Environmental Compliance Services – COTA – Various Sites, Ohio
STONE performed site audits for three COTA transit terminals. The purpose of these audits was threefold:
• Perform a Gap Analysis identifying any potential environmental non-compliance concerns.
• Update the current Spill Prevention, Control & Countermeasure (SPCC) Plan, or verify that the an SPCC is not needed.
• Update the current Storm Water Pollution Prevention Plan (SWP3)
Pre-Audit Planning
STONE reviewed online sources to determine current permits, registrations, and reporting and reviewed existing permits and plans provided by the facility. This included air permits, hazardous waste status, registered underground storage tanks (USTs) and reported releases, storm water permit, registered water and monitoring wells, reported spills, City of Columbus GIS data, and satellite imagery.
On-Site Auditing Activities
STONE conducted an on-site audit of each facility, as escorted by knowledgeable COTA personnel and documented findings with photographs. Each visit began with a brief kick-off meeting to discuss any questions that came up during the document pre-audit planning, the purpose of the site visit, any facility rules or procedures to be aware of, and clarify expectations. Each facility was reviewed with respect to the design, construction, operation, or maintenance that materially affects the facility’s potential for an oil discharge and compliance with SPCC regulations of 40 CFR part 112. The audit included potential sources of stormwater contamination and best management practices (BMPs) to mitigate that potential. STONE reviewed the hazardous material and hazardous waste management and storage at each facility, as well as evaluated the need for air permits based on existing emission sources (such as paint booths).
On-site document review included inspection reports (stormwater and SPCC), spill and incident reports, training records, hazardous and non-hazardous waste manifests, and safety data sheets. The site audit concluded with a close-out meeting to discuss preliminary findings.
Updated SPCC Plan and SWP3 and Gap Analysis Report
STONE incorporated information obtained from the previous versions of the SPCC Plans, site visit, and interviews to prepare SPCC Plans to meet the regulatory requirements of 40 CFR 112, including certification by a licensed professional engineer. The SWP3 was updated to include the current site conditions and industrial general permit terms. The Gap Analysis Reports were prepared using leading industry standards and ISO 14010 – Guidelines for Environmental Auditing; in addition to the American Society for Testing and Materials (ASTM) E210700 standard, Standard Practice for Environmental Regulatory Compliance Audits for the environmental gap assessment. The reports documented environmental gap assessment findings in both an Excel table summary to allow for corrective action tracking, as well as a narrative format.