Practical Aspects of Thorough and Effective Inspections.

Practical Aspects of Practical Aspects of Thorough and Thorough and

Effective Effective InspectionsInspections

Reasons for Thorough and Reasons for Thorough and Effective InspectionsEffective Inspections

• Identify problemsIdentify problems

• Assess compliance with regulations Assess compliance with regulations • Evaluate the potential for problemsEvaluate the potential for problems

Pre-inspection Pre-inspection ActivitiesActivities

• Define the inspected facility’s Define the inspected facility’s processesprocesses

• Determine the types of products Determine the types of products manufactured or producedmanufactured or produced

• Determine the types of equipment Determine the types of equipment utilized in the processesutilized in the processes

• Use or raw materials and cleaning Use or raw materials and cleaning solventssolvents

• Determine waste streamsDetermine waste streams

• Obtain process flow diagram and Obtain process flow diagram and plant layoutplant layout

• Review requirements of permits Review requirements of permits and permit applicationsand permit applications

• Determine applicable Determine applicable regulations, limits based on the regulations, limits based on the type of industry or individual type of industry or individual operations within facilityoperations within facility

• Compliance history ( Caution, not Compliance history ( Caution, not pre-judgment) pre-judgment)

• Problem areas (Noncompliance Problem areas (Noncompliance history)history)

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

• Area Surveillance Area Surveillance

• • Other industrial/commercial sites in Other industrial/commercial sites in area – may contribute or be true area – may contribute or be true source of emissions or odors as part source of emissions or odors as part of a complaint investigation.of a complaint investigation.

• Observe and sketch diagram of stack Observe and sketch diagram of stack and wall exhausts. and wall exhausts.

Onsite and Entrance Onsite and Entrance Meeting ActivitiesMeeting Activities

• Discuss inspection with involved Discuss inspection with involved personnel. personnel.

• Discuss preliminary assessment of Discuss preliminary assessment of facility based on pre-inspection facility based on pre-inspection information gathered.information gathered.

Onsite and Entrance Onsite and Entrance Meeting Activities Meeting Activities

(Cont’d.)(Cont’d.)• Resolve question related to stacks. Resolve question related to stacks.

Exhausts points, emissions or odors Exhausts points, emissions or odors observed and permits. observed and permits.

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

• • Finally, “Finally, “most important” most important” discuss safety discuss safety issues.issues.

• • What types of safety equipmentWhat types of safety equipment are required or needed ? are required or needed ? • • Areas of particular caution ? Areas of particular caution ?

• • Finally, “Finally, “most important” most important” discuss safety discuss safety issues (continued).issues (continued).

• • Emergency rescue evacuationEmergency rescue evacuation locations?locations? • • Meteorological (i.e. precipitation,Meteorological (i.e. precipitation, lighting, heat, cold, etc.) related lighting, heat, cold, etc.) related issues for outdoor inspections?issues for outdoor inspections?

Facility Inspection TourFacility Inspection Tour

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

Facility Inspection Tour Facility Inspection Tour Cont’d.Cont’d.

• • Material preparation areas (i.e.Material preparation areas (i.e. cutting, grinding cleaning, cutting, grinding cleaning, degreasing, etc.). degreasing, etc.).

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

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

Facility Inspection Exit Facility Inspection Exit MeetingMeeting

• Discussion of inspection observationsDiscussion of inspection observations• Resolve questions regarding exhaust Resolve questions regarding exhaust

points, observed emissions, process points, observed emissions, process equipment, control equipment, storage equipment, control equipment, storage activities and detected odorsactivities and detected odors

Facility Inspection Exit Facility Inspection Exit Meeting Cont’d.Meeting Cont’d.

• Review records and information Review records and information requested during entrance requested during entrance meeting meeting

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

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

Inspection ReportInspection Report

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

Inspection Report Cont’d.Inspection Report Cont’d.

• Start with a draft, complete as much Start with a draft, complete as much of the report as possible, even if all of the report as possible, even if all the data is not yet available the data is not yet available

• Remember the purpose of the Remember the purpose of the inspection in writing the reportinspection in writing the report

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

Final CommentsFinal Comments

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

approachapproach

Final Comments Cont’d.Final Comments Cont’d.

• Starting and focal points of strategy Starting and focal points of strategy is the purpose of the inspectionis the purpose of the inspection

• Avoid tunnel vision; be observant Avoid tunnel vision; be observant and cover as many aspects of the and cover as many aspects of the facility as possiblefacility as possible

• Take notes, do not rely on memory of Take notes, do not rely on memory of what you have seen, questions you what you have seen, questions you may want to ask and points you want may want to ask and points you want to cover.to cover.

• Having notes and diagrams can Having notes and diagrams can make a complicated inspection more make a complicated inspection more manageable and effectivemanageable and effective

Additional Training ResourcesAdditional Training Resources

• U.S. EPA Education and Outreach GroupU.S. EPA Education and Outreach Group http://www.gov/oar/oaqps/eoghttp://www.gov/oar/oaqps/eog• • U.S. EPA Compliance and EnforcementU.S. EPA Compliance and Enforcement hhttpttp://www.://www.govgov/compliance/compliance • LADCO - LADCO - http://64.27.125.175/http://64.27.125.175/• Other Consortiums’ Training CoursesOther Consortiums’ Training Courses