Attachment_Q_Environment_Survey.pdf

National Consolidated Risk Management Survey

ENVIRONMENT SURVEY

RAC Summary

Survey Area RAC Score Documentation Air Programs Fuel Storage Tanks Hazardous Materials Hazardous Waste PCBs Solid Waste Water Pollution

Environment Survey Overall RAC Score:

Building Information

Questions Response Findings/Observations

Building Profile Region GSA Building Number GSA Building Name Building Street Address Building City Building State Date(s) of Onsite Survey Surveyor Type of Occupancies Building Point(s) of Contact for Surveys Date of Building Construction Date of Last Major Building Renovation Has any work been done since the last survey (e.g., any tenant fit-outs, changes in occupancy, etc.)? If yes, please describe in the findings section.

Property Type What is the tenant breakdown?

Primary Tenants

Is there a law enforcement tenant in this facility?

Name of O&M or Facilities Management Services Contractor Name of Custodial Services Contractor

Building Information

Questions Response Findings/Observations Identify any Unique Space Type(s). If "other" is chosen, please describe the "other" unique space in the comments section.

Building Size (GSF) Building Size (RSF) Total Number of Floors Above Grade Total Number of Floors Below Grade

Is the building a highrise according to Rexus?

Is the building a highrise according to FPE?

What is the building construction classification (IBC Code)?

What is the pitch of roof?

Are there photovoltaic (PV) cells on the roof?

Type of Roof Anchoring System Are there antennas?

How many elevators are there?

Identify Fuel Fired Equipment What are the fuel types?

How many confined spaces are there?

What type of confined spaces are there?

How many permit-required confined spaces are there?

What is the potable water source?

Is there asbestos containing material(s)?

Is there lead paint or other lead material(s)?

Is there PCB containing material(s)?

Building Information

Questions Response Findings/Observations

What energy sources are used onsite? (select all that apply) Above-Ground Storage Tanks (ASTs) Are there any ASTs?

If yes, how many are there?

What is their total value?

Tank Size (gallons) Type Tank Location Fuel Type Installation Date Underground Storage Tanks (USTs) Are there any USTs?

If yes, how many are there?

What is their total value?

Tank Size (gallons) Type Tank Location Fuel Type Installation Date Occupant Emergency Plan (OEP) Is there an OEP?

Date of plan Are persons in plan current?

Is there OEP training for designated persons?

Building Information

Questions Response Findings/Observations Are there procedures for evacuation of disabled persons?

Are there procedures for after-hours emergencies?Is there a fire department pre-fire plan?

Documentation

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Water

Does the facility have a welI that requires a permit?

2 If the well requires a permit, is the permit onsite?

3 Is a NPDES/SPDES issued to the facility?

Is a waste water pretreatment permit/registration issued to the facility? If yes, provide key requirements description in findings section.

Hazardous Materials

Is documentation available that shows the facility has coordinated with state and/or local emergency planning commitees? If yes, describe in the findings section.

If required to do so, has the facility filed a Tier II Report?

Is there a complete (e.g. all occupants) facility chemical inventory available? Please identify the sources of the inventory in the findings section.

Sources can include O&M contractors, custodial contractors, and tenants.

Are Safety Data Sheets (SDS) maintained for materials stored at the building? Compare materials/chemicals observed during site visit to inventory. Specify discrepancies in the findings section.

Are there any findings of non-compliance with PCBs recordkeeping? If yes, describe in the findings section.

Solid Waste

Does the facility maintain records of solid waste disposed and recycled?

Does the facility have an EPA or State ID number assigned to GSA?

Fuel Storage Tanks

If FSTs (ASTs or USTs) are on-site, are they on GSA's National Tanks Inventory?

Are required tank permits and/or registration on file? Describe non-compliance with permit/registration requirements in the findings section. Please include the expiration dates in findings section as well.

Are UST(s) automatic leak detection system maintenance records properly maintained?

Are UST manual inventory controls records maintained (fill/consumption, dipstick, etc.)?

Are three any lack of records or other issues regarding any leak detection system? If yes, please describe in the findings section.

Documentation

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

If underground tanks were closed in place, is there a closure report or No Further Action (NFA) letter on file? If no, provide additional details in the findings section.

Does staff have the appropriate level of UST Owner/Operator Training (levels A/B/C) as required by the Energy Policy Act of 2005 and are certifications/training records available for review?

