1
Procedures
for
Conducting
Compliance
Audit
Required
by
40
CFR
§
270.275(
f)
Standardized
Permit
Environmental
Compliance
Audit
1.
Section
270.275(
f)
requires
that
in
addition
to
other
information,
the
standardized
permit
applicant
must
submit
to
the
permitting
authority
an
audit
of
the
facility's
compliance
status
with
40
CFR
part
267.
This
guidance
provides
environmental
compliance
auditing
procedures
that
may
be
used
by
the
auditor
to
satisfy
the
requirements
of
§
270.275(
f).
When
conducting
this
audit,
the
auditor
may
follow
the
environmental
compliance
audit
procedures
set
forth
below.
The
auditor
may
also
wish
to
consult
the
Protocol
for
Conducting
Environmental
Compliance
Audits
of
Treatment,
Storage
and
Disposal
Facilities
under
the
Resource
Conservation
and
Recovery
Act,
EPA­
305­
B­
98­
006
(
December
1998).
You
will
find
that
protocol
at
the
following
web
address:
www.
epa.
gov/
compliance/
incentives/
auditing/
protocol.
html.

2.
As
required
by
§
270.280(
c)(
2),
the
scope
of
the
audit
shall
address
the
requirements
of
proposed
40
CFR
part
267,
Standards
for
Owners
and
Operators
of
Hazardous
Waste
Facilities
Operating
Under
a
Standardized
Permit,
that
apply
to
the
facility.
The
auditor
may
develop
a
sitespecific
audit
protocol
or
inspection
checklist
to
be
used
while
conducting
the
audit.

3.
As
required
by
§
270.280(
c)(
1),
the
auditor
shall
be
appropriately
trained
for
conducting
the
audit.
The
auditor
should
have
a
working
process
knowledge
of
the
facility
or
of
another
facility
with
similar
operations,
and
should
have
a
working
knowledge
of
the
proposed
40
CFR
part
267
requirements
that
apply
to
the
facility.

Standardized
Permit
Environmental
Compliance
Auditing
Procedures
Scope
of
Audit
As
required
by
§
270.280(
c)(
2),
the
scope
of
the
audit
shall
include
the
following
requirements
of
40
CFR
part
267,
Standards
for
Owners
and
Operators
of
Hazardous
Waste
Facilities
Operating
Under
a
Standardized
Permit,
as
applicable:

Subpart
A­
General
Subpart
B­
General
Facility
Standards
Subpart
C­
Preparedness
and
Prevention
Subpart
D­
Contingency
Plan
and
Emergency
Procedures
Subpart
E­
Recordkeeping,
Reporting,
and
Notifying
Subpart
F­
Releases
from
Solid
Waste
Management
Units
Subpart
G­
Closure
Subpart
H­
Financial
Requirements
Subpart
I­
Use
and
Management
of
Containers
Subpart
J­
Tank
Systems
Subpart
DD­
Containment
Buildings
2
Audit
Scheduling
The
auditor
may
schedule
the
audit
by
contacting
the
facility's
environmental
manager
to
determine
the
optimal
date(
s)
for
the
audit.
The
auditor
may
then
follow
up
with
a
letter
to
the
facility's
environmental
manager
(
with
a
copy
to
the
permitting
authority)
confirming
the
audit
date(
s)
and
describing
the
audit
agenda,
scope,
and
plan.

Pre­
Audit
Preparation
1.
This
guidance
recommends
that
the
facility's
environmental
manager
provide
the
auditor
with
environmental
information
about
the
facility,
including
a
description
of
the
primary
function
of
the
facility
and
each
of
the
facility's
manufacturing
processes;
an
organization
chart;
facility
map;
process
flow
diagrams;
identification
of
all
waste
streams,
sources
of
emissions,
and
emissions
points;
and
copies
of
all
applicable
environmental
permits.

2.
It
is
also
recommended
that
the
facility's
environmental
manager
identify
any
and
all
sitespecific
training
requirements
that
may
be
necessary
to
ensure
that
the
auditor
can
effectively
and
safely
conduct
the
required
audit.

3.
The
facility's
environmental
manager
may
discuss
the
facility­
specific
audit
plan
with
the
auditor
and
give
guidance
and
support
as
needed;
provide
access
to
the
facility's
environmental
files;
provide
the
auditor
with
his/
her
own
work
space;
make
appropriate
facility
personnel
available
for
interviews
during
the
audit;
and
plan
to
operate
the
facility
under
normal
conditions
during
the
audit.

