Tips to Prepare for Audits, Tests, and Inspections

With the various kinds of field support and audits that may be required by your facility’s operating permit, such as U.S. EPA Method 9 Visible Emissions (VE) testing, stack testing, Leak Detection and Repair (LDAR) inspections, and Spill Prevention, Control, and Countermeasure (SPCC) storage container inspections, getting prepared can be a daunting task, especially since this is not an exhaustive list. Here are some tips to help you prepare for your upcoming audit, test, or inspection.

The first thing that will prepare you for your upcoming site visit is making sure the consultant is aware of their environment, keeping safety a top priority. Inform your consultant of any required safety trainings before they come on-site and provide them with a list of required and recommended personal protective equipment (PPE). Consider sending them a detailed site map featuring equipment locations and pedestrian walkways, if possible. This will help them be mindful of the equipment and machinery operated on site and the hazards they present (e.g., hot piping, forklift traffic, combustible dust, and reactors and storage tanks containing hazardous materials), as well as get a general idea of potential blind spots and the direction of pedestrian and equipment traffic at your facility. With regards to hazardous chemicals, it is important to be knowledgeable of the potential hazards of any compounds you will be working with or around. Consider providing your consultant with a list of chemicals produced or used on-site and any available safety data sheets (SDSs) and asking that they read through them before coming on-site. Have them pay special attention to the hazard symbols and inform them of any risk mitigation procedures in place for spills and leaks. Also, be sure to pay attention to the weather conditions around the site on the day of the site visit, and reschedule if inclement weather will present an unnecessary hazard; for example, performing a U.S. EPA Method 9 inspection or stack testing during a thunderstorm would pose a hazard to the inspectors.

Having a technical understanding of the service you are receiving is also crucial to increasing your preparedness. Regulatory agencies will sometimes consider data invalid if the equipment being used during the test or inspection is not properly operated or calibrated. Taking some time beforehand to make sure you and your consultant are familiar with the types of equipment being used, as well as how to properly calibrate, could potentially save you from a massive headache later. Consider providing your consultant with instruction manuals for any relevant equipment before they come on-site. Knowledge of the specific regulations (e.g., Various subparts of 40 CFR Parts 60, 61, and 63, as well as 40 CFR Part 60, Appendix A for LDAR, 40 CFR Part 60, Appendix A for U.S. EPA Method 9, and 40 CFR Part 112 for SPCC inspections) under which the testing is being conducted is also very important. Your operating permit will define what kinds of testing are required and the test methods that must be followed, so be sure to check the permit to confirm what services you need. This is especially key for emissions tests, where some pollutants, such as sulfur dioxide, nitrogen oxides, and particulate matter, have several different test methods defined in 40 CFR Part 60, Appendix A.

Make sure to take some time to inform your consultant about the specific process they will be working with and how the equipment fits in. Provide your consultant with a list of on-site equipment relevant to the service they will be providing and let them know if there is anything that they will need to supply. Be aware of the differences between similar types of equipment. For example, flame ionization detectors (FIDs) and photo ionization detectors (PIDs) can both produce a volatile organic compound (VOC) reading during an LDAR inspection; however, of these two, only a FID can detect methane, so if your facility is being inspected for natural gas leaks, a PID cannot be used. Providing details on your process is also essential so that the consultant knows when to conduct the test and collect data; for example, you cannot conduct an LDAR test on a nitrogen-purged line because it will interfere with the accuracy of the VOC reading, so being aware of when the line being worked on is typically purged will save you from having to repeat the test. Some inspections and tests require you to have certain qualifications to perform them, such as Smoke School for U.S. EPA Method 9 tests and Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) for anything involving hazardous materials. Therefore, it is crucial to ensure everyone involved is certified to perform the service you need before coming on-site.

In summary, you can make sure you’re prepared for your next audit, test, or inspection by taking the following steps:

1. Make sure your consultant is aware of and comfortable with their environment by informing them of any required safety trainings, as well as any hazards associated with on-site equipment and chemicals, and by paying attention to weather conditions in your area on the day of the visit.
2. Have a technical understanding of the support you’re receiving by making sure you and your consultant are familiar with the types of equipment used and any applicable regulations.
3. Provide your consultant with details surrounding your process and any equipment you have on-site that is relevant to the task they will be performing.
4. Make sure all personnel coming on-site have obtained any qualifications necessary to be able to perform the service you are needing.

If you have any questions, feel free to contact me at kwalburn@all4inc.com or at (678) 599-9011.