Air Compliance Auditing for Industrial Facilities
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