Document OzNBD5qOek2m8YR3oV6mXMXDM

TO: Distribution FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles August 8, 1988 ENVIRONMENTAL MANPOWER NEEDS ASSESSMENT TEAM MEETING VISTA I've only received questions from Warner. Please review before the meeting. His and mine are attached. I'll have a facilitator at our meeting. I've also asked Tom O'Brien, Quality Coordinator for Marketing, to come for a while to consult with us on survey methods and pitfalls. I'll have a final agenda at the meeting. See you Wednesday at 10:00 a.m. M G~v-- T. G. Grumbles .416 Attachment Distribution: M. G. Hayes-LCCP (fax) J. P. Warner-LCLAB (fax) Doug Michels-Houston VVV 000008643 ENVIRONMENTAL AUDITS Environmental audits are one way of determining how well a plant is complying with environmental programs and procedures. Audits can be both formal and informal and can involve non-plant personnel. An audit is a check to see if plant practices are in line with requirements. 1. Does your plant have an audit program? 2. Does your plant have a formal audit program? 3. Who conducts the audit(s)? 4. Do you feel that the audit program is of sufficient scope to detect problem areas in plant practices? 5. Do you feel that you should do (more, less or same) amount of auditing? 6. Do you need additional auditing resources? If yes, please explain. 7. Briefly, please describe your audit program. VVV 000008644 ..REIVED AUG2 '88 Bouts: ...... Copy: Flic: X-F; REPORTS 1. Are routine reports submitted per regulatory requirements? 2. Are non-routine reports (leads, spills, bypasses, etc.) reported per regulatory requirements. 3. Who completes and submits routine reports? Do these individuals have sufficient environmental knowledge to detect problems in the reports? 4. Who makes non-routine reports? 5. Is there someone at the plant at all times that has the knowledge and training to make non-routine reports? If not, how are such reports handled? 6. Are there changes that need to be made to your reporting procedures? 0000086*5 ENVIRONMENTAL TRAINING 1. Do you conduct the environmental training required by regulations? 2. Please list your training programs. 3. Do you test individuals receiving training to determine level of comprehension? 4. Is your training effective? 5. Who conducts the training? 6. Do both hourly and management receive environmental training? 7. What additional training needs to be done? 8. Are these additional training resources that are needed? If yes, please detail. 9. Briefly, please describe your training program. VVV 000008646 MEETING PERMIT REQUIREMENTS 1. Do you have problems meeting existing permit requirements? 2. Do Operations and Maintenance supervisors understand the limitations placed upon their activities by your permits? 3. Do Operations and Maintenance field personnel understand the limitations placed upon their activities by your permits? 4. Do you audit your compliance with your permits? VVV 000008647 ENVIRONMENTAL MANPOWER NEEDS ASSESSMENT TEAM SURVEY QUESTIONS CONOCO APA 1. Does your plant have current environmental liability issues? ongoing APA retained 2. Are you or plant management comfortable with your knowledge of the APA language, scope and requirements? 3. Have you had APA problems such as missing a notice letter requirement or involving Conoco when necessary? INCIDENT RESPONSE/PREVENTION 1. Have you evaluated your processes for release potential to impact off-site areas? 2. Have you done any emergency release modeling? 3. Have you done any release mitigation work? 4. Who does the release reporting at the plant? 5. Does the plant have a formal in-house notification procedure for release events? 6. Does the plant do post release reviews? a) Who participates? b) What is done with the results? REGULATORY TRACKING 1. How does the plant stay aware of federal regulatory developments? 2. How does the plant stay aware of state regulatory developments ? 3. Who is responsible for regulatory information dissemination? 4. How does the plant address new regulatory needs? 5. Do you receive enough information to assure compliance with regulations? VVV 000008648