonium-nitrogen.

  • 8a. If collected samples exceed 200 ppm, the operator has notified the WDNR and implemented an approved plan to manage collected precipitation containing more than 200 ppm of total nitrogen.

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  • 9. All required records are maintained in an organized manner and are readily accessible.

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iv. Precipitation Management

  • 1. If collected precipitation is recovered it is transfered to a storage container inside the secondary containment structure by the end of the first business day.

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  • 2. If collected precipitation is discharged to a Publicly Owned Treatment Works (POTW), documentation of a written agreement between the facility and the authority that operates the system is available.

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  • 3. If collected precipitation is discharged to surface water via a storm sewer or other conduit, documentation of a written agreement in the form of a Wisconsin Pollution Discharge Elimination System (WPDES) permit between the facility and the Wisconsin Department of Natural Resources (WDNR) is available

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  • 4. If collected precipitation is stored in the secondary containment structure and allowed to evaporate, total accumulation is not allowed to exceed 20% of containment capacity and samples are collected in the months of April, June, August, and September and analyzed for nitrate/nitrite-nitrogen and ammonium-nitrogen. Records are maintained for at least 3 years.

  • 4a. If collected samples exceed 200 ppm, the operator has notified the WDNR and implemented an approved plan to manage collected precipitation containing more than 200 ppm of total nitrogen.

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  • 5. If collected precipitation is applied to a vegetative filter strip at or adjacent to the stroage facility, the precipitation is applied according to a written plan approved by WDNR that considers the volume of liquid to be applied, the nutrient content of the liquid, the nutrient utilization capacity of the filter strip, and seasonal conditions that may affect that utilization capacity.

  • 5a. The facility maintains living vegetation on the entire filter strip and samples of the precipitation are collected in the months of April, June, August, and September and analyzed for nitrate/nitrite-nitrogen and ammonium-nitrogen. Records are maintained for at least 3 years.

  • 5b. If collected samples exceed 200 ppm, the operator has notified the WDNR and implemented an approved plan to manage collected precipitation containing more than 200 ppm of total nitrogen.

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  • 6. If collected precipitation is discharged to other areas of the storage facility there is no potential for direct runoff to waters of the state.

  • 6a. Samples of the precipitation are collected in the months of April, June, August, and September and analyzed for nitrate/nitrite-nitrogen and ammonium-nitrogen. Records are maintained for at least 3 years.

  • 6b. If collected samples exceed 200 ppm, the operator has notified the WDNR and implemented an approved plan to manage collected precipitation containing more than 200 ppm of total nitrogen.

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  • This facility repackages mini-bulk containers from bulk storage containers.

B. Pesticide Repackaging

i. Registration & Recordkeeping

  • 1. This location is a registered U.S. EPA Pesticide Producing Establishment and has an active Establishment Number.

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  • 2. The establishment number and the net contents are added to a current registered product label on repackaged mini-bulk containers.

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  • 3. A written letter of authorization from the registrant of the bulk product to be repackaged is on file at the location where the repackaging occurs.

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  • 4. The facility reports annually the types and amounts of pesticides that are produced via repackaging.

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  • 5. Pesticides are only repackaged into mini-bulk containers which are either dedicated for a specific product or cleaned out prior to filling according to written instructions from the product manufacturer.

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ii. Packaged Pesticide Storage Areas

  • 1. Pesticide mini-bulk containers are stored in a diked area.

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  • 2. Packaged pesticides are stored in a secure area.

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  • 3. Pesticides are stored in accordance with temperature and moisture requirements and other precautionary storage instructions on the product label. The storage methods assure that original labels on the containers are protected from damage and kept in a readable condition.

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  • 4. Caps, lids, or other sealing devices on containers removed from original shipping packaging are tight or secure and the container is sound and unbroken.

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  • 5. Pesticides are segregated from feed grain, or other materials to prevent possible contamination of those products.

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  • 6. Areas used for pesticide storage are maintained in a clean condition and are thoroughly inspected and cleaned prior to use for any other purpose.

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  • 7. Only containers greater than 55-gallons are filled and re-sold.

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  • 8. Records of sales of Restricted-Use Pesticides are maintained for at least two (2) years.

