United States Air and Radiation EPA340/1-91-007
Environmental Protection (EN-341W) June 1991
Agency
vvEPA Inspection Protocol
and Model Reporting
Requirements For
Stationary Sources
Printed on Recycled Paper
-------
EPA 340/1-91-007
INSPECTION PROTOCOL AND MODEL REPORTING REQUIREMENTS
FOR STATIONARY SOURCES
U.S ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
June 1991
-------
CONTENTS
Section Page
CONTENTS i
1 INTRODUCTION 1
2 PRE-INSPECTION PREPARATION 3
2.1 Establish Inspection Objectives/Scope 3
2.2 Review Source Files 3
2.2.1 Availability of Source Files 5
2.2.2 Process Information 5
2.2.3 Previous Inspection Reports 5
2.2.4 Previous Enforcement Actions 6
2.3 Review Regulations and Others 6
2.3.1 Enforceable Limitations 6
2.3.2 Inspection Manuals 7
2.3.3 Compliance Determination Methods 7
2.3.4 Other Information 7
2.4 Assemble Inspection Material 7
3 ON-SITE INSPECTION 9
3.1 Pre-Entry On-Site Activities 9
3.1.1 Opening Interview 9
3.2 On-Site Records Review 11
3.2.1 Safety Review 12
3.3 Facility Inspection 12
3.3.1 Documentation and Sampling Equipment 12
3.3.2 Visible Emissions 13
3.3.3 Process Information 13
3.3.4 Control Equipment 13
3.3.5 CEM Evaluation 14
3.3.6 Sample Handling 14
3.4 Post Inspection On-Site Activities 14
3.4.1 Exit Interview 15
4 INSPECTION EVALUATION AND REPORT PREPARATION 17
4.1 Post Inspection Evaluation 17
4.2 Inspection Report 17
4.3 Standard Form 19
5 REFERENCES 21
Page i
-------
Appendices
A PRE-INSPECTION ACTIVITIES CHECKLIST A-1
B VISIBLE EMISSION OBSERVATION (VEO) FORM B-1
C INSPECTION GUIDE AND REPORT FORM C-1
Page ii
-------
SECTION 1
INTRODUCTION
This protocol provides guidance to
EPA and State inspectors and
supervisory staff in preparing for,
conducting, evaluating, and reporting on-
site compliance determination
inspections. It applies to State and EPA
permit inspections and state overview
inspections of any stationary source,
except asbestos demolition/renovation.
The EPA Clean Air Act Compliance/
Enforcement Guidance Manual1 specifies
five levels of EPA inspections, of which
Level 2 is considered to be the minimum
compliance determination inspection.
Additionally, the Compliance Monitoring
Strategy (CMS)* requires that the quality
of compliance inspections be Level 2 or
higher.
This protocol presents the minimum
requirements to ensure Level 2
inspections. It is aimed at developing
consistency among EPA inspectors in
terms of the level of inspections
conducted and information reported.
EPA encourages State and Local
inspectors to use this protocol. It
identifies the activities that would ensure
a thorough and complete inspection for
the determination of compliance with
applicable regulations.
Level 2 requires an on-site inspection,
in which current control device and
process operating conditions are
recorded in addition to visible emission
observations. It requires a review of
existing records and log books on
source operations, recording such
process information as raw material and
process throughput and compositions,
and recording control equipment design
and gas flow parameters. It does not
require the actual measurement of
process or flue gas conditions.
Of the remaining EPA inspection
levels, Level 0 is a "drive-by" inspection
conducted off the source's property and
is insufficient for compliance
determination. Level 1 is an on-site
inspection limited to the evaluation of
visible emissions and is recommended
only to enforce opacity standards.
Levels 3 and 4 are significantly more
complex and are designed to provide
detailed engineering analyses of source
compliance. Level 3 requires the
measurement of all control device
operating parameters, whereas the
monitoring of operating parameters and
emissions through stack testing is a
requirement of Level 4.
EPA inspectors who conduct Level 2
inspections must meet the requirements
of the Air-Specific Inspector Training Plan
(ITP)* developed by SSCD. These
requirements include a combination of
classroom training and on-site on-the-job
training with an experienced inspector in
inspection techniques and safety
procedures. EPA Order, 'Training and
Development for Compliance
Inspections/Field Investigators,"
Classification No. 3500.1, June 29,1988,
establishes an Agency-wide training and
Page 1
-------
development program for employees
leading environmental compliance
inspections/field investigations. It applies
to all EPA personnel who lead or oversee
the conduct of compliance
inspections/field investigations, and is
advisory to State and local agencies.
Applicable health and safety training and
respiratory protection are defined in EPA
Orders 1440.2 and 1440.3.
Chapters 2 and 3 of this report
present the procedures for conducting a
Level 2 compliance inspection grouped
into the pre-, on-site-, and post-
inspection activities. These activities are
intended to ensure that:
The compliance status of each source
to be inspected is determined in a
credible manner
A source in violation of regulated or
permitted emissions is not overlooked
Sources determined to be in
compliance with applicable emission
limitations have been thoroughly and
completely evaluated
In any type of inspection, a listing of
all activities to be performed in an
inspection allows the inspector to check
and verify that the preparation for and
the conduct of the actual on-site
inspection are thorough and complete.
Example checklist forms for various
inspection activities are presented in the
appendices. They can be partially
completed prior to the on-site inspection
and referred to during all phases of the
inspection to ensure that the minimally
acceptable data is obtained.
A model post-inspection report that
summarizes the findings and
recommendations following a Level 2
inspection is discussed in Chapter 4. All
of the relevant data that must be
documented in support of a compliance
determination are indicated and a
standard data presentation form is
suggested. The use of this model report
is recommended in order to maintain
consistency among the EPA inspectors
nationwide when reporting compliance
evaluations. It is also recommended for
state and local inspectors to simplify and
standardize reporting for review
purposes.
