Developing an In-House Air Quality Audit Program

March 22, 2006

Judy B. YorkeYorke Engineering, LLC

949-248-8490 x25JYorke@YorkeEngr.com

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!

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