Industrial Inspections Making Good Inspections Better David Long EPA 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 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 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

David Long 1445 Ross Avenue Dallas, Texas (214)