It is expected that inspectors, after
becoming completely familiar with the
inspection activities indicated in this
report, will be able to routinely use the
standard forms and the model inspection
report to ensure thorough and complete
compliance evaluations.
Those individuals interested in
learning the details of various other
inspection activities should refer to the
references presented in Chapter 5.
Page 2
-------
SECTION 2
PRE-INSPECTION PREPARATION
Prior to an on-site inspection, the
inspector must become as familiar as
possible with the facility to be inspected.
If the time spent on-site is to be effective
and efficient, the inspector must be
familiar with all process emission points
to be evaluated and the applicable
regulations and permit conditions. The
pre-inspection process involves a review
of all available background information
on the source and assembly of the
required inspection material.
As shown in Figure 2.1, pre-
inspection preparation can be divided
into four phases, each involving several
activities. They are: 1) Establishment of
Inspection Objectives/Scope, 2) Review
of Background Information Source Files,
3) Review of Regulations and Compliance
History, and 4) Assembling of Inspection
Material.
Once the necessary pre-inspection
activities are completed, the inspector
may assemble and arrange all the
information pertinent to the actual
inspection in a manner most suitable to
the individual's liking. The inspector will
use such information to review and verify
the data obtained during the actual on-
site inspection.
2.1 ESTABLISH INSPECTION
OBJECTIVES/SCOPE
Typically, inspections of stationary
sources are conducted to determine if
the source is in compliance with the
applicable regulations. Inspections are
also conducted to obtain information
necessary for verifying the appropriate-
ness of reissuing of any operating permit.
When EPA conducts an inspection to
determine compliance with any federally
enforceable emission standard or
limitation, EPA must give the State or
local air pollution control agency
reasonable prior notice of the inspection.
Defining specific objectives initially in
preparation of on-site inspections
establishes the correct framework for
conducting the entire inspection process.
The inspector will:
Determine what portions of the facility
must be emphasized during the
inspection
Prepare a list of the routine operating
records and logbooks which should
be requested during the pre-
inspection meeting
Review any permit conditions or
stipulations which should be verified
during the inspection
2.2 REVIEW SOURCE FILES
The source-specific files typically
available from the EPA Regional offices
and State agency offices provide
background information on the source
Pages
-------
Figure 2.1. Stationary Source Pre-lnspection Flow Chart
Establish Inspection Objectives / Scope
Review Source Files
Process / Pollutant Data
Previous Inspection Reports
Previous Enforcement Actions
Review Regulations
SIP Limits
NSR Limits
NSPS / NESHAP Limits
Alternative Compliance Plans (Equivalency or Bubbles)
Source, Control Device, and CEM Inspection Manuals
Compliance Methods
Applicable AP-42 Sections
Assemble Inspection Material
Applicable Operations Data Sheets
Applicable Control Device Data Sheets
Pertinent Information from:
- Source and Control Device Specific Inspection Manual
- CEM Inspection Manual
- EVE Data Sheets
Personnel Protection Equipment
Sampling Equipment (for VOC sources)
Camera / Notebook / Pencils / Stopwatch / Flash Light
Page 4
-------
and are an effective way of preparing for
on-srte inspection. In order to identify
previous enforcement activity at the site,
reviewing the existing records from the
last inspection is essential.
Pertinent data available may include:
current and out of date permits;
applicable regulations; emission test
reports; correspondence, such as prior
contacts with source personnel; previous
enforcement actions, such as notices of
violation; dates of construction or
replacement of equipment potentially
subject to NSPS; and process, control
equipment, and pollutant related
information.
2.2.1 Availability of Source Files
Inspectors will have access to EPA's
Aerometric Information Retrieval System's
Facility and Air Quality Subsystems
(AIR/AFS/AQS), a computerized data
base containing information on source
compliance and emissions. Other
sources include CDS and NARS.
Nearly all State and some local
agencies have computerized data bases
containing emission, permitting, and
compliance information on sources in
their jurisdiction. Some agencies
maintain separate data bases for
emissions inventory information and
compliance data. Paper files on a source
may exist at both Headquarters and
Regional offices. In some States,
detailed permitting information resides in
one location while inspection information
is located elsewhere.
EPA Inspectors should seek guidance
from their supervisors before contacting
a State or local agency for information
acquisition. They may conduct a
telephone search for potentially useful
files at State and local agencies before
visiting offices where files are known to
exist.
2.2.2 Process Information
The primary information of concern
includes facility process descriptions,
pollutants emitted by each process,
emission points, and associated control
equipment. Typical information on
process operating parameters that may
be obtained from source files consist of
such items as feed rates, temperatures,
and raw material compositions. The
most relevant information on control
equipment includes design capture and
control efficiencies, gas volume flow
rates, emission rates, and specific control
equipment parameters.
2.2.3 Previous Inspection
Reports
Previous inspection reports, stack test
reports, and correspondence between
the regulatory agency and the source
provide sources of information for
identifying non-compliance problems and
changes made to rectify these problems.
Baseline emission test and inspection
data will include operating parameters
that should be noted for comparison to
the observations made during
subsequent inspections. Additionally,
upset reports and excess emission
reports will identify previous problems
and provide focal points for the
inspection.
Page 5
-------
2.2.4 Previous Enforcement
Actions
The inspector should examine if any
enforcement action has been taken
against the facility such as issuance of a
notice of violation, Compliance Orders,
etc., and if it resulted in any remedial or
corrective actions.
2.3 REVIEW REGULATIONS AND
OTHERS
The source files may also provide
information on specific regulations
applicable to the source. The inspector
must also be familiar with all applicable
SIP-approved state and local regulations
and all applicable non-delegated or non-
Si P federal regulations.
