Jon Konings Audit Survivor

Transcription

1 Jon Konings Audit Survivor

2 Prepared in 2003 A little out of date but it is currently being updated It s a great resource for explaining the measurement technologies used in today s P75 CEMS Has 8 sections 2

3 It s being updated by EPA It needs to reflect how ECMPS is used today to support the audit process The PGVP needs to be rolled into the manual The require ments on using AETB 3

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5 The manual provides an insight to what the EPA is expecting from those who are operating CEMS and COMS. Using the field manual as a guide or tool is a low cost way of staying in good shape and staying out of compliance trouble. Many companies periodically conduct internal audits to make sure they are staying focused and not drifting off track. Some companies also bring in outside consultants to perform periodic audits or assessments. 5

6 The manual has eight (8) sections to it and 11 (eleven) check lists prepared for performing various types of audits. Section 1 introduces the P75 program, the role of field audits and the inspector, the importance of inspector training, and a list of key materials with Internet links to them. These are an excellent resources to help people new to the CEMS field. Section 2 provides a short introduction to the various types of CEM systems and the components of a CEMS, including the basis for installations and operating principles. This is an EXCELLENT resource of background information. 6

7 Section 3 describes preparing for an audit prior to the plant visit, with emphasis on using CAMD s Monitor Data Checking (MDC)* software to review electronic data. * MDC preceded ECMPS. Section 4 covers the on-site CEM inspection, including what to look for and questions to ask during a walk through of the CEM components, as well as how to review the QA/QC plan and other in-plant records. This is a KEY section to review Section 5 describes how to observe CEMS performance tests, such as linearities and relative accuracy test audits (RATAs). 7

8 Section 6 outlines specific on-site review procedures for Appendix D and E monitoring systems and records. Section 7 guides you in conducting the exit interview and preparing a written audit report. Section 8 discusses issues that should be considered by a state or local agency in developing a performance testing program, with emphasis on single gas challenges and linearity tests. 8

9 These checklists provide an excellent opportunity to compare your written procedures to the requirements that audits are looking for. The audit manual and checklists constantly reference your QAQC plan, and the required contents of that plan, for your facility. The P75 regulations require facilities operating CEM/COMS systems to have developed a QAQC plan, which includes written procedures for performing the various quality assurance checks. Many states require these plans to be submitted for their review and approval. Are yours? 9

10 Pre-audit Preparation CEMS Inspection Sheet Daily Calibration Error Test Observation Sheet Linearity Test Observation Sheet Gas RATA Observation Sheet Flow RATA Observation Sheet Relative Accuracy Equations Appendix D Inspection Sheet Appendix E Inspection Sheet Sample Standard Operating Procedure for Linearity Tests Sample Calibration Gas Cylinder Tracking Form 10

11 I would use the checklists that are relevant to your facility and compare them against: Your Monitoring Plan as found in ECMPS. Make sure the serial number and span/ranges settings agree. Your daily or weekly data review procedures. The Quality Assurance/Quality Control Plan required by Part 75, Part 60, Part 63, and your operating permit. Any procedures that address compliance or how to handle outside auditors and/or visitors. 11

12 Written procedures for: Performing routine quality assurance checks, such as daily calibrations, quarterly linearities or cylinder gas audits. Performing preventative maintenance and record keeping. Reviewing emissions data generated by the system and how to react to the data recorded. Annual or infrequent performances tests, such as RATAs, NOx Correlation Testing, fuel flow meter calibrations, or primary element inspections. 12

13 Written procedures for: Reacting to permit deviations (i.e. exceedances). In some cases, the facility might be required to notify the agency within a specific time frame (within 24 hours). Operating any add on controls to reduce or minimize emissions. Preparing quarterly or periodic performance reports, which are submitted to local environmental agency. Compare your written procedures to the requirements outlined in these checklists. These checklists are telling you what the EPA is expecting from your procedures. 13