  • 8a. Records are legible and include pesticide brand name, identity of the pesticide manufacturer or labeler, US EPA pesticide registration number, amount sold or distributed, date of sale or distribution, identity of the purchaser or intended recipient (including name, address, seller/applicator license number if any, and applicator certification number if any), and the name and address of the person to whom the seller delivered custody of the pesticide (if other than the purchaser or intended recipient).

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v. Pesticide Loading Areas

  • 1. Pesticide loading areas are paved or contained.

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  • 2. Discharges or spills at the loading area are promptly recovered.

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  • 3. .Cracks, seams, and other openings at the loading pad are properly sealed.

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  • 4. The water supply has a back-siphon device or other means to prevent back flow to the water supply system.

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III. ENERGY

  • This facility has Underground Storage Tanks (UST) for petroleum.

A. Underground Storage Tanks

i. Tank Integrity & Leak Detection

  • 1. Each UST at this site is registered with the Wisconsin Department of Agriculture, Trade, and Consumer Protection (DATCP).

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  • 2. A current Permit to Operate is available for each UST at the facility.

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  • 3. Each UST meets the corrosion protection systems requirement by being either coated and cathodically protected steel, fiberglass, steel clad with fiberglass, or cathodic protection added to an existing tank. The associated piping is either coated and cathodically protected steel, fiberglass, or cathodic protection added to existing piping.

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  • 4. All systems equipped with cathodic protection have been tested within six (6) months of installation and every three (3) years thereafter. Testing was conducted by a qualified cathodic protection tester and records of the two (2) most recent inspections are available.

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  • 5. USTs with impressed cathodic protection are tested every sixty (60) days and records of the three most recent inspections are available.

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  • 6. Each UST is equipped with spill prevention equipment that will prevent the release of product to the environment when the transfer hose is detached from the fill-pipe (i.e. a spill catchment basin).

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  • 7. Tank overfill protection is provided via either automatic shutoff devices, overfill alarms, or ball float valves.

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  • 8. Monthly tank leak detection monitoring is performed via one of the following methods: automatic tank gauging, statistical inventory reconciliation, insterstital monitoring, vapor monitoring, groundwater monitoring, inventory control with tank tightness testing, or manual tank gauging.

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  • The UST system is equipped with Suction Piping.

  • 9a. The suction piping has enough slope so product in the pipe can drain back into the tank when suction is released, has only one check valve which is as close as possible under the pump in the dispenser, and there is a way to verify both. If these criteria can't be met, one of the following leak detection methods is used: line tightness test every three (3) years, monthly vapor monitoring, monthly groundwater monitoring, or monthly interstitial monitoring.

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  • The UST is equipped with Pressurized Piping.

  • 9b. Each pressurized piping run has an automatic line leak detector and one of the following leak detection methods are performed: an annual tighness test, monthly vapor monitoring, monthly groundwater monitoring, or monthly interstitial monitoring.

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  • 10. Release detection sampling, testing, or monitoring results for the previous one (1) year are available.

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  • 11. Results of the most recent tightness test are available.

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  • 12. Copies of written performance claims and schedules of required equipment calibration and maintenance of leak detection systems are available for the past five (5) years.

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  • 13. Records of maintenance, repair, and calibration of leak detection equipment are available for at least one year after the service work has been completed.

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  • 14. Records of the operation of the corrosion protection system are available and maintained for the service life of the tanks and piping. These records include the two (2) most recent inspections of the system by a qualified cathodic protection inspector. The three (3) most recent inspections must be available for impressed current systems.

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  • 15. If cathodic protection of a metal tank is determined to not be needed, documentation of the corrosion expert's analysis of site corrosion potential are available and maintained for the life of the tank and piping.

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  • 16. Records of all repairs and upgrades to the UST are available and maintained for the life of the system.

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  • 17. Records of the site assessment results for permanent closure are maintained for at least three (3) years after closure.

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  • This facility has Aboveground Storage Tanks (AST) used for petroleum.

B. Aboveground Storage Tanks

i. Company Use Tanks

  • 1. All ASTs with a storage capacity greater than 110 gallons are registered with the Wisconsin DATCP.

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  • 2. All ASTs are listed or approved (i.e. UL) for aboveground use.

