Practical Aspects of Thorough and Effective Inspections Reasons

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Practical Aspects of Thorough and Effective Inspections

Practical Aspects of Thorough and Effective Inspections

Reasons for Thorough and Effective Inspections • • • Identify problems Assess compliance with

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

Pre-inspection Activities • Define the inspected facility’s processes • Determine the types of products

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

 • Determine the types of equipment utilized in the processes • Use or

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

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

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

 • Review requirements of permits and permit applications • Determine applicable regulations, limits

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

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

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

 • Residential area- potential source of complaints due to odors, visible emissions, fugitive

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

 • Other industrial/commercial sites in area – may contribute or be true source

• 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.

Onsite and Entrance Meeting Activities • Discuss inspection with involved personnel. • Discuss preliminary

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

Onsite and Entrance Meeting Activities (Cont’d. ) • Resolve question related to stacks. Exhausts

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

 • Request what information you need for later review (i. e. Raw material

• 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).

 • Finally, “most important” discuss safety issues. • What types of safety equipment

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

 • Finally, “most important” discuss safety issues (continued). • Emergency rescue evacuation locations?

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

Facility Inspection Tour • Process-flow tour of facility • Start with receiving and raw

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

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

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

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

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

 • Assembly areas (welding, soldering, gluing, etc. ) • Product storage, loading and

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

Facility Inspection Exit Meeting • Discussion of inspection observations • Resolve questions regarding exhaust

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

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

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

 • Compare equipment identified on permits with equipment observed during the inspection and

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

 • Conduct one last area surveillance and return to facility to resolve any

• 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

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

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

Inspection Report Cont’d. • Start with a draft, complete as much of the report

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

 • Include other observations, information, findings and conclusions that may not be directly

• 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

Final Comments • Remember, the most important aspect of conducting a thorough and effective

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

Final Comments Cont’d. • Starting and focal points of strategy is the purpose of

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

 • Take notes, do not rely on memory of what you have seen,

• 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

Additional Training Resources • U. S. EPA Education and Outreach Group http: //www. gov/oar/oaqps/eog

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