2.3.1 Enforceable Limitations
Construction and operating permits
often delineate control guidelines specific
to the facility being permitted. The
inspector must review all federally-
enforceable requirements contained in
the existing permit in order to determine
the specific compliance requirements and
any exemptions which could apply to
conditions observed during the on-site
visit.
The requirements of the following are
examples of enforceable limitations:
Permits issued pursuant to the
Prevention of Significant Deterioration
(PSD) of Air Quality portion of the
State Implementation Plans (SIPs)
Permits directly issued by EPA
The non-permit limitations (i.e., New
Source Performance Standards
[NSPS] and National Emission
Standards for Hazardous Air
Pollutants [NESHAP]).
Applicable restrictions contained in
these federally enforceable limitations
may include production or operational
limitations in addition to the emission
limitation. Restrictions on production or
operation include limitations on quantities
of raw materials consumed, fuel
combusted, hours of operation, or
conditions which specify that a source
must install and maintain controls that
reduce emissions to a specified emission
rate or a specified efficiency level.
When permits contain production or
operational limits, they usually have
recordkeeping requirements that allow
verification of a source's compliance with
its limits. In some circumstances, the
enforceable permits may specify limits
such as an amount of emission per unit
time, (e.g., Ib/hr). This reflects the
operation of the control equipment and
accompanies the requirements to install,
maintain, and operate a continuous
emission monitoring (CEM) system.
CEM data must be retained and may be
used to determine compliance with the
emission limit.
The inspector should verify and note
the process and operating conditions
and any other parameters that the
source is required to meet to ensure
compliance with the permit. The
expiration date for the operating permit
along with any CEM information showing
emission exceedances should be noted.
A source may have more than one
Page 6
-------
permit and expiration date for different
process lines or pollutant types.
If any CEM requirements are
specified, then the inspector should also
note the current information on certifi-
cation and operation of OEMs in addition
to the other regulatory requirements.
2.3.2 Inspection Manuals
A review of the source control device
and CEM inspection manuals will give the
inspector typical ranges of operation to
gauge the source against, and provide
information on critical operating
parameters and pollutant emission rates.
2.3.3 Compliance Determination
Methods
Compliance determination methods
include, but are not limited to: calculation
procedures and emission factors for
determining compliance with emission
limits; review of stack test reports; and
review of records such as process rates,
production reports, upset reports, excess
emissions reports, startup and shut-down
logs, and fuel compositions and
consumption logs.
2.3.4 Other Information
Review any plant specific health and
safety problems which have been noticed
on previous visits to the plant and note
precautions to be taken concerning
specific chemicals and other hazards to
which the inspector could conceivably be
exposed on-site. The inspector should
discuss the information with the plant
representatives on-site prior to the tour of
the affected facility. Such information
may guide the inspector in selecting the
appropriate respirators, respirator
cartridges/canisters, and protective
clothing.41* The inspector should briefly
refer to the Material Safety Data Sheets
and other reference guides concerning
the symptoms of exposure and proper
first aid procedures.
When there is a complete lack of data
in the source file, a review of the AP-42
reference manual sections for the source
category may provide the inspector
insight into the expected conditions and
range of emissions at the source.6
If necessary, the list of records and
other information considered confidential
by agency personnel and by source
personnel should be reviewed. The need
for sampling should also be evaluated
and required sampling instrumentation to
take on-site should be assembled.
2.4 ASSEMBLE INSPECTION
MATERIAL
At the end of the source file review,
an inventory of the material needed for
the inspection should be taken by the
inspector. At this point, the inspector
may proceed to fill out a checklist such
as that provided in Appendix A. The
inspector must take on-site:
An inspection notebook for recording
observations
Method 9 Visible Emission data
forms, if applicable
Page 7
-------
Personnel protection equipment (eye
and hearing protection, hardhat,
safety shoes/boots, appropriate
clothing), and sample collection
equipment/containers as applicable
Optional items might include a
camera, stop watch, audio recorder,
flash light, and any reference material
or check lists
Pages
-------
SECTION 3
ON-SITE INSPECTION
On-site facility inspections are the
primary activity in evaluating source
compliance status; it is comprised of
reviewing facility records, making
observations, taking samples, and
preparing documentation. Inspectors
provide current information on actual
process and control equipment operating
conditions. The background information
collected prior to the on-site inspection
serves to compare and verify the data
obtained through actual process
observation. Section 114 of the Clean Air
Act enables the Administrator or any
authorized representatives of EPA, upon
presentation of credentials, to enter a
source for monitoring, sampling,
inspecting or copying records.
Inspections can be unannounced during
normal facility operating hours.
Figure 3-1 presents a flowchart
describing the step-by-step procedures
for conducting a stationary source
compliance inspection. They are divided
into: 1) Pre-Entry On-Site Activities, 2)
On-site Records Review, 3) Facility
Inspection, and 4) Post Inspection On-
Site Activities. These procedures are
explained in detail below.
3.1 PRE-ENTRY ON-SITE
ACTIVITIES
Upon arrival at the site, inspectors
should identify themselves, present their
credentials to the person authorized by
the source, be prepared to explain the
authority for the inspection, and ask for
consent to conduct the inspection.
Record the name of the person providing
entrance to the facility. If entry is
unnecessarily delayed or entry to parts of
the facility is denied, this can be
considered a denial of consent. If
consent is denied for any reason, EPA
Regional Counsel should be contacted
for advice on how to proceed.
