Setting Yourself Up for Success: Air Compliance Inspections
Picture this…. it’s a beautiful April day, and it’s the first warm day of the year. You walk into work feeling refreshed and energized, confident of the great day that lies ahead. You begin your morning routine… maybe you scroll through your email or daily schedule, or perhaps you enjoy a cup of coffee or tea and chat with a coworker. When out of nowhere, your phone rings. It’s security. There’s a state inspector is at your gate for a surprise air audit. Suddenly, you’re a little less confident in the great day that lies ahead and a lot more stressed out.
Sound familiar? Whether you call this an air audit or an air inspection, any EHS manager knows this exact scenario, as we have all been through it before. No matter what you call it, these unexpected visits from any regulatory agency can be a hassle. I worked as an environmental manager in industry for several years; however, prior to that, I worked as a state inspector. By seeing both sides of air inspections, I learned a lot… some of which I would like to pass along to you by offering advice on how to not only make air inspections go quicker, but also give the inspector exactly what they need.
1. Read your permit!
Although this may seem obvious, there are many managers who have either only partially read their permit or haven’t read it at all. Knowing what information an inspector will request and what machines they want to see will ensure a speedy inspection.
2. Ensure you are familiar with past inspection reports and corrective actions.
Before an inspector shows up at your door, review past inspection reports and ensure that corrective action has been taken from previous violations. This shows the inspector that you and your company take environmental compliance seriously. The state typically takes more aggressive action on violations that occur more than once.
3. Make yourself aware of regulations that are not contained in your permit.
Not knowing that you were applicable to regulations is not an excuse for non-compliance. Although most states do a sufficient job of including all applicable federal regulations in their air permits, what about the regulations that are passed between your facility’s permit cycles? The most common federal regulations affecting industrial sources are those concerning boilers and stationary generators. If you need assistance in determining your applicability to federal air regulations, Cornerstone offers a NESHAP and NSPS applicability determination to ensure your facility is in full compliance with all applicable air regulations.
4. Always have a hard copy of your most recent air permit somewhere that is easily accessible.
The inspector will most likely have their own hard copy with them when they request a tour of your facility. They will ask questions related to identifying the emissions units and operations listed in the permit. Having your own copy of the permit in front of you to field questions will make the tour go much more quickly and smoothly.
5. Know the terminology in your permit.
If you call a certain emission unit “Axle Refurbishment Booth” and IDEM calls it “Paint Booth #5” in your permit, it’s going to take both yourself and the inspector several minutes trying to match up emissions units to what is at your facility. Although this problem is easily resolved during permitting activity, it is of no help to you during a surprise inspection.
6. Keep all of your air recordkeeping in one place.
If you prefer to retain hard copies, keep all permit-required records (as well as the permit itself) in a labeled binder or file that is easily accessible. If you retain records digitally, ensure that all records are kept in one file that is easily accessible, regardless of internet availability. Storing all air recordkeeping in one place not only speeds up the inspection itself but also serves as a security blanket if you are on vacation when the inspector shows up and your second-in-command has to conduct the inspection.
7. Use the exact phrasing in your records as the permit.
This allows the inspector to quickly and easily skim your documents for compliance. Ensure that your units of measure match the units of measure in the permit limits and audit your own records to ensure that all permit-required information is reflected in the records. It is a good practice to highlight the “final” data such as tons of pollutants per year to draw the inspector to the most important information.
8. Regularly communicate with other departments about recordkeeping needs.
If the permit-required recordkeeping involves information from other departments in your company such as purchasing, don’t wait until the day of an inspection to request those records. On a monthly basis, send out a request for information (i.e., purchase records, usage information, etc.) to the necessary departments. This will ensure that you can provide an inspector with information in a timely manner.
9. Make note of any non-operational dates.
If you have daily records such as pressure drop readings, it is necessary to note which days your units were not in operation. If an inspector reviews records and sees days with nothing noted, they will assume that this is a missed record. A good rule of thumb to operate under is that it doesn’t count if it’s not written down.
10. It is important to speak with discretion during an audit.
Although it is important to be kind, allow the inspector to ask questions before providing technical answers. Air compliance is full of acronyms and jargon. If you accidentally say the wrong term, the inspector’s interest could pique and open a can of worms you did not mean to open.
During the peak of COVID lockdowns, most state agencies turned to alternative inspection protocols such as requesting records virtually and performing outdoor-only inspections. As we enter 2023, Cornerstone sees a mix of states who have maintained COVID protocols, states which have created hybrid in-person and virtual inspections, and some states that have gone back to full on-site unannounced inspections. It’s important to be prepared for any of these possibilities and respect the timeline that your inspector has provided.
Air inspections can be intimidating, but by setting yourself up for success and following audit best management practices, you can ensure that all future air inspections are quick and hiccup-free.
