Introduction to the Compliance Spreadsheets February 28, 2006 Judy B. Yorke Yorke Engineering, LLC 949-248-8490 x25 JYorke@YorkeEngr.com

Overview: Rule Summaries Identify all compliance requirements Summarize policies and procedures Identify responsible individuals Identify mechanism for systematic compliance assurance

Overview: Audit Checklists Provide systematic compliance assurance Ensure compliance with all requirements Record keeping

Types of Checklists For RECLAIM and Non-RECLAIM Facilities Summaries: Rule Requirements Audit Checklists: Facility-Wide Requirements Boilers and Process Heaters Ovens Internal Combustion Engines Gas Turbines

How to Use Checklists STEP FOUR Audit Checklists: Complete One for Each Unit STEP THREE Audit Checklists: Review & Modify STEP TWO Rule Summary: Complete Compliance Assurance STEP ONE Rule Summary: Review and Modify

Rule Summaries Rule Number/Identifier Rule Name Date of Adoption or Most Recent Amendment

Rule Summaries Defines What the Rule Applies To Defines Exemptions Summarizes Rule Requirements

Rule Summaries Summarizes the Rule’s Monitoring Requirements Reporting Requirements Summarizes the Rule’s Recordkeeping Requirements

Rule Summaries Policies and Procedures to Ensure Continuous Compliance Individual Responsible

Rule Summaries Summary of Compliance Documentation Date of Most Recent Compliance Verification

Equipment Checklists Rule Number/Identifier Rule Name/Descriptor

Equipment Checklists Date of Adoption or Most Recent Amendment Audit Question: Is This Rule Current?

Equipment Checklists Audit Question Applies to These Units... ...Unless These Exemptions Apply Audit Question Number

Equipment Checklists Suggested Response to Findings Specific Question Answer to Question

Equipment Checklists Suggested Method to Obtain Answer Actual Method to Obtain Answer

Equipment Checklists If Problem, Long Term Plan to Attain Compliance If Problem, Short Term Response to Avoid Violation

Commitment to Assistance The Gas Company is Committed to Assisting Our Customers Throughout the Title V Process Call for Questions or Assistance! 562-803-7428