Developing an In-House Air Quality Audit Program March 22, 2006 Judy B. Yorke Yorke Engineering, LLC x25

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 Program Select audit team Find applicable regulations Develop audit checklists Audit for compliance Develop corrective action plan 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 StaffPlant Personnel

Finding Applicable Regulations California Health and Safety Code Agency Policy Statements Gas Company Audit Checklists Local Agency Rule Books Federal Register

Developing Audit Checklists - General Requirements Involve the audited facility Include verification methods Build in documentation methods Audit Checklist Involve the audit team

Developing Audit Checklists - Content Audit Check list User-Friendliness User’s knowledge of regulations User’s access to regulations Avoid jargon Customize for your equipment, products

Developing Audit Checklists - Content Audit Check list 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 Check list Audit Components Specific equipment information Compliance question and answer Regulatory or other citation & date Verification steps Compliance plan

Developing Audit Checklists - Content Audit Check list 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 Check list Multiple Facilities Modular format Allows customization

Developing Audit Checklists - Ongoing Audit Check list Updating Checklists Who’s responsible? How often are they updated? How are regulatory changes incorporated?

Conducting an Audit – The Process Get familiar with 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 inspect plant Confirm possession of permits Review permit conditions Review emission limits Review rule com- pliance Snoop Around! 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 action plan 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 people on board educate staff on Title V give staff training and time to maintain compliance Staff responsibilities responsible official obligations explain penalties give them time to audit recognize/ reward identification and correction of noncompliance recognize and reward “clean” audits recognize and reward just doing audits!

Get Help When You Need It The Gas Company is Committed to Assisting their Customers - Call the AnswerLine Find a knowledgeable third party – choose carefully and check references!