Air Pollution Permit Compliance
The APCD Compliance department works with facilities that have been issued permits by the APCD to help ensure they are following the requirements of their permits and can continue doing business in a safe and responsible manner.
APCD Engineers regularly inspect industrial sources that have been issued a permit by APCD to monitor compliance with permit requirements. The frequency of inspection depends upon the type of source and the requirements in the permit, but may be done more frequently at the discretion of the compliance team.
The inspection process generally begins with a plant tour where the equipment and monitoring techniques used by the company are observed to ensure that emissions are minimized by proper and efficient operations. Reviews are also done to make sure that the recordkeeping requirements of the permits are being fulfilled. Recordkeeping is done to provide proof of compliance and adherence to the monitoring requirements described in the permits. If the inspection reveals that the source may be in violation then a Notice of Violation will likely be issued and enforcement action taken.
Each inspection is documented and maintained on file in an inspection report. All inspection reports are available to the public through open records request.
Permits issued by the APCD often require annual, semi-annual, or quarterly reports to be provided to APCD. These reports document that proper records are being maintained by the facility, and are directly tied to the recordkeeping and monitoring that the company is required to perform on their equipment. The facility's reporting, recordkeeping, and monitoring requirements are explicitly stated in their issued permit.
The reports are not required to contain all of the recordkeeping information that is required by the permit, but an adequate amount to show that hourly, daily, monthly, or yearly standards are not being exceeded by the company. The reports are also provide the APCD with insight into the emission levels emitted by the company over the course of each year. If due to the information in the report, APCD believes exceedance of the standards is likely, preemptive action may be taken to help the facility maintain compliance.
Federal Regulations as established in the Code of Federal Regulations, 40 CFR Part 60, 40 CFR Part 61, and 40 CFR Part 63 also have reporting requirements and independent due dates that are applicable to the affected facility regardless of their description in the permit issued by the APCD.
Annual Compliance Certifications and Emissions Inventories are examples of additional reports that are required by the APCD.
A permit may require testing to demonstrate compliance with the permit standards or to determine an emission rate. The test methods follow procedures from Federal Regulations and EPA guidance documents.
The tests are often conducted at the outlet vent of a control device, a piece of production equipment, or may be required to be conducted at the inlet and outlet of a control device such as a baghouse. Tests are accomplished using sample probes inserted into ductwork and stacks which exit processes, controls and sometimes buildings.
The compliance team reviews all test reports submitted for accuracy and to determine if additional permit limits may be needed for compliance.
Stack test requirements in most cases are as follows:
- The owner or operator shall provide written notification to the APCD of the actual date of achieving normal operation. The written notification shall be postmarked within 15 days after the date of achieving normal operation.
- The owner or operator shall within 180 days of achieving normal operation conduct a compliance test.
- The owner or operator shall submit a written compliance test plan including all the details of how the compliance test is to be conducted. The compliance test plan shall be furnished to the APCD at least 30 days prior to the actual date of the compliance test.
- The owner or operator shall provide the APCD at least 10 days prior notice of any compliance test to afford the APCD the opportunity to have an observer present.
- Testing should be performed at the maximum rated capacity of the process equipment.
- The owner or operator shall furnish the APCD with a written report of the results within 60 days following the actual completion date of the compliance test.
- The test report furnished to the APCD shall include a certification statement, with the date and signature of the Responsible Official for the company having the stack test performed.
APCD has provided a Compliance Assistance Templates and Forms web page to help businesses comply with air pollution regulations. Engineers are also trained to provide assistance with calculations and record keeping. The engineering staff can be reached by contacting the APCD through this form or at (502) 574-6000.
Smaller sources and small business may contact our Small Business Environmental Assistance Program through this form or at (502) 574-6000.