Industrial Inspections Making Good Inspections Better David Long EPA Region 6
Dec 25, 2015
Industrial Inspections
Making Good Inspections Better
David LongEPA Region 6
This presentation is not intended to be used as the definitive developmental tool or guide. It is intended to point out some of the more common problems that have been noted during EPA reviewed industrial inspections. Remember, the EPA provides the information and tools. It is your responsibility to build the best program you can and then, constantly review and improve that program.
What is the “Golden Rule” when performing an industrial inspection?
Follow the yellow brick road
Don’t eat the yellow snow
If you don’t document your inspection, did the inspection really happen?
A typical industrial inspection usually includes the following sections:
SECTION A – GENERAL FACILITY INFORMATION
SECTION B – RECORDS AND REPORTS
SECTION C – CHEMICALS AND STORAGE
SECTION D – OPERATION AND MAINTENANCE
SECTION E – POLLUTION PREVENTION
SECTION F – COMPLIANCE SCHEDULES
SECTION G – WALK THROUGH INSPECTION
SECTION A – GENERAL FACILITY INFORMATION
Typical information includes:
Company name
Facility address
Corporate address
Name of ranking official
Number of employees
SECTION A – GENERAL FACILITY INFORMATION
Typical information can also include:
Other environmental permits
Major product or service
Main waste materials produced
SECTION B – RECORDS AND REPORTS
Typical information can include:
Self monitoring records
Chain of Custody records
Sampling locations
Laboratory procedures (40 CFR 136)
SECTION C – CHEMICALS AND STORAGE
Typical information can include: What chemicals are handled at the site
How and where are virgin chemicals stored
Is there a spill pollution prevention plan
SECTION D – OPERATION AND MAINTENANCE
Is the process wastewater treated prior to being discharged to the sanitary sewer
Is it possible to by-pass the waste treatment system
Have any bypasses occurred
Is the treatment unit equipped with an alarm
Does the IU generate waste sludge
How and where is the sludge stored/disposed
SECTION E – POLLUTION PREVENTION
Do any processes recycle or reuse water
Has the IU implemented any pollution prevention activities
Have employees been trained in pollution prevention activities
SECTION F – COMPLIANCE SCHEDULES
Is the IU under a compliance schedule
Have design plans and specifications been completed
Has construction been completed
SECTION G – WALK THROUGH INSPECTION
Process description
Treatment system
Floor drains
Virgin chemical storage areas
Waste (oil, paint, solvent, etc.) generation and storage areas
SECTION A – GENERAL FACILITY INFORMATIONSECTION B – RECORDS AND REPORTSSECTION C – CHEMICALS AND STORAGESECTION D – OPERATION AND MAINTENANCESECTION E – POLLUTION PREVENTIONSECTION F – COMPLIANCE SCHEDULESSECTION G – WALK THROUGH INSPECTION
These sections represent the bulk of an industrial inspection or what my 10 year old daughter calls the tinker toys of my job.
So how do you make a good industrial inspection better?
You have to go back to the beginning……..
The Industrial User Survey
Has the industrial survey been kept updated?
What procedure is being used to update the industrial user survey?
Have all industrial users been properly categorized?
What procedure is being used to update the industrial user survey?
User Survey/Mass Mailing
When was the survey performed?
How many responses/non-responses?
How many of the respondents have you visited?
How many of the respondents have you inspected?
What procedure is being used to update the industrial user survey? (continued)
How did you target the industries surveyed?
Water use records
Complaints from citizens or City personnel
Referral from City Offices (Building Inspections, Fire Department, Health Department, etc.)
What procedure is being used to update the industrial user survey? (continued)
Phone Book
Manufacturers Guides
Scheduled re-inspection every three years
Have all industrial users been properly categorized?
What the industries tell you.
What your inspection shows you.
Keeping up with the literature
When inspecting a new facility, try to remember the following:
Be professional and be courteous, but know also that you are not Blanche Dubois … You are not dependent upon the kindness of others and you should not just accept what you are told.
Look inside cabinets and under sinks, ask workers questions about their jobs, ask why there is a hose going from a production unit to a floor drain…
Remember, when the EPA comes to visit your city, we will be asking:
Are you doing your inspections?
Are you doing all of your sampling?
Is your paperwork completed on time?
Was there anyone available to meet with the EPA Inspector when he came to do a PCI in your City?
Concluding Thoughts by David:
Seek and you shall find
Seek harder, and be refined
Seek not and be fined