prd-wret.s3-us-west-2.amazonaws.com€¦ · Web viewprd-wret.s3-us-west-2.amazonaws.com

Environmental Audit Handbook515-2-H

Prepared by the USGS Office of AdministrationOffice of Management ServicesEnvironmental Management Branch

April 2019

Disclaimer: Any use of trade, firm, or product names is for descriptive purposes only and does not imply endorsement by the U.S. Government.

USGS Environmental Audit Handbook

Error! Main Document Only.

Table of Contents

I. INTRODUCTION................................................................................................................................................1

A. BACKGROUND....................................................................................................................................................1B. ENVIRONMENTAL AUDIT GUIDELINES...............................................................................................................1

II. PLANNING A USGS ENVIRONMENTAL AUDIT........................................................................................2

A. SCOPE OF AN ENVIRONMENTAL AUDIT.............................................................................................................21. The Audited Facility......................................................................................................................................22. Type of Audit.................................................................................................................................................23. Audit Criteria................................................................................................................................................34. Audit Frequency............................................................................................................................................3

B. THE AUDIT TEAM...............................................................................................................................................4

III. ENVIRONMENTAL AUDIT PROCESS......................................................................................................5

IV. INTERNAL ENVIRONMENTAL COMPLIANCE AUDITS....................................................................6

A. PRE-VISIT ACTIVITIES........................................................................................................................................61. Contact USGS Facility..................................................................................................................................62. Administer Pre-Site Visit Questionnaire (PVQ)............................................................................................63. Determine Audit Scope..................................................................................................................................64. Review Applicable Regulations.....................................................................................................................75. Coordinate Audit Logistics............................................................................................................................76. Develop Audit Plan.......................................................................................................................................77. Prepare In-Brief............................................................................................................................................7

B. SITE VISIT ACTIVITIES.......................................................................................................................................71. Conduct In-brief............................................................................................................................................82. Facility Overview Tour.................................................................................................................................93. Gather Audit Data.........................................................................................................................................94. Interactions with Environmental Regulatory Agencies...............................................................................105. Audit Findings.............................................................................................................................................106. Determine Applicable BMPs.......................................................................................................................117. Conduct Exit-Brief.......................................................................................................................................11

C. POST-VISIT ACTIVITIES....................................................................................................................................111. Close Out any Open Issues..........................................................................................................................112. Prepare and Submit Draft Audit Report.....................................................................................................123. Solicit and Respond to Draft Audit Report Comments................................................................................124. Complete Final Audit Report......................................................................................................................12

V. ENVIRONMENTAL COMPLIANCE SELF-ASSESSMENTS...................................................................13

A. PREPARATION FOR THE SELF-ASSESSMENT.....................................................................................................131. Contact USGS Facility................................................................................................................................132. Prepare Pre-Site Visit Questionnaire.........................................................................................................133. Determine Audit Scope................................................................................................................................134. Coordinate Audit Logistics..........................................................................................................................14

B. ON-SITE ACTIVITIES........................................................................................................................................141. Gather Assessment Data.............................................................................................................................142. Begin Development of Assessment Findings...............................................................................................15

C. POST-ON-SITE ACTIVITIES...............................................................................................................................161. Close Out any Open Issues..........................................................................................................................162. Prepare and Submit Assessment Report......................................................................................................16

VI. ENVIRONMENTAL MANAGEMENT SYSTEM AUDITS....................................................................17

A. PRE-VISIT ACTIVITIES......................................................................................................................................171. Contact USGS Facility................................................................................................................................172. Administer Pre-Site Visit Questionnaire.....................................................................................................17

USGS Environmental Audit HandbookPage i


3. Determine Audit Scope................................................................................................................................184. Coordinate Audit Logistics..........................................................................................................................185. Develop Audit Plan.....................................................................................................................................186. Prepare In-Brief..........................................................................................................................................18

B. SITE VISIT ACTIVITIES.....................................................................................................................................181. Conduct In-brief..........................................................................................................................................192. Facility Overview Tour...............................................................................................................................193. Gather Audit Data.......................................................................................................................................194. Begin Development of Audit Findings........................................................................................................215. Conduct Exit-Brief.......................................................................................................................................21

C. POST-VISIT ACTIVITIES....................................................................................................................................221. Close Out any Open Issues..........................................................................................................................222. Prepare and Submit Draft Audit Report.....................................................................................................223. Solicit and Respond to Draft Audit Report Comments................................................................................224. Complete Final Audit Report......................................................................................................................22

USGS Environmental Audit HandbookPage ii


Appendices

Appendix A Audit Frequency (Separate Workbook)……………………………………………23

Appendix B Audit Finding Categories…………………………………………………………. 24

Appendix C Pre-Visit Questionnaire (Compliance)……………………………………………. 25

Appendix D Pre-Visit Questionnaire (EMS)…………………………………………………… 26

USGS Environmental Audit HandbookPage iii


I. INTRODUCTION

A. Background

This Environmental Audit Handbook (Handbook) describes how the U.S. Geological Survey (USGS), a bureau of the Department of the Interior (DOI), will conduct audits of its facilities and operations to help ensure compliance with the U.S. Environmental Protection Agency (EPA) and the Council on Environmental Quality regulations, and DOI and USGS policies; and conformity with the Environmental Management System (EMS). The Handbook broadly outlines the objectives and scope of the environmental audits and assists in maintaining consistency among the audits conducted across USGS.

The environmental audit fosters long-term performance improvement in operating Federal facilities and aligns with DOI audit protocol and procedures. The Handbook is designed to provide audit process information to auditors, those being audited, and management staff who will be responsible for assuring that audit findings are responded to appropriately.

/s/ Katherine M. McCulloch 04/11/19_______________________________________ _____________Katherine M. McCulloch DateAssociate Director for Administration

B. Environmental Audit Guidelines

To address the challenge faced by Federal agencies in achieving compliance with environmental regulations, an interagency workgroup developed a Generic Protocol for Conducting Environmental Audits of Federal Facilities in 1996. This was followed by detailed guidance from the EPA on program development entitled Environmental Audit Program Design Guidelines for Federal Agencies. These guidance documents, along with The Department of the Interior Manual Chapter 515 DM 2, Environmental Auditing, International Organization Standard ISO 19011-2011, Guidelines for Auditing Management Systems, and U.S. Army Corps of Engineers (USACE) The Environmental Assessment and Management Guide (TEAM Guide) have formed the basis for the process used in conducting environmental audits for USGS facilities.