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  • 3. All ASTs are properly labeled as to their contents. Tanks used for storing Class I liquids (i.e. gasoline) have the words "FLAMMABLE - KEEP FIRE AWAY" painted conspicuously in contrasting color and with letters at least 5-inches high with a minimum stroke of 1-inch.

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  • 4. All new and replacement ASTs installed after May 1, 1991 are contained within an impermeable dike system which is designed to withstand all foreseeable loading conditions including the tank load and the full hydrostatic head of any discharge liquid. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity taken up by other tanks in the dike, have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves), and the walls of the dike system must be constructed of earth, steel, concrete, or solid masonry and all cracks, seams, and joints must be sealed.

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  • 5. All existing tanks greater than 5,000 gallons that were installed before May 1, 1991 were brought into compliance no later than May 1, 2001 by installing a dike system with walls constructed of earth, steel, concrete, or solid masonry and with all cracks, seams, and joints sealed. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity of taken up by other tanks in the dike or have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves).

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  • 6. ASTs used for vehicle fueling do not exceed 10,000 gallons indivudually and do not exceed an aggregate capacity of 30,000 gallons.

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  • 7. ASTs used for vehicle fueling meet the setback requirements, which are as follows: 100-2,000 gallons: 25 feet; 2,001-10,000 gallons: 50 feet; 10,001-20,000 gallons: 75 feet; 20,001-30,000 gallons: 100 feet.

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  • 8. ASTs used for vehicle fueling and secondary containment are enclosed by a 6-foot high non-combustible fence with a gate or a 6-foot high non-combustible building with gates and doors that are normally locked. If the surrounding property has a security fence, the enclosure of the tanks and containment are not required. Buildings and fenced enclosures shall not be used for occupancy, storage, or any other use. Ventilation must be provided for buildings and liquids or vapors shall not be able to escape inside the enclosure.

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  • 9. ASTs used for vehicle fueling must be protected from vehicle impact by a barrier which is located at least 24 inches from the tank(s). The protection must be able to withstand a minimum horizontal live load of 1,000 pounds per lineal foot acting at 18-inches above grade. Dikes, fences, or other enclosures may be used for impact protection if they meet the listed requirements.

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  • 10. An emergency internal check valve is installed on each pipe connection to any tank opening below the normal liquid level. The valve shall be effectively located inside the tank shell and be capable of being operated both manually or by heat activation in the event of a fire. These emergency internal check valves shall be in addition to the normal tank valve and shall be capable of closing even if the pipe lines are broken from the tank.

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  • 11. ASTs used for vehicle fueling are equipped with an electrically operated solenoid valve on the downstream side of the internal check valve or at the location where piping leaves the tank when drawing off the top of the tank. The valves are equipped with a pressure relieving device that will relieve any pressure generated by thermal expansion of the contained liquid back to the storage tank. It is recommended that the solenoid valve be located inside the diked area.

  • 12. ASTs no longer in service meet all the requirements for Temporarily Closed, Seldom Used, or Permanently Closed tanks.

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  • This facility has retail ASTs.

ii. Retail Tanks

  • 1. All ASTs with a storage capacity greater than 110 gallons are registered with the Wisconsin DATCP.

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  • 2. All ASTs are listed or approved (i.e. UL) for aboveground use.

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  • 3. All ASTs are properly labeled as to their contents. Tanks used for storing Class I liquids (i.e. gasoline) have the words "FLAMMABLE - KEEP FIRE AWAY" painted conspicuously in contrasting color and with letters at least 5-inches high with a minimum stroke of 1-inch.

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  • 4. All new and replacement ASTs installed after May 1, 1991 are contained within an impermeable dike system which is designed to withstand all foreseeable loading conditions including the tank load and the full hydrostatic head of any discharge liquid. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity of taken up by other tanks in the dike, have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves), and the walls of the dike system must be constructed of earth, steel, concrete, or solid masonry and all cracks, seams, and joints must be sealed.

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  • 5. All existing tanks greater than 5,000 gallons that were installed before May 1, 1991 were brought into compliance no later than May 1, 2001 by installing a dike system with walls constructed of earth, steel, concrete, or solid masonry and with all cracks, seams, and joints sealed. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity taken up by other tanks in the dike or have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves).

