Quick CEMS Audit Preparation Checklist
Updated: Sep 9
The Environmental Protection Agency uses audits to safeguard health and the environment by helping facilities discover and fix federal and state law violations.
The EPA may audit your facility for several reasons — increased failed calibrations, questionable data for CO2 audits, flow-to-load or heat input changes, reporting errors, late quarterly reports, or as 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 a data acquisition system (DAS) like StackVision, Alliance's industry-leading DAS, 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 how to make adjustments to parameters. With a DAS like StackVision, you decide how you need to comply and how you want to configure your system — while starting within the framework of a robust compliance engine that gives you full transparency and control.
StackVision creates, calculates, records, and retains each of these averages and data points for verification purposes. This traceability is extremely valuable during audits with regulators, since you can show the exact values, processes, and calculations behind any questioned average.
Being able to easily prove that quality assurance procedures are in place — and being followed precisely — also gives you firm ground to stand on during an audit. A quick review of a few displays or scheduled reports each morning tells you the state of your system and lets you plan your day. If a monitor is drifting out of control, you can respond. If a calibration check fails, you can act quickly to fix it and reduce downtime. Since much of what used to eat up your time is automated, you have more time to investigate anything trending toward a problem.
That doesn't mean the process is out of your hands, though. A good DAS configures the system to fit your needs and the automation level that's right 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 explain any unusual situation.
Additionally, a DAS can provide predictive averages and alarming to help you avoid hazardous or legally challenging situations like exceedances and deviations — helping you stay out of trouble from an environmental or permit perspective while maximizing operating efficiency.
Download Our CEMS Regulatory Audit Checklist:
CEMS Regulatory Audit Checklist
CEMS Audit Checklist: General Questions
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?
CEMS Audit Checklist: Recordkeeping Questions
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 the unit does not operate, you still need records proving that the full complement of records isn't required.
CEMS Audit Checklist: Quality Assurance Quality Control (QA/QC) Plans
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 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 procedure for each of the quality assurance tests in 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 opacity data is 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
CEMS Audit Checklist: Acid Rain Program Questions
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:
Part 75 regulations
Reporting instructions for Monitoring Plan records
Quality Assurance and Certification
Emission records
Establish a designated location for all correspondence with the EPA, including:
Notices for Commencing Certification/Recertification activities
Notices for RATAs
Submission notices and feedback reports from the EPA via ECMPS
Have an up-to-date written procedure for how to prepare, generate, and evaluate EDR files for:
Updating and revising Monitoring Plan records
Quality Assurance and Certification records
Emission Records
Have an up-to-date written procedure to review Part 75 submission files prior to submission.
Have a written procedure outlining the facility's plans for balancing any SO2 or NOx mass emissions versus allowances (federal or state programs).
CEMS Audit Checklist: ECMPS Questions
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?
Need assistance? We're here to support you and make sure your facility is audit-ready.
