Braun Intertec performed an EHS Compliance Audit of the Terminal to identify potential compliance gaps related to environmental and occupational health and safety regulations. Two Braun Intertec auditors conducted the five-day facility audit.

The audit scope included an evaluation of compliance with the following federal regulations and programs in addition to associated Indiana Department of Environmental Management (IDEM) regulations.

• Clean Air Act (CAA) / Air Emissions and Permitting
• Resource Conservation and Recovery Act (RCRA)/Hazardous & Non-Hazardous Waste Generation & Recycling
• Emergency Planning and Community Right to Know (EPCRA) / Reporting
• Stormwater Multi Sector General Permit (MSGP) Compliance
• Hazardous and Non-Hazardous Waste Management
• Hazardous Materials Management
• SPCC and Release Reporting Requirements
• Aboveground Storage Tank Permitting/Registration
• Tier II Reporting
• Toxics Release Inventory (TRI) Reporting
• Risk Management Plan (RMP)

The health and safety portion of the audit assessed compliance with the following OSHA regulations and programs:

• Process Safety Management (PSM)
• Contractor Safety
• Welding, Cutting, and Brazing/Hot Work
• Accident Reporting and Investigation
• Accessing Medical Records
• Confined Space Entry (Permit Required Spaces)
• Bloodborne Pathogens
• Control of Hazardous Energy (Lockout/Tagout)
• Electrical Safety
• Emergency Action Plan
• Fall Protection / Walking Working Surfaces
• Fire Prevention
• Hazard Communication (HazCom)
• Hearing Conservation
• OSHA Recordkeeping
• Personal Protective Equipment (PPE)
• Powered Industrial Trucks (PIT)
• Respiratory Protection
• Machine and Equipment Safeguarding
• Flammables and Combustibles
• Compressed Gases
• Slings, Hoists, and Cranes

The regulatory data gaps identified during the audit were documented in a summary table “Environmental Health and Safety Compliance Gaps Summary”.