USGS Survey Manual SM 515.1 on Environmental Compliance and USGS Environmental Management and Compliance Handbook 515-1-H form the basis of the Environmental compliance program for the USGS. In addition, the USGS has implemented an EMS to manage its environmental program. Additional information on EMS is available from the USGS Environmental Management SharePoint site, USGS Environmental Management System 515.4 , and EMS Handbook 515-4-H. The USGS EMS is consistent with DOI Manual Chapter 515 DM 4, Environmental Management Systems and is based on International Organization Standard (ISO) 14001:2004 on Environmental Management Systems. Together, these documents outline the environmental compliance, EMS requirements, and roles and responsibilities for personnel involved in the auditing process.

USGS Environmental Audit HandbookPage 1

http://elips.doi.gov/elips/browse.aspx?dbid=0


https://cms.usgs.gov/about/organization/science-support/survey-manual/environmental-management-system-515-4-h

https://cms.usgs.gov/about/organization/science-support/survey-manual/5154-environmental-management-systems

https://cms.usgs.gov/about/organization/science-support/survey-manual/515-1-h-environmental-management-and-compliance

https://cms.usgs.gov/about/organization/science-support/survey-manual/515-1-h-environmental-management-and-compliance

https://cms.usgs.gov/about/organization/science-support/survey-manual/5151-environmental-compliance



http://www2.epa.gov/compliance/guidance-environmental-audit-program-design-guidelines-federal-agencies

http://www2.epa.gov/compliance/guidance-environmental-audit-program-design-guidelines-federal-agencies


II. PLANNING A USGS ENVIRONMENTAL AUDIT

A. Scope of an Environmental Audit

The audit scope is a description of what is to be audited. It is defined by the following four elements of an audit program:

1. The Audited Facility (business entity (BE), referred to as facility, or portion of the facility’s operations that will be audited)

2. Type of Audit (e.g., EMS audit, multi-media compliance audit, self-assessment, etc.)3. Audit Criteria (measurable, observable requirements applicable to facility being audited)4. Audit Frequency

Each of these four elements is discussed below.

1. The Audited Facility

All USGS facilities that are owned and operated by the USGS, leased to and operated by the USGS, and joint venture sites where the USGS has ownership or operational responsibility will be subject to an environmental audit based on their risk profile. USGS operations that are controlled by others are not covered by the audit program, including USGS personnel operating at a University in space under the control of the University. A USGS facility typically consists of one or more BEs under control of a Science Center. There are cases in which one Facility/BE could be shared by several Science Centers. A Science Center generally reports to a Regional Director (RD), unless it is of national capability, in which case it reports to an Associate Director (AD).

Prior to each audit, the auditor defines the facilities to be audited, which may include one or more business entities and finalizes the audit reporting procedures. The auditor may seek help of others in conducting the audit.

2. Type of Audit

This Handbook covers four types of Environmental Audits:

Environmental Compliance Self-Assessment. This assessment is conducted on an annual basis by the Collateral Duty Environmental Protection Coordinator (CDEPC) or other person designated by the Science Center Director to assess the Science Center’s activities at a given facility with respect to compliance with environmental regulations and policies.

Internal Environmental Compliance Audit. This comprehensive environmental compliance audit is conducted by a member of the Environmental Management Branch (EMB) team or by the Contractor of the activities at a given facility or group of facilities. This audit frequency is determined by a risk-based approach using the procedure outlined in this Handbook.



Internal EMS Audit. This EMS audit is conducted to assess the conformance of the USGS EMS in preparation for the external EMS audit. The audit can be conducted by either USGS personnel or by those outside of the USGS.

External EMS Audit. This EMS audit is conducted by auditors external to the USGS to confirm conformance of the EMS system with the ISO Standard. The external audit is conducted at a frequency determined by the CFT.

The audit criteria for each different type of audit are discussed in the next section.

3. Audit Criteria

Criteria for the environmental compliance audit applicable to the USGS facility being audited include, but are not limited to:

The Code of Federal Regulations (CFR) administered by U.S. agencies, such as the EPA (40 CFR) and Department of Transportation (49 CFR)

Applicable State, local, and Tribal regulations Executive Orders (EOs) regarding environmental issues (e.g., EO 13101 - Greening the

Government Through Waste Prevention, Recycling, and Federal Acquisition) DOI and USGS management policies, or other stipulated requirements or procedures Site specific permits and plans

The TEAM Guide is used to identify the Federal regulations applicable to a facility.

The criteria for the EMS audit are based on ISO 14001:2004 on Environmental Management Systems and USGS Environmental Management System Handbook 515-4-H. If the EMS is revised to follow the ISO 14001:2015 Standard, the audit criteria will be changed accordingly.

These audit criteria are the basis for creating the audit protocols used to conduct USGS environmental compliance inspection and internal Environmental Compliance and EMS Audits.

4. Audit Frequency

The Internal Environmental Compliance Audit of each facility will be conducted by a member of the EMB team or a contractor at a frequency determined using a risk-based approach. Locations with the greatest level of risk are audited every two to six years. The risk factors for an individual facility are based on the following:

The physical area of the business entity Number of employees Site geology and hydrogeology (migration potential of contaminants) Age of the facility Proximity and density of human population Natural resources (proximity to bodies of water, storm drain outfall, storm drain inlet,

presence of endangered or protected species)



Toxic/hazardous chemical usage (quantity and type) at the facility History of accidents and danger associated with the operations conducted at the facility Compliance record (facilities with poor compliance records may require more frequent

audits than those with good records, e.g., facilities operating under consent decrees, settlement agreements, etc.)

The potential for combining sites will be taken into consideration when scheduling a compliance audit. If business entities are located close to each other or are co-located, they can be audited during one site visit.

Based on the above information, a workbook has been developed to determine the frequency of internal compliance audits for a site (Appendix A). The member of the EMB team will use the workbook to determine the frequency at which an internal audit will be conducted at a site.

Environmental Compliance Self-Assessments are conducted on an annual basis by the CDEPCs, except for the year when an internal environmental compliance audit is conducted.

B. The Audit Team

The Internal Environmental Compliance Audit is conducted by either the member of the EMB team responsible for a facility or group of facilities or a contractor selected by the EMB. At times, the member of the EMB team may enlist help of others to conduct the audit, such as the CDEPC.

The Environmental Compliance Self-Assessment is conducted by the CDEPC assigned to a Science Center. The CDEPC may enlist subject matter experts to assist in conducting the audit.

The EMS Audits are conducted by a team of auditors selected by the EMB. The Audit Team consists of a minimum of two members, one of them designated as Lead Auditor.