14 Be sure you are familiar with it: When was the last time it was reviewed and updated. When this review occurred should be documented into the plan. It is your commitment on how you are going to operating and react to the CEM systems you facility is operating. Therefore, it is the BIBLE that an auditor is going to use to evaluate your performance during an audit. Make sure it is your Friend and not your worst Enemy. Be sure it listed other support resources available to help you, such as your OEM manuals, training materials, etc. Prove to the auditor that you know what you are doing. 14

15 Warning: I have seen a lot of crappy plans. They include a lot of junk that has no business being in these plans. Things such as: Bill of materials used to build the instrument racks or the shelter itself. (gauge of steel, wire sizes, listing of all labels used in the shelter, etc. A complete copy of the P75 regulations (not needed). Copy of the Title V operating permit. Copy of the Acid Rain permit. This plan really needs to reflect how you operate your CEMS/COMS and other related equipment. 15

16 There are three levels of audits all include a site visit Level 1 mostly a review of electronic records; a site visit would include observing or watching the daily calibration. Level 2 similar to level 1, but observing a linearity or a RATA is included in a site visit. Level 3 it goes further and involves agency personnel conducting a performance test instead of merely observing the test. Level 3 tests are usually performed by EPA personnel and seldom involves the states. 16

17 Lessons I learned from audits Your plant should have a plan or procedure for handling an audit. Most audits are scheduled in advance. If the EPA or a state contacts you about having an audit, notify your senior management immediately! Notify senior plant management when the auditor arrives on site and when they leave. Once an auditor is on site, anything they see, hear, smell or hear can trigger an investigation. So be careful. Avoid unnecessary activities. 17

18 Lessons I learned from audits - 2 Don t go into this alone. Always have at least two people from your company participating in the audit. Contact your corporate people to make them aware of when this audit occurring and seek their help and support. If the auditor asks for copies of any documents, keep a list of what documents they are given. Be sure you know and understand your company s policy is on photographing. Some companies have policies against allowing photos. 18

19 Lessons I learned from audits - 3 Have your QAQC plan handy as a reference. Some facilities have a separate manual of procedures, referenced by the QAQC plan. Watch what you say. Stick to the facts and don t offer opinions or make small talk. Your goal during the audit is to make sure the auditor recognizes that you know what is required to operate a CEMS/COMS and that you know what to do, when to do it, and how to react to whatever occurs. 19

20 Lessons I learned from audits - 4 It s OK to say I don t know. Let me check into that and get back to you. One issue that frequently comes up in audits are the record keeping requirements. It can be very difficult to keep all the records required every day. Auditors frequently ask about training records. Training records show your intent and plan on staying current in your knowledge and skills, and your desire to do a good job. Volunteer nothing!! 20

21 Lessons I learned from audits - 5 Ask the auditor if you can get a copy of the draft version of their report. Tell them your intent is to make sure the facts included in the report are accurate. Once a report is finalized, it is nearly impossible to change facts, even if they are wrong. Some auditor won t share their draft reports. The requirement for good maintenance records isn t limited to just CEMS/COMS. Hardware which provides a signal or an input into the CEMS like fuel flow meters, critical orifice plate inspections, thermocouples calibrations need to be documented. 21

22 Lessons I learned from audits - 6 At the end of the audit, conduct an exit interview. Ask if there are any outstanding issues that need follow up attention. Review your list of questions that you promised to provide follow up answers. Provide written or answers within 48 hours. Watch very carefully what comments are recorded in your maintenance records or in log books. Stick to the facts. Coach others about what is recorded in the log books. 22

23 Use the manual to make sure your QAQC plan measures up! Review your written procedures and compare then against what is called out by the field manual and the checklists. Have practice audits to prepare yourself for the real thing! 23

24 There is no excuse to allow yourself to fail an audit. Use the resources available to prevent a failure. Jon Konings jkonings@envirosys.com 512/