Many companies provide blank sign-
in sheets, such as a visitors log, to
determine an on-site body count. The
inspector may sign such a log, taking
care not to sign any document which
compromises the inspection or limits the
source's liability, such as confidentiality
agreements or waivers of liability. It is
EPA policy that liability waivers are never
signed. If there is any statement of
liability waiver on the sheet, the inspector
may sign the sheet only after modifying it
appropriately. The inspector can either
cross out the liability waiver at the top of
the sheet or may write "no liability waiver"
next to his or her signature. These
actions should be discussed with the
facility representative should the issue
arise. Once this preliminary plant entry
procedure is completed, the inspector
may proceed with the opening interview
followed by on-site records review prior
to the actual facility tour.
3.1.1 Opening Interview
The opening interview provides an
opportunity for the inspector to
supplement the information gathered in
Page9
-------
Figure 3.1. Stationary Source Inspection Flow Chart
Pre-Entry On-Site Activities
Present Credentials and Obtain Consent
Communicate Objectives of Inspection
Discuss Claims of Confidentiality / Safety Issues / Policies on
Photography
Review On-Site Records for:
Operating Status of Processes and Emission Control Equipment
/ Changes
Applicable Regulations
Comparing with the Data Obtained from the Source File
Facility Inspection
Safety Review
Inspect Processes, Control Equipment, and CEM Monitors, and
Record Relevant Information
Conduct Visible Emission Observations
Take Samples
Take Photographs
Post Inspection On-Site Activities
Exit Interview
Request Additional Information
Page 10
-------
the agency file review. Additionally, it will
give the inspector an overview of the
facility and identify potential emission
points.
Proper documentation of the pre-entry
interview discussions is critical. The
inspector should communicate the
objectives of the inspection and indicate
specific process areas that are to be
observed. At this time, the safety issues
associated with touring of the area
should also be addressed. Facility
policies on photography as well as claims
of confidentiality should be thoroughly
discussed and understood by all parties.
The facility representatives may object
to the use of cameras on the company
property. Under Court ruling, EPA has
the right to take photographs if they are
necessary and pertinent to the source
compliance evaluations. The facility may
request that any photographs taken be
considered confidential. EPA must
comply with this request pending further
legal determination. However, any
restrictions placed on the inspector
regarding the use of cameras could be
construed as a denial of entry.
If samples are to be collected, facility
representatives should be informed that
they may receive a split of any sample
taken during the inspection. The facility
representatives should express their
desire for split samples before the
sampling begins, so that arrangements
can be made to secure the samples
during the investigation. However, the
inspection should not be unduly delayed
while the facility gathers sample
containers or equipment necessary for
obtaining the samples. It is also not
recommended that the Inspector provide
sampling materials to the facility.
3.2 ON-SITE RECORDS REVIEW
Once the opening interview is
completed, the inspector may discuss
the current operating status of all
processes and emission control
equipment and any changes that may
have occurred since the last inspection.
The inspector may review site records
for pertinent information on the emission
points and the pollutants under
evaluation for compliance. Depending
upon the type of source and pollutants,
information such as process throughput,
fuel consumption rates, fuel composition
analysis, plant operating levels (i.e.,
percent of capacity), operational
schedules, and other information are
pertinent in the compliance evaluation. In
the case of an inspection conducted for
the purpose of determining compliance
with VOC emission regulations, the
minimum recordkeeping data for review
includes the following: coating
formulation and analytical data, coating
consumption data, capture and control
equipment performance data, and
process information.
In situations where a large quantity of
data are available, especially in a large
facility, the inspector may want to "spot
check" the data and compliance
calculations. The inspector might want to
request that the facility make copies of a
representative set of records so that a
more thorough review can be made in
the office.
Page 11
-------
At this point, the inspector may use
the values of parameters obtained from
the background information review to
determine any significant change since
the last inspection or any process
operations outside normal permitting
conditions. If the situation warrants, the
inspector should inquire about the
reasons for any significant changes.
3.2.1 Safety Review
No inspection should be performed
unless the inspector has the proper
safety equipment, the training necessary
to USB the equipment, and the training to
recognize potential safety hazards.
General safety guidelines are mainly
common sense:
Always be accompanied by a facility
representative
Wear the appropriate protective
clothing and equipment when
necessary
Never enter any confined space, such
as a bag house
Although the inspectors' supervisors
are responsible for ensuring that each
inspector is properly trained in safety
procedures and the use of safety
equipment, the ultimate responsibility for
the inspectors' safety is their own.
3.3 FACILITY INSPECTION
The facility inspection enables the
inspector to verify the information from
the records and provides an opportunity
to inspect the processes and control
equipment and record process and
control equipment operating parameters.
A complete walk-through of the facility
should be performed to verify and identify
existing or new emission points.
The inspection should proceed in a
"counter flow" direction (i.e., beginning at
the stack [emission point], and
proceeding backwards through control
equipment and on to the process),
especially if excess emissions are
observed, in order to ascertain the cause
of those emissions, such as upsets.
However, if the inspector is not familiar
with the plant or process it is easier to
conduct the inspection in the "process
flow" direction. It is very important that
the inspector take thorough and legible
field notes. This is due to the fact that
enforcement action will take years to
complete. Often the inspector may
become a witness long after the
inspection.
3.3.1 Documentation and
Sampling Equipment
In order to assure maximum
credibility, the inspector must prepare
proper documentation of inspection
activities and must select the appropriate
documentation equipment. Cameras and
accurate stop watches are often
necessary. As indicated earlier, the
inspector should bring sampling
equipment when necessary. Proper
documentation of observations of
significant visible emissions is important
as it may be the only means of
determining compliance.
Page 12
-------
3.3.2 Visible Emissions
If visible emissions from any process
are significant, then the inspector should
estimate such visible emissions by
measuring the opacity by EPA Method 9
observation.7 Opacity should be
documented formally, even if it means
observing essentially zero opacity for six
minutes. If a violation is observed a
minumum of 30 minutes of readings
should be recorded as this will greatly
strenthen any enforcement action. The
cause of these excess emissions should
be investigated and reported (e.g.,
malfunctioning control equipment, upset,
or other circumstances).