Does the facility have written or verbal procedures for product or waste transfers? If yes, please describe in the findings section.

Spill Response and Prevention

If required, does the facility have a Spill Prevention, Control and Countermeasures (SPCC) Plan? If yes, provide the title for the plan, the date the plan was written, and note when the last annual SPCC training was conducted.

Does the SPCC Plan reflect the actual situation at the facility (number of ASTs, number of 55 gallon drums, location of spill control equipment)?

Does the SPCC Plan meet all regulatory requirements?

Do personnel comply with all sections of the SPCC Plan? Descibe any non-compliance or violations with the SPCC requirements in the findings section.

Air 24 Are air permits issued to the facility?

Are permits/registration documents on file for individually permitted/registered emissions generating equipment? Review the air permits.

Give brief description of permit conditions in the findings section. Describe emission sources/equipment listed in the permit, allowable throughout in gallons for ASTs, recordkeeping requirements discrepancies, etc. in the findings section.

Are there other sources/equipment requiring air permits? This may include laboratory vents, generators, fuel storage tanks, maintenance activities and operations such as welding, and firing ranges. If yes, please describe in the findings section.

If there is an Emergency Generator, does the Generator require a permit or plan for the state/country/local air district?

If required, does the boiler have a permit? Where applicable, review permit and results of any boiler emissions test. Provide a brief descritpion of permit conditions in the findings section.

Descriptions should include allowable NOX, SOX, PM, and other restrictions, etc.

Are chiller maintenance records, including replacement refrigerants, registration of recovery units, etc. up to date?

Documentation

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Are training certificates for GSA staff and contractors performing maintenance on chillers, replacement refrigerants, registration of recovery units up-to-date?

Shipping Documents

Does the facility maintain hazardous waste manifests or bills of lading?

Are there incomplete or illegible waste manifests or evidence of exceeding hazardous waste generator status? If yes, describe in the findings section.

Does the facility maintain required shipping documents for asbestos waste, lead-contaminated, or lead based paint wastes?

Does facility maintain shipping documents for recycled materials?

Other Findings

Overall Documentation RAC

Once the surveyor has reviewed the Documentation findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Documentation RAC

Explanation of User Adjusted RAC

Air Programs

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Permit Compliance

If an air permit exists, do the facility operations comply with the air permit?

If an air permit exists, is the emergency generation operation compliant with the sulfur content for diesel fuel, run time, etc. and other aspects of the permit? If not, describe in the findings section.

Emergency Generator

Is there an Emergency Generator for the site? If yes, please provide the Total Output Rated Capacity (KW) in the findings section.

What type of fuel does the Emergency Generator use? - - -

Are there any outstanding deficiencies associated with the Emergency Generator? If yes, please describe in the findings section.

Boilers

Are there any boilers in this facility? If yes, please list the BTU capacity in the findings section.

42 What is the fuel used? - - -

If required to have a permit, are facility boiler operations compliant with the permit? Including allowable NOX, SOX, PM, and other restrictions, etc.

Cooling Systems

Are there operating cooling systems at this facility? If yes, please provide the size of the cooling system in the findings section.

If there is a cooling system at the facility, please list the refrigerants that are in use or stored onsite in the findings section.

Is there evidence of leaks and/or lack of system re-certification? Review chiller records (invoices, work orders, logs). If yes, please describe in the findings section.

Is used chiller oil taken off-site for disposal/recycling by the maintenance service contractor? If not, describe in the findings section.

Were any findings during this assessment a repeat from a previous assessment? If yes, provide details in the findings section.

Other Findings

Overall Air Programs RAC

Once the surveyor has reviewed the Air Programs findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Air Programs RAC

Fuel Storage Tanks

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Underground Storage Tanks

Does the facility have any underground storage tanks (USTs)?

Is the UST(s) corrosion protection system properly maintained? Check records. If no, describe in the findings section.

Are tank and piping tightness tests conducted? If yes, describe frequency of testing, the date of the last test(s) and the results in the findings section.

Does the facility use methods of leak detection other than automatic leak detection?

Are the spill buckets for the UST dry and intact (not cracked)? Describe any issues with spill buckets and loading/unloading procedures and operations in the findings section.

Is any UST more than 15 years old? If yes, please list the age of each in the findings section.

Does the facility/staff monitor loading/unloading operations? If yes, describe in the findings section.

