Practical Aspects of Thorough and Effective Inspections

1. Practical Aspects of Thorough and Effective Inspections

2. Reasons for Thorough and Effective Inspections • Identify problems • Assess compliance with regulations • Evaluate the potential for problems

3. Pre-inspection Activities • Define the inspected facility’s processes • Determine the types of products manufactured or produced

4. Determine the types of equipment utilized in the processes • Use or raw materials and cleaning solvents

5. Determine waste streams • Obtain process flow diagram and plant layout

6. Review requirements of permits and permit applications • Determine applicable regulations, limits based on the type of industry or individual operations within facility

7. Compliance history ( Caution, not pre-judgment) • Problem areas (Noncompliance history)

8. Residential area- potential source of complaints due to odors, visible emissions, fugitive dust and noise. • Area Surveillance

9. • Other industrial/commercial sites in area – may contribute or be true source of emissions or odors as part of a complaint investigation. • Observe and sketch diagram of stack and wall exhausts.

10. Onsite and Entrance Meeting Activities • Discuss inspection with involved personnel. • Discuss preliminary assessment of facility based on pre-inspection information gathered.

11. Onsite and Entrance Meeting Activities (Cont’d.) • Resolve question related to stacks. Exhausts points, emissions or odors observed and permits.

12. Request what information you need for later review (i.e. Raw material usage, material safety data sheets, records regarding compliance or required by permit conditions).

13. • Finally, “most important” discuss safety issues. • What types of safety equipment are required or needed ? • Areas of particular caution ?

14. • Finally, “most important” discuss safety issues (continued). • Emergency rescue evacuation locations? • Meteorological (i.e. precipitation, lighting, heat, cold, etc.) related issues for outdoor inspections?

15. Facility Inspection Tour • Process-flow tour of facility • Start with receiving and raw material storage (i.e. tank identity, capacity and stored material).

16. Facility Inspection Tour Cont’d. • Material preparation areas (i.e. cutting, grinding cleaning, degreasing, etc.).

17. • Formulation areas (reactors, mixing vessels, heat treating spraying, lamination, baking coating, etc.).

18. • Assembly areas (welding, soldering, gluing, etc.) • Product storage, loading and packing • Identify waste streams

19. Facility Inspection Exit Meeting • Discussion of inspection observations • Resolve questions regarding exhaust points, observed emissions, process equipment, control equipment, storage activities and detected odors

20. Facility Inspection Exit Meeting Cont’d. • Review records and information requested during entrance meeting

21. Compare equipment identified on permits with equipment observed during the inspection and resolve differences and the need for additional permit applications

22. Conduct one last area surveillance and return to facility to resolve any questions or concerning stacks, control equipment, emissions, odors, etc. and return to facility if necessary

23. Inspection Report • Review all the information (notes observations, data, calculations, etc.) gathered about the facility

24. Inspection Report Cont’d. • Start with a draft, complete as much of the report as possible, even if all the data is not yet available • Remember the purpose of the inspection in writing the report

25. Include other observations, information, findings and conclusions that may not be directly related to original purpose, but which have a direct impact on facility compliance issues

26. Final Comments • Remember, the most important aspect of conducting a thorough and effective inspection is to develop an organized plan of approach

27. Final Comments Cont’d. • Starting and focal points of strategy is the purpose of the inspection • Avoid tunnel vision; be observant and cover as many aspects of the facility as possible

28. Take notes, do not rely on memory of what you have seen, questions you may want to ask and points you want to cover. • Having notes and diagrams can make a complicated inspection more manageable and effective

29. Additional Training Resources • U.S. EPA Education and Outreach Group http://www.gov/oar/oaqps/eog • U.S. EPA Compliance and Enforcement http://www.gov/compliance • LADCO - http://64.27.125.175/ • Other Consortiums’ Training Courses