III. ENVIRONMENTAL AUDIT PROCESS

Internal compliance audit preparations should begin approximately eight weeks prior to the site visit with pre-visit activities and conclude within four weeks following the site visit with the final audit report. Due to funding constraints for the travel, consideration is given to remotely carrying out tasks associated with physical site visits. In this case the physical site visit is replaced by virtual site visit, where camera is utilized to gather site specific information with the help of Science Center Personnel. The term “Site Visit” will mean either physical site visit or virtual site visit. The Environmental Audit process includes:

Pre-visit activities Site visit activities Post-visit activities

The procedure for conducting each type of audit is included in the subsequent sections.


The Audit Process

Post-Visit

Close out any open issues Develop recommended

corrective actions Assign corrective actions Develop draft audit report Review and respond to

science center’s draft audit report comments

Complete final audit report Submit final audit report

Site Visit

Conduct in-brief Tour facility Gather audit data:

o Review documents and records

o Interview staffo Observe operations

Begin to develop findings Determine applicable BMPs Conduct exit-brief with

preliminary findings

Pre-Visit

Contact USGS facility Administer Pre-Visit

Questionnaire (PVQ) Determine audit scope Review applicable regulations Initiate document and records

reviews, if possible Coordinate audit logistics Develop audit plan Prepare in-brief


IV. INTERNAL ENVIRONMENTAL COMPLIANCE AUDITS

A. Pre-Visit Activities

The audit process begins with activities designed to gather background information about the facility and prepare for the site visit. The member of the EMB team/contractor generally acts as the sole internal auditor or s/he may include additional staff, as a part of the audit team, to effectively conduct the internal audit. Effective coordination between the auditor, CDEPC, and Science Center Director in the pre-visit process is essential for successful completion of the audit. The following is a description of each of the pre-visit activities that should be accomplished before each audit. Pre-visit activities vary with the type of facility audited.

1. Contact USGS Facility

The member of the EMB team will notify the Science Center Director and the auditor will notify the CDEPC of the upcoming audit, approximately six to eight weeks prior to the site visit.

2. Administer Pre-Site Visit Questionnaire (PVQ)

Before the auditor can determine which audit criteria apply to a facility, s/he must gather as much information as possible about the location activities and operations. Approximately six weeks before the site visit, the auditor will request the CDEPC to complete a PVQ. The CDEPC should return the completed PVQ no later than two weeks prior to the site visit. Audit criteria applicable to the facility will be determined based on responses received on the PVQ.

The auditor should review the background information with the CDEPC, the facility manager, and other knowledgeable personnel by phone to ensure that the scope of the audit is understood. In addition to the information requested in the PVQ, the auditor may also need additional information such as:

Past audit reports General background information about the facility Facility description and map indicating key operations areas and storage locations Permits, plans, and other compliance related information

Based on the information gathered from the PVQ, the auditor may identify key staff (e.g., safety officers, maintenance staff, laboratory manager) to be interviewed during the audit site visit. Contact key staff to ensure that they are available during the audit process. Coordination with facility staff is the responsibility of the Science Center Director or designee.

Conduct a conference call with the Science Center to discuss the PVQ and clarify any issues at least one week prior to the site visit.

3. Determine Audit Scope

After receiving the completed/updated PVQ, the auditor will define the audit scope and prepare an audit checklist using the Audit System of Record (Audit Tool) available at the USGS EMS SharePoint site. Preparation of the audit checklist (using the TEAM Guide checklist in the Audit



Tool) prior to the site visit is critical to balance the level of effort expended in different areas of the facility. This includes prioritizing higher risk operations that will be reviewed.

4. Review Applicable Regulations

It is the auditor’s responsibility to determine the regulations applicable to a facility’s operations. The TEAM Guide audit checklist available in the Audit Tool will have the Federal environmental regulations that are most likely to apply to USGS operations. The checklist will be supplemented by State, Local, and Tribal regulations applicable to the Center, as well as any requirements set forth in plans and permits.

To determine the correct State, Local, and Tribal regulations, the auditor may want to review information available from the respective websites to determine the extent to which current state regulations are more stringent than Federal requirements. Most state environmental departments are accessible online through EPA website http://www2.epa.gov/home/health-and-environmental-agencies-us-states-and-territories. The facility’s performance is evaluated against the more stringent of the Federal, State, Local, or Tribal requirements. Depending upon the nature of a facility’s operations, it may be necessary to conduct additional research to ensure the audit includes the applicable regulatory requirements.

5. Coordinate Audit Logistics

Thorough logistical planning and scheduling ensures that both the auditor and the facility’s staff can invest the time needed toward the audit. Scheduling includes setting dates and assigning responsibilities for collecting pre-visit information, site visit activities, and post-visit activities such as reporting and times for meeting with the Science Center Director and/or key staff. Planning also secures workspace for the auditor where s/he may conduct online research, provide interpretive documents, and conduct internal meetings. To assist the auditor, the facility should provide access to a phone, printer, copy machine, and internet/intranet.

6. Develop Audit Plan

The auditor will develop an audit plan for completing the audit based on the audit schedule (i.e., number of days the auditor will be on site), facility information, and audit criteria applicable to that facility. The plan outlines detailed roles and responsibilities, a schedule for completing the audit, and other necessary aspects of the audit process depending upon the nature of the facility’s operations. The complexity of the audit plan itself will depend upon the complexity of the facility being audited.

7. Prepare In-Brief

The in-brief presentation developed by the auditor is used to provide the Science Center with information about the scope, schedule, and reporting plans.

B. Site Visit Activities

Site visit activities involve an exchange of information between the auditor, the CDEPC, and other facility personnel involved in facility environmental management and the auditing process.


http://www2.epa.gov/home/health-and-environmental-agencies-us-states-and-territories

http://www2.epa.gov/home/health-and-environmental-agencies-us-states-and-territories


The auditor gathers information to understand compliance issues and identify pollution prevention opportunities, while at the same time communicating with facility staff regarding important environmental issues and potential corrective action opportunities.

The auditor should understand how the facility meets its environmental responsibilities and what systems it has in place to address environmental requirements. To do so, the auditor may review the facility’s organizational charts and standard operating procedures. The auditor may observe operations and interview key staff to learn how the facility operates. Doing so will allow the auditor to determine the significance of an audit finding (i.e., whether the finding is an isolated incident or an indication of a programmatic problem; or to provide more relevant recommendations for corrective action).

Following is a detailed description of the site visit tasks that will be completed by the auditor.

1. Conduct In-brief

The site visit commences with an in-brief that provides the facility with a presentation of what to expect during the audit site visit. The in-brief allows the auditor to begin to build a working relationship with the facility’s staff. It also provides an opportunity to schedule time for the auditor and key staff to meet.

