Trinity Consultants

Air Compliance Auditing for Industrial Facilities

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This 1-day course is for industrial corporate and facility environmental personnel responsible for air permitting and compliance audits. The course covers general auditing concepts and practices, a brief overview of air regulations and permitting requirements, how to prepare and complete an air compliance audit, and documenting and handling audit findings.

The course includes a review of example audit work documents, dissection of an air permit for auditing purposes, and group exercises. Learn to:

  • Grasp compliance obligations of an air permit and categorize air permit derived tasks for compliance review
  • Understand the depth and scope needed for completing an air audit; develop an audit plan and auditing protocol
  • Develop audit question checklists, interview personnel, and review compliance data
  • Leverage auditing tools to prepare and execute necessary audit tasks
  • Identify common air compliance issues at facilities and prepare an effective audit report

Auditing Concepts and Practices

  • Environmental auditing objectives
  • Types of environmental audits
  • EPA’s Auditing Policy
  • EH&S auditing organizations
  • Unique challenges to air compliance auditing

Air Regulations and Permitting Review

  • New Source Performance Standards
  • National Emission Standards for Hazardous Air Pollutants
  • State Implementation Plan Rules
  • NSR/PSD Permitting
  • Title V/Air Operating Permit Programs

Dissection and Categorization of Air Permits for Auditing Purposes

  • Assimilating and understanding compliance obligations of an air permit
  • Qualifying permit conditions based on implicit and inferred compliance status
  • Subdividing between general, facility, and unitspecific requirements
  • Categorization of air permit derived tasks
  • Exercises in reviewing air permits for auditing purposes

Preparing for an Air Audit

  • Choosing the depth and scope of the air audit
  • Defining a plant’s air regulatory profile
  • Importance of air permitting history
  • Facility information to gather and review
  • Developing an audit plan and auditing protocol
  • Developing audit question checklists

Conducting Air Audits

  • Proper organization and work flow during audit
  • Interviewing personnel and reviewing data
  • Assessing completion status of action tasks
  • Assessing emissions and monitoring data
  • Common air compliance issues
  • Handling historical air permitting liabilities

Documenting and Handling Audit Findings

  • Preparation of the audit report
  • Presentation and ranking of audit findings
  • Confidentiality and attorney-client privilege
  • Disclosure of audit findings- EPA/state policies
  • Corrective action plans and closing audits

Air Compliance and Auditing Tools

  • Management of change program
  • Task delineation tools and calendars
  • Environmental Management Information Systems (EMIS)
  • Audit preparation and execution aides

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