Are You Ready For Your Next Air Quality Facility Inspection? Inspection Categories

Transcription

1 Are You Ready For Your Next Air Quality Facility Inspection? Inspection Categories 1. Announced (scheduled in advance) 2. Unannounced (surprise inspections) 1

2 Different types of inspections Pre construction permitting, Operating permit compliance, Incident investigation, Sample collection, Source testing observation, Continuous Emission Monitoring (CEM) validation Annual compliance certification, and Multi media audit. Preparing for an Inspection? Things To Remember: 1. Most violations are for what the company didn t do. Not what they did. 2. NOVs for failure to keep adequate records 3. NOVs for failure to report on time. 4. Anything the Agency observes during the inspection will likely be part of their report and possibly result in an NOV. 2

3 Preparing for the Inspection 1. Conduct a thorough review of the facility s operating permit and unincorporated preconstruction permits. 2. Pay special attention to any specific sources that have been identified by the regulatory Agency for the inspection. 3. Make certain that any records that are required by the facility operating permit are available for the inspection. 4. Review the records for completeness. 5. Review the records for errors and unreported violations. Preparing for the Inspection 1. Facility personnel should conduct a pre inspection walk around of the plant, as if doing a real inspection. 2. Verify that all equipment and air quality monitoring equipment is operating properly. 3. Verify that all daily/weekly process logs are available. 4. Observe the plant housekeeping conditions. Indications of spills, discoloration on buildings near exhaust points, and spills show general bad housekeeping and possible control problems. 5. Check for new sources that have not been permitted. 3

4 Preparing for the Inspection 1. The Agency will collect material samples such as fuels, raw materials, or consumables; especially those containing volatile organic compounds (VOCs). 2. The facility should have sampling acceptable containers to take duplicate samples of whatever the Agency collects. 3. If visual emission observations are required by the operating permit, the facility should have a certified reader to take readings along with the Agency. 4. The facility should make certain that key plant personnel are available. The Inspection 1. Be cooperative and friendly, the Agency personnel are justdoing their job. 2. Make a good impression by looking prepared and organized, primarily because you are prepared. 3. Plant environmental personnel should clear their schedule so as to not be rushed and answer to allow time to answer all of the Agency s questions. 4. Know where all the facility records are located. Better yet, records should be available for review by the Agency. For scheduled inspections this can save a lot of time and it makes the inspection go smoother. 4

5 The Surprise Inspection 1. Usually this can be anticipated, and not be a surprise. 2. If the facility recently received an NOV or has a history of non compliance, an unscheduled inspection is almost guaranteed. 3. Unscheduled inspections are often made for a followup to check on corrective actions, and where new source installations are on going. 4. Expect unscheduled inspections of facilities that are on the Agencylist of priority source categories. Checkthe Agency websites, press releases and public notices. Look for patterns in enforcement actions taken by the Agencies. The Surprise Inspection 1. A scheduled inspection can turn into a surprise inspection if you do not understand the intended extent tof the inspection. 2. Even if the agency tells you the inspection is routine, if the U.S.EPA accompanies the local agency it is never routine. 3. Things go wrong even during scheduled inspections. Have additional staff scheduled to help out if needed. 4. Routine and timely QA/QC for daily, weekly and monthly recordkeeping pays you back big time when a surprise inspection happens. 5

6 After the Inspection 1. Plan for and request the Agency to sit down with you for an after inspection debriefing. 2. Try to answer all of the Agency questions during the inspection. 3. If there is a need for follow up information to be sent to the Agency, it is important to clearly understand what is being requested and the timeframe for supplying the information. The facility could ask to get the request in writing if needed. 4. If there were problems during the inspection, provide a written report to the Agency to explain what happened as soon as practical. 5. And if there were problems, expect a surprise follow up inspection. 6