The following individuals should be present at the in-brief meeting:

Member of the EMB team/auditor Science Center Director or his/her designee CDEPC Other key staff

The following should be done at the audit in-brief:

Introduce auditor to the facility’s staff Review the audit purpose, scope, and schedule for the site visit Clarify any remaining issues associated with the PVQ Identify areas to be reviewed, people to be interviewed, and records to review Review logistics such as how to contact the key staff during the day, building hours,

limitations of auditor’s use of the workspace, parking, and reporting of emergency issues Review reporting procedures

During the in-brief, the auditor may be required to revise the audit plan and schedule based on site conditions.

At the end of the meeting, the auditor and the CDEPC confirm their agreement on the review and reporting schedule for the draft and final audit reports. The CDEPC should be aware that s/he has a specific period (two to four weeks is the time recommended) to review the draft audit report and submit comments to the auditor. It is important for the CDEPC to understand that following the audit, they may contact the auditor for recommendations regarding corrective action implementation.



2. Facility Overview Tour

Before conducting the audit, the auditor should get an overview of the facility, especially when s/he has not had a chance to visit the facility previously. The facility tour familiarizes the auditor with locations of relevant activities, operations to be reviewed, and the physical and geographical scope of the area. This will help the auditor set priorities when the audit begins.

3. Gather Audit Data

Following the overview tour, the auditor should begin an in-depth tour to collect audit data. The auditor will then evaluate facility operations against the audit criteria. Means of collecting data will involve:

Observing relevant operations Interviewing staff Reviewing records Taking photographs of facility and operation

Each of these methods of data collection, discussed in more detail below, is used to develop supportable conclusions written up as audit findings. Throughout the audit site visit, the data collected will be used to develop conclusions about facility operations that do not conform to audit criteria, as well as any positive findings.

If the auditor identifies issues associated with safety, the Collateral Duty Safety Protection Coordinator (CDSPC) should be briefed on those issues. Safety findings are not part of the official environmental compliance audit report and should not be included in the Audit Tool.

Observing relevant operations. Physical observation is the most reliable method of gathering audit data. Storage areas, work practices, and operations should be observed to provide information that supports audit findings (e.g., hazardous waste being stored in a container that is not properly labeled). To substantiate audit findings, the auditor should take comprehensive notes on their observations. Photographs are not required but are strongly encouraged. If photographs are taken, they should be discrete; ensuring that any staff personnel are not identified. The photographs should not be taken in an area where photography is restricted.

Interviewing staff. Interviews are conducted throughout the site visit and are used to:

Discuss employee job responsibilities Develop an understanding of operational areas and environmental program

implementation Confirm the implementation of facility policies and procedures Assess the effectiveness of training

Gaining a general understanding of the facility’s operations and activities is one of the most important purposes of interviews. When using interviews to verify observation, it is important that the auditor interviews the person knowledgeable about the subject. Interviews should include staff at all levels. They should not be limited to supervisors.



If possible, the information gathered during an interview should be corroborated with additional source of information. The auditor should keep in mind that staff may not be familiar with regulatory terminology. Interviews should be held in the employee’s work area, if possible, so that the employee will be more comfortable.

When conducting interviews, the questions should be framed using the following guidelines:

Ask a variety of open-ended and specific questions (“Describe what happens when you change the oil,” and “How do you transfer oil to the 250-gallon tank?”)

Avoid leading questions (“You don’t mix anything with used oil, and you clean up spills immediately, right?”)

Probe for definitive answers (e.g., asking the same question several times in different ways)

Avoid questions of judgment or blame (e.g., “So, it’s your fault the hazardous waste storage area is a mess”)

Reviewing records. Records are reviewed to assess compliance and verify issues identified by interviews and observations. The records should generally be maintained for a period of five years unless a different timeframe is stipulated in a specific permit. The auditor should not remove records from the facility or share those records with individuals outside of the facility.

The auditor should consider the scope when reviewing records to minimize facility efforts in locating records. Records are not always maintained at the corresponding location. For example, purchase records for oil used in maintenance may be in the procuring office.

4. Interactions with Environmental Regulatory Agencies

The auditor may contact the EMB during the audit process should they need interpretation of laws and regulations. If the EMB is not able to provide immediate assistance, and the auditor needs to contact Federal, State, Local, or Tribal regulatory representatives, great care should be taken not to disclose information specific to the facility, unless necessary.

5. Audit Findings

As audit data are collected, the auditor should begin to develop conclusions stemming from audit findings. All findings are generated from objective evidence acquired during the audit process. To ensure quality, findings should be:

Compared with applicable audit criteria Verified through observations, record reviews, and interviews Reviewed with appropriate facility staff Documented

For issues that are not clearly related to the audit criteria, the member of the EMB team or audit contractor should determine whether those issues are sufficiently relevant to be listed as an observation. Positive observations should also be documented.



Developing accurate audit findings is one of the most significant contributions that can be made to the audit process. All findings must be documented in the Audit Tool, even if they are corrected during the site visit. The findings are classified in one of the five categories listed in Appendix B. All findings must be assigned to a point of contact (POC) at the location. This is usually the CDEPC for the Science Center. Assign all findings in the Audit Tool.

6. Determine Applicable BMPs

Prior to the site visit, based on operations at the science center, the auditor should consider potential Best Management Practices (BMPs) that could benefit the facility. In general, implementation of a BMP leads to reduction in a facility’s environmental footprint. Implementation of a BMP may not be required by law, but its implementation may benefit the facility in the long run.

While not required, the auditor should review applicable BMPs found in the pollution prevention guides available at the FedCenter website and the DOI Office of Environmental Policy and Compliance Web Page and USGS SharePoint Best Management Practices.

7. Conduct Exit-Brief

The final site visit activity is the audit exit-brief. The exit-brief reviews the audit process, scope, potential key findings and associated potential corrective actions, and reporting process. This is the last face-to-face contact between the auditor and the facility staff. The auditor should prepare the exit-brief and summarize potential audit findings and recommendations.

C. Post-Visit Activities

Following the site visit, the auditor will perform the following tasks:

Research and close out any open issues Prepare and submit a written draft audit report Develop recommended corrective actions Solicit and respond to comments on the draft audit report Prepare and submit a final report to the Science Center Director and the CDEPC

Each task is discussed in more detail below.

1. Close Out any Open Issues

If there are unresolved findings that need further verification or research, the auditor should complete this work expeditiously. Research may include collecting additional information from the facility, consulting with EMB, or with appropriate Federal, State, or local regulatory authorities to determine compliance findings or compiling information on appropriate and applicable pollution prevention technologies.


http://www.doi.gov/oepc

http://www.doi.gov/oepc

https://www.fedcenter.gov/programs/p2/


2. Prepare and Submit Draft Audit Report

The draft audit report is issued by the member of the EMB team to the CDEPC within four weeks of the completion of the site visit. The auditor will submit the draft report to EMB Chief within two weeks of the completion of the site visit. The EMB Chief transmits the report to the CDEPC within two weeks of the receipt of the report. The time between the audit exit-brief and delivery of the draft audit report is used for quality assurance review, confirming regulatory applicability of any open issues, and developing suggested corrective actions. The draft report will be prepared using the Audit Tool.

