Environmental Regulatory Compliance Self-Assessment
for Small and Mid-Sized Industrial Facilities
The following questions and suggestions are self-explanatory. They are categorized so as
to address your facility's historical background, current operation, air emissions, liquid effluents,
storage tanks, solid waste generation, and management of hazardous waste. Upon completion,
you will develop insight as to where your facility stands with regard to environmental
compliance. This document is not meant to be utilized in place of the regulations
themselves or a consultant, rather its use will probably be most effective in supplementing
them. Before getting started, you may wish to click
for a brief refresher on national
Developing an Understanding of Your Site's History and Current Processes
- Make note of your site's history prior to the establishment of your operations.
- Describe previous operations' use of chemicals, pesticides, hazardous substances, or oil.
- Try to develop an understanding of the local geology and hydrology.
- Understand the surrounding land use (e.g., urban, suburban, industrial, commercial, etc.).
- Know the size and location of the nearest upwind and downwind residential communities.
- Develop a complete process schematic for your current operation. Update it as required.
- Such information is valuable, especially in the development of the environmental site assessments which should be conducted prior to the sale of potentially contaminated industrial property.
- Which regulatory agencies inspect the plant for air emissions and with what frequency? Make sure to keep records of all correspondence with such agencies.
- Identify all emission sources. Develop a separate process schematic identifying such sources and update it as needed. Keep a file of emissions inventories.
- Indicate the number of boilers, furnaces, and incinerators on-site and their rating. Check applicable regulations to find out if they require a permit. Local (e.g., county and regional) and state regulations may differ, check both.
- Keep a file on all local, State, and Federal air quality regulations applicable to your facility.
- Know which emission sources require permits or registrations. Are all of your regulated sources permitted?
- Maintain a file with all of your permits in order. In addition, the regulations may require that you keep a running record of the raw materials utilized in a particular operation. For example, with surface coating operations, the NJ Department of Environmental Protection (NJDEP) requires that a log be maintained which includes the quantity of paint used and its VOC content. Always be prepared, this way you don't get caught with your pants down when an inspector makes an unannounced visit and when it comes time to renew permits.
- Confirm and detail compliance with permit requirements. For example, opacity, particulates, modifications, maintenance, etc.
- Is your facility required to install continuous monitoring equipment on any of its sources? If yes, make a list of such sources and equipment.
- If required, maintain records that include all air emission measurements.
- Document maintenance procedures and activities for all air pollution control and monitoring devices. Are these activites being conducted in accordance with the manufacturer's recommendations?
- Is reclaimed oil, wood, paper or plastic burned in boilers, furnaces or incinerators? Does the facility have a permit to conduct such actvities? Is testing conducted to evaluate harmful components prior to incineration?
- Describe any fugitive emissions observed at the facility. List sources and any control measures currently in place.
- Develop a separate process schematic of the wastewater collection and treatment sytem(s). Include all contributing plant operations, floor drains, and sinks.
- List the type and description of wastewater discharges (BOD, COD, SS, pH, daily volume, etc.). Understand the local POTW's effluent guidelines.
- Maintain a file for required permits and correspondence with the local POTW.
- Are the permit parameters being monitored as prescribed in the permit? Are recordes kept? Are tests carried out by an independent laboratory? Are the samples representatve of the plant's discharge?
- Are there surface water flows onto the property that could influence the quality of the facility's discharge?
- Which facility processes routinely discharge to floor drains? Upon accidental releases, which processes have the potential to discharge into the floor drains? Is the wastewater treatment system adequate to handle such accidents?
Above Ground Storage Tanks (AST's)
- Are copies of all applicable local, state, and federal regulations regarding AST's kept on site?
- Is there a detailed schematic available on site that indictates the locations, instrumentation, and piping layouts for all AST's on site?
- What is the size, material of costruction, age, and content of each AST? Does the facility maintain such an inventory and is it updated periodically?
- Are materials stored in the tanks compatible with the material of construction of the tanks?
- Do tanks have air emission permits where required?
- Do all AST's have adequate:
- containment (Impervious, adequate volume, dikes)?
- corrosion protection?
- level indicators?
- high level alarms?
- concrete pads?
- Are AST's and associated piping visually inspected on a periodic basis? Have integrity tests been performed? Are records kept?
- Are all tanks in commonly contained (diked) areas compatible?
- Are valves that permit direct outward flow of the tank's contents locked?
- Is the facility in compliance with applicable spill prevention regulations?
Underground Storage Tanks (UST's)
- Are copies of all applicable local, State, and Federal regulations regarding UST's kept on site?
- Is there a detailed schematic available on site that indictates the locations, instrumentation, and piping layouts for all UST's on site?
- What is the size, material of construction, age, and content of each underground tank? Does the facility maintain an inventory and update it periodically?
- Do all UST's have:
- cathodic protection or are constructed of non-corrosive material?
- piping that is cathodically protected or constructed of non-corrosive material?
- spill prevention equipment?
- secondary containment at the fill point?
- a leak detection system?
- guaging or inventory controls?
- Have they been upgraded by installing:
- an internal lining?
- cathodic protection?
- spill and overflow equipment?
- Have any UST's been closed on site? If so, are there records?
- Are records maintained dealing with tank integrity, tightness, testing, maintenance, and repair?
Solid Waste Management
- Identify solid waste streams, quantities, and disposal methods.
Hazardous Waste Management
- Are copies of all applicable local, State, and Federal hazardous waste regulations available on site?
- Have all sources been identified?
- Are all regulatory requirements with regard to accumulation being met?
- Is the manifesting being done in accord with the applicable regulations?
- Are personnel properly trained in relevant aspects of solid and hazardous waste management?
- Is the facility and its personnel prepared to deal with on-site emergencies involving hazardous waste and the release of hazardous substances?
- Are local, State, and Federal authorities prepared to respond to your facility in the case of such emergencies?
For more detailed regulatory information in the State of New Jersey, either look into the New Jersey Administrative Codes at your local library or modem into the New Jersey Department of Environmental Protection's BBS at (609)-292-2006. The BBS is a DOS-based, menu-driven service which provides electronic access to a variety of NJDEP documents including regulations. Regulations are conveniently "downloadable" as files which are divided into program specific categories such as Air Quality and Hazardous Waste.
In addition, for federal regulatory information, you may wish
to visit the US EPA's
web site. The US EPA's web site facilitates electronic access to
the Federal Register and Code of Federal Regulations. Just click on "Regulations" at the
EPA's home page.