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

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                                          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

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                                 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


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Appendices



A    PRE-INSPECTION ACTIVITIES CHECKLIST  	A-1



B    VISIBLE EMISSION OBSERVATION (VEO) FORM  	B-1



C    INSPECTION GUIDE AND REPORT FORM	 C-1
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                                  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
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 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.
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                                  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
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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

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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.
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   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
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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
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   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
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                                   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
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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
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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.
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   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.
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    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

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 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-
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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

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                                 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

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 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

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 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

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   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

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                                  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

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                     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

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               Appendix B
Visible Emission Observation (VEO) Form
                  B-1

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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

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                         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

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           Appendix C
Inspection Guide and Report Form
            C-1

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                     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

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                   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

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                    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

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                Inspection Guide and Report For
                            (Company Name)
VI. Findings and Recommendations
VII. State Inspection Report Review (If Applicable)
                              C-6

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