When the opacity observations are
made, a copy of the observation form
should be provided to the facility
representative. Appendix B presents a
standard Visible Emission Observations
(VEO) form that can be used for making
Method 9 observations. A detailed
description of Method 9 and the use of
the VEO form is given in Section 3.12 of
the "EPA Quality Assurance Handbook
for Air Pollution Measurement Systems."8
To make Method 9 observations valid,
the inspector must be certified to
conduct Method 9 observations, and the
minimum data required by Method 9
must be obtained according to the
conditions specified. If the items in the
VEO form are correctly completed, then
a valid, enforceable VEO will be the
result.
3.3.3 Process Information
The inspection processes should
include, at a minimum, the operating
equipment, the material throughput, fuel
consumption, and process rate. The
inspector should review each process
(emission point) independent of other
processes, since the regulations in
general apply to each process. The
exception to this could be sources which
have received authorization to average or
"bubble" the emissions over several
processes. However, even these
processes should be inspected
individually by the inspector to ascertain
how they are operating.
During the inspection, if any process
is found not to be operating, the facility
representative should be asked about the
reasons and all the pertinent information
should be duly documented.
The inspector should know prior to
the facility inspection about any
scheduled or unscheduled process
shutdowns either through the State/Local
office or directly from the facility
representatives if the inspection is pre-
announced.
3.3.4 Control Equipment
If any part of the operation vents to
add-on control equipment, the operation
of this equipment should be evaluated.
The specific areas which may need to be
inspected include: the exhaust system
(i.e., capture device, ducts, fans),
monitors for control equipment (i.e.,
temperature, pressure, VOC
concentration gauges), the control
device, and any stack emission monitors.
There are two parts to an add-on
emission control system. The first is the
capture system used to collect the
Page 13
-------
pollutant and deliver it to the control
device. The second part of the system is
the actual control device that either
removes or destroys the pollutant in the
air stream. The capture system consists
of: enclosures and hoods that trap the
emissions, ductwork that transfers the
emissions to the control device, and a
fan that supplies the energy necessary to
move the emissions through both the
capture and control systems, then
through the stack to the atmosphere.
Examples of data that should be
recorded and evaluated are: differential
static pressure, inlet and outlet gas
stream temperatures, pulse-jet air
pressure, electrostatic precipitator
primary and secondary voltages and
currents and spark rates, gas flow rates,
and CO and 02 concentrations. Fans
and ductwork should be observed for air
leakage and wear. Evaluation of the
source's quality control procedures for
the control equipment should be
conducted. To understand how these
data are useful in evaluating control
equipment, refer to the "EPA APTI
Course 445 Baseline Source Inspection
Techniques Student Manual and the EPA
APTI Field Inspection Notebook,
December 1985."* References 10 and 11
are additional resources for on-site
inspections.
3.3.5 CEM Evaluation
In the plant control room at the time
of the inspection, record the readings
from the continuous emission monitor
(CEM) readouts (e.g., LED, CRT, or strip
chart). When it is safe to do so, take
readings from the meters on the
instruments for comparison with the
control room readings. The purpose of
these comparisons is to evaluate the
accuracy of the data acquisition system.
For opacity monitors, compare your
visible emissions observations with
concurrent opacity CEM readings.
The inspector should check
stripcharts to ensure that the proper
calibrations are being performed. He
should record the calibration gas
concentrations and compare them with
the required values if any exist in the
regulation. Often it is useful to have
facility personnel manually demonstrate
the calibration.
3.3.6 Sample Handling
If any samples are taken during the
course of an inspection they must be
handled in a manner consistent with
agency policy, approved methods and
chain of custody procedures. The
samples taken must be properly labelled
with such information as sample date,
exact sampling location, contents, and
sampler's name.
In addition to correctly labeling
samples, a chain of custody must be
maintained from the point of sample
generation to the end of the analysis
process. In general, the inspector must
assure that the sample is supplied to a
laboratory for analysis as soon as
possible, and that the chance of loss is
minimized.
3.4 POST INSPECTION ON-SITE
ACTIVITIES
Proper post inspection procedures
must be followed properly and expedi-
Page 14
-------
tiously. An exit interview with the source
representatives is the primary activity in
which both parties get a final opportunity
to obtain clarifications on the status and
nature of the information being gathered
by the inspector.
3.4.1 Exit Interview
The closing conference with source
representatives enables the inspector to
answer questions and seek any
additional information needed. At the
closing conference, the inspector "wraps
up" the inspection by:
Accepting the declaration of
confidential business information
Advising that results of any analysis
of samples will be furnished to the
source
Discussing specific inspection findings
(i.e., factual observations only)
Requesting any additional information
and arranging for receipt of missing
data if not readily available before the
inspection ends
In discussing the specific findings, the
inspector should inform the source that
no conclusions can be drawn until all
pertinent findings, data, and information
are evaluated. It is imperative that the
inspector not make a final compliance
determination on-site. However, when
the field citation program is implemented,
the inspector will need to make
compliance determinations for certain
requirements relative to the program.
The notes and data collected should
be reviewed to ensure their
completeness. If possible, the data
obtained on-site should be compared
with the data compiled from the source
file. In any event, the inspector may
make a detailed comparison of these
data later during the compliance
evaluation. If the source inspection
reveals that a significant change has
occurred in operating conditions, the
upgrading of the inspection to a Level 3
or Level 4 (a stack test) to verify
compliance may be necessary.
Even after the on-site inspection, the
inspector may request any additional
data deemed necessary to determine
compliance. EPA has the authority under
Section 114 of the Clean Air Act to
request information, or to require
emission testing at a facility. States may
use their analogous authority to achieve
this result. When requesting additional
information on-site or after leaving the
source premises, the inspector should
only request the information necessary to
determine compliance.
