Notification by ACvqJL

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									                         Audit Protocol Number: CAP441                                                                                                                                                                                                                                                                                                                 November 2007
                         Revision Number: 4                                                                                                                                                                                                                        Audit Protocol Questions / Checklist

                                                                                            Country




                                                                                                               Venezuela




                                                                                                                                      Province
                                                                                             Canada
                                                                                                      Mexico
                                                                                                                                                   Citation                        Media     Subcategory   Type of Req.                                                                                     Evidence




                                                                                                                                       State /
                                                                     SEB No. &                                              Agency                                  Related                                                                     Requirement Description




                                                                                     U.S.
 Number              Audit Protocol Question / Checklist                                                                                         (sets ECAR                      (In ECAR     (In ECAR      (In ECAR                                                                                  (Documents for auditor to                Comments
                                                                      Section                                              Category                               Requirements                                                            (either SEB or federal/state citation)
                                                                                                                                                   Priority)                     Database)    Database)     Database)                                                                                         verify)



                                                                                                                                                                                                                                                                                                                                     Chrysler facilities most likely
                                                                                                                                                                                                                                                                                                                                         to be subject to NSPS
                                                                                                                                                                                                                                                                                                                                          requirements include
                                                                                                                                                                                                                                                                                                                                      surface coating operations
                                                                                                                                                                                                                                                                                                                                       at assembly plants built or
                                                                                                                                                                                                                                                                                                                                     modified after October 1979,
                                                                                                                                                                                                                                                                                                                                       boilers and water heaters
                                                                                                                                                                                                                                                                                                                                      built or modified after June
                                                                                                                                                                                                                                                                                                                                        9, 1989, combustion gas
                                                                                                                                                                                                                                                                                                                                     turbines with a heat input of
               For U.S. facilities, has the facility constructed,                                                                                                                                                                                                                                  Interview facility staff, inspect
                                                                                                                                                                                                                                                                                                                                     at least 10 MMBtu/hr built or
               modified, or reconstructed any emission units                                                                                                                                                                   For sources constructed/modified/reconstructed since the last              facility and review
                                                                                                                                                                                                                                                                                                                                        modified after October 3,
             covered by NSPS (boilers, water heaters, vehicle                                                                                                                                                              compliance audit and for sources whose NSPS status is uncertain,           construction activities to
                                                                                                                                                                                                                                                                                                                                       1977, and organic storage
            coating operations, tanks containing organics, gas                                                                                                                                                            compare a list of the types of air emissions sources within the facility      identify any changes
                                                                                                                                                 EPA 40 CFR                                                                                                                                                                             tanks larger than 19,813
CAP441-US- turbines, or compression ignition interal combustion      SEB441                                                                                                                                  Record        and the dates for which actual construction commenced against the           (planned, underway or
                                                                                  X                                        Federal               Part 60.1(a) &                     Air        NSPS                                                                                                                                  gallons in capacity that were
   001        engines (emergency generators or fire pumps))       Section 5.2.1.2                                                                                                                            Keeping       list of NSPS source categories (for Chrysler, boilers, water heaters,     completed) since the last
                                                                                                                                                       (b)                                                                                                                                                                             built or modified after July
            since the last audit? If yes, is there a documented                                                                                                                                                            vehicle coating operations, tanks containing organics, gas turbines).        audit. Review facility
                                                                                                                                                                                                                                                                                                                                        23, 1984. Each category
             assessment of NSPS applicability? Is it correct?                                                                                                                                                             Document the assessment of NSPS applicability and send it to SE&E environmental files to locate
                                                                                                                                                                                                                                                                                                                                             may have certain
            Was a copy of this assessment sent to SE&E, Sr.                                                                                                                                                                                          for concurrence.                               relevant NSPS applicability
                                                                                                                                                                                                                                                                                                                                         exclusions. Note that a
            Specialist, Air Compliance and did SE&E concur?                                                                                                                                                                                                                                                 assessments.
                                                                                                                                                                                                                                                                                                                                      modification triggers NSPS
                                                                                                                                                                                                                                                                                                                                      if peak emissions increase
                                                                                                                                                                                                                                                                                                                                      or the investment is greater
                                                                                                                                                                                                                                                                                                                                              than 50% of the
                                                                                                                                                                                                                                                                                                                                     replacement cost of the unit.
                                                                                                                                                                                                                                                                                                                                      The auditor should look for
                                                                                                                                                                                                                                                                                                                                     documentation in the facility
                                                                                                                                                                                                                                                                                                                                            records of SE&E’s
                                                                                                                                                                                                                                                                                                                                          concurrence with the
                                                                                                                                                                                                                                                                                                                                      applicability determination.

                For sources recently installed or modified that
               trigger NSPS, is there a record of the following                                                                                                                                                            For sources recently installed or modified that trigger NSPS, submit
               notifications being submitted to the appropriate                                                                                                                                                           notifications and reports directly to the appropriate state/local agency
                   state/federal agencies: Within 30 days of                                                                                                                                                                       as follows: Notification within 30 days of the date that
           commencement of construction? Within 15 days of                                                                                                                                                                 construction/reconstruction of the affected facility has commenced.       Review facility environmental
                                                                                                                                                                                                                                                                                                                                    Since EPA has delegated
           initial startup? At least 60 days prior to any physical                                                                                                                                                          Notification within 15 days of the actual date of initial startup of an      files to locate relevant
                                                                       SEB441                                                                                                                                                                                                                                                        NSPS authority to most
           or operational change to an existing facility that may                                                                                EPA 40 CFR                                                                affected facility. Notification at lest 60 days prior to any physical or    notification documents for
CAP441-US-                                                             Sections                                                                                                                              Record                                                                                                                 states, the facility should
              increase the emission rate of any air pollutant to                     X                                     Federal                60.7(a)(1)-                       Air        NSPS                          operational change to an existing facility that may increase the       affected projects. Cross-check
   002                                                               5.2.1.7.1 and                                                                                                                           Keeping                                                                                                                have notified the state. If
                 which a standard applies, unless specifically                                                                                      (a)(7)                                                                emission rate of any air pollutant to which a standard applies, unless         notification dates with
                                                                       5.2.1.7.2                                                                                                                                                                                                                                                   they have notified Regional
                      exempted? At least 60 days prior to                                                                                                                                                                       specifically exempted. Notification at least 60 days prior to         regulatory requirements for
                                                                                                                                                                                                                                                                                                                                      EPA also, that is fine.
              commencement of reconstruction of an affected                                                                                                                                                               commencement of reconstruction of an affected source. Notification                   consistency.
                source? Within 30 days of commencement of                                                                                                                                                                  within 30 days of commencement of continuous monitoring system
               continuous monitoring system performance? At                                                                                                                                                                  performance. Notification at least 30 days prior to any required
                  least 30 days prior to any required opacity                                                                                                                                                                                       opacity demonstration.
                                demonstration?
           For each applicable NSPS, were initial performance
             tests required? If so, is there documentation that                                                                                                                                                           Required performance tests to demonstrate compliance with NSPS               Review performance test
             they were completed within 60 days of achieving                                                                                                                                                              must be completed within 60 days of achieving maximum production             records for each affected       Initial performance tests are
                                                                       SEB441
CAP441-US-     max production but within 180 days of startup?                                                                                    EPA 40 CFR                                                                 rate (but no later than 180 days after startup). Notification, test        project. Cross-check test           required for the boiler,
                                                                       Section       X                                     Federal                                                  Air        NSPS         Reporting
   003     Were the NSPS-specified methods followed? Were                                                                                           60.8                                                                     conditions and methods, and submittal of a report must be in               records with applicable         turbine and vehicle coating
                                                                       5.2.1.10
                the appropriate state/federal agencies notified                                                                                                                                                             accordance with NSPS general requirements and any specific                regulatory requirements for             NSPS categories.
           within the specified time period prior to any required                                                                                                                                                            requirements in the subpart applicable to the affected facility.                consistency.
                                     test?
                                                                                                                                                                                                                                                                                                    Interview facility staff. Review
                                                                                                                                                                                                                                                                                                    facility project files and NSPS
                                                                                                                                                                                                                                                                                                    applicability determinations to
                                                                                                                                                                                                                                                                                                          identify any qualifying
                                                                                                                                                                                                                                                                                                      changes and their dates of
                                                                                                                                                                                                                                                                                                      construction/reconstruction
              Is there documentation that for any changes
                                                                       SEB441                                                                                                                                               An affected facility that has become subject to a NSPS due to a          and implementation. Cross-
CAP441-US- qualifying as a modification under NSPS, the facility                                                                                 EPA 40 CFR                                                  Record
                                                                       Section       X                                     Federal                                                  Air        NSPS                        "modification" must be in compliance with the applicable standard            check operating records,
   004       was in compliance with the applicable standard                                                                                        60.14(g)                                                  Keeping
                                                                       5.2.1.11                                                                                                                                                     within 180 days of the completion of the change.                  emissions calculations and
              within 180 days of completion of the change?
                                                                                                                                                                                                                                                                                                            additional relevant
                                                                                                                                                                                                                                                                                                       environmental records as
                                                                                                                                                                                                                                                                                                       necessary with applicable
                                                                                                                                                                                                                                                                                                         NSPS requirements for
                                                                                                                                                                                                                                                                                                     consistency, and to confirm
                                                                                                                                                                                                                                                                                                           dates of compliance.

