developing an in-house air quality audit program
DESCRIPTION
Developing an In-House Air Quality Audit Program. March 22, 2006 Judy B. Yorke Yorke Engineering, LLC 949-248-8490 x25 [email protected]. Developing an Audit Program. What is an audit program? How do I put together an audit program? strategies audit team checklists auditing. - PowerPoint PPT PresentationTRANSCRIPT
Developing an In-House Air Quality Audit Program
March 22, 2006
Judy B. YorkeYorke Engineering, LLC
949-248-8490 [email protected]
Developing an Audit Program What is an audit program? How do I put together an audit
program? strategies audit team checklists auditing
Why do I need an audit program? Annual Certification responsibilities
Title V Citizen suits Agency enforcement
subject to prosecution by both local and federal agencies
administrative, civil, and criminal
Preventing Problems…
Why do I need an
audit program?Make sure your facility complies with regulations
Avoid fines and citations
Meet the compliance certification requirement
Make sure your responsible official
is comfortable
Plan corrections, additions, improvements
to your permits
What’s the Bottom Line? An great environmental audit will:
Improve plant profitability, by: Lowering compliance costs, and Increasing operating flexibility.
Lower compliance liability, by: Correcting problems, Assuring due diligence for certifications.
What an audit is – or is not!
Systematic Demonstrates compliance Rigorous Critical to planning
improvements to your compliance program
An audit is:
… But an audit is NOT Confidential
Setting up an Audit ProgramSelect audit team
Find applicable regulations
Develop audit checklists
Audit for compliance
Develop corrective actionplan Certify to
compliance
Putting Together an Audit Team
Detached and objective
Less familiar with plant
Ask “Why?” Understands
requirements
Critical to day-to-day compliance
Knowledgeable about plant
Understands impacts of imposed requirements
Has ideas about improvements or changes needed
Environmental Staff Plant Personnel
Finding Applicable Regulations
California Health and Safety Code
Agency Policy Statements
Gas Company Audit Checklists
Local Agency Rule BooksFederal Register
Developing Audit Checklists - General Requirements
Involve the audited facility
Include verification methods
Build in documentationmethods
Audit ChecklistInvolve the audit team
Developing Audit Checklists - Content
Audit Checklist
User-Friendliness
• User’s knowledge of regulations
• User’s access to regulations
• Avoid jargon• Customize for
your equipment, products
Developing Audit Checklists - Content
Audit Checklist
Items to Audit
• MRR requirements
• Permit conditions
• Trouble spots – violations, breakdowns, etc.
• Company policies•Who develops policies?•Who carries them out?
• Operator knowledge
Developing Audit Checklists - Content
Audit Checklist
Audit Components
• Specific equipment information
• Compliance question and answer
• Regulatory or other citation & date
• Verification steps
• Compliance plan
Developing Audit Checklists - Content
Audit Checklist
Resources Needed
•Text of regulations•Permits•Working knowledge of plant•Past compliance information
•Company policies•Back-up resources
•Legal•Technical
Developing Audit Checklists - Content
Audit Checklist
Multiple Facilities
•Modular format•Allows customization
Developing Audit Checklists - Ongoing
Audit Checklist
Updating Checklists
• Who’s responsible?
• How often are they updated?
• How are regulatory changes incorporated?
Conducting an Audit –The Process
Get familiarwith plant
Check paperwork
Interview plant
personnel
Test conclusions
Conducting an Audit – The Process
Build rapport Use everything: monitoring data, reports,
interviews, inspections, instincts Exhaust all lines of inquiry Verify major findings Document what you checked, what
results were Document what allows you to determine
compliance
Conducting an Audit – Items to Check
Visually inspectplant
Confirm possession of permits
Review permit
conditions
Review emission
limits
Reviewrulecom-
pliance
SnoopAround!
•Rule 219 Exempt•RECLAIM•Title V
•NOVs/NTCs•Source Tests•Variances•Abatement Orders•Audit Reports•Complaints•Interviews
Briefing the responsible official
Build rapport Focus on facts May need to explain regulations Develop solutions together
How should past noncompliance be treated? EPA policy Certify to ongoing, not
intermittent, compliance Some historical violations have
current implications
Must a source disclose noncompliance? Title V facilities are required to self-
report May need variance to make ongoing
certification Other reporting requirements
Rule 430 breakdown conditions reporting requirements may need a variance
Preparing a Compliance Plan Need for a compliance plan
Helps avoid “smoking gun” Required by Title V
What to include Specific regulatory citation What actions will be taken to achieve
compliance Date at which compliance will be achieved
May need to get variance May need permit application
Ongoing Compliance Assurance
Revisit audit team selection
Update applicable regs
Update audit checklists
Audit for compliance
Develop corrective actionplan Certify to
compliance
Ongoing Compliance Assurance
Frequency Meet Title V requirements consider results of past audits complexity of operation/likelihood of problems may want to do “spot” audits consider EPA audit policy
Updating checklists make sure regulations haven’t changed first one after Title V application is completed:
make sure all your permit conditions are included
Making Compliance Second Nature Build Auditable Systems
consider setting up internal systems to make auditing easier
regular recordkeeping regular inspections and logging of
inspections Management Attitude
Audit protects company, employees Avoid scape-goating
Making Compliance Second Nature
Get plant peopleon board
educatestaff onTitle V
give staff training and time to maintain
complianceStaff
responsibilities
responsibleofficial
obligations
explainpenalties
give them time to audit
recognize/reward
identification and correction of
noncompliance
recognizeand reward
“clean”audits
recognizeand rewardjust doing
audits!
Get Help When You Need It
The Gas Company is Committed to Assisting their Customers - Call the AnswerLine - 562-803-7428
Find a knowledgeable third party – choose carefully and check references!