EPA inspectors arrive with specific documentation requests. Facilities that can produce complete records within minutes demonstrate compliance. Facilities scrambling to locate equipment specs, service logs, and discharge certifications create red flags that trigger closer inspection.
This comprehensive air compressor EPA audit checklist covers exactly what inspectors request and how to prepare documentation before they arrive.
Pre-Audit Documentation Verification
Before EPA inspectors schedule a visit, facilities should verify they can produce all required compressed air condensate documentation within 30 minutes.
Critical Documents Checklist
| Document Category | What Inspectors Request | Where to Find It |
|---|---|---|
| Equipment Specifications | Model number, serial number, CFM rating, installation date | Compliance documentation package |
| Discharge Certification | <15 ppm oil-in-water verification | Manufacturer certification (included with Joruva systems) |
| Service Records | Maintenance log showing service intervals | Pre-formatted log (provided with equipment) |
| Regulatory Compliance | 40 CFR 279 requirements summary | Compliance documentation package |
| State-Specific Requirements | California, NY, OR additional requirements | State compliance addendum |
Equipment Inspection Points
EPA inspectors conduct physical equipment inspections to verify documentation matches actual installation:
What Inspectors Examine
- Oil-water separator location and condition
- Properly mounted and connected
- No visible leaks or damage
- Discharge line properly routed to sewer connection
- Secondary containment if required
- Labeling and identification
- Equipment labeled as “Oil-Water Separator” or equivalent
- Warning labels visible and legible
- Hazardous material placards if applicable
- Service indicator status
- Hours meter reading (if equipped)
- Service indicator color/status
- Last service date visible
- Condensate routing
- All compressor condensate drains route to separator
- No bypass lines allowing untreated discharge
- Proper air-gap at discharge point
Service Interval Verification
Inspectors verify that oil-water separators receive service within manufacturer-specified intervals:
Service Documentation Requirements
For each service event, documentation should show:
- Date of service
- Operating hours at service
- Service kit part number installed
- Technician name/company
- Post-service verification (system operational)
Facilities using 6,000-hour service interval equipment must demonstrate intervals don’t exceed 6,000 hours between services.
Red Flags That Trigger Violations
- Service intervals exceeded by >10%
- Missing service documentation for current interval
- No service performed for >12 months (even on low-use equipment)
- Service indicator showing past-due status
Discharge Quality Verification
Inspectors may request discharge quality testing or review existing test results:
Discharge Testing Options
| Testing Approach | Frequency | Typical Cost |
|---|---|---|
| Manufacturer Certification | At installation | Included with equipment |
| Periodic Lab Testing | Annual or as permit requires | $150-300/test |
| On-Site Field Testing | As requested by inspector | $200-400/visit |
Joruva systems include manufacturer <15 ppm discharge certification as standard. This documentation satisfies most inspection requirements without additional testing unless specific permit conditions require periodic verification.
Common Inspector Questions
Facilities should prepare answers to standard questions EPA inspectors ask:
Operational Questions
- “How do you manage condensate from your compressed air systems?”
Prepared answer: “We use an EPA-certified oil-water separator that treats condensate to <15 ppm before sewer discharge. Here's our discharge certification and service log."
- “When was your oil-water separator last serviced?”
Prepared answer: “Service was performed on [date] at [hours] operating time. Here’s our service record showing the service kit installed and technician information.”
- “How do you track service intervals?”
Prepared answer: “We receive automated email/SMS reminders before service intervals expire. Our equipment vendor monitors intervals and notifies us proactively.”
- “What happens to the treated condensate?”
Prepared answer: “Treated condensate discharges to our sanitary sewer system after meeting <15 ppm certification. We maintain required air-gap at the discharge point."
- “Do you have permits for this discharge?”
Prepared answer: [State-specific] “California facilities: Yes, here’s our Industrial Wastewater Discharge Permit from [Regional Board]. Other states: Discharge is covered under general sewer discharge provisions as treated non-hazardous wastewater.”
State-Specific Compliance Points
Different states impose varying documentation requirements beyond federal baselines:
California
- Industrial Wastewater Discharge Permit from Regional Water Board
- Used Oil Generator Registration (if applicable)
- Quarterly discharge quality reports (if required by permit)
- Best Management Practices documentation
New York
- Used Oil Generator registration (if >25 gal/month)
- Annual used oil reports to DEC
- Spill Prevention Control and Countermeasure (SPCC) plan compliance
Oregon
- Enhanced labeling requirements for storage areas
- Secondary containment verification
- DEQ hazardous waste determination documentation
Facilities operating in multiple states should maintain state-specific compliance files for each location.
Inspection Day Protocol
When EPA inspectors arrive, facilities should follow structured protocols to ensure smooth inspections:
Step-by-Step Inspection Process
- Gather pre-assembled documentation
- Equipment specifications
- Discharge certification
- Service records
- Regulatory compliance summary
- Designate knowledgeable escort
- Facilities manager or maintenance supervisor
- Familiar with compressed air system operation
- Can answer operational questions
- Conduct equipment walkthrough
- Show location of all air compressors
- Demonstrate condensate routing to separator
- Point out discharge connection and air-gap
- Provide documentation as requested
- Present organized files
- Explain service tracking system
- Highlight proactive monitoring approach
- Answer questions directly
- Don’t speculate if unsure
- Offer to provide follow-up information if needed
- Document any inspector concerns for follow-up
Post-Inspection Follow-Up
Even successful inspections may generate follow-up requests or recommendations:
Typical Post-Inspection Actions
- Information requests: Additional documentation not available during inspection
- Minor corrections: Labeling updates, secondary containment enhancements
- Periodic reporting: Quarterly or annual compliance reports if required
Facilities should respond to all inspector requests within stated timeframes. Delayed responses create appearance of non-cooperation.
Violations and Remediation
If inspectors identify violations, facilities should:
- Document the specific violation cited
- Request clarification on remediation requirements
- Develop correction timeline
- Implement corrections promptly
- Document corrective actions
- Submit verification to inspector
Minor violations corrected quickly typically result in warnings rather than financial penalties. Delays or incomplete corrections escalate enforcement.
The Compliance Partnership Advantage
Facilities working with compliance partner vendors gain significant advantages during EPA inspections:
- Pre-audit consultation calls: 30-minute preparation before inspections
- Documentation completeness review: Verify all required records are accessible
- Inspector Q&A preparation: Rehearse common questions with prepared answers
- Post-inspection support: Assistance with follow-up requests
This support eliminates the need to hire compliance consultants or scramble internally to prepare for inspections.
Downloadable Checklist
Joruva provides a comprehensive air compressor EPA audit preparation checklist to all customers. The checklist includes:
- Pre-inspection documentation verification
- Equipment inspection preparation
- Inspector question preparation
- State-specific compliance items
- Inspection day protocol
Request a quote to receive the complete audit preparation checklist along with equipment-specific compliance documentation.
Next Steps
EPA inspections don’t need to be stressful. Facilities that maintain organized documentation and prepare for common inspector questions complete audits quickly without violations.
If your facility needs compressed air condensate management equipment with complete compliance support, request a quote or call (602) 428-4236 to discuss audit preparation assistance.
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