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  • 6. An emergency internal check valve is installed on each pipe connection to any tank opening below the normal liquid level. The valve shall be effectively located inside the tank shell and be capable of being operated both manually or by heat activation in the event of a fire. These emergency internal check valves shall be in addition to the normal tank valve and shall be capable of closing even if the pipe lines are broken from the tank.

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  • 7. ASTs no longer in service meet all the requirements for Temporarily Closed, Seldom Used, or Permanently Closed tanks.

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  • This facility is a petroleum bulk plant.

iii. Bulk Plant Tanks

  • 1. All ASTs with a storage capacity greater than 110 gallons are registered with the Wisconsin DATCP.

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  • 2. All ASTs are listed or approved (i.e. UL) for aboveground use.

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  • 3. All ASTs are properly labeled as to their contents. Tanks used for storing Class I liquids (i.e. gasoline) have the words "FLAMMABLE - KEEP FIRE AWAY" painted conspicuously in contrasting color and with letters at least 5-inches high with a minimum stroke of 1-inch.

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  • 4. All new and replacement ASTs installed after May 1, 1991 are contained within an impermeable dike system which is designed to withstand all foreseeable loading conditions including the tank load and the full hydrostatic head of any discharge liquid. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity taken up by other tanks in the dike, have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves), and the walls of the dike system must be constructed of earth, steel, concrete, or solid masonry and all cracks, seams, and joints must be sealed.

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  • 5. All existing tanks greater than 5,000 gallons that were installed before May 1, 1991 were brought into compliance no later than May 1, 2001 by installing a dike system with walls constructed of earth, steel, concrete, or solid masonry and with all cracks, seams, and joints sealed. Additionally, the dike must hold 125% of the capacity of the largest tank minus the capacity taken up by other tanks in the dike or have provisions for the removal of rainwater (drainage systems that breach the dike must have self-closing valves).

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  • 6. An emergency internal check valve is installed on each pipe connection to any tank opening below the normal liquid level. The valve shall be effectively located inside the tank shell and be capable of being operated both manually or by heat activation in the event of a fire. These emergency internal check valves shall be in addition to the normal tank valve and shall be capable of closing even if the pipe lines are broken from the tank.

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  • 7. A standard color-coding system identifies all piping at the bulk plant. High Octane Gas = Red, Mid-Grade Gas = Blue, Low Octane Gas = White, Diesel = Yellow, # 1 Fuel Oil = Purple, # 2 Fuel Oil = Green, Kerosene = Brown

  • 8. The facility conforms to the GROWMARK Identification Program requirements, which are: product lines are identified by color-coding and labels, valves are identified with valve tags, tanks are identified by product name, color-code, gallons per inch, and max. capacity, and a current tank chart is available at the plant.

  • 9. ASTs no longer in service meet all the requirements for Temporarily Closed, Seldom Used, or Permanently Closed tanks.

  • This facility has retail fueling systems.

C. Retail Fueling Systems

i. Safety Systems

  • 1. At unattended facilities, at least one clearly identified and easily accessible switch or circuit breaker that is capable of shutting off power to all dispensing devices in the event of an emergency is provided. The emergency control(s) is at least 20 feet, but no more than 100 feet, from the dispenser(s).

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  • 2. Training records are available for all persons who will operate key, card, or code-accessed dispensing devices.

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  • 3. At unattended facilities, operating instructions are conspicuously posted in the dispensing area and include the location of emergency controls and a requirement that the user must remain outside their vehicle and in full view of the fueling nozzle during dispensing. Additionally, emergency information is conspicuously posted in the dispensing area and incorporates the following or similar wording: "IN CASE OF FIRE OR SPILL: 1. USE EMERGENCY STOP BUTTON, 2. REPORT ACCIDENT BY CALLING (specify local fire department number) BY PHONE. REPORT LOCATION.

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  • 4. Dispensing devices, except those attached to containers, are either mounted on a concrete island or otherwise protected against collision damage by suitable means and are securely bolted in place.

