FIT Service Specialty: Improving the Environmental Program

A great deal of effort and resources are used to ensure environmental compliance at most process industry plants. FIT provides specialty consulting services, review and audits of environmental programs to facilitate superior environmental performance and to minimize risk of non- compliance. Environmental excellence supports and encourages excellence in reliability, capacity utilization and other critical operational and business metrics as well as employee morale and community acceptance of industry.

The review and audit focus on the performance against regulatory requirements as well as site- specific permits and requirements. Current programs and performance will be benchmarked against industry “Best Practices”.

FIT consultants will initiate the process by meeting with key management personnel to define expectations and determine the scope of the review. In some cases, the review or audit will be initiated by the site’s legal counsel, which will direct the scope and coverage.

Generally speaking, the program review or audit will consist of two parts:

• Permit / Documentation Status
  After a site tour and general overview of the site, FIT consultants will review the applicability of regulations, status of permit activities, required documentation and record-keeping, data collection methodology, exemption documentation, and required reports for air emissions, water use, water treatment and wastewater discharge, waste generation, treatment and disposal activities. This review will involve meeting with site environmental personnel as well as select operations, maintenance, laboratory and logistics personnel, assessment of documentation, and resolution of any discrepancies found.
  
• Compliance Status
  As a second step, FIT will review data, emission factors and measurement methods, calculations, and record keeping in sufficient detail to ensure that compliance with the permit requirements can be validated. This step often involves visiting regional or state environmental regulatory agencies to ensure that the regulatory entities are aware of site efforts toward compliance and that required reporting is being done. In some cases, regional EPA offices may be visited instead of or in addition to the state agencies.
  
  A selected number of interviews with site personnel will also be conducted to assess the site personnel’s understanding of requirements and responsibilities.
  
  Site environmental personnel will be kept up to date as frequently as possible. Site management will be kept up to date by daily reviews of progress and clarification of questions or issues should be initiated at those meetings. The intent is to provide a cooperative environment in which questions can be addressed and resolved, not an antagonistic investigation.

The second part of the Personnel Safety program the FIT consultants is the perceptions of the employees of the program. This portion of the review takes the view that "perception is reality". The FIT consultants will identify the range of employee views and the predominant view. In many cases the employees? view of the program is far different from what is intended. Employees may be reluctant to express their views to the local management or the management can become numb to the same old gripes. Use of "outside ears" can be helpful in finding the employees views.

As appropriate, recommendations will be developed for improvements to the program and remedies for any issues identified during the review/audit.

A preliminary report on findings and recommendations of the review will be provided, usually on the afternoon of the next-to-last day.

At the end of the process a comprehensive audit report will be prepared and submitted to the site, or the site’s Legal Counsel, and a final meeting will be held with site personnel. The report may or may not compare the site’s practices to industry-accepted best practices and may or may not offer potential means for addressing any problems found during the review/audit – these features will be determined in the original scope determination meeting. If the site desires the potential solutions to be included, the report will also include rough estimates of timing and cost for those remedies. The meeting will be based on a summary of the audit report, with examples where appropriate, and the site will be provided with an electronic copy of the meeting presentation.