                                                                                                                                                                                                                                                                                                        Review facility emission
                                                                                                                                                                                                                                                                                                         calculations (typically
                                                                                                                                                                                                                                                                                                       available in PO reports) to
                                                                                                                                                                                                                                                                                                     confirm that the calculations
             For NSPS-covered vehicle coating lines, is there                                                                                                                                                              The facility must keep adequate records for reporting the volume
                                                                                                                                                                                                                                                                                                      were completed consistent
CAP441-US-    documentation that the NSPS VOC emissions            SEB441                                                                        EPA 40 CFR                                                 Emission      weighted average mass of VOC per volume of applied coating solids                                          Documentation generally
                                                                                X                                          Federal                                                  Air        NSPS                                                                                                  with permit requirements and
   005     limits on primecoat (E-coat), guidecoat, and topcoat Section 5.2.5.2                                                                   60.395(c)                                                  Limit            for each affected facility (primecoat, guidecoat and topcoat                                          provided in PO VOC report.
                                                                                                                                                                                                                                                                                                    the EPA Topcoat Protocol (for
                           operations are met?                                                                                                                                                                                                          operations).
                                                                                                                                                                                                                                                                                                     plants covered by the vehicle
                                                                                                                                                                                                                                                                                                      surface coating NSPS), and
                                                                                                                                                                                                                                                                                                    that applicable emission limits
                                                                                                                                                                                                                                                                                                             have been met.

                                                                                                                                                                                                                                                                                                                                     For assembly plants, this
                                                                                                                                                                                                                                                                                                                                   includes any periods when
                                                                                                                                                                                                                                                                                                                                   the VOC limits established
                                                                                                                                                                                                                                                                                                                                   in the automobile and light
                                                                                                                                                                                                                                                                                                                                    duty truck surface coating
                                                                                                                                                                                                                                                                                                      Review facility operating
                                                                                                                                                                                                                                                                                                                                    NSPS are exceeded. Note
                                                                                                                                                                                                                                                                                                        records and emission
                                                                                                                                                                                                                                                                                                                                  that these limits typically are
                                                                                                                                                                                                                                                                                                    calculations (typically in PO
                                                                                                                                                                                                                            Facilities with gas turbines covered by NSPS must submit excess                                             cross-referenced in a
                                                                                                                                                                                                                                                                                                   reports for assembly plants).
                                                                                                                                                                                                                             emissions reports for NOx and SO2, including reports for periods                                         facility’s permit. Excess
                                                                                                                                                                                                                                                                                                     Identify periods of excess
                                                                                                                                                                                                                           when exemptions to the standards are in effect, to the appropriate                                            emission reports for
                                                                                                                                                                                                                                                                                                   emissions. Cross-check with
                                                                       SEB441                                                                                                                                              agency. Facilities with auto and light duty coating lines covered by                                    assembly plants should be
                                                                                                                                                                                                                                                                                                    emissions reports that have
           For any units that are covered by the vehicle surface       Sections                                                                  EPA 40 CFR                                                                   NSPS must submit to the appropriate agency excess emissions                                          submitted every quarter. If
CAP441-US-                                                                                                                                                                                                                                                                                             been submitted to the
           coating NSPS or the gas turbine NSPS, are periods           5.2.4.3.3,    X                                     Federal               60.334(c) and                      Air        NSPS         Reporting      reports for each instance in which the volume weighted average of                                           no instances of excess
   006                                                                                                                                                                                                                                                                                              regulatory agency. Confirm
               of excess emissions recorded and reported?            5.2.5.4.1 and                                                                 60.395(b)                                                                 the total mass of VOCs emitted to the atmosphere per volume of                                        emissions have occurred, a
                                                                                                                                                                                                                                                                                                       that periods of excess
                                                                       5.2.5.4.2                                                                                                                                          applied coating solids is greater than the limit specified by the NSPS.                                   report to that effect should
                                                                                                                                                                                                                                                                                                        emissions have been
                                                                                                                                                                                                                            If no such instances have occurred during a particular quarter, the                                         be submitted every six
                                                                                                                                                                                                                                                                                                  reported. For assembly plants,
                                                                                                                                                                                                                            facility must submit a report stating this to the appropriate agency                                    months. For gas turbines,
                                                                                                                                                                                                                                                                                                      if no such periods have
                                                                                                                                                                                                                                                       semiannually.                                                                 this includes any periods
                                                                                                                                                                                                                                                                                                  occurred, confirm that a report
                                                                                                                                                                                                                                                                                                                                  when fuel is combusted that
                                                                                                                                                                                                                                                                                                       to that effect has been
                                                                                                                                                                                                                                                                                                                                       exceeds the nitrogen or
                                                                                                                                                                                                                                                                                                             submitted.
                                                                                                                                                                                                                                                                                                                                    sulfur limits established in
                                                                                                                                                                                                                                                                                                                                       the gas turbine NSPS.
                                                                                                                                                                                                                                                                                                                                   Excess emission reports for
                                                                                                                                                                                                                                                                                                                                       gas turbines should be
                                                                                                                                                                                                                                                                                                                                  submitted every six months.

