Industrial Inspections Making Good Inspections Better

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Industrial InspectionsMaking Good Inspections
Better

• David Long
• EPA Region 6

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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.
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What is the Golden Rule when performing an
industrial inspection? Follow the yellow brick
road Dont eat the yellow snow If you dont
document your inspection, did the inspection
really happen?
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A typical industrial inspection usually includes
the following sectionsSECTION 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
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SECTION A GENERAL FACILITY INFORMATIONTypical
information includesCompany nameFacility
addressCorporate addressName of ranking
officialNumber of employees
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SECTION A GENERAL FACILITY INFORMATIONTypical
information can also includeOther
environmental permitsMajor product or
serviceMain waste materials produced
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SECTION B RECORDS AND REPORTSTypical
information can include Self monitoring
recordsChain of Custody recordsSampling
locationsLaboratory procedures (40 CFR 136)
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SECTION C CHEMICALS AND STORAGETypical
information can include What chemicals are
handled at the siteHow and where are virgin
chemicals storedIs there a spill pollution
prevention plan
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SECTION D OPERATION AND MAINTENANCEIs the
process wastewater treated prior to being
discharged to the sanitary sewerIs it possible
to by-pass the waste treatment system Have any
bypasses occurredIs the treatment unit equipped
with an alarm Does the IU generate waste
sludgeHow and where is the sludge
stored/disposed
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SECTION E POLLUTION PREVENTIONDo any
processes recycle or reuse waterHas the IU
implemented any pollution prevention
activitiesHave employees been trained in
pollution prevention activities
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SECTION F COMPLIANCE SCHEDULESIs the IU under
a compliance scheduleHave design plans and
specifications been completedHas construction
been completed
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SECTION G WALK THROUGH INSPECTIONProcess
descriptionTreatment systemFloor
drainsVirgin chemical storage areasWaste
(oil, paint, solvent, etc.) generation and
storage areas
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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
INSPECTIONThese sections represent the bulk of
an industrial inspection or what my 10 year old
daughter calls the tinker toys of my job.
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So how do you make a good industrial
inspection better?You have to go back to the
beginning..
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The Industrial User SurveyHas the industrial
survey been kept updated? What procedure is
being used to update the industrial user
survey?Have all industrial users been properly
categorized?
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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?
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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.)
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What procedure is being used to update the
industrial user survey? (continued) Phone
Book Manufacturers Guides Scheduled
re-inspection every three years
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Have all industrial users been properly
categorized?What the industries tell you.What
your inspection shows you.Keeping up with the
literature
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When inspecting a new facility, try to remember
the followingBe 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
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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?

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Concluding Thoughts by DavidSeek and you shall
findSeek harder, and be refinedSeek not and
be fined
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David Long1445 Ross AvenueDallas, Texas
75212Long.David_at_epa.gov(214) 665-7323