Page 15
-------
Page 16
-------
SECTION 4
INSPECTION EVALUATION AND REPORT PREPARATION
4.1 POST INSPECTION
EVALUATION
At the completion of an inspection, a
final evaluation should be made to
ensure the following:
The inspection conducted was Level
2. That is, visible emission obser-
vations were made, control equipment
operating data and process
information were recorded, and
emission calculations were
performed. Reasons are to be given
if any of these activities were not
done.
All emission points have been
properly identified and evaluated for
compliance. Emission calculations,
as well as the source of emission
factors used, were spot-checked.
(Unless a stack test is available and
considered to still be valid, EPA's AP-
42 emission factors should be used,
not the NEDS SCC emission factors.)
References againstwhich compliance
determinations were made are
indicated for each emission point.
The most current permits with
federally enforceable conditions were
used and all conditions were
evaluated properly. Proper
regulations were applied, for example,
if an emission point was
"grandfathered" under the regulation
requiring a permit, it was evaluated
against the common SIP provisions.
The compliance determination is
based on complete and thorough
information. A complete State
overview inspection will require that
the EPA inspector await completion of
his/her report until an evaluation of
the State inspector's report can be
made and the compliance
determination verified.
4.2 INSPECTION REPORT
Inspection reports are prepared to
summarize findings and
recommendations following Level 2
inspections of stationary sources,
regardless of the compliance status of
the source. The primary requirement of
inspection reports is to provide sufficient
and proper documentation of an
inspector's evaluation of the sources's
compliance status. The information that
must be included consists of:
A description and summary of all
emission points, applicable regulatory
requirements, and on-srte inspection
observations, including exit interview
with the source representatives
Source file review observations
Procedures followed and information
gathered for evaluating source's
compliance with the applicable
regulations
For the sources which are believed to
be in violation of one or more regulatory
Page 17
-------
requirements, the inspection report
serves to support subsequent
enforcement actions. Otherwise, for
sources which are believed to be in
compliance, the inspection report serves
simply to document the operating data
and obser-vations at the time of the
inspection.
To serve the purpose stated above,
the reports of inspections must
summarize all the supporting information
used in the inspector's evaluation of the
source compliance status. The report
should provide a quick review of the
source, its emission points, and its
compliance status, without requiring an
in-depth reading. The length of an
inspection report is primarily dependent
on the number of emission points, and
on the ability of the inspector to be
thorough but concise, that is, present just
the relevant facts. The information
presented would obviously be the
summary of that gathered from the
source background files during the pre-
inspection and from the on-site
inspection. Additional information, such
as process description and photographs,
can be attached in appendices as the
inspector deems necessary. However,
since this information is not required for
a review of the source's compliance
status, they should not be included in the
body of the report.
The minimally acceptable information
to be included in a Level 2 inspection
report is as follows:
General information
Previous enforcement actions and
compliance status
Inspection activities
Findings and recommendations
State inspection report review
(applicable to EPA's State overview
inspections only)
These minimally acceptable data are
necessary in the source compliance
determination. Specific data
requirements in each of these are
discussed in more detail in Section 4.3.
Some information gathered by the
inspector may be sensitive in nature and
the source may request it be kept
confidential and not be made available to
the public. Such information could
include proprietary industrial processes
and production rates.
In general, the inspection report
should not include sensitive data unless
necessary and relevant to the violation.
Regional Counsel should be consulted if
the source is claiming confidentiality. It is
recommended that information claimed to
be confidential be excluded from the
inspector's report if possible. If the
information is important, the best
procedure is to refer to it in the main
inspection report while keeping the
confidential information separate. The
entire inspection report must be labeled
"confidential" if any portion of it is
confidential.
However, certain information dealing
with emissions cannot be withheld from
the public under federal law. Such
information includes process descriptions
and rates used in estimating emissions,
and the general description of the
Page 18
-------
location and nature of the source of
emissions.
4.3 STANDARD FORM
A standard form that can be used to
provide an inspection compliance report
is shown in Appendix C. This form is
intended to provide for a complete and
concise reporting of the minimally
acceptable information for a Level 2
inspection, and can accommodate a
State inspection, an EPA inspection, or a
combination of both. The use of this
form is recommended in order to
maintain consistency among inspectors
nationwide when reporting compliance
evaluations. However, the standard form
cannot take the place of a thorough
review of applicable regulations prior to
the inspection.
An additional purpose of this form is
that it serves as a "checklist" for the
inspector throughout the pre-inspection
and on-site and thereby simplifies the
inspection and reporting process. When
using this form, those words and line
items that are not applicable can be
answered with an "NA." Some of the
data in the form may be partially
completed prior to the on-site inspection.
If this form does not accommodate
inspections for any given type of source,
it can be expanded suitably to document
additional relevant data.
Following is a discussion of each of
the elements of the Standard Inspection
Guide/Report form provided in Appendix
C.
General Information
The information such as the date and
type of inspection and the person
submitting the report is necessary in the
identification of the particular inspection.
Such information provides a starting point
for the reviewer of the report.
Source Information
The primary purpose of the source
information in the form is to identify the
source of the data and present
background information on the
processes and emission points
evaluated. Besides source name,
location, and contact, the information on
process code, applicable regulations,
source tests, emission inventory, and
previous enforcement actions is
important. This information is basically
compiled from the review of the source
files.
Processes Evaluated
This portion of the form is used to
provide process information for each
emission point that is regulated or
permitted for certain emission limits. This
portion along with the applicable
regulations portion of the form constitute
the most important information
considered in the evaluation. This
information should be completed initially
during the source file review and updated
later as more accurate information is
available from the on-site records review
and actual inspection. The information
on processes, pollutants and associated
control equipment and OEMs as well as
allowable and actual emissions are
essential in compliance determinations.