                                                                                                                                                                                                                                                                                                                                  Monitoring device calibration
                                                                                                                                                                                                                                                                                                                                           includes both the
                                                                                                                                                                                                                                                                                                                                       thermocouple and the
                                                                                                                                                                                                                                                                                                                                        recording device. For
                                                                                                                                                                                                                                                                                                                                     thermal incinerators, this
                                                                                                                                                                                                                                                                                                                                      calibration requirement
                                                                                                                                                                                                                                                                                                                                  applies to the thermocouple
                                                                                                                                                                                                                                                                                                                                       used to determine the
                                                                                                                                                                                                                                                                                                                                         official compliance
                                                                                                                                                                                                                                                                                                                                          temperature in the
                                                                                                                                                                                                                                                                                                                                  incinerator’s firing chamber.
                                                                                                                                                                                                                                                                                                     Review facility maintenance     For catalytic incinerators,
                                                                                                                                                                                                                             Install, calibrate, and maintain each temperature measurement             and calibration records.    this calibration requirement
            For assembly plants, are records maintained of             SEB441
CAP441-US-                                                                                                                                       EPA 40 CFR                                                Preventative       device according to accepted practice and the manufacturer's           Confirm that calibration has            applies to the
           oxidizer temperature monitoring device calibration           Section      X                                     Federal                                                  Air        NSPS
   007                                                                                                                                            60.394(b)                                                Maintenance     specifications. It is company policy that compliance will mean that         been performed at least        thermocouples used to
                   checks/adjustments/maintenance?                     5.2.5.4.3
                                                                                                                                                                                                                                           calibration must occur at least annually.                annually on the thermocouple        determine the official
                                                                                                                                                                                                                                                                                                      and the recording device.      compliance temperatures
                                                                                                                                                                                                                                                                                                                                  before and after the catalyst
                                                                                                                                                                                                                                                                                                                                  bed. Calibration must occur
                                                                                                                                                                                                                                                                                                                                    at least annually according
                                                                                                                                                                                                                                                                                                                                  to accepted practice and the
                                                                                                                                                                                                                                                                                                                                            manufacturer’s
                                                                                                                                                                                                                                                                                                                                       specifications. Some
                                                                                                                                                                                                                                                                                                                                  facilities may find it easier to
                                                                                                                                                                                                                                                                                                                                   replace thermocouples with
                                                                                                                                                                                                                                                                                                                                       new factory-calibrated
                                                                                                                                                                                                                                                                                                                                   thermocouples to meet this
                                                                                                                                                                                                                                                                                                                                             requirement.




                         SEB441
                                                                                                                                                                                                                                                                                                     1 of 23
                         Audit Protocol Questions
                         Audit Protocol Number: CAP441                                                                                                                                                                                                                                                                                                                    November 2007
                         Revision Number: 4                                                                                                                                                                                                                        Audit Protocol Questions / Checklist

                                                                                            Country




                                                                                                               Venezuela




                                                                                                                                      Province
                                                                                             Canada
                                                                                                      Mexico
                                                                                                                                                    Citation                       Media     Subcategory   Type of Req.                                                                                     Evidence




                                                                                                                                       State /
                                                                      SEB No. &                                             Agency                                  Related                                                                     Requirement Description




                                                                                     U.S.
 Number              Audit Protocol Question / Checklist                                                                                          (sets ECAR                     (In ECAR     (In ECAR      (In ECAR                                                                                  (Documents for auditor to                   Comments
                                                                       Section                                             Category                               Requirements                                                            (either SEB or federal/state citation)
                                                                                                                                                    Priority)                    Database)    Database)     Database)                                                                                         verify)