3. Solicit and Respond to Draft Audit Report Comments

The CDEPC is requested to submit comments on the draft audit report within two-to-four weeks after receiving the report from the member of the EMB team/auditor. The specific due date(s) should have been communicated to the CDEPC during both the in-brief and exit-brief and when the draft was submitted to them. Comments should focus on the accuracy of the findings and appropriateness of corrective actions and corrective action dates. The facility is not required to complete corrective actions or develop detailed corrective action plans within this period, unless specifically directed by the AD, Office of Administration, through the appropriate RD or AD due to the need to immediately address high risk issues.

4. Complete Final Audit Report

The final audit report completes the audit process for the auditor. The auditor reviews the comments with the CDEPC and prepares the final audit report. The auditor addresses science center comments by either revising the audit report based on the comments or by explaining to the science center why the audit report was not changed, as requested. As a general guideline, the final audit report should be prepared within two weeks of the auditor receiving comments from the Science Center.

The auditor will use the Audit Tool to prepare the final report. The final audit report will be submitted to the Science Center Director and the CDEPC.



V. ENVIRONMENTAL COMPLIANCE SELF-ASSESSMENTS

A. Preparation for the Self-Assessment

The environmental compliance self-assessment (assessment) is coordinated by the CDEPC. The assessment is conducted once a year, skipping the year in which the internal environmental audit is conducted. If a determination is made that environmental aspects at a facility do not warrant an annual self-assessment, a formal annual self-assessment need not be conducted. The CDEPC may act as the sole inspector or determine if s/he needs additional staff as a part of the audit team to effectively conduct the assessment. Effective coordination between the CDEPC and key facility staff is essential. Following is a description of pre-assessment activities, which may vary with the type of facility.


The CDEPC should notify the key staff and the Science Center Director of the upcoming assessment at least two weeks prior to the assessment. Key staff may include safety officers, maintenance staff, and the laboratory manager.

2. Prepare Pre-Site Visit Questionnaire

The CDEPC should review the Pre-Site Visit Questionnaire (PVQ) used by the member of the EMB team prior to an assessment. The PVQ will help the CDEPC in determining the audit criteria.

In addition to the information included in the PVQ, the CDEPC may also need additional information such as:

Past audit reports General background information about the facility Facility description and map indicating key operation areas Permits, plans, and other compliance related information

Based on the information gathered from the PVQ, the CDEPC should identify the key staff that s/he may like to interview.


Assessment criteria applicable to the facility will be determined based on information available in the PVQ and regulations applicable to a facility’s operations. The CDEPC checklist in the Audit Tool will be used for assessments. It is a subset of TEAM Guide and is accessible through the Audit Tool available at the USGS EMS SharePoint site. The CDEPC is encouraged to seek assistance from the member of the EMB team in determining audit checklist items applicable to the Center. Review of the audit checklist prior to the on-site activities visit is critical in order to balance the level of effort expended in different areas.




Thorough logistical planning and scheduling ensures that the CDEPC and the facility staff can invest the time needed toward the assessment. Scheduling includes setting dates, assigning responsibilities for collecting information, and securing a workspace for the CDEPC where s/he may conduct online research and conduct internal meetings. To assist the CDEPC, the facility should provide access to a phone, printer, copy machine, and internet/intranet.

B. On-Site Activities

On-site activities involve an exchange of information between the CDEPC and other facility personnel involved in the assessment process. The CDEPC gathers information to understand compliance issues.

The CDEPC should understand how the facility meets its environmental responsibilities and what systems it has in place to address environmental requirements. To do so, s/he may review standard operating procedures, observe operations, and interview key staff to learn how the facility operates. Doing so will allow the CDEPC to determine the significance of an audit finding (i.e., whether the finding is an isolated incident or an indication of a programmatic problem; or to provide more relevant recommendations for corrective action).

Following is a detailed description of the on-site activities that will be completed by the CDEPC.

1. Gather Assessment Data

The CDEPC will evaluate facility operations against assessment criteria. Means of collecting data will involve:

Observing relevant operations Interviewing staff Reviewing records

Each of these data collection methods, discussed in more detail below, is used to develop supportable conclusions, written up as audit findings. Throughout the audit site visit, the data collected will be used to develop conclusions about facility operations that do not conform to audit criteria.

If the CDEPC identifies issues associated with safety, provide the information to the site safety coordinator. Do not include safety issues in the environmental assessment report or in the Audit Tool.

Observing relevant operations. Physical observation is the most reliable method of gathering audit data. Storage areas, work practices, and operations should be observed to provide information that supports audit findings (e.g., hazardous waste being stored in a container that is not properly labeled). To better assure accurately documented audit findings, the CDEPC should take comprehensive notes on their observations. Inclusion of photographs is not required but is strongly encouraged. If photographs are taken, they should be discrete; ensuring that any staff



personnel are not identified. The photograph should not be taken from an area where photography is restricted.



implementation Confirm the implementation of facility policies and procedures Assess the effectiveness of training

Gaining a general understanding of facility’s operations and activities is one of the most important purposes of interviews. When using interviews to verify an observation, it is important that the CDEPC interviews the person most knowledgeable about the subject or process. The CDEPC may need to interview more than one individual to answer a question. Interviews should include staff at all levels. They should not be limited to supervisors.

It is important to verify information gathered during an interview with an observation of the subject matter. When conducting interviews, the questions should be framed using the following guidelines:

Ask a variety of open-ended and specific questions (“Describe what happens when you change the oil,” and “How do you transfer oil to the 250-gallon tank?”)

Avoid leading questions (“You don’t mix anything with used oil, and you clean up spills immediately, right?”)

Probe for definitive answers (e.g., asking the same question several times in different ways

Avoid questions of judgment or blame (e.g., “So, it’s your fault the hazardous waste storage area is a mess”)

Reviewing records. Records are reviewed to assess environmental compliance and to verify issues identified during interviews or observations. The records should generally be maintained for a period of five years unless a different timeframe is stipulated in a specific permit.