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  • 5. Each hose used for dispensing Class I liquids (i.e. gasoline) is equipped with a listed emergency breakaway device designed to retain liquid on both sides of the breakaway point.

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  • 6. For remote pumping systems where the pump is located at the tank, a listed and rigidly anchored emergency shutoff valve incorporating a fusible link or other thermally actuated device is installed in the supply line at the base of each island-type dispenser. The shutoff device is designed to close automatically in the even of a severe impact or fire exposure.

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  • 7. For remote pumping systems where the pump is located at the tank, the automatic closing feature on the emergency shutoff valve is tested at the time of installation and annually thereafter by manually tripping the hold-open linkage.

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  • 8. For remote pumping systems where the pump is located at the tank, a leak detection device is installed on the discharge side and each of these detection devices is checked and tested annually.

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  • This facility has bulk gasoline storage.

D. Vapor Recover Requirements

  • The average daily throughput of gasoline at this facility is 4,000 gallons or more per day on a 30-day rolling average AND the storage tanks have a capacity of 575 gallons or more AND the facility is located in one of the following counties: Brown, Calumet, Dane, Dodge, Door, Fond du Lac, Jefferson, Kenosha, Manitowoc, Milwaukee, Outagammie, Ozaukee, Racine, Rock, Sheboygan, Walworth, Washington, Waukesha, or Winnebago.

i. Bulk Gasoline Storage

  • 1. The load-in (receiving) area is equipped with a vapor balance system and load-out (dock) area utilizes submerged or bottom-filling equipment. This subsection does apply if gasoline is transferred during the ozone season to a delivery vessel whose last previous delivery was to a gasoline dispensing facility, either inside or outside Wisconsin, which is required to have a vapor balance system.

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  • The annual gasoline throughput at this facility exceeds 1.25 million gallons per year and the facility can not demonstrate that benzene emissions are less than 300 pounds per year OR the facility is located in one of the following counties: Brown, Calumet, Dane, Dodge, Door, Fond du Lac, Jefferson, Kenosha, Manitowoc, Milwaukee, Outagammie, Ozaukee, Racine, Rock, Sheboygan, Walworth, Washington, Waukesha, or Winnebago.

ii (a). Gasoline Dispensing Facilities

  • 1. Stage I (load-in) vapor recovery is installed on all tanks in gasoline service with a capacity greater than 2,000 gallons and which were in use prior to August 1, 1979 and on those tanks in gasoline service with a capacity gretater than 575 gallons that were first in use after August 1, 1979.

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  • The facility has exceeded 10,000 gallons of gasoline throughput per month for any 24-month period since 1991 and is located in one of the following counties: Kenosha, Kewaunee, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, or Waukesha OR the facility dispenses over 2 million gallons of gasoline per year and is unable to demonstrate that benzene emissions are under 300 pounds per year.

ii (b). Gasoline Disepnsing Facilities

  • 1. Stage II (load-out) vapor recovery is installed on tanks in gasoline service.

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iii. Gasoline Delivery Vehicles

  • 1. If the facility is required to be equipped with submerged or bottom loading vapor recovery devices, or if fuel transports deliver product to dispensing facilities that are required to be equipped with Stage I vapor recovery at load-in, loading vapor recovery (submerged or bottom loading) is installed on the delivery vehicle(s).

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  • This facility has bulk lubricant storage.

E. Lubricant Storage

i. Storage Areas

  • 1. Products are stored in accordance with temperature and moisture requirements and other precautionary storage instructions contained on the product label and in a manner that will assure that the original labels on the containers are protected from damage or destruction and kept in a readable condition. Products are stored in an area that is not readily accessible to children or the general public.

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  • 2. Floors are composed of concrete, are structurally sound, and have chemical-resistant sealant on all cracks, saw joints, and sidewall joints. There are no open drains and existing floor drains are properly plugged and sealed. If the facility is subject to SPCC, the facility must have the capability of controlling or containing a release from the largest container in the storage area. The storage area(s) is maintained in a clean condition and is cleaned prior to use for any other purpose.

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  • 3. All containers are properly labeled as to their contents.

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  • 4. The facility is free of old/unusable products.