                                                                                                                                                                                                                                                                                                            Review incinerator
            For assembly plants that achieve compliance with                                                                                                                                                                                                                                             temperature charts and
                NSPS VOC emission limits through thermal                                                                                                                                                                                                                                                 documentation for most
                                                                                                                                                                                                                              For assembly plants that achieve compliance with NSPS VOC                 recent performance test.      Reports of incinerator
              incineration, is there a continuous record of the
                                                                                                                                                                                                                          emission limits through thermal incineration, a continuous record of         Cross-check temperature    temperature deviations must
           incinerator combustion temperature during coating
                                                                                                                                                                                                                            the incinerator combustion temperature during coating operations              charts with applicable     be submitted every six
           operations? Is every three-hour period during which         SEB441
CAP441-US-                                                                                                                                       EPA 40 CFR                                                               must be maintained. Also, every three-hour period during which the          compliance temperature, as    months. If no incinerator
            the average temperature is more than 28 oC below            Section      X                                     Federal                                                  Air        NSPS         Reporting
   008                                                                                                                                            60.395(c)                                                                     average temperature is more than 28oC below the average              determined from performance temperature deviations have
             the average temperature during the most recent            5.2.5.4.2
                                                                                                                                                                                                                           temperature during the most recent performance test (at which the               test. Review agency      occurred, a report to that
                 performance test (at which the destruction
                                                                                                                                                                                                                               destruction efficiency was determined) must be recorded and            submittals and confirm that  effect should be submitted
            efficiency was determined) recorded and reported
                                                                                                                                                                                                                              reported to the appropriate state/local/EPA Regional agencies.                any qualifying low-         every six months.
                to the appropriate state/local/EPA Regional
                                                                                                                                                                                                                                                                                                      temperature periods during
                                  agencies?
                                                                                                                                                                                                                                                                                                          production have been
                                                                                                                                                                                                                                                                                                                 reported.
            For assembly plants that achieve compliance with
               NSPS VOC emission limits through catalytic
          incineration, is there a continuous record of the gas                                                                                                                                                           Assembly plants that achieve compliance with NSPS VOC emission
                                                                                                                                                                                                                                                                                                      Review incinerator
              temperature upstream and downstream of the                                                                                                                                                                      limits through catalytic incineration must maintain a continuous
                                                                                                                                                                                                                                                                                                   temperature charts and
             catalyst bed during coating operations? Is every                                                                                                                                                                 record of the gas temperature upstream and downstream of the
                                                                                                                                                                                                                                                                                                   documentation for most
               three-hour period recorded during which the                                                                                                                                                                     catalyst bed during coating operations. Every three-hour period
                                                                                                                                                                                                                                                                                                  recent performance test.      Reports of incinerator
               average temperature immediately before the                                                                                                                                                                  recorded during which the average temperature immediately before
                                                                                                                                                                                                                                                                                                 Cross-check temperature    temperature deviations must
            catalyst bed is more than 28oC below the average                                                                                                                                                                the catalyst bed is more than 28oC below the average temperature
                                                                                                                                                                                                                                                                                                    charts with applicable     be submitted every six
                                                                       SEB441                                                                                                                                                during the most recent performance test (at which the destruction
CAP441-US- temperature during the most recent performance                                                                                        EPA 40 CFR                                                                                                                                     compliance temperature, as    months. If no incinerator
               test (at which the destruction efficiency was            Section      X                                     Federal                                                  Air        NSPS         Reporting        efficiency was determined) must be recorded and reported to the
   009                                                                                                                                            60.395(c)                                                                                                                                    determined from performance temperature deviations have
           determined) recorded and reported? Is every three-          5.2.5.4.2                                                                                                                                             appropriate state/local/EPA Regional agencies. Every three-hour
                                                                                                                                                                                                                                                                                                     test. Review agency      occurred, a report to that
            hour period during which the average temperature                                                                                                                                                                period during which the average temperature difference across the
                                                                                                                                                                                                                                                                                                submittals and confirm that  effect should be submitted
          difference across the catalyst bed when the coating                                                                                                                                                             catalyst bed when the coating system is operational is less than 80%
                                                                                                                                                                                                                                                                                                      any qualifying low-         every six months.
               system is operational is less than 80% of the                                                                                                                                                               of the average temperature difference of the device during the most
                                                                                                                                                                                                                                                                                                temperature periods during
          average temperature difference of the device during                                                                                                                                                                   recent control device performance test (at which destruction
                                                                                                                                                                                                                                                                                                    production have been
           the most recent control device performance test (at                                                                                                                                                               efficiency was determined) must be recorded and reported to the
                                                                                                                                                                                                                                                                                                           reported.
               which destruction efficiency was determined)                                                                                                                                                                            appropriate state/local/EPA Regional agencies.
                 recorded and reported to the appropriate
                   state/local/EPA Regional agencies?
                                                                                                                                                                                                                                                                                                                                      For units covered by the
                                                                                                                                                                                                                                                                                                                                      boiler NSPS, any fuel oil
                                                                                                                                                                                                                                                                                                                                      combusted must comply
                                                                                                                                                                                                                                                                                                                                     with the 0.5% wt fuel sulfur
                                                                                                                                                                                                                                                                                                                                       content limit. Note that
                                                                                                                                                                                                                                                                                                                                     compliance with the sulfur
                                                                                                                                                                                                                                                                                                                                      content limit is normally
                                                                                                                                                                                                                                                                                                                                          based on supplier
           For sites that are covered by the gas turbine NSPS                                                                                                                                                                                                                                          Review facility operating        certifications for each
                                                                       SEB441                                                                    EPA 40 CFR
            or that are covered by the boiler NSPS and which                                                                                                                                                                Facilities with boilers covered by NSPS that burn oil must comply       records, material use logs and     shipment that certify in
CAP441-US-                                                             Sections                                                                    60.42c(d),                                                Record
           burn any oil, even as back-up, are there records of                       X                                     Federal                                                  Air        NSPS                       with fuel sulfur content and opacity limits. Facilities with gas turbines fuel supplier certifications to writing that the oil complies
   010                                                               5.2.2.5.2 and                                                                 60.332(a),                                                Keeping
           compliance with the applicable fuel nitrogen and/or                                                                                                                                                            covered by NSPS that burn oil must comply with NOx and SO2 limits.           confirm compliance with        with ASTM D396-78. For
                                                                        5.2.4.2                                                                  and 60.333(b)
                           sulfur content limits?                                                                                                                                                                                                                                                         applicable limits.          units covered by the gas
                                                                                                                                                                                                                                                                                                                                       turbine NSPS, any fuel
                                                                                                                                                                                                                                                                                                                                      combusted must comply
                                                                                                                                                                                                                                                                                                                                      with the 0.8% fuel sulfur
                                                                                                                                                                                                                                                                                                                                     content limit and the fuel-
                                                                                                                                                                                                                                                                                                                                         bound nitrogen limit
                                                                                                                                                                                                                                                                                                                                      established in the initial
                                                                                                                                                                                                                                                                                                                                        performance test, as
                                                                                                                                                                                                                                                                                                                                    determined on a daily basis.
                                                                                                                                                                                                                                                                                                    Interview facility staff, inspect   Testing is required to be
                For sites that are covered by the boiler NSPS,
                                                                                                                                                                                                                           Initial performance testing is required for units that may burn gas, oil        facility and review        conducted within 60 days of
                 which burn any oil (even as back-up), gas or
                                                                                                                                                                                                                          or a combination of the two with a heat input capacity of 30 MMBtu/hr        construction activities to       achieving the maximum
                    combination of the two, and commence               SEB441
CAP441-US-                                                                                                                                       EPA 40 CFR                                                 Emission      or greater, when the unit commences construction, reconstruction, or           identify any changes         production rate but not later
               construction, reconstruction, or modification after      Section      X                                     Federal                                                  Air        NSPS
   011                                                                                                                                            60.45c(a)                                                  Limit         modification after February 28, 2005. (60.45c(a)) This testing would         (planned, underway or          than 180 days after initial
                February 28, 2005, is there documentation that         5.2.2.4.2
                                                                                                                                                                                                                             need to utilize EPA Reference Methods: Method 1, Method 3, and completed) since February 28, startup of the constructed,
              particulate matter testing has been completed or is
                                                                                                                                                                                                                                             Method 5, Method 5B, or Method 17.                        2005. Review stack test         reconstructed or modified
                          scheduled to be completed?
                                                                                                                                                                                                                                                                                                       protocols and/or reports.                  unit.
                                                                                                                                                                                                                          Facilities with boilers covered by NSPS that burn oil must submit fuel
                                                                                                                                                                                                                                                                                                       Review agency submittals
           For sites that are covered by the boiler NSPS and                                                                                                                                                              oil certification reports for each 6-month period to the state/local/EPA
                                                                                                                                                                                                                                                                                                        and confirm that fuel oil
             which burn any oil, even as back-up, is there                                                                                       EPA 40 CFR                                                                   Regional agency, accompanied by a certified statement by the                                                If no oil was burned during a
CAP441-US-                                                              SEB441                                                                                                                                                                                                                         certification reports were
           documentation that fuel oil certification reports for                     X                                     Federal               60.48c(e)(11)                      Air        NSPS         Reporting         owner/operator of the facility that the records of fuel oil supplier                                         6-month period, no report is
   012                                                               Section 5.2.2.6                                                                                                                                                                                                                     included. Cross-check
              each 6-month period were submitted to the                                                                                           & 60.48c(j)                                                              certifications submitted represent all of the fuel oil combusted during                                           required to be submitted.
                                                                                                                                                                                                                                                                                                       submittals and reports for
            appropriate state/local/EPA Regional agencies?                                                                                                                                                                the reporting period. The report shall be postmarked by the 30th day
                                                                                                                                                                                                                                                                                                               consistency.
                                                                                                                                                                                                                                           following the end of the reporting period.
                                                                                                                                                                                                                                                                                                        Review facility operating
                                                                                                                                                                                                                                                                                                     records and identify daily fuel
             For sites that are covered by the boiler NSPS, is                                                                                                                                                               Facilities with boilers covered by the NSPS must record daily or                                                  If a site is using an
                                                                       SEB441                                                                                                                                                                                                                        use records. Interview facility
CAP441-US-      there documentation of daily, or monthly if                                                                                      EPA 40 CFR                                                  Record           monthly, if applicable, fuel use; new units subject to fuel use                                             alternative method to track
                                                                        Section      X                                     Federal                                                  Air        NSPS                                                                                                    staff and inspect affected
   013     applicable, fuel use for each NSPS unit, based on a                                                                                    60.48c(g)                                                  Keeping       recording requirements must be equipped with an individual meter                                               fuel use, see Question #13
                                                                       5.2.2.5.1                                                                                                                                                                                                                      units to confirm that meters
                            meter for each unit?                                                                                                                                                                                    and the ability to record daily usage from the meter.                                                         of this protocol.
                                                                                                                                                                                                                                                                                                       are used for each affected
                                                                                                                                                                                                                                                                                                                   unit.
                                                                                                                                                                                                                                                                                                                                  For organic storage tanks
                                                                                                                                                                                                                                                                                                                                 greater than 40,000 gallons
                                                                                                                                                                                                                                                                                                                                      in capacity for which
                                                                                                                                                                                                                                                                                                                                   construction commenced
                                                                                                                                                                                                                                                                                                                                    after June 11, 1973 and
                                                                                                                                                                                                                                                                                                                                     prior to May 19, 1978,
                                                                                                                                                                                                                                                                                                Review facility tank inventory
                                                                                                                                                                                                                                                                                                                                    consult 40 CFR 60.110
                                                                                                                                                                                                                                                                                                    to confirm that records
                                                                                                                                                                                                                                                                                                                                       through 60.113 for
                                                                                                                                                                                                                                                                                                showing tank dimension and
                                                                                                                                                                                                                                                                                                                                applicable requirements. For
                 For organic storage tanks greater than 19,813                                                                                                                                                                                                                                  storage capacity are available
                                                                                                                                                                                                                           Facilities with organic storage tanks greater than 19,813 gallons in                                      organic storage tanks
                   gallons in capacity for which construction                                                                                                                                                                                                                                    for each tank covered by the
                                                                                                                                                                                                                          capacity for which construction commenced after July 23, 1984 must                                     greater than 40,000 gallons
CAP441-US-     commenced after July 23, 1984, does the facility        SEB441                                                                    EPA 40 CFR                                                  Record                                                                                NSPS. If no inventory is
                                                                                     X                                     Federal                                                  Air        NSPS                          have readily accessible records showing the dimensions of the                                            in capacity for which
   014            have readily accessible records showing the        Section 5.2.3                                                                60.116b(b)                                                 Keeping                                                                              available, interview facility
                                                                                                                                                                                                                           storage vessel and an analysis showing the capacity of the storage                                      construction commenced
               dimensions of the storage vessel and an analysis                                                                                                                                                                                                                                  staff to determine the size of
                                                                                                                                                                                                                                                          vessel.                                                               after May 18, 1978 and prior
                  showing the capacity of the storage vessel?                                                                                                                                                                                                                                     the largest tank built since
                                                                                                                                                                                                                                                                                                                                 to July 23, 1984, consult 40
                                                                                                                                                                                                                                                                                                   1984, and use the above
                                                                                                                                                                                                                                                                                                                                     CFR 60.110a through
                                                                                                                                                                                                                                                                                                    procedure to determine
                                                                                                                                                                                                                                                                                                                                  60.115a for applicable. For
                                                                                                                                                                                                                                                                                                           compliance.
                                                                                                                                                                                                                                                                                                                                ROP sources, the applicable
                                                                                                                                                                                                                                                                                                                                   requirements for organic
                                                                                                                                                                                                                                                                                                                                storage tanks can generally
                                                                                                                                                                                                                                                                                                                                  be found in the ROP, e.g.,
                                                                                                                                                                                                                                                                                                                                for MI ROP sources, located
                                                                                                                                                                                                                                                                                                                                         in "FG-TANKS"
                                                                                                                                                                                                                                                                                                                                          To the extent that a Chrysler
              Does the facility use landfill gas from a municipal
                                                                                                                                                                                                                                                                                                                                           facility receives and uses
              solid waste landfill in its fired equipment? If yes,                                                                                                                                                         Facilities that use landfill gas from a municipal solid waste landfill in Locate supplier certification in
                                                                                                                                                                                                                                                                                                                                             landfill gas, the landfill
                does the facility have a certification from the                                                                                    SEB441                                                                 its fired equipment must have a certification from the supplier that the      site environmental files.
CAP441-US-                                                            SEB441                                                                                                                                 Record                                                                                                                            operator retains all
                  supplier that the gas meets all applicable                       X                                       Chrysler                Section                          Air        NSPS                       gas meets all applicable requirements in the MSW NSPS [40 CFR 60              Interview facility staff to
   015                                                             Section 5.2.6.2                                                                                                                           Keeping                                                                                                                           responsibilities for
                requirements in the MSW NSPS [40 CFR 60                                                                                            5.2.6.2                                                                 Subpart WWW, 60.750-759. The certification must be submitted to determine if a copy was sent
                                                                                                                                                                                                                                                                                                                                          compliance with applicable
             Subpart WWW, 60.750-759? Was this certification                                                                                                                                                                                       SE&E for concurrence?                                        to SE&E.
                                                                                                                                                                                                                                                                                                                                           NSPS requirements under
                    submitted to SE&E for concurrence?
                                                                                                                                                                                                                                                                                                                                                 Subpart WWW.
                                                                                                                                                                                                                                                                                                        Interview facility staff and
                                                                                                                                                                                                                                                                                                     review facility project activities
                                                                                                                                                  EPA 40 CFR                                                                                                                                           since the last audit. Cross-
              If the auditor determines that any other NSPS
                                                                                                                                                 60 Subpart A                                                              When compliance is being audited or uncertainty regarding NSPS            check recent construction and
CAP441-US-   category applies to a facility, consult the NSPS           SEB441                                                                                                                               Record
                                                                                     X                                     Federal               and additional                     Air        NSPS                         applicability arises, consult the NSPS regulations directly for          modification activities with list
   016     directly for requirements and determine if they are       Section 5.2.1.2                                                                                                                         Keeping
                                                                                                                                                  subparts as                                                                requirements and comply with the applicable requirements.               of NSPS categories in 40 CFR
                                 being met.
                                                                                                                                                   applicable                                                                                                                                          60 to determine if any other
                                                                                                                                                                                                                                                                                                     NSPS category applies to the
                                                                                                                                                                                                                                                                                                                  facility.
           For affected engines (emergency generators and
                                                                       SEB441                                                                                                                                             The facility must keep a copy of the manufacture's specifications on
              fire pumps), is a copy of the manufacturer's                                                                                                                                                                                                                                                Locate manufacturer
CAP441-US-                                                              Section                                                                  EPA 40 CFR                                                  Record        site for all emergency generators and/or fire pumps affected by the
           specifications maintained on site? Verify that the                        X                                     Federal                                                  Air        NSPS                                                                                                       specifications in site
   017                                                               5.2.7.2.3 and                                                                 60.4206                                                   Keeping       NSPS. Also, the equipment is required to be equipped with a non-
           equipment is equipped with a non-resettable hour                                                                                                                                                                                                                                                environmental files.
                                                                       5.2.7.4.1                                                                                                                                                                  resettable hour meter.
                                 meter.
                                                                                                                                                                                                                          If you are an owner or operator of a stationary CI internal combustion
                                                                                                                                                                                                                             engine equipped with a diesel particulate filter to comply with the
              For eMergency generators and fire pumps subject
                                                                       SEB441                                                                                                                                              emission standards in §60.4204, the diesel particulate filter must be          Locate records for the
CAP441-US-     to the NSPS, are the affected engines equipped                                                                                    EPA 40 CFR                                                  Record
                                                                        Section      X                                     Federal                                                  Air        NSPS                           installed with a backpressure monitor that notifies the owner or           particulate filters in site
   018            with a particulate filter with a backpressure                                                                                   60.4209(b)                                                 Keeping
                                                                       5.2.7.4.2                                                                                                                                                 operator when the high backpressure limit of the engine is                environmental files.
                                    monitor?
                                                                                                                                                                                                                                                       approached.