2. Begin Development of Assessment Findings

As audit data are collected, the CDEPC should begin to develop conclusions that are documented as assessment findings. All findings are based on the checklist used and are generated from objective evidence acquired during the assessment process. To ensure quality, findings should be:

Compared with the CDEPC Checklist criteria Verified through observations, record reviews, and interviews Reviewed with appropriate facility staff Documented in the CDEPC’s working papers



For issues that are not clearly related to the audit criteria, the CDEPC should determine whether those issues are sufficiently relevant to be listed as observations. Positive observations should also be documented.

Developing accurate audit findings is one of the most significant contributions the CDEPC can make to the audit process. All findings must be documented, even if it is corrected during the site visit, in the Audit Tool. All findings must be assigned to the POC at the Science Center in the Audit Tool.

The findings are the results of the noncompliance against the audit criteria. The CDEPC will classify them in one of the five categories listed in Appendix B.

C. Post-On-Site Activities

Once the on-site activities are completed, the CDEPC will perform the following tasks:

Research and close out any open issues Prepare and submit a report to the Science Center Director

Each step is discussed in more detail below.


If there are unresolved findings that need further verification or research, the CDEPC should complete this work expeditiously. Research may include consulting with the member of the EMB team to determine compliance findings.

2. Prepare and Submit Assessment Report

The assessment report should be prepared by the CDEPC within two weeks of the conclusion of on-site activities using the CDEPC Self-Assessment Checklist. The report should discuss the root cause of findings and, if possible, associated corrective action plans. The report should be submitted to the Science Center Director. This report completes the assessment process for the CDEPC.



VI. ENVIRONMENTAL MANAGEMENT SYSTEM AUDITS

This section describes the process for USGS auditors conducting internal EMS audits. External auditors (non-USGS personnel) conducting either internal or external EMS audits will develop their own procedures for conducting the audit. However, external auditors can benefit from this section while developing/implementing their audit procedures, as it will give them information on the expectations of the USGS.

A. Pre-Visit Activities

EMS audits are conducted by a team of auditors selected by the EMB. The Audit Team consists of a minimum of two members, one of them designated as Lead Auditor. The USGS EMS Program Manager (PM) will be the primary contact for the Lead Auditor. Effective coordination between the Lead Auditor and PM is essential for successful audit completion. The audit process begins with activities designed to gather background information about the facilities and prepare for the site visit. The following is a description of each of the pre-visit activities that shall be accomplished before each audit.


The Lead Auditor should notify the PM which USGS facilities the audit team intends to visit. The PM will notify the members of the EMB team, CDEPCs, and Science Center Directors of the affected facilities of the upcoming audit at least eight weeks prior to the site visit. Depending on the availability of funds, it is possible that telephone interviews will substitute for actual site visits at some facilities.

2. Administer Pre-Site Visit Questionnaire

In preparation of the audit the Lead Auditor must gather as much information as possible about the facilities’ activities and operations. Prior to the site visit, the Lead Auditor will request the member of the EMB team or CDEPC to complete a PVQ. The PVQ requests information on USGS activities and environmental management programs. The PVQ also includes a list of records that the audit team will need to review during the audit process. USGS staff may need to review those documents to respond to the PVQ. Audit criteria applicable to the facility will be determined based on responses received on the PVQ.

Approximately four weeks before the site visit, the Lead Auditor reviews the background information with the PM to assure that the scope of the audit is understood. In addition to the information requested in the PVQ, the Lead Auditor may also need additional information such as:

Past audit reports General background information about USGS and facilities selected for verification site

visits Facility description and map of facilities to be visited indicating key operational areas Permits, plans, and other compliance related information for selected facilities



Based on the information gathered from the PVQ, the audit team may identify key staff to interview during the audit site visit. The PM will coordinate with the key staff and the members of the EMB team to ensure their availability during the audit process.


After the completed PVQ is received, the Lead Auditor will define the audit scope. Preparation of the audit checklist prior to the site visit is critical to balance the level of effort expended in different areas. The TEAM Guide EMS checklist is available in the Audit Tool and may be used. The audit scope and checklist will be submitted to the member of the EMB team, CDEPC, and Science Center director at a minimum of two weeks prior to the planned audit.


Thorough logistical planning and advanced scheduling ensures that both the audit team and the USGS staff can invest all the time needed toward the audit. Scheduling includes setting dates and assigning responsibilities for collecting pre-visit information, site visit activities, and post-visit activities such as reporting and times for meeting with the selected USGS staff. Planning also secures workspace for the audit team where they may conduct online research, review documents, and conduct internal meetings. To assist the audit team, they should have access to a phone, printer, copy machine, and intranet/internet.

5. Develop Audit Plan

The Lead Auditor will develop an audit plan for completing the audit based on the audit schedule. The plan outlines detailed roles and responsibilities, a schedule for completing the audit, and other necessary aspects of the audit process depending upon the nature of the facility’s operations. The complexity of the audit plan itself will depend upon the complexity of the facility being audited. The audit plan is an organizational tool helpful to the audit team; it does not necessarily need to be communicated to the PM, except for the schedule, which should be prepared in consultation with the PM.

6. Prepare In-Brief

The in-brief presentation developed by the Lead Auditor is used to provide the key USGS personnel with information about the scope, schedule, and reporting plans.

B. Site Visit Activities

Site visit activities involve an exchange of information between the audit team, the PM, and other USGS personnel involved in the auditing process. The audit team gathers information to understand how different elements of EMS have been implemented.

The audit team should understand how the facility meets its environmental responsibilities and what systems it has in place to address environmental requirements. To do so, the audit team may seek clarification on any questions that the team may have after reviewing the facility’s organizational charts and standard operating procedures prior to the site visit. The audit team may observe operations and interview key staff to learn how the facility operates. Doing so will



allow the audit team to determine the significance of an audit finding (i.e., whether the finding is an isolated incident or an indication of a programmatic problem; to provide more relevant recommendations for corrective action, or whether the facility is doing something positive that is worthy of others to follow).

Following is a detailed description of the site visit tasks that will be completed by the audit team.

1. Conduct In-brief

The in-brief initiates the site visit by providing the facility with a presentation of what to expect during the audit site visit. The follow should be reviewed during the in-brief:

Introduction of the audit team Review the audit purpose, scope, and schedule for the site visit Clarify any remaining issues associated with the PVQ Identify areas to be reviewed, people to be interviewed, and records to review Review logistics such as how to contact the key staff during the day, building hours,

limitations of audit team’s use of the workspace, parking, reporting of emergency issues, and location of restrooms, cafeteria, etc.

Review reporting procedures

During the in-brief, the Lead Auditor may be required to revise the audit plan and schedule based on site conditions. These revisions should be discussed with the PM and member of the EMB team, as soon as they are made.

