Logan ESS Quarterly WPO/Compliance Review

This purpose of this review is to determine the overall health of the unit's WPO/
Compliance Process. While all the findings should be addressed. The intent is that a
review of each finding should be completed to determine if it was an isolated issue
or is a symptom of a larger process issue. Addressing overall process opportunities
will improve the unit's overall performance.

Element #1 - Walking / Working Surfaces
- Are any of the conditions present?
Tripping and/or slipping hazards caused
by liquids, process material, or
equipment.
- Cleanliness and Condition of floor,
ladders, stairs, and platforms
- Aisle ways are accessible, clear of
material and equipment
- Floor marking's are legible and
maintained
- Accumulations of any debris and/or
spent materials on inside and outside of
buildings.
- Poor housekeeping in office areas
including: private offices, meeting
rooms, copier rooms, computer rooms,
restrooms, boiler rooms, electrical
rooms, HVAC rooms, basements,
storage rooms, closets, etc.

Element # 2 - Machinery / Equipment (includes mobile equipment)

Are any of these conditions present?
Excessive leaking fluids: water, oil,
solvents, etc. on or near machinery and
equipment.

- Drip pans full of rags, oil absorbent
material and/or liquids.
- Process materials (scrap, UBC,
dross, fluxing salts, dust, etc.) spilled
around the process equipment.
- Trash, debris and unnecessary
materials on or near the machinery or
equipment.
- Mobile Equipment
·Inspections of equipment current
·General condition of equipment
·Parking brake applied
·Leaks for equipment
·Equipment parked in appropriate
location

Element #3 - Storage

Are any of these conditions present?
Unstable or otherwise unsafe storage of
process materials (raw materials,
product, scrap, etc.)

- Poor housekeeping in storerooms,
stockrooms and storage areas.
- Storage of hazardous, flammable
and combustible materials improperly.
-Storage of materials on top of
cabinets and shelve units where
employees can pull objects off onto their
head.
- Damaged, unlabeled, and/or
improperly anchored storage racks,
shelving or cabinets if required.
- Laydown Yards for old equipment
and material that are not well
maintained.
- Proper storage of materials, parts,
supplies, tools.
- Unnecessary tools and materials
hanging, leaning against or around
machinery and equipment.
- Arranged items are close to the
point of use, clearly marked and
organized for flow.

Element #4 - Health & Safety Compliance

Are any of these conditions present?

- Machine Guarding that is not in
place or can be removed without a tool
or key.
- Stationary tools and equipment not
properly anchored to the floor.
- Grinders with incorrect tool rest
and tongue guard adjustments
- Fixed blade utility knives.
- Slab knives not properly stored in
sleeves.
- Damaged tools in service.
- Planned inspections not
completed. (i.e.….Emergency
Equipment, Cords, Tools, Ladder, etc...)
- Hoses not connected with proper
secure device
- Emergency aisles that are less
than 28 inches wide.
- Stairs with four or more risers
without standard stair railings.
- Platforms that are 4 foot high or
higher lacking standard railings and toe
boards and/or no personal fall protection
provision.
- Confined Space labeling not in
place.
- Electrical hazards

Element #5 - Environmental Compliance

Are any of these conditions present?
SPCC
- Secondary containers are not
labeled (i.e. buckets / pails, cans,
bottles, spray bottles are not labeled
properly indicating contents).
- Drums/totes stored near storm
drains outside the building or out of
normal staging areas.
- Secondary containment systems
not clean, should be empty of rainwater
or oils or any other residue or debris...
- Drum storage/containment
Waste Segregation/Recycling
- Waste materials not properly
segregated
- Evidence that recyclable materials
are being disposed of.
- Dumpsters are clean of residue
and are not overfilled or contain
incompatible wastes.

Air Pollution Control Equipment/
Compliance
- System appears to be operating
normally with no visible leaks, fume, or
evidence of poor maintenance or
upkeep.
- Fugitive emissions are minimized
and controlled as anticipated.
- Visible emissions from stacks are
normal, as expected.

Noted Improvements - Sustainable change to meet or exceed expectations that
were initiated at the unit level. (An example: picking up a leaning tool is an
opportunity. Creating a storage rack for that tool is an improvement) each
improvement noted adds one point to the appropriate category. Units should point
out these improvements during the walk through.