                                                                                                                                                                                                                             The facility must maintain records of the dates the engine was
            For emergency generators and fire pumps subject            SEB441                                                                                                                                                                                                                            Locate records for the
CAP441-US-                                                                                                                                       EPA 40 CFR                                                  Record       operated, the number of hours it was in operation, and the purpose of
           to the NSPS, are the operating hours of the affected         Section      X                                     Federal                                                  Air        NSPS                                                                                                      operating hours in site
   019                                                                                                                                            60.4211(e)                                                 Keeping      the engine operation. Each affected engine must not be operated for
                          engines maintained?                          5.2.7.4.3                                                                                                                                                                                                                          environmental files.
                                                                                                                                                                                                                                 more than 100 hours per year for non-emergency use.




                         SEB441
                                                                                                                                                                                                                                                                                                     2 of 23
                         Audit Protocol Questions
                      Audit Protocol Number: CAP441                                                                                                                                                                                                                                                                                                                                                         November 2007
                      Revision Number: 4                                                                                                                                                                                                                            Audit Protocol Questions / Checklist

                                                                                            Country




                                                                                                               Venezuela




                                                                                                                                      Province
                                                                                             Canada
                                                                                                      Mexico
                                                                                                                                                    Citation                        Media     Subcategory   Type of Req.                                                                                     Evidence




                                                                                                                                       State /
                                                                    SEB No. &                                               Agency                                   Related                                                                     Requirement Description




                                                                                     U.S.
Number           Audit Protocol Question / Checklist                                                                                              (sets ECAR                      (In ECAR     (In ECAR      (In ECAR                                                                                  (Documents for auditor to      Comments
                                                                     Section                                               Category                                Requirements                                                            (either SEB or federal/state citation)
                                                                                                                                                    Priority)                     Database)    Database)     Database)                                                                                         verify)



