1. Region 4 Air Directors Spring Meeting May 20, 2015
Inspection Oversight
Todd Russo
EPA Region 4

2. Inspection Oversight
OECA’s National Program Guidance states that EPA will conduct oversight inspections to ensure integrity and quality of State/Local Agency compliance monitoring programs
New activity for the Air Enforcement Program starting soon – Inspection Oversight.
Background

3. Inspection Oversight
Region 4 Annual letter sent to the Commissioners states that the Region will fulfill its oversight responsibilities by conducting oversight inspections
Annual letter (9/15/14) about Enforcement activities for the upcoming FY (national and regional priorities).
All big Programs (Air, Water, RCRA)

4. Inspection Oversight
Determine the effectiveness of the State/Local Agency inspection activities as it relates to the existing air permit requirements
What is an oversight inspection – EPA inspector observing a S/L inspector during an inspection
We’ll verify that the S/L inspector takes the necessary steps to be able to accurate determine as to whether or not the source is complying with each requirement in the permit.
EPA will not be making an independent compliance determination but rather checking to see S/L inspector conducts a thorough and complete inspection to be able to make an accurate compliance determination.

5. Inspection Oversight
EPA management will contact State/Local Agency Management prior to oversight inspection
Contact to discuss objectives and logistics of the oversight inspection.
Ask for a copy of any inspector training manual and inspector SOP.

6. Inspection Oversight
State/Local Agency management may select the sources to be inspected
One major source
One synthetic minor source
EPA may suggest a source
Typically, 2 oversight inspections minimum.
Don’t want too simple of an inspection (only 2 permit requirements) – moderate level of complexity – variety of permit requirements.
FCE should be conducted; however, we can discuss the need to conduct a PCE. (FCE is all permit requirements).

7. Inspection Oversight
State/Local Agency management may select the State/Local inspector(s) to be observed
1 inspector for both or 2 inspectors.

8. Inspection Oversight Consist of the Following:
Pre-Inspection Preparation
Onsite Inspection
Post Inspection Activities
Ex - Pre – EPA/S/L meet before - reviewed and familiar with permit requirements, process emission points, the process equipment, review reports, source files, etc.
Onsite – air pollution control equipment (parameters, but also ductwork in good condition, does the capture system appear to be effectively capturing), read VEs if seen, CEMS, parametric monitoring, new process equipment not included in the permit, records.
The EPA inspector will not provide assistance during the inspection. Only observe.
EPA may offer advice on the side (not in front of facility reps).
EPA inspector will say at the beginning of the inspection that EPA is observing the S/L inspector and not conducting a compliance inspection.
Post – Prepare inspection reports (since inspection reports are evaluated during SRF, they will not be evaluated for this review), make compliance determination for each permit requirement, review T5 ACC and semiannual reports, all emission points identified.

9. Inspection Oversight
EPA inspector will use a Clean Air Act State/Local Program Oversight Inspection Form
6 page form that has questions and identifies the activities to be observed – EPA will document activities on the form during the oversight inspection.
Preinspect Ex – S/L familiar with air permit – review reports submitted by company
Onsite – conduct opening meeting – record parametric monitoring values – observe each capture/collections system
Post – review T5 ACC – prepare document that identifies potential violations or states that there are no violations for the permit requirements.
After inspection and after receive any other pertinent information (inspection report), we’ll send a draft of the form to S/L Management for review and comment, and discussion.
The final observation results will be sent to the S/L management via transmittal letter which will ask the S/L to address the observations and to provide us with a response about how the observations will be addressed.
If S/L inspector did not take the necessary steps to make an accurate compliance determination, then additional oversight may be needed.

10. Inspection Oversight
Conduct Oversight Inspections at State/Local Agencies that have been selected for the State Review Framework
Complete Oversight Inspections at four agencies by September 30, 2015
This is first round - Select S/L agencies - Conduct oversight inspections within 12 months of SRF. Not necessarily at same time.
If a need arises, we can select an agency not selected for SRF.
About 3 or 4 a year.
Conducting the oversight inspections close in time to the SRF may provide a more complete overall picture of the S/L compliance monitoring program.
2 State Agencies and 2 Local Agencies.

11. Inspection Oversight Kentucky Department for Environmental Protection
Mississippi Department of Environmental Quality
KY in December.
MS last week.

12. Inspection Oversight
Nashville-Davidson County Metro Public Health Department, Air Pollution Control
Jefferson County (Alabama) Department of Health
Nashville last year (Dec 2013, final report issued Apr 2015)
Reaching out to the 4 agencies soon to discuss the oversight inspections.
First year, so refine the process and make better.

13. Inspection Oversight
Questions