compliance audit issues - all

Compliance Audit Issues

Berwyn

Air Quality

1. The organization must develop work instructions for the cold cleaner and post them at the cold cleaner. The cold cleaner must be operated with the top down except when parts are being handled. The cold cleaner top was not in place during this site visit. Employees must be aware of the requirement to keep tops down except when cold cleaners are in use.

2. The organization must contact District MDEQ to determine whether the Rule 290 exemption would be appropriate. The District MDEQ Air Quality personnel make the decision regarding appropriate exemptions. In this situation, the Rule 282 exemption for foundry pots does not apply, as the capacity is greater than 1,000 lbs per pot. The Rule 290 exemption is not often used in this situation, but it the District MDEQ may agree that it could be used in this situation. Only District MDEQ can make this decision.

Water Quality

1. The organization is required to have an SPCC, and does not have one at either facility.

2. The organization is required to have a PIPP, and does not have one at either facility.

Aboveground and Underground Storage Tanks

1. None identified at this time.

Solid Waste1. None identified at this time.

Hazardous Waste

1. Part 121 – The facility must ship liquid industrial waste following the manifest handling procedures defined for shipping hazardous waste. There were several manifests for waste shipped in 2001 and 2003 where the blue generator 2 copy was not available (6-04-01, 9-17-01, 11-30-01, 7-01-02, 7-12-02 [manifest 8348806], and It could not be determined whether the waste had been properly disposed. Furthermore, the organization is required to file an exception report when a completed manifest has not been received within 45 days of shipment. It could not be determined whether an exception report was warranted or if one was completed.

2. Part 121 – No generator-copies of the manifest was available for the shipments on 12-18-02.

3. Part 121 – The organization is required to send MDEQ the top copy of the manifest within the first 10 days of the month following shipment. The white copy for the shipment sent on 12-18-02 was not sent to MDEQ as of 1-22-03.

4. 40 CFR 273 – A program must be implemented to properly label waste florescent bulbs, High Intensity Discharge bulbs, lead acid batteries, and NiCd batteries as universal waste. Bulbs must be labeled as “Waste Lamps” or “Used Lamps” or “Universal Waste – Lamps.” Batteries must be labeled as “Waste Batteries” or “Used Batteries” or “Universal Waste – Batteries.”

PCB Compliance1. Continue the current practice.

Community Right-to-Know (SARA Title III)

1. The organization has not submitted Tier 2 reports, as required, before March 1 of each year.


Hoover

Air Quality1. Rule 336.1707 – The degreaser in the maintenance crib needs to have posted work instructions, including the

requirement that it be kept closed except when parts are being added, removed, or actively cleaned.

Water Quality1. The organization needs to redirect the compressor condensate from the storm water system to the sanitary

sewer system (provided that the manufacturer cannot support the contention that the treated water is clean enough to discharge). I have seen similar systems at other manufacturing facilities, and this water is normally discharged to the sanitary sewer for treatment.

2. The organization needs to establish and maintain a Spill Prevention, Control and Countermeasure plan to cover oil storage at the facility.

3. The organization needs to establish and maintain a Pollution Incident Prevention Plan (PIPP) to cover polluting material storage at the facility.

4. The organization needs to comply with the storm water permitting requirements, which includes developing a storm water pollution prevention plan, training a Certified Storm Water Operator, and submitting an application to MDEQ to obtain coverage under the Michigan General Permit.


1. None identified at this time.Solid Waste

1. None identified at this time.Hazardous Waste

1. Part 111 – The facility must ship hazardous waste following the manifest handling procedure defined for shipping hazardous waste. The organization must send MDEQ the top copy of the manifest by the 10th day of the month following shipment.

2. Part 111 – Warren is presently recycling the unbroken fluorescent light bulbs. The organization needs to continue recycling the unbroken fluorescent light bulbs, unless the manufacturer can guarantee that the bulbs do not test as hazardous waste due to mercury or lead content. Bulbs are presently labeled as “Bad Bulbs.” The bulbs need to be labeled as “Waste Lamps” or “Used Lamps” or “Universal Waste – Lamps.”

3. Part 111 – The broken bulbs are being thrown in the trash. Broken bulbs must be handled as hazardous waste.

4. Part 111 – The organization needs to develop a program to ensure that NiCd rechargeable batteries (such as Radio batteries, cell phone batteries and drill batteries) and lead acid batteries are recycled and are not disposed in the ordinary trash. Batteries must be labeled as “Waste Batteries” or “Used Batteries” or “Universal Waste – Batteries.”

5. Part 121 – The facility must ship liquid industrial waste following the manifest handling procedures defined for shipping hazardous waste. The top copy of the manifest must be sent to MDEQ before the 10th day of the month following the shipment.

6. Part 121 and Part 111 – The August 2002 manifest was not fully completed, as the Warren telephone number was not included on the manifest.

PCB Compliance1. None.

Community Right-to-Know (SARA Title III)1. The organization must submit the Tier 2 report before March 1, 2003.


Glendale

Air Quality1. None.

Water Quality1. None.


1. None identified at this time.Solid Waste

1. None identified at this time.Hazardous Waste

1. Part 111 – The facility must ship hazardous waste following the manifest handling procedure defined for shipping hazardous waste. It could not be determined whether the organization has been filing an exemption report in 2002 when a completed manifest has not been received within 60 days of shipment.

2. Part 111 – Weekly inspections need to be conducted of the waste being accumulated at CVC. Emergency contact information needs to be available for any emergencies involving hazardous waste. Consider incorporating the weekly inspections into the 5S inspections.

3. Part 111 – CVC will need to develop a program for managing fluorescent bulbs as universal waste.

4. Part 121 – The facility must ship liquid industrial waste following the manifest handling procedures defined for shipping hazardous waste. It could not be determined whether the organization has been filing an exemption report in 2002 when a completed manifest has not been received within 45 days of shipment.

PCB Compliance

1. None.Community Right-to-Know (SARA Title III)

1. None

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