                                                                                                                                                    Ontario
          For Canadian facilities, if the facility has boilers/hot                                                                                                                                                            Boilers and hot water heaters with input ratings larger than 10          Review facility emissions
                                                                                                                                                 Ministry of the
CAP441-   water heaters with input ratings > 10 MMBtu/hr, is          SEB441                                                State /   Ontari                                                                 Emission        MMBtu/hr are must comply with NOx emission limits in Ontario              calculations. Cross-check
                                                                                             X                                                   Environment                         Air        NSPS
CAN-001      there documentation of compliance with the            Section 5.3.1.1                                         Province     o                                                                     Limit        Ministry of Environment Guideline A-9, NOx Emissions From Boilers           with applicable emission
                                                                                                                                                 Guideline A-
                  appropriate NOx emissions limits?                                                                                                                                                                                                   and Heaters .                                      limits for consistency.
                                                                                                                                                   9, Part 2
          For Canadian facilities, if the facility has boilers/hot
           water heaters with input ratings > 10 MMBtu/hr, is                                                                                       Ontario                                                                  Boilers and hot water heaters with input ratings larger than 10
                                                                                                                                                                                                                                                                                                 Locate signed statement in
            there documentation that the facility presented a                                                                                    Ministry of the                                                           MMBtu/hr are subject to NOx emission limits and must present to the
CAP441-                                                               SEB441                                                State /   Ontari                                                                                                                                                   facility environmental records.
          signed statement certified by an Ontario-registered                                X                                                   Environment                         Air        NSPS         Reporting      Ministry a statement signed by an Ontario-registered Professional
CAN-002                                                            Section 5.3.1.1                                         Province     o                                                                                                                                                       Cross-check with applicable
          Professional Engineer that the new/modified boilers                                                                                    Guideline A-                                                                Engineer that the new/modified boilers will emit NOx within the
                                                                                                                                                                                                                                                                                                 regulation for consistency.
             will emit NOx within the specified limits prior to                                                                                    9, Part 2                                                                   specified limits before operating the new/modified boilers.
                            operating the boilers?
               For Canadian facilities, if the facility has an
                                                                                                                                                                                                                                                                                                       Review facility emissions
          automotive coating line, is there documentation that                                                                                                                                                               Canadian motor vehicle assembly plants must comply with New
CAP441-                                                               SEB441                                                State /   Ontari     CCME NSPS                                                   Emission                                                                                  calculations. Cross-check
           the facility is meeting the appropriate standards of                              X                                                                                       Air        NSPS                        Source Performance Standards limiting VOCs emitted in grams per
CAN-003                                                            Section 5.3.2.1                                         Province     o        Section 3.3.1                                                Limit                                                                                    with applicable emission
          VOC emitted in grams per square meter of surface                                                                                                                                                                               square meter of vehicle surface coated.
                                                                                                                                                                                                                                                                                                         limits for consistency.
                                   coated?
                                                                                                                                                                                                                                                                                                      Review facility environmental
                For Canadian facilities, if the facility has                                                                                        Ontario
                                                                                                                                                                                                                           Canadian facilities with combustion turbines must comply with NOx,          records, operating records
           combustion turbines, is there documentation that          SEB441                                                                      Ministry of the
CAP441-                                                                                                                     State /   Ontari                                                                  Record         CO, and SO2 emissions limits unless they meet the exemption              and emissions calculations.
           the units are either exempt or meeting emissions          Section                 X                                                   Environment                         Air        NSPS
CAN-004                                                                                                                    Province     o                                                                     Keeping       requirements in Ontario Ministry of Environmental Guideline A-5,          Cross-check with applicable
          and operations requirements under the appropriate          5.3.3.1                                                                     Guideline A-
                                                                                                                                                                                                                             Atmospheric Emissions from Stationary Combustion Turbines .               regulatory requirements for
                               regulations?                                                                                                       5, Parts 4-8
                                                                                                                                                                                                                                                                                                              consistency.
           For Mexican facilities, if the facility has boilers/hot
                                                                                                                                                   NOM-085-                                                                Mexican facilities with boilers and hot water heaters with input ratings    Review facility emissions
            water heaters with input ratings > 5 MMBtu/hr, is         SEB441
CAP441-                                                                                                                                           ECOL-1994                                                  Emission       larger than 5 MMBtu/hr must comply with NOx, opacity, SO2, and             calculations. Cross-check
              there documentation of compliance with the              Section                         X                    Federal                                                   Air        NSPS
MEX-001                                                                                                                                          5.0 Specifica-                                               Limit        particulate emissions limits in Mexico Regulations NOM-085-ECOL-            with applicable emission
             appropriate NOx, opacity, SO2 and particulate            5.4.1.1
                                                                                                                                                     tions                                                                                                   1994.                                       limits for consistency.
                             emissions limits?
                For Mexican facilities, if the facility has an
                                                                                                                                                   NOM-121-                                                                                                                                            Review facility emissions
          automotive coating line, is there documentation that                                                                                                                                                               Mexican facilities with automotive coating lines must comply with
CAP441-                                                               SEB441                                                                      ECOL-1997                                                  Emission                                                                                  calculations. Cross-check
           the facility is meeting the appropriate standards of                                       X                    Federal                                                   Air        NSPS                          standards limiting VOCs emitted in grams per square meter of
MEX-002                                                            Section 5.4.2.1                                                               4.0 Specifica-                                               Limit                                                                                    with applicable emission
           VOC emitted in grams per square meter of surface                                                                                                                                                                vehicle surface coated in Mexico Regulations NOM-121-ECOL-1997.
                                                                                                                                                     tions                                                                                                                                               limits for consistency.
                                  coated?
             For Venezuelan facilities, if the facility has an                                                                                                                                                                                                                                         Review facility emissions
                                                                      SEB441
CAP441-   automotive coating line, is there documentation that                                                                                   Rules Decree                                                Emission      Venezuelan facilities with automotive coating lines must comply with        calculations. Cross-check
                                                                      Section                                  X           Federal                                                   Air        NSPS
VEN-001   the facility is meeting the VOC emission standard of                                                                                   638 Article 10                                               Limit                       a VOC emission standard of 3 kg/hr.                          with applicable emission
                                                                      5.5.1.1
                                  3 kg/hr?                                                                                                                                                                                                                                                               limits for consistency.
                                                                                                                                                                                                                                                                                                                                                 Media                                  Subcategory
                                                                                                                                                                                                                                                                                                                                                 Air                                    Air Emission Inventory & Measurement (NOM 085#615)
                                                                                                                                                                                                                                                                                                                                                 Asbestos                               Air Operating/Emission Permits
                                                                                                                                                                                                                                                                                                                                                 Construction\Deactivation\Remediaion   Asbestos Notification
                                                                                                                                                                                                                                                                                                                                                 Emergency Preparedness & Response      Asbestos Removal/Storage
                                                                                                                                                                                                                                                                                                                                                 EPCRA _NPRI                            Asbestos Training
                                                                                                                                                                                                                                                                                                                                                 NPM Standards                          ASTs
                                                                                                                                                                                                                                                                                                                                                 Pollution Prevention                   Certificate of Approval
                                                                                                                                                                                                                                                                                                                                                 Storage Tanks                          CFCs
                                                                                                                                                                                                                                                                                                                                                 TSCA                                   Containment
                                                                                                                                                                                                                                                                                                                                                 W aste                                 Emergency Equipment
                                                                                                                                                                                                                                                                                                                                                 W ater                                 Episode Plan
                                                                                                                                                                                                                                                                                                                                                 All                                    ETI - 103
                                                                                                                                                                                                                                                                                                                                                                                        ETI - 104
                                                                                                                                                                                                                                                                                                                                                                                        Functional/Operational License
                                                                                                                                                                                                                                                                                                                                                                                        Incident Commander Training
                                                                                                                                                                                                                                                                                                                                                                                        Infectious W aste
                                                                                                                                                                                                                                                                                                                                                                                        IW TP Cost Report
                                                                                                                                                                                                                                                                                                                                                                                        LDRs
                                                                                                                                                                                                                                                                                                                                                                                        Liquid Industrial W aste (Used Oil)
                                                                                                                                                                                                                                                                                                                                                                                        MACT
                                                                                                                                                                                                                                                                                                                                                                                        Miscellaneous
                                                                                                                                                                                                                                                                                                                                                                                        Monthly Reports (Surface W ater)
                                                                                                                                                                                                                                                                                                                                                                                        Monthly Reports (W W TP)
                                                                                                                                                                                                                                                                                                                                                                                        Municipal Permits/By-laws
                                                                                                                                                                                                                                                                                                                                                                                        Municipal W astewater Permit
                                                                                                                                                                                                                                                                                                                                                                                        National Pollutant Release Inventory
                                                                                                                                                                                                                                                                                                                                                                                        Noise Compliance (NOM 081 ECOL)
                                                                                                                                                                                                                                                                                                                                                                                        NSPS
                                                                                                                                                                                                                                                                                                                                                                                        NSR Permits
                                                                                                                                                                                                                                                                                                                                                                                        ONT Environmental Protection Act
                                                                                                                                                                                                                                                                                                                                                                                        ONT Gasoline Handling Act
                                                                                                                                                                                                                                                                                                                                                                                        ONT Liquid Fuels Handling Act
                                                                                                                                                                                                                                                                                                                                                                                        ONT Memo of Understanding
                                                                                                                                                                                                                                                                                                                                                                                        ONT Municipal Industrial Strategy Abatement (MISA)
                                                                                                                                                                                                                                                                                                                                                                                        ONT Reduce/Reuse & Recycle Act
                                                                                                                                                                                                                                                                                                                                                                                        ONT Regulation #127/01: Airborne Contaminants Monitoring & Dis
                                                                                                                                                                                                                                                                                                                                                                                        ONT Regulation #346 - General Air Pollution
                                                                                                                                                                                                                                                                                                                                                                                        ONT W ater Resources Act - Certificate of Approval
                                                                                                                                                                                                                                                                                                                                                                                        Operations and Cost Data
                                                                                                                                                                                                                                                                                                                                                                                        Outfall Discharge Permits & Application
                                                                                                                                                                                                                                                                                                                                                                                        Outfall Parameters Measurement & Analysis
                                                                                                                                                                                                                                                                                                                                                                                        PCB Recordkeeping/Documentation
                                                                                                                                                                                                                                                                                                                                                                                        PCBs
                                                                                                                                                                                                                                                                                                                                                                                        Pollution Prevention Plan
                                                                                                                                                                                                                                                                                                                                                                                        RCRA BB/CC
                                                                                                                                                                                                                                                                                                                                                                                        Record Retention Requirements
                                                                                                                                                                                                                                                                                                                                                                                        Records of Coated Vehicles (NOM 121)
                                                                                                                                                                                                                                                                                                                                                                                        Registration & Operating License
                                                                                                                                                                                                                                                                                                                                                                                        SARA 302 - Facility Registration
                                                                                                                                                                                                                                                                                                                                                                                        SARA 303 - Incident Notification
                                                                                                                                                                                                                                                                                                                                                                                        SARA 311 - Hazardous Material Notifications
                                                                                                                                                                                                                                                                                                                                                                                        SARA 312 - Hazardous Material Annual Report
                                                                                                                                                                                                                                                                                                                                                                                        SARA 313 - Toxic Chemical Release
                                                                                                                                                                                                                                                                                                                                                                                        Solid & Hazardous W aste Identification
                                                                                                                                                                                                                                                                                                                                                                                        Special W aste
                                                                                                                                                                                                                                                                                                                                                                                        State Regulations
                                                                                                                                                                                                                                                                                                                                                                                        Stormwater Pollution Prevention Plan
                                                                                                                                                                                                                                                                                                                                                                                        Surface W astewater Permit
                                                                                                                                                                                                                                                                                                                                                                                        Surplus Machinery
                                                                                                                                                                                                                                                                                                                                                                                        Synthetic Minor/FESOP Permit
                                                                                                                                                                                                                                                                                                                                                                                        Tank Manuals
                                                                                                                                                                                                                                                                                                                                                                                        Title V Permit
                                                                                                                                                                                                                                                                                                                                                                                        TSD&R Program
                                                                                                                                                                                                                                                                                                                                                                                        Universal & Special W aste
                                                                                                                                                                                                                                                                                                                                                                                        Used Oil
                                                                                                                                                                                                                                                                                                                                                                                        USTs
                                                                                                                                                                                                                                                                                                                                                                                        W aste (Six Month) Reporting
                                                                                                                                                                                                                                                                                                                                                                                        W aste Labeling
                                                                                                                                                                                                                                                                                                                                                                                        W aste Management Training
                                                                                                                                                                                                                                                                                                                                                                                        W aste Shipping/Manifesting & Transportation
                                                                                                                                                                                                                                                                                                                                                                                        W aste Station Signs
                                                                                                                                                                                                                                                                                                                                                                                        W aste Tank / Container Management