Have any underground tanks been closed at the facility? If yes, verify records.

Has the facility had incidents of leaks or spills from a UST? If yes, describe the incident.

Describe any lack of reporting or record issues in the findings section.

59 Is the facility compliant with UST requirements?

Were any findings during this assessment a repeat from a previous assessment? If yes, provide details in the findings section.

Above Ground Storage Tanks

Does the facility have any above ground storage tanks (ASTs)?

Is the facility compliant with AST requirements?

Describe the size, age and general condition of the ASTs in the findings section.

Is AST inspected and tested for tightness/integrity (this may include automatic tank gauging, hydrostatic tightness testing, etc.)? Describe monitoring/testing methodology in the findings section.

Other Findings

Overall Fuel Storage Tanks RAC

Once the surveyor has reviewed the Fuel Storage Tanks findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Fuel Storage Tanks RAC

Hazardous Materials

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Hazardous Materials

Does the facility store hazardous materials/chemicals on-site? - - -

Does the facility store any old unusable materials/chemicals? If yes, describe any observed unusable chemical storage in the findings section.

Does the facility employ a Green Procurement Program to reduce the acquisition of hazardous materials?

Does the facility use Integrated Pest Management (IPM) techniques either indoors or outdoors? If yes, please provide details in the findings section.

Were any findings during this assessment a repeat from a previous assessment? If yes, please provide details in the findings section.

Other Findings

Overall Hazardous Materials RAC

Once the surveyor has reviewed the Hazardous Materials findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Hazardous Materials RAC

Hazardous Waste

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Hazardous Waste

Has the facility determined if hazardous wastes are generated onsite?

Based on available data, what is the facility's generator status? If other, specifiy in the comments section.

Does the facility comply with hazardous/universal waste storage requirements?

Is electronic equipment (e-waste) disposed in accordance with state or local regulations?

Are there any deficiencies or other observations that are not captured in this questionnaire? If yes, please describe in the comments

Were any findings during this assessment a repeat from a previous assessment? If yes, please provide details in the findings section.

Other Findings

Overall Hazardous Waste RAC

Once the surveyor has reviewed the Hazardous Waste findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Hazardous Waste RAC

PCBs

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

PCBs

Is there evidence of old spills or leaks from PCB containing equipment? If yes, describe in the findings section.

Are there any registered PCB transformers at the facility? If yes, describe in the findings section.

Is PCB equipment labeled as required? If applicable, please describe deficiencies in the findings section.

Has the building been relamped? If yes, describe the relamping program in the findings section.

Has the facility identified any sources of PCB-contaminated building materials?

Has the facility undergone any renovation, remediation, or other projects that require the removal of PCB contaminated building materials?

Were improper PCB management activities observed? If yes, please describe in the comments section.

Were any findings during this assessment a repeat from a previous assessment? If yes, please provide details in the findings section.

Other Findings

Overall PCB RAC

Once the surveyor has reviewed the PCB findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted PCB RAC

Solid Waste

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Solid Waste

Is there a municipal solid waste diversion / recycling program at the facility?

What municipal solid waste does the facility recycle? (select all that apply) - - -

What other waste (universal waste, electronic waste, etc.) does the facility recycle? (select all that apply)

Is there evidence of improper disposal or abandonment of hazardous or universal waste at the facility?

Were any findings during this assessment a repeat from a previous assessment? If yes, please provide details in the findings section.

Other Findings

Overall Solid Waste RAC

Once the surveyor has reviewed the Solid Waste findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Solid Waste RAC

Water Pollution

# Questions Response Findings/Observations Regulatory Citation Risk Assessment Code (RAC) Recommended Corrective Actions

Probability Severity RAC Is there a recommended corrective action associated with this item? Location Recommended Action

Water Pollution

If the facility is included in a pretreatement permit, are operations compliant with permit/registration and local regulations for maintenance activities?

If "no", describe in the findings section.

If facility is included in a NPDES/SPDES, are operations compliant with permit requirements?

If facility is included in either a general storm water permit or a storm water pollution prevention plan (SWPPP), are facility operations or activities (including tenants) compliant? List non-compliances in the findings section.

Does the facility discharge any waste waters -other than storm water runoff - to sanitary or storm sewers? If yes, describe in the findings section.

Is storm water testing required either as part of a SWPPP requirement or for other reasons? If yes, describe testing requirements/testing results in the findings section.