The following individuals should be present at the in-brief meeting:

Audit Team Member of the EMB team USGS EMS Program Manager Science Center Directors CDEPC Other key USGS staff

2. Facility Overview Tour

Before conducting the audit, the audit team should get an overview of the facility. The facility tour will be helpful in familiarizing the audit team with locations of relevant activities, operations to be reviewed, and the physical and geographical scope of the area. The audit team should use the opportunity to make initial observations during the tour.

3. Gather Audit Data

The audit team will gather information and evaluate it against audit criteria. The information will be gathered by:

Reviewing records Interviewing staff



Observing relevant operations

Each of these methods is discussed in more detail below. Throughout the audit site visit, the information gathered will be used to develop conclusions about facility operations that do not conform to audit criteria.

Reviewing records. Records are reviewed to assess conformance with various elements of the EMS and verify issues identified by interview or observation. The audit team members should not remove records from the facility or share those records with individuals outside of the facility. Copies of permits and compliance records can be made and shared with OMS and the EMB Chief.

The audit team members should consider the scope when reviewing records to minimize facility efforts in locating records. Records may not always be maintained at the auditing location. For example, purchase records for oil used in maintenance may be in the procuring office.



implementation Confirm the implementation of EMS policies and procedures, progress on objectives and

targets (via Eco-Action Plans) Assess the effectiveness of training

Gaining a general understanding of facility’s operations and activities is one of the most important purposes of interviews. When using interviews to verify observation, it is important that the audit team members interview the person most knowledgeable about the subject. The audit team may need to interview more than one individual to answer a question. Interviews should include staff at all levels. They should not be limited to supervisors.

It is important to verify information gathered during an interview with an observation of the subject matter. Interviews should be held in the employee’s work area so that the employee will be more comfortable.

When conducting interviews, the questions should be framed using the following guidelines:

Ask a variety of open-ended and specific questions (“Describe the significant environmental aspects that are applicable to your facility” and “Do you have a copy of the certificate for your EMS training?”)

Avoid leading questions (“You don’t think that the upper administration has bought into the idea of using EMS to manage environmental aspects, do you?”)

Probe for definitive answers (e.g., asking the same question several times in different ways)

Avoid questions of judgment or blame (e.g., “Do you think that the CFT did a good job of identifying the significant environmental aspects for USGS?”)



Observing relevant operations. Physical observation is the most reliable method of gathering audit data related to EMS requirements; operations control; and monitoring measurement and evaluation of compliance. Check the EMS website and records and documents to provide information that supports audit findings. To better assure accurately documented audit findings, the audit team should take comprehensive notes on their observations.

4. Begin Development of Audit Findings

As audit data are collected, the audit team should begin to develop conclusions that are documented as audit findings. All findings are based on the checklist used and are generated from objective evidence acquired during the audit process. To ensure quality, findings should be:

Compared with the Checklist criteria Verified through observations, record reviews or interviews Reviewed with appropriate facility staff Documented in the audit team’s working papers

For issues that are not clearly related to the audit criteria, the audit team should determine whether those issues are sufficiently relevant to be listed as observation. Positive observations should also be documented.

Developing accurate audit findings is one of the most significant contributions the audit team can make to the audit process. All findings shall be documented, even if it is corrected during the site visit. The findings are the results of the evaluation of the collected audit evidence against audit criteria. The audit team will classify them in one of the four categories listed in Appendix B.

5. Conduct Exit-Brief

The final site visit activity is the audit exit-brief. The exit-brief reviews the audit process, scope, potential key findings, and reporting process. This is the last face-to-face contact between the audit team and the facility staff. The Lead Auditor should prepare the exit-brief and summarize potential audit findings and recommendations.

At the end of the meeting, the Lead Auditor and the PM confirm their agreement on the review and reporting schedule for the draft and final audit reports. The PM should be aware that s/he has a specific period (two weeks is the recommended time) to review the draft audit report and submit comments to the Lead Auditor. It is important for the PM to understand that following the audit, the Lead Auditor serves as the primary point of contact for questions regarding corrective action implementation.

C. Post-Visit Activities

If pre-visit research was conducted and comprehensive information was gathered during the site visit, then the post-visit activity may be the least intensive portion of an audit for the audit team. In general, the Lead Auditor will perform the following tasks:



Research and close out any open issues Prepare and submit a written draft audit report Solicit and respond to comments on the draft audit report Prepare and submit a final report to the PM

Each step is discussed in more detail below.


If there are unresolved findings that need further verification or research, the Lead Auditor, with assistance from the audit team, completes this work expeditiously.

2. Prepare and Submit Draft Audit Report

The draft audit report should be transmitted to the PM two weeks of the completion of the site visit. The time between the audit exit-brief and delivery of the draft audit report is used for quality assurance review, confirming applicability of any open issues, and developing suggested corrective actions.

3. Solicit and Respond to Draft Audit Report Comments

The PM solicits comments from all appropriate USGS personnel involved with the audit and submits comments on the draft audit report within two-three weeks after receiving the report from the Lead Auditor. The specific due date(s) are communicated to PM during both the in-brief and exit-brief and when the draft was submitted to him/her. Comments should focus on the accuracy of the findings and appropriateness of corrective actions and corrective action dates. The facility is not required to complete corrective actions or develop detailed corrective action plans within this period.

4. Complete Final Audit Report

The final audit report completes the audit process for the audit team. The Lead Auditor reviews the comments and prepares the final audit report. The Lead Auditor addresses comments by either revising the audit report based on the comments or by explaining to the PM why the audit report was not changed, as requested. As a general guideline, the final audit report should be prepared and submitted to the PM two weeks of the Lead Auditor receiving comments from the PM.



Appendix AAudit Frequency

This Appendix is attached as a separate workbook. The instructions for the Audit Frequency Workbook and the Workbook are included as an MS Word file and MS Excel Workbook, respectively on the EMS SharePoint Site.



Appendix BAudit Finding Categories

(Compliance)

The findings are the results of the evaluation of the collected audit evidence against audit criteria. They are classified in the following five categories:

P1: Emergency Conditions: They must be immediately reported by the member of the EMB team to the CDEPC. Emergency conditions include practices or situations that could reasonably be expected to cause death, serious physical harm to persons or the environment, or immediate loss of USGS structures or resources before the danger can be eliminated through normal procedures. Should such an emergency be identified that results in the release of oil or any hazardous substance to the environment, the Science Center Director or his or her designee must call the National Response Center (NRC) at 1-800-424-8802. The member of the EMB team will provide information based on the list of reportable quantities for any release from USGS facilities. The NRC can assist in determining whether the issue requires written reporting and can advise the facility on next steps.

P2: Noncompliance: This refers to non-fulfillment of a legal requirement. P3: Non-conformity with Organization Requirements: This refers to finding that

indicates nonconformity with audit criteria related to fulfillment of Executive Orders, DOI, or USGS requirements.

