Quick CEMS Audit Prep Checklist
Use our quick checklist to pass an EPA CEMS audit of your facility. Use a proven CEMS DAS like StackVision and Prism for critical data and have current information about your designated representative, record keeping, QA/QC plan, permit & acid rain program at hand.
CEMS Regulatory Audit Preparation Overview
The Environmental Protection Agency (EPA) uses audits to voluntarily safeguard the health and the environment by allowing facilities to discover and fix federal and state law violations.
The EPA may audit your facility for several reasons. You may have increased numbers of failed calibrations or have questionable data for CO2 audits, flow-to-load or heat input changes, reporting errors, late quarterly reports, or be part of an EPA, state, or annual compliance review.
This process can be time-consuming and stressful. Your facility can best handle an audit with preparation and using a data acquisition system (DAS) like StackVision or Prism for monitoring, reporting, and compliance.
How Your Data Acquisition System Helps You Pass Regulatory Audits
It’s essential that you can walk the person certifying compliance at your facility through how all of your compliance averages are calculated and make adjustments to parameters. With data acquisition systems like StackVision and Prism, you can decide how you need to comply and want to configure your system. Still, you are starting within the framework of a robust compliance engine that provides transparency into how your system is configured and puts you in control.
Data Acquisition Systems create, calculate, record, and retain each of these averages and data points for verification purposes. This level of traceability is extremely valuable during audits with regulators because you can show the exact values, processes, and calculations used to create any questioned averages.
Secondly, being able to easily prove that you have quality assurance procedures in place and that they are being adhered to precisely gives you firm ground to stand on when facing an audit. On a day-to-day basis, a quick review of a few displays or scheduled reports in the morning can tell you the state of your system and let you plan your day. If a monitor is drifting toward being out of control, you can respond. If a calibration check has failed, you can act quickly to fix issues and reduce downtime. If you see anything that could be heading your system toward a problem, you will have more time to investigate since so much of what used to tie up your time is automated.
Don’t worry, though; automation doesn’t mean that the process is out of your control. A good DAS should configure the system to fit your needs and achieve whatever automation level is correct for you. You should also be able to use the software to dig into your data, see charts comparing factors, edit operational data and add notes, codes, and flags to clearly explain any unusual situation.
Additionally, a DAS can help you by providing predictive averages and alarming to help you avoid hazardous or legally challenging situations like exceedances and deviations. These tools can be employed in various ways to stay out of trouble from an environmental or permit perspective and maximize operating efficiency.
CEMS Regulatory Audit Checklist
To prepare for an audit, know the answers to the following general questions.
- Has this facility ever been through an audit? If yes, when?
- What was the outcome of the audit, and what was the response to the audit report?
- What training have plant operators received to understand the permit, their obligations under the permit, and plant management expectations? How often is refresher training provided?
- What training have the CEM system operators received to understand the permit, their obligations under the permit, and plant management expectations? How often is refresher training provided?
- What kind of training have the CEM system operators received on maintaining the hardware? How often is refresher training provided?
- Are there records showing when all the training occurred?
- Is there documentation describing the topics covered for all the training mentioned?
To prepare for an audit, know the answers to the following record-keeping questions.
- Does the plant have organized record-keeping or a filing system?
- Does the plant have a designated area for retaining all working records for the CEM/COM systems? Usually, these are the records for the current year.
- Does the plant have a designated area for the long-term retention of past operating and maintenance records (at least five years or more)?
Remember, even on days that the unit does not operate, you still need records proving that the need for the full complement of records is not required.
To prepare for an audit, know the answers to the following QA/QC plan questions:
- When was the last time the QA/QC Plan was updated? When was the last time the CEM Operators reviewed the QA/QC Plan?
- Are there any records documenting the dates of review?
- Are the Designated Representative and Alternate Designated Representative identified in the plan by title and name?
- Has the plan ever been submitted to the local or state agency for their review?
- If yes, what was the result of that review?
- What was the plant’s reaction to the regulatory review?
- Is there an outline or written procedures for each of the quality assurance tests on the plan?
- Does the plan describe how to address invalid data for Part 75 reporting and apply Missing Data algorithms?
- Does the plan describe how to address invalid data for Part 60 reporting? How to add reason and action codes?
- Does the plan describe how to process opacity data processed when invalid or during maintenance work?
- Does the plan describe how to calculate monitored values for:
- 6-minute opacity averages
- 1-hour averages for Part 75
- 1-hour averages for Part 60
- 3-hour averages
- Extended averages for 24-hour, 30-day, or 30-boiler operating averages
To prepare for an audit, please do the following:
- Review the Part 75 CEM Field Audit Manual
- Have up-to-date copies of the following documents:
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Part 75 regulations
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Reporting instructions for Monitoring Plan records
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Quality Assurance and Certification
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Emission records
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- Establish a designated location for all correspondence with the EPA, including:
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Notices for Commencing Certification/Recertification activities
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Notices for RATAs
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Submission notices and feedback reports from the EPA by ECMPS.
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- Have an up-to-date written procedure for how to prepare, generate and evaluate EDR files for:
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Updating and revising Monitoring Plan records
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Quality Assurance and Certification records
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Emission Records
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Have an up-to-date written procedure to review the Part 75 submission files prior to submission.
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Have a written procedure outlining the facility’s plans for balancing any SO2 or NOx mass emissions versus allowances (federal or state programs).
To prepare for an audit, know the answers to the following ECMPS questions:
- Does the plant know where to find ECMPS information?
- Does the plant have the latest set of reporting instructions for:
- Monitoring Plan records
- Quality Assurance and Certification records
- Emissions records
- Does the plant have a procedure for securing and updating the passwords for ECMPS used by the various agents?
CEMS Regulatory Audit Preparation Conclusion
This information in this overview provides an excellent starting point for audit preparations. Read our more detailed and extensive version of Part 75 Audit Preparation Guidelines and Procedures here. We encourage operators to learn from others’ experiences to determine their best courses of action in addition to reading additional resources from the EPA and ESC Spectrum. Need assistance? We’re here to support you and make sure your facility is audit-ready. Contact us to discuss your CEMS audit preparation needs.
Interested in learning more about regulations and staying in compliance? Read our Definitive Guide to Air Emissions Regulations.
Interested in learning a more comprehensive overview of how CEM Systems work? Read Understanding Continuous Emissions Monitoring Systems (CEMS): A Comprehensive Guide. This guide will give you a complete understanding of all the components in the flow of a CEMS.