                      SEB441
                                                                                                                                                                                                                                                                                                      3 of 23
                      Audit Protocol Questions
Country    Media
Canada     Air
Canada     Air
Canada     Air
Canada     Air
Canada     Air
Canada     Air
Canada     Asbestos
Canada     Asbestos
Canada     Asbestos
Canada     Asbestos
Canada     Construction\Deactivation\Remediaion
Canada     Emergency Preparedness & Response
Canada     Emergency Preparedness & Response
Canada     Emergency Preparedness & Response
Canada     Emergency Preparedness & Response
Canada     Emergency Preparedness & Response
Canada     EPCRA_NPRI
Canada     EPCRA_NPRI
Canada     EPCRA_NPRI
Canada     NPM Standards
Canada     NPM Standards
Canada     Pollution Prevention
Canada     Pollution Prevention
Canada     Pollution Prevention
Canada     Pollution Prevention
Canada     Storage Tanks
Canada     Storage Tanks
Canada     Storage Tanks
Canada     Storage Tanks
Canada     Storage Tanks
Canada     Storage Tanks
Canada     TSCA
Canada     TSCA
Canada     TSCA
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Waste
Canada     Water
Canada     Water
Canada     Water
Canada     Water


CAP 441 Rev 2 October 2005                        page 4 of 23
Canada     Water
Canada     Water
Canada     Water
Canada     Water
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Air
Mexico     Asbestos
Mexico     Asbestos
Mexico     Asbestos
Mexico     Construction\Deactivation\Remediaion
Mexico     Emergency Preparedness & Response
Mexico     Emergency Preparedness & Response
Mexico     Emergency Preparedness & Response
Mexico     Emergency Preparedness & Response
Mexico     NPM Standards
Mexico     NPM Standards
Mexico     Pollution Prevention
Mexico     Pollution Prevention
Mexico     Pollution Prevention
Mexico     Storage Tanks
Mexico     Storage Tanks
Mexico     Storage Tanks
Mexico     TSCA
Mexico     TSCA
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Waste
Mexico     Water
Mexico     Water
Mexico     Water
Mexico     Water
Mexico     Water
Mexico     Water
Mexico     Water


CAP 441 Rev 2 October 2005                        page 5 of 23
Mexico     Water
USA        Air
USA        Air
USA        Air
USA        Air
USA        Air
USA        Air
USA        Air
USA        Air
USA        Asbestos
USA        Asbestos
USA        Asbestos
USA        Asbestos
USA        Asbestos
USA        Asbestos
USA        CERCLA
USA        Construction\Deactivation\Remediaion
USA        Emergency Preparedness & Response
USA        Emergency Preparedness & Response
USA        Emergency Preparedness & Response
USA        Emergency Preparedness & Response
USA        Emergency Preparedness & Response
USA        EPCRA _NPRI
USA        EPCRA _NPRI
USA        EPCRA _NPRI
USA        EPCRA _NPRI
USA        EPCRA _NPRI
USA        EPCRA _NPRI
USA        NPM Standards
USA        NPM Standards
USA        Pollution Prevention
USA        Pollution Prevention
USA        Pollution Prevention
USA        Storage Tanks
USA        Storage Tanks
USA        Storage Tanks
USA        Storage Tanks
USA        TSCA
USA        TSCA
USA        TSCA
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste
USA        Waste