Page 19
-------
When possible, the allowable and
actual emission values should be
expressed in terms of the same units as
the applicable permit limits or regulations.
Applicable Regulations
Almost all of the information
concerning applicable regulations is
accessible to the inspector prior to the
on-site inspection. Documenting such
information would reveal if any alternative
emission compliance plans such as
averaging or bubbling of emissions from
multiple emission points has occurred.
Source Inspection
This portion of the form reveals the
information from the on-site inspection
and can also provide a view on the
attitudes of the plant towards the
inspector. All observations, comments
by plant personnel, readings from
instruments, summaries of records
reviewed, and process flow or plant
layout diagrams, etc., are to be recorded
here.
Other Data and Observations
In the report, be observant and note
any conditions such as work practices,
house-keeping, record-keeping, safety
conditions, and source representatives's
attitude toward the inspector's presence
that may be mitigating or aggravating a
potential enforcement action. Do not rely
on memory alone to carry through a
potential referral years after the
inspection.
Findings and Recommendations
It is essential that this portion of the
report be clearly presented. The findings
must be clearly defined and summarized.
The recommendations should also be
listed in a clear and concise manner.
State Inspection Report Review
This section is applicable to EPA's
State overview inspection only. For other
inspections list an "NA".
Page 20
-------
SECTION 5
REFERENCES
1. The Clean Air Act Compliance/Enforcement Guidance Manual, U.S. Environmental
Protection Agency, Revised 1987.
2. Compliance Monitoring Strategy for FY 1989, U.S. EPA Stationary Source
Compliance Division, March 31, 1988.
3. Air-Specific Inspector Training Plan for the Stationary Source Compliance Program,
U.S. Environmental Protection Agency, February 1989.
4. Air Pollution Source Inspection Safety Procedures: Respiratory Protection Program
Guideline, EPA-340/1-85-002C, U.S. Environmental Protection Agency, February
1983.
5. Air Pollution Source Inspection Safety Procedures: Student Manual. EPA-340/1-
85-002a. U.S. Environmental Protection Agency, September 1984.
6. Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area
Sources, Fourth Edition, U.S. Environmental Protection Agency, September 1985.
7. 40 C.F.R, Part 60, Appendix A, Method 9, Revised July 1, 1987.
8. Quality Assurance Handbook for Air Pollution Measurement System: Volume ill.
Stationary Source Specific Methods. Section 3.12 Method 9 - Visible Determination
of the Opacity of Emissions from Stationary Sources, EPA-600/4-77-027b, U.S.
Environmental Protection Agency, February 1984.
9. Baseline Source Inspection Techniques: Student Manual. U.S. EPA Air Pollution
Training Institute, APTI Course 445, Draft December 12,1985.
10. Air Pollution Source Field Inspection Notebook. Revision 2, U.S. EPA Air Pollution
Training Institute, June 1988.
11. Field Inspection Protocol for Region VIII Stationary Sources, Excluding Asbestos
Demolition/Renovation. U.S. EPA Region VIII, Air & Toxics Division, June 13,
1988.
Page 21
-------
Appendix A
Pre-lnspection Activities Checklist
Assemble Inspection Material (put a check mark)
Writing pads / pens
Camera
Stop watch
Flashlight
Measuring tape
Personal Protection Equipment (Required):
Hard Hat
Eye protection
Ear plugs
Respirators
Safety boots
VOC Sampling Equipment
Credentials
VE data sheets
Inspection Guide / Report Form
Additional Equipment / Checklists (List):
A-1
-------
Appendix B
Visible Emission Observation (VEO) Form
B-1
-------
VISIBLE EMISSION OBSERVATION FORM
No.
COMPANY NAME
STREET ADDRESS
crnr STATE ap
PHONE {KEY CONTACT)- SOURCE 10 NUMBER
PROCESS EQUIPMENT OPERATING MODE
CONTROL EQUIPMENT - OPERATING MODE
DESCRIBE EMISSION POINT
HEIGHT ABOVE GROUND LsVEL H=iGHT RELATIVE TO OBSERVER
Stan End
DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER
San End San End
DESCRIBE EMISSIONS
5tatt E.ie
EMISSION COLOR IF WATER DROPLET PLUME
Son End Asacrwe - ' Dttaewd C-
POINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED
San Er-S
OE5CRIBE PLUME BACKGROUND
San Eix
BACKGROUND COLOR SKY CONDITIONS
San End Sari End
WIND SPEED WINC DIRECTION
Sart End Sart End
AMBIENT TEMP WET BULB TEMP RH. ptrant
San End
Suoc _ SOURCE LAYOUT SKETCH Draw Norm Arrow
wnti Q^^ --,
Plum* f\
Sun -4- (J
Wind ^
X Emmion Point
. ^OOttntr'i Petition
Sun Location Lm«
AOOmONAL INFORMATION
OBSERVATION DATE
\SEC
UIN \
1
2
3
4
s
e
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
23
27
28
29
30
0
IS
X
i
START TIME END TIME
45 COMMENTS
-
V
.
1
OBSERVER'S NAME (PRINT)
OBSERVER'S SIGNATURE DATE
ORGANIZATION
CERTIFIED BY - DATE
CONTINUED ON VEO FORM NUMBER
-------
VISIBLE EMISSION OBSERVATION FORM
This form i* designed to be used in conjunction with EPA Method 9. "Visual Determination of tha Opacity of Emissions from Stationary
Sourest." Tampers! changes in emisaion coJor. plum* water droplet content, background color, sky conditions, observer position, etc.
should be noted in the comments section adjacent to each minute of readings. Any information not dealt with elsewhere on the form should
be noted under additional information. Following are brief descriptions of the type of information that needs to b« entered on the form: for a
more detailed discussion of each pan of the form, refer to "Instructions for Use of Visible Emission Observation form."