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IV. MISCELLANEOUS WAREHOUSE

A. Anti-Freeze, Paint, Batteries, & Tire Storage

i. Storage Areas

  • 1. Products are stored in accordance with temperature and moisture requirements and other precautionary storage instructions contained on the product label and in a manner that will assure that the original labels on the containers are protected from damage or destruction and kept in a readable condition. Products are stored in an area that is not readily accessible to children or the general public.

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  • 2. Floors are composed of concrete, are structurally sound, and have chemical-resistant sealant on all cracks, saw joints, and sidewall joints. There are no open drains and existing floor drains are properly plugged and sealed. If the facility is subject to SPCC, the facility must have the capability of controlling or containing a release from the largest container in the storage area. The storage area(s) is maintained in a clean condition and is cleaned prior to use for any other purpose.

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  • 3. All containers are properly labeled as to their contents.

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  • 4. The facility is free of old/unusable products.

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B. Bagged Feed, Seed, & Equipment Storage

i. Storage Areas

  • 1. Products are stored in accordance with temperature and moisture requirements and other precautionary storage instructions contained on the product label and in a manner that will assure that the original labels on the containers are protected from damage or destruction and kept in a readable condition. Products are stored in an area that is not reasily accessible to children or the general public.

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  • 2. All containers are properly labeled as to their contents.

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  • 3. Feed products are stored in separate rooms or areas and are adequately segregated from pesticides and other toxic products.

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  • 4. The facility is free of old/unusable products and the storage area(s) is maintained in a clean condition and is cleaned prior to use for any other purpose.

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V. SPILL RESPONSE

A. Emergency Response Plans, HAZWOPER, Recordkeeping

i. Emergency Response Plans

  • 1. This facility has implemented an Emergency Response Plan (PF-1 or equivalent). The plan includes information on emergency notification procedures and accidental discharge/release control, containment, & release procedures.

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  • 2. The Emergency Response Plan is updated annually or within 60 days of a material change or a change in Emergency Coordinator.

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  • 3. Elements of the Emergency Response Plan have been communicated to outside agencies (police, fire, EMS, LEPC, etc.) and spill response contractors have been identified.

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ii. HAZWOPER

  • 1. Personnel who are expected to be able to identify the release of a hazardous material and notify the proper authorities have received at least Operations Level HAZWOPER training and documentation is available.

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  • 2. Personnel who are expected to be able to identify the release of a hazardous material and notify the proper authorities have received at least Awareness Level HAZWOPER training and documentation is available.

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  • 3. HAZWOPER trained employees have completed an annual refresher every year following initial training and documentation is available. Response to an actual release of hazardous materials may be substituted for refresher training.

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iii. Safety Data Sheets (SDS)

  • 1. Location employees have access to up-to-date Safety Data Sheets (SDS) for hazardous chemicals handled at this facility.

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iv. Spill Response Materials

  • 1. Spill response materials are readily accessible, are suitable for the products handled at this facility, and are present in adequate quantities to respond to spills or leaks that occur during normal activities.

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v. Recordkeeping

  • 1. Incident report records are maintained for those spills that required reporting to a regulartory agency due to the size or impact of the release.

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VI. WASTE MANAGEMENT

A. Hazardous Waste

i. Waste Determination & Storage Areas

  • 1. A Hazardous Waste Determination has been conducted on the waste generated at this facility.

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  • 2. All waste streams are segregated and not allowed to mix.

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B. Used Oil and Used Oil Filters

i. Storage & Disposal

  • 1. Used oil is not used as a dust suppressant at this facility.

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  • 2. Used oil is burned at this facility in a used oil-fired space heater of not more than 0.5 million BTUs.

  • 2a. The used oil burned at this facility is only generated by the facility or received from household "do-it-yourself" generators.

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  • 3. Containers and/or aboveground tanks used to store used oil are in good condition, not leaking, and are labeled "USED OIL".

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  • 4. Used oil storage areas are diked or otherwise provided with secondary containment adequate to contain the full contents of the largest container in the storage area.

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  • 5. This facility either self-transports used oil to a used oil collection center or a company-owned aggregation point or has the used oil transported offsite by a transporter possessing an EPA identification number.