CAP 441 Rev 2 October 2005                        page 6 of 23
USA        Waste
USA        Waste
USA        Waste
USA        Water
USA        Water
USA        Water
USA        Water
USA        Water
USA        Water
USA        Water




CAP 441 Rev 2 October 2005   page 7 of 23
Subcategory
Certificate of Approval
CFCs
Miscellaneous
ONT Environmental Protection Act
ONT Memo of Understanding
ONT Regulation #346 - General Air Pollution
Asbestos Removal / Storage
Record Retention Requirements
Asbestos TSD&R
Waste Shipping/Manifesting & Transportation
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Incident Commander Training
Miscellaneous
Miscellaneous
National Pollutant Release Inventory
ONT Regulation #127/01: Airborne Contaminants Monitoring & Discharge Reporting
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
ONT Reduce/Reuse & Recycle Act
Pollution Prevention Plan
ASTs
Miscellaneous
ONT Gasoline Handling Act
ONT Liquid Fuels Handling Act
Tank Manuals
USTs
Asbestos
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
Liquid Industrial Waste (Used Oil)
Miscellaneous
Record Retention Requirements
Solid & Hazardous Waste Identification
Special Waste
Surplus Machinery
TSDF Program
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank/Container Management
IWTP Cost Report
Miscellaneous
Monthly Reports (WWTP)
Municipal Permits/By-laws


CAP 441 Rev 2 October 2005                                                       page 8 of 23
Municipal Wastewater Permit
ONT Municipal Industrial Strategy Abatement (MISA)
ONT Water Resources Act - Certificate of Approval
Surface Wastewater Permit
Air Emission Inventory & Measurement (NOM 085#615)
Air Operating/Emission Permits
CFCs
Functional/Operational License
Incident Commander Training
Miscellaneous
Noise Compliance (NOM 081 ECOL)
Records of Coated Vehicles (NOM 121)
Asbestos Removal / Storage
Record Retention Requirements
Waste Shipping/Manifesting & Transportation
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Miscellaneous
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
Pollution Prevention Plan
ASTs
Miscellaneous
USTs
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
Miscellaneous
Record Retention Requirements
Registration & Operating License
Solid & Hazardous Waste Identification
Special Waste
Surplus Machinery
TSDF Program
Used Oil
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank Container Management
Waste (Six Month) Reporting
IWTP Cost Report
Miscellaneous
Monthly Reports (WWTP)
Municipal Wastewater Permit
Operations and Cost Data
Outfall Discharge Permits & Application
Outfall Parameters Measurement & Analysis


CAP 441 Rev 2 October 2005                           page 9 of 23
Surface Wastewater Permit
CFCs
MACT
Miscellaneous
NSPS
NSR Permits
State Regulations
Sythetic Minor/FESOP Permit
Title V Permit
Asbestos Notification
Asbestos Removal / Storage
Asbestos Training
Record Retention Requirements
Asbestos TSD&R
Waste Shipping/Manifesting & Transportation
Miscellaneous
Miscellaneous
Containment
Emergency Equipment
Episode Plan
Incident Commander Training
Miscellaneous
Miscellaneous
SARA 302 - Facility Registration
SARA 303 - Incident Notification
SARA 311 - Hazardous Material Notifications
SARA 312 - Hazardous Material Annual Report
SARA 313 - Toxic Chemical Release
ETI - 103
Miscellaneous
ETI - 104
Miscellaneous
Pollution Prevention Plan
ASTs
Miscellaneous
Tank Manuals
USTs
Asbestos
PCB Recordkeeping/Documentation
PCBs
Infectious Waste
LDRs
Miscellaneous
RCRA BB/CC
Record Retention Requirements
Solid & Hazardous Waste Identification
Surplus Machinery
TSDF Program
Universal & Special Waste
Used Oil
Waste Labeling
Waste Management Training


CAP 441 Rev 2 October 2005                    page 10 of 23
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank/Container Management
IWTP Cost Report
Miscellaneous
Monthly Reports (Surface Water)
Monthly Reports (WWTP)
Municipal Wastewater Permit
Stormwater Pollution Prevention Plan
Surface Wastewater Permit




CAP 441 Rev 2 October 2005                    page 11 of 23
                             Agency Category    Type of Requirement
                             Federal            Emission Limit
                             State / Province   Operating Criteria
                             Local Agency       Design
                             Facility Permit    Reporting
                             Coporate           Record Keeping
                                                Inspection




                                                Preventative Maintenance
                                                Training




CAP 441 Rev 2 October 2005                                         page 12 of 23
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CAP 441 Rev 2 October 2005   page 19 of 23
Subcategory
Air Emission Inventory & Measurement (NOM 085#615)
Air Operating/Emission Permits
Asbestos
ASTs
Certificate of Approval
CFCs




Containment
Emergency Equipment
Episode Plan
ETI - 103
ETI - 104
Functional/Operational License
Incident Commander Training
Infectious Waste
IWTP Cost Report
LDRs
Liquid Industrial Waste (Used Oil)
Miscellaneous
Monthly Reports (Surface Water)
Monthly Reports (WWTP)
Municipal Permits/By-laws
Municipal Wastewater Permit
National Pollutant Release Inventory
Noise Compliance (NOM 081 ECOL)
NSPS
NSR Permits
ONT Environmental Protection Act
ONT Gasoline Handling Act
ONT Liquid Fuels Handling Act
ONT Memo of Understanding
ONT Municipal Industrial Strategy Abatement (MISA)
ONT Reduce/Reuse & Recycle Act
ONT Regulation #127/01: Airborne Contaminants Monitoring & Discharge Reporting
ONT Regulation #346 - General Air Pollution
ONT Water Resources Act - Certificate of Approval
Operations and Cost Data
Outfall Discharge Permits & Application
Outfall Parameters Measurement & Analysis
PCB Recordkeeping/Documentation
PCBs
Pollution Prevention Plan
RCRA BB/CC
Record Retention Requirements
Records of Coated Vehicles (NOM 121)
Registration & Operating License
SARA 302 - Facility Registration
SARA 303 - Incident Notification


CAP 441 Rev 2 October 2005                                                       page 20 of 23
SARA 311 - Hazardous Material Notifications
SARA 312 - Hazardous Material Annual Report
SARA 313 - Toxic Chemical Release
Solid & Hazardous Waste Identification
Special Waste
State Regulations
Stormwater Pollution Prevention Plan
Surface Wastewater Permit
Surplus Machinery
Sythetic Minor/FESOP Permit
Tank Manuals
Title V Permit



TSDF Program
Universal & Special Waste
Used Oil
USTs
Waste (Six Month) Reporting
Waste Labeling
Waste Management Training
Waste Shipping/Manifesting & Transportation
Waste Station Signs
Waste Tank Container Management




CAP 441 Rev 2 October 2005                    page 21 of 23
Type of Requirement

Emission Limit



Operating Criteria

Design

Reporting

Record Keeping

Inspection

Preventative Maintenance

Training




CAP 441 Rev 2 October 2005
Description

Emission limit was not met
Operating requirements such as drum labeling, emergency equipment, waste storage locations,
Hazardous Waste Determination, waste station signs, required CFC leak verification testing,
manhole markings, etc.

A design requirement such as containment of tanks.

A report or information sent to the agency.

Records kept at the plant

Required inspections (tank inspections, RCRA inspections, etc.)

Required preventative maintenance

Required training




CAP 441 Rev 2 October 2005

								
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