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Published on December 17, 2007

Author: Chyou

Source: authorstream.com

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Investigation Preparation:  Investigation Preparation Susan Thompson TCEQ Investigator, Amarillo Region Bet you already know a lot about this topic!:  Bet you already know a lot about this topic! Has anyone here not yet done any on-site compliance investigations? Try to guess what I’m going to say… Guess the five steps I’ve written down as parts of “Investigation Preparation.” You could get chocolate for this. 5 Steps to Preparation:  5 Steps to Preparation Locate/Read/Review facility file. Familiarize yourself with units/processes and their permits/authorizations/rules. Familiarize yourself with the particular investigation and equipment protocols. Create or locate a “checklist” you can follow while on site. Gather PPE and other equipment. Preparation:  Preparation Overall preparation time should take at least as long as the investigation itself. Facility File:  Facility File Allow plenty of time to review. Time invested here will more than pay itself back. Try to figure out what every single document in the file means – flag questions. Focus especially on permits and other authorizations, and rule applicability. Units & Processes:  Units & Processes Do your best to understand, but… Refuse to let yourself be intimidated by the stuff you don’t yet understand. Seriously. I mean it. Don’t be intimidated. You can still do your job. (I have met many a company environmental rep. who doesn’t recognize and understand all of the equipment and processes either.) Questions Toolbox:  Questions Toolbox Level 1 – When you don’t mind admitting the true depths of your ignorance. Congratulations! You have selected the express track to getting up to speed. No loss of face for brand-new investigator Just say, “What’s ‘at?” and “How’s it work?” a lot. Take pictures and copious notes. Especially rewarding when company rep. has a “helping” attitude. Questions Toolbox: Level 1 (continued):  Questions Toolbox: Level 1 (continued) Won’t slow you down at all in noticing things that might turn out to be problems “Should that be smoking?” “So if the still vent is being re-routed to the firebox, how come there’s steam coming out of it?” “What’s the deal with all those vapors I can see coming from the top of that tank?” Questions Toolbox:  Questions Toolbox Level 2 – When you feel a little embarrassed; you think you “should” know more by now; you’ve forgotten stuff you used to know DO NOT let your worries and insecurity cause you to rush through the investigation. Let the permits and reg’s be your guide. Stick to them like glue. Go step by step. Your best friend is the all-purpose question: “How does your company show you are complying with this rule?” Questions Toolbox – Level 2 (continued):  Questions Toolbox – Level 2 (continued) It’s always best to have a working knowledge of the equipment and processes, but… To be perfectly candid, 90% of the time it’s not a prerequisite to determining compliance with the rules. So get over it. You’ll learn as you go. Questions Toolbox – Level 2 (continued):  Questions Toolbox – Level 2 (continued) Consider spending more time accompanying other investigators on their investigations. Ask them your questions. (But maybe not directly in front of company rep.) Note that they may not know all the answers, either. See? This is realistic. Questions Toolbox – Level 2 (continued):  Questions Toolbox – Level 2 (continued) You can take steps that don’t involve asking questions to others. Read trade journals. Refer to Air Pollution Engineering Manual. Take some training. Check out Howstuffworks.com Other online resources. Questions Toolbox: Level 2 (continued):  Questions Toolbox: Level 2 (continued) If the difficulty lies in understanding the reg’s themselves… You’re in a big, albeit largely unacknowledged and secret, club. To locate other members of the club, try walking up to them and saying, “So, I was wanting to talk to you about 40 CFR 60 Subpart [whatever]” Note eye twitches, loud sighs, cursing, sudden yoga poses, holding of head, rocking in place with “faroff” expression on face, and open weeping. Questions Toolbox: Level 2 (continued):  Questions Toolbox: Level 2 (continued) For the sufferers of CFR-induced PTSD Read (and re-read) the Reg’s. Check out the available aids on EPA’s website. Ask other investigators if they have any checklists they have created themselves. If out of prep. time: Just ask company rep., “Show me what you’ve got for KKK compliance.” Take notes and evaluate later. Investigation & Equipment Protocols:  Investigation & Equipment Protocols Theoretically, these should be easy-to-find and follow. Rely on more experienced investigators and your supervisor. “Snoop” by reading approved reports from other regions. Use them as templates. Equipment questions for which you cannot find an answer – call an expert (trainers, authors of the protocol, headquarters contact person) “Checklists”:  “Checklists” If you are doing an investigation with a pre-existing checklist, rock on! You are lucky. Many times you will have to create your own. Use it as a guide and to make sure you don’t forget anything. Photocopy of plot plan can be helpful. Gather PPE & Equipment:  Gather PPE & Equipment Check with company for PPE guidelines. “Fit” is not a vanity issue. Make sure your stuff fits. Know and follow proper use and care of equipment. Priority is to know ways in which the equipment is vulnerable to being damaged or broken, or giving “bad” data. (Hold questions until after Alice’s part):  (Hold questions until after Alice’s part)

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