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  • 6. Used oil disposal records are maintained for at least five years. These records include the transporter's EPA identification number, the date on which the used oil was picked up, and the amount of used oil that was picked up. The same information is maintained for used oil that is self-transported to a collection center or aggregation point.

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  • 7. Used oil filters are punctured, hot drained for 12-hours, and recycled or landfilled.

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  • 8. This facility retails engine oil and either collects used oil and posts a sign stating "ENGINE WASTE OIL COLLECTION FACILITY. PLEASE RETURN YOUR WASTE OIL HERE" (or similar) or posts a sign with the name, location, and hours of operation of the nearest waste oil storage facility.

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C. Waste Parts Solvents

i. Disposal

  • 1. Waste parts solvents are disposed of through a reputable waste management company.

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  • 2. Copy of a signed recycling agreement between the location and the recycler is on file.

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D. Paint Waste

i. Disposal

  • 1. Paint residue is allowed to dry thoroughly so that evaporation and solidification may occur prior to landfilling materials or containers.

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E. Used Batteries & Anti-Freeze

i. Storage & Disposal

  • 1. Waste lead-acid batteries are returned to the distributor or recycled.

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  • 2. Waste lead-acid batteries are stored on an impermeable surface and under cover. Battery leakage is not allowed to contaminate storm or sewer drains.

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  • 3. Used anti-freeze is either reused or recycled.

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F. Open Burning

i. Prohibition

  • 1. Open burning of any type is not allowed at this facility.

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G. Building Demolition & Renovation

i. Asbestos

  • 1. For renovations and demolition projects, an asbestos inspection has been completed and the required notification form has been filed with the WDNR at least ten (10) days before the start of the project.

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H. Other Waste

i. Fluorescent & High-Intensity Discharge Lamps

  • 1. Fluorescent tubes and and high-intensity discharge (HID) lamps are recycled through a reputable waste management company.

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VII. REGULATORY ISSUES

  • Aggregate aboveground oil storage in containers greater than 55-gallons is greater than 1,320 gallons and/or aggregate undergound oil storage is greater than 42,000 gallons at this facility.

A. Spill Prevention, Control, & Countermeasures (SPCC)

i. SPCC Plans

  • 1. The location has a:

    • P.E. Certified Plan
    • Self-Certified Plan
    • No Plan

  • 2. The Certification of the Applicability of Substantial Harm Criteria document is attached to the SPCC plan.

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  • 3. A review and evaluation of the plan has been conducted at least once every five (5) years from the date the facility became subject to the revised SPCC plan requirements.

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  • 4. Location personnel perform monthly and annual inspections of oil storage areas and containers.

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  • 5. Records of monthly and annual inspections for the previous 3 years were available.

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  • 6. Records of storm water discharges was available.

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ii. Employee Training & Spill Briefings

  • 1. Documentation that oil-handling personnel have been trained at least annually in operations & procedures, plan contents, operation and maintenance of equipment to prevent discharges, discharge procedure protocols, and applicable pollution control laws, rules, and regulations was available.<br>

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  • 2. Documentation of annual spill briefings was available.

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B. Wastewater Regulations

i. Water Service, Equipment Washing, & Stormwater Permitting

  • 1a. If the facility is connected to a municipal water system, all drains are connected to the Publicly Owned Treatment Works (POTW).

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  • 1b. If the facility is connected to a private septic system, only human waste is allowed to enter the system.

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  • 2. Vehicle and equipment washing is prohibited on-site unless conducted on a chemical or fertilizer loading pad.

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  • 3. Because of it's Standard Industrial Classification (SIC) code, this facility is required to have a storm water permit.

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C. SARA Reporting

i. SARA Tier II

  • 1. This facility submits the annual Tier II inventory reports and maintains these records for three (3) years.

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ii. SARA Toxic Release Inventory

  • 1. This facility submits the annual Toxic Release Inventory Reports and maintains these records for three (3) years.

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D. Air Quality Regulations

i. Visible Emissions

  • 1. This facility takes reasonable precautions to prevent the discharge of visible emissions of fugitive dusts.

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GROWMARK Wisconsin Environmental Compliance Audit
Chad Baxley

GROWMARK Wisconsin Environmental Compliance Audit

Environmental compliance audit for Wisconsin retail locations.

Use this Template
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