P4: Observation: A statement of fact made in the audit report that something was found during the audit that doesn’t rise to the level of nonconformity (no objective evidence of nonconformity, doesn’t require a corrective and preventive action) but which, if left alone, could result in finding in future.

P5: Positive Observation: Audit finding that shows that audit criteria are being met and identify best practices is Positive Finding. Such BMPs may serve as an example for good practice for other facilities.

EMS Audit Findings

In conformance: Conformance with the requirements specified in an Element of the EMS.

Major nonconformance: An Element of the EMS has not been addressed or has not been implemented; or several similar minor non-conformances that are related to the same EMS Element.

Minor nonconformance: A single observed nonconformance to a requirement of the organization's EMS that is not considered to be a breakdown in the EMS.

Observation: A statement of fact made in the audit report that something was found during the audit that doesn’t rise to the level of nonconformity (no objective evidence of nonconformity, doesn’t require a corrective and preventive action) but which, if left alone, could result in non-conformance future.

Positive Observation: Audit finding that shows that audit criteria are being met and identify best practices is a Positive Finding.



Appendix CEnvironmental Compliance Audit

Pre-Visit Questionnaire

This Pre-Visit Questionnaire (PVQ) is used to collect information regarding your facility’s operations. This information will assist in planning and conducting an environmental compliance audit at your facility.

The facility’s Collateral Duty Environmental Protection Coordinator (CDEPC) should coordinate filling out the PVQ, with input from various facility personnel, as appropriate. Answer the questions to the best of your collective knowledge. The PVQ is designed to facilitate the audit process and provide facility staff with a better understanding of the audit criteria.

If the answer to a question is unknown, it is fine to leave it blank and the member of the EMB team for your facility will assist you with deciding during the audit site visit. Some of the questions may not be applicable to your facility. Please answer these questions by marking N/A (Not Applicable). If you do not have sufficient information to confidently address a question, answer by marking U (Unknown) where these options are provided.

Please return the completed PVQ to your member of the EMB team no later than two weeks prior to your audit site visit. If you have any questions or wish to discuss your responses, please contact your member of the EMB team. A copy of the PVQ can be accessed from the EMS SharePoint Site.



Appendix DEMS Audit

Pre-Visit Questionnaire

A Pre-Visit Questionnaire (PVQ) may be helpful in collecting information regarding a facility’s operations and environmental management activities. The following information will assist in planning and conducting an EMS audit and preparing the PVQ for the facility:

The facility’s EMS Manual and/or EMS procedures Environmental Policy List of Environmental Aspects (with significant aspects identified) – EMB can provide Objectives and targets and programs (environmental action plans aka Eco-Action Plans) General EMS Awareness Training material, presentations, etc. EMB can provide Results of previous internal or external EMS audits and corrective action plans Results of previous internal compliance evaluations Roles and responsibilities of people involved in the EMS, with organizational chart if

available Organizational charts Minutes from Cross Functional Team (CFT) meetings – EMB can provide Environmental Management Plans and Standard Operating Procedures related to

significant aspects, such as: HWMP, Storm Water Pollution Prevention Plan (SWPPP), SPCC, Emergency Preparedness and Response Plan, INRMP, etc.

If you operate an electronic EMS on your intranet, provide access to the site Meeting minutes from the last two management reviews (including presentation material)

– EMB can provide Emergency Response Procedures such as: Emergency Preparedness and Response Plan,

SPCC, Hazardous Waste Contingency Plans, etc. Other EMS documentation that the EMS Lead auditor determines is needed prior to the

site visit

The EMS Lead Auditor should coordinate completing the PVQ, with input from various facility personnel, as appropriate. The PVQ is designed to facilitate the audit process and provide facility staff with a better understanding of the audit criteria. The PM, the member of the EMB team, and the CDEPC should answer the questions to the best of their collective knowledge since the Lead Auditor will receive a copy of the completed PVQ.

Some of the questions that the Lead Auditor may ask may not be applicable. Please answer these questions by marking N/A (Not Applicable). If you do not have sufficient information to confidently address a question, answer by marking U (Unknown) where these options are provided.



Along with specific questions related to the audit, the PVQ will typically have general facility specific information, as shown below. Please return the completed PVQ to the PM no later than four weeks prior to your audit site visit. A copy of Facility Information Form can be accessed from the EMS SharePoint site.



APPENDIX E

Records to be Made Available During the Site Visit

Air Emissions

Copies of all current air permits

Air monitoring data

Air emissions inventories

Air emissions reports submitted to regulatory agencies

Copies of any violation notices received

Risk Management Plan

Fuel Storage Tanks (Aboveground and Underground)

A listing of all fuel storage tanks which includes: capacity, contents, use, and volume capacity of secondary containment (if not included in PVQ). The list may be obtained from the last inspection of the system.

A copy of the underground storage tank (UST) registration form(s) submitted to any authority or removal/closure records

A copy of the site’s SPCC Plan

Map indicating location of USTs and/or Aboveground Storage Tanks (ASTs)

Hazardous Materials

Copies of latest chemical inventory or the list of chemicals or MSDSs sent to LEPC

Copies of §311/312 Tier I and II report

Copies of §313 Form R submissions

List of all chemical substances on-site

Drinking Water

PWIS monitoring schedule

Sampling analysis and reports

Community Confidence Reports



Sanitary Surveys

Groundwater

Well construction diagrams for on-site water supply or groundwater monitoring wells

Water quality analyses from water supply or groundwater monitoring wells

Stormwater

Any analysis conducted for permit requirements Construction stormwater permit Municipal Separate Storm Sewer System (MS4) Permit

Wastewater

Copies of discharge monitoring data and reports

Pretreatment permit

National Pollutant Discharge Elimination System (NPDES) permit

Wastes Generated

RCRA permits

Waste manifests

Hazardous and miscellaneous waste manifests

Waste analysis data for hazardous waste streams

Latest generator report to EPA/State


Copies of any notices of involvement at Superfund sites

Copy of the Waste Minimization Plan

Copies of Pollution Prevention and other waste minimization plans

TSCA/PCBs

Any TSCA adverse reaction report

A copy of an annual PCB report

PCB test results from analysis on electrical equipment




Asbestos inventory, testing and classification and disposal records

Lead-based paint inventory, testing and classification and disposal records


prd-wret.s3-us-west-2.amazonaws.com€¦ · Web viewprd-wret.s3-us-west-2.amazonaws.com

Documents

Transcript of prd-wret.s3-us-west-2.amazonaws.com€¦ · Web viewprd-wret.s3-us-west-2.amazonaws.com