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 ------- |