4.
The
auditor
should
review
all
available
information
on
the
facility,
confirm
the
applicable
environmental
requirements,
and
develop
a
facility­
specific
audit
plan
based
on
the
information
received
from
the
facility's
environmental
manager.
A
comprehensive
audit
plan
would
probably
include
the
applicable
environmental
requirements
at
the
facility;
the
scope
and
schedule
of
the
audit;
and
a
detailed,
site­
specific
audit
protocol
or
inspection
checklist.
The
auditor
may
provide
the
facility
with
a
copy
of
the
plan
approximately
thirty
(
30)
days
prior
to
the
scheduled
audit.

5.
The
auditor
should
make
any
other
pre­
audit
preparations
s/
he
deems
necessary,
such
as
confirming
arrangements
with
the
facility's
environmental
manager
for
the
opening
meeting;
making
arrangements
for
safety
briefings
and
security
clearances;
and
preparing
a
list
of
required
safety
equipment.

Specific
Provisions
for
Conducting
the
Audit
1.
An
opening
meeting
chaired
by
the
auditor
and
attended
by
the
facility's
environmental
manager
and
other
appropriate
personnel
may
be
held
to
begin
the
audit.
At
that
meeting,
the
facility's
environmental
manager
may
provide
the
auditor
with
an
overview
of
operations
and
environmental
issues.
The
auditor
may
outline
the
audit
process,
addressing
the
objectives
and
3
scope
of
the
audit;
audit
agenda;
arrangements
for
staff
interviews
(
as
necessary);
document
control;
and
arrangements
for
the
closing
meeting.

3.
After
the
opening
meeting,
the
auditor
may
confirm
arrangements
for
safety
equipment,
any
additional
safety
training
(
if
necessary),
and
work
space.

4.
This
guidance
recommends
that
the
facility's
environmental
manager
provide
the
auditor
with
a
site
plot
plan
and
an
initial
tour
of
the
facility.
If
the
facility
is
spread
out,
the
initial
tour
may
serve
as
the
main
inspection.

5.
In
conducting
the
audit,
the
auditor
should
take
all
necessary
action
to
determine
the
facility's
compliance
with
40
CFR
part
267.
Such
actions
may
include
examining
records;
interviewing
employees;
taking
samples;
examining
control
equipment;
observing
the
operation
of
the
facility;
identifying
all
historical
and
existing
waste
streams,
sources
of
emissions,
and
emission
points;
and
revisiting
areas
of
the
facility,
as
necessary.
It
is
recommended
that
the
auditor
keep
good
notes
on
what
is
discovered,
source(
s)
of
information,
and
sampling
strategies
used
in
conducting
the
audit.

6.
If
at
any
time
during
the
audit
the
auditor
identifies
an
imminent
threat
to
health
or
the
environment
at
the
facility,
s/
he
shall
immediately
notify
the
owner
or
operator
of
the
facility
and
provide
all
available
information
on
the
nature
of
the
threat.
As
required
by
§
270.30(
l)(
6),
the
facility
shall
notify
the
permitting
authority
within
twenty­
four
(
24)
hours
of
becoming
aware
of
any
such
noncompliance
which
may
endanger
health
or
the
environment.

7.
In
preparation
for
the
closing
meeting,
the
auditor
may
prepare
written
Audit
Findings.
Each
Audit
Finding
should
be
factually
accurate
and
adequately
supported
by
evidence.
If
when
reviewing
the
Audit
Findings
the
auditor
determines
that
multiple
findings
relate
to
a
basic
problem,
such
findings
may
be
grouped
into
one
finding
that
identifies
the
more
common
underlying
problem.

8.
At
the
end
of
the
audit,
the
auditor
may
meet
with
the
facility's
environmental
manager
and
other
appropriate
personnel
to
share
his/
her
findings
and
observations.
The
purpose
of
this
meeting
should
be
to
give
the
facility
an
opportunity
to
hear
the
Audit
Findings
and
to
clarify
any
facts
concerning
them.

9.
If
the
auditor
determines
that
additional
information
is
needed
from
the
facility
or
other
sources
in
order
to
prepare
the
Audit
Report,
s/
he
should
request
such
information.
The
facility
should
make
all
reasonable
efforts
to
assist
the
auditor
in
obtaining
the
additional
information.

10.
As
required
by
§
270.280(
c)(
3),
the
auditor
shall
issue
a
written
Audit
Report.
The
Audit
Report
should
document
all
instances
of
compliance,
as
well
as
noncompliance,
with
the
applicable
requirements
of
40
CFR
part
267.
The
Audit
Report
shall
be
signed
and
certified
by
the
auditor
as
accurate.