* Company Name - full company name, parent company or division or
subsidary information, if necessary.
* Street Address street (not mailing or home office) address of facility
where VE observation is being made.
Phone (Key Contact) number for appropriate contact.
Source IO Number number from NEOS. CCS, agency file, etc.
* Process Equipment. Operating Mode brief description of process
equipment (include type of facility) and operating rate. % capacity.
and/or mode (e.g. charging, tapping, shut down).
* Control Equipment. Operating Mode - specify type of control device(s)
and % utilization, control efficiency.
* Describe Emission Point for identification purposes, stack or
(mission point appearance, location, and geometry; and whether
emissions are confined (have specifically designed outlet) or
unconfined (fugitive).
* Height Above G round Level - stack or emission point height relative to
ground level: can use engineering drawings. Abney level, or
clineometer.
Height Relative to Observer indicate height of emission point relative
to the observation point.
Distance From Observer
rangefinder or map.
distance to emission point: can use
* Direction From Observer direction to emission point; can use
compass or map to estimate to eight points of compass.
* Describe Emissions - include physical characteristics and plume
behavior (e.g.. looping, lacy, condensing, fumigating, secondary
particle formation, distance plume visible, etc.).
* Emission Color - gray, brown, whit*, red. black, etc. Note color
changes in comments section.
If Water Droplet Plume Check "attached" rf water droplet plume
forms prior to exiling stack, and "detached" if water droplet plume
forms after exiting stack.
Point in the Plume at Which Opacity was Determined describe
physical location in plume where readings were made (e.g.. 1 ft. above
stack exit or 10 ft. after dissipation of water plume).
* Describe Plume Background - object plume is reed against, include
texture and atmospheric conditions (e.g.. hazy).
* Background Color sky blue, gray-white, new leaf green, etc.
Sky Conditions - indicate cloud cover by percentage or by description
(ciear. scattered, broken, overcast).
* Wind Speed - record wind speed: can use Beaufort wind scale or
hand-held anemometer to estimate.
* Wind Direction direction from which wind is Wowing: can use
compass to estimate to eight points.
* Ambient Temperature in °F or °C.
Wet Bulb Temperature can be measured using a sling psychrometer.
Relative Humidity can be measured using a sling psychrometer: use
local U.S. Weather Bureau measurements only if nearby.
* Source Layout Sketch - include wind direction, sun position.
associated stacks, roads, and other landmarks to fully identify location
of emisaion point and observer position.
Draw North Arrow to determine, point line of sight in direction of
emission point, place compass beside circle, and draw in arrow
parallel to compass needle.
Sun's Location - point line of sight in direction of emission point, move
pen upnght along sun location line, mark location of sun when pen's
shadow crosses the observer's position.
Additional Information - factual conditions or deviations not
addressed elsewhere on form.
* Observation Date - date observations conducted.
Stan Time. End Time beginning and end times of observation period
(e.g.. 1635 or 4:35 p.m.).
* Data Set - percent opacity to nearest 5%; enter from left to right
starting in left column. Use a second (third, etc.) form, if readings
continue beyond 30 minutes. Use dash (-) for readings not made;
explain in adjacent comments section.
Comments note changing observation conditions, plume charact-
eristics, and/or reasons for missed readings.
* Observer's Name print in full.
Observer's Signature. Date - sign and date after performing VE
observation.
* Organization - observer's employer.
* Certified By. Date - name of "smoke school" certifying observer and
date of most recent certification.
Continued on VEO Form Number - note the 6-digit number of the VE
Observation Form where the observations from the form in use are
continued.
Required by Reference 9: other items recommended
-------
Appendix C
Inspection Guide and Report Form
C-1
-------
Inspection Guide and Report For
(Company Name)
I. General Information
Report Prepared By: Date:
Report Submitted To:
Date of Inspection:
Type of Inspection:
(e.g.. FYxx Overview
Inspection, FYxx EPA
Permit Inspection)
II. Source Information
Company Name:
Plant Location:
Mailing Address:.
Source Contacts:
SIC Code and Description:
AFS No: AFS Class:
Local Non-Attainment Areas:
Applicable Air Programs
Issue Date of State / EPA PSD Permit:.
Permit Expiration Date:
Date of Last Source Test:
Results of That Test:
(Compliance / Non-Compliance)
Applicable Federal Regulations:
Source Emission Inventory: Actual Emissions (Tons /Year)
TSP SO, NO, CO VOC Reference
Summary of Enforcement Actions:
Date Action Taken State / EPA Violation
Comments:
C-3
-------
Inspection Guide and Report For
(Company Name)
III. Processes Evaluated and Test Data
Control Equipment and OEM Data
Emission Point
Pollutant
Control
Equipment
GEM ID
Source Tests & Compliance Status
Date
Emission
Point
Pollutant
Allowable
Emissions
Actual
Emissions
CEM Performance Specifications Tests
Date
Emission
Point
Pollutant
Passed / Failed
IV. Applicable Regulations
Regulation or
Permit No. Emission Point Pollutant
CEM
(Y/N)
Allowable
Emissions
C-4
-------
Inspection Guide and Report For
(Company Name)
V. Source Inspection
Date /Time:
Weather:
Names of Participants:
Inspection Notes and Narratives
Entrance Interview
On-Site Inspection
Exit Interview
Description of Sampling
Additional Information Requested
Other Data and Observations
Does Company Keep Any:
Operating Logs
0 & M Records on Process or Controls
C-5
-------
Inspection Guide and Report For
(Company Name)
VI. Findings and Recommendations
VII. State Inspection Report Review (If Applicable)
C-6
------- |