Is unpermitted waste water (i.e. fire system test water, etc.) tested prior to discharge into either the santiary or storm sewer?

Is there evidence of any old, no longer usable liquid products disposed in the sanitary sewer?

Were any findings during this assessment a repeat from a previous assessment? If yes, please provide details in the findings section.

Other Findings

Overall Water Pollution RAC

Once the surveyor has reviewed the Water Pollution findings and Overall RAC provided above, if the RAC does not represent the risk associated with the findings as a whole, please provide an adjusted RAC and explanation below.

User Adjusted Water Pollution RAC

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location

D oc um en ta tio n

Water

Hazardous Materials

Solid Waste

Fuel Storage Tanks

Spill Response and Prevention

Air

Action Taken Completion Date

ENVIRONMENT SURVEY

Work Item Summary and Tracking Sheet

Water

Hazardous Materials

Solid Waste

Fuel Storage Tanks

Spill Response and Prevention

Air

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location

D oc um en ta tio n

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location Shipping Documents

Other Findings - Documentation

A ir

Pr og ra m s

Permit Compliance

Emergency Generator

Boilers

Cooling Systems

Other Findings - Air Programs

Fu el

S to ra ge

T an ks

Underground Storage Tanks

D oc um en ta

Shipping Documents

Other Findings - Documentation

Permit Compliance

Emergency Generator

Boilers

Cooling Systems

Other Findings - Air Programs

Underground Storage Tanks

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location

Above Ground Storage Tanks

Other Findings - Fuel Storage Tanks

H az ar do us M at er ia ls Hazardous Materials

Other Findings - Hazardous Materials

Fu el

S to ra ge

T an ks

Above Ground Storage Tanks

Other Findings - Fuel Storage Tanks

Hazardous Materials

Other Findings - Hazardous Materials

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location

H az ar do us W as te

Hazardous Waste

Other Findings - Hazardous Waste

PC

B s

PCBs

Other Findings - PCBs

So lid

W as te

Solid Waste

Other Findings - Solid Waste

W at er P ol lu tio n

Water Pollution

Hazardous Waste

Other Findings - Hazardous Waste

PCBs

Other Findings - PCBs

Solid Waste

Other Findings - Solid Waste

Water Pollution

Work Item Summary and Tracking Sheet

# Findings/Observations Recommended Action Location

Other Findings - Water Pollution

W at er P ol lu

Other Findings - Water Pollution

Severity and Probability Assessment Guidance

SEVERITY ASSESSMENT GUIDANCE

SCOPE and APPLICABILITY

Environmental Fire Protection Risk Safety & Health

Contamination of air, water soil, and biota or non-compliance with environmental regulations

Effects to occupants or facility as a result of a condition or potential event.

Adverse health effects or injury to facility occupants, contractors or visitors in response to a condition or event

SEVERITY LEVEL DEFINITIONS

CATASTROPHIC Irreversible long-term impacts.

(1) Death, permanent disability or irreversible health effect to occupants or (2) a loss of an entire facility.

Permanent disability, irreversible health effect or death.

SEVERE

Reversible long-term damage (5+ years to remediate).

(1) Severe injury, potential long-term health effect or

(2) major loss or impact to a facility.

Potential long-term health effect or severe injury.

SIGNIFICANT

Reversible medium-term damage (1-5 years to remediate).

(1) Minor injury or reversible health effect or

(2) damage to a portion of a facility requiring an extended period of time to repair.

Reversible health effect or minor injury.

MODERATE

Reversible short-term impact (<1 year to remediate).

(1) First aid, no lost time or

(2) damage to a facility requiring a minimal amount of time to repair.

First aid or no lost time.

MINOR De minimis regulatory violation. De minimis code violation. De minimis code violation.

NO IMPACT No risk of impact. No risk of impact to the occupants or facility. No risk of impact.

PROBABILITY ASSESSMENT GUIDANCE

PROBABILITY LEVEL DEFINITIONS

Likely Imminent or 1 in 10

Probable Probable or 1 in 100

Possible Possible or 1 in 1000

Remote Remote or 1 in 10,000

Unlikely Unlikely or 1 in 100,000

Not Possible Non-existent

MODERATE

Reversible short-term impact (<1 year to remediate).

(1) First aid, no lost time or

(2) damage to a facility requiring a minimal amount of time to repair.

First aid or no lost time.