Surviving an Ohio EPA Inspection – Part 2
by: Amy Wyatt
As discussed in an earlier blog, being prepared is the best starting point for surviving an EPA inspection. By preparation, good record keeping throughout the year, and keeping up with requirements, the inspection itself will be seamless. Preparing for an Air Pollution Inspection requires several considerations.
First of all, you need to know what needs permitted?
There are 4 general rules of thumb when it comes to air permitting.
- Something with a stack, vent or dust collector needs a permit
- Something that uses solvents, paints, inks or adhesives needs a permit
- Something that burns fuel needs a permit
- Something that causes smoke, dust or odors needs a permit
Not everything needs an air permit. There are some permanent exemptions listed in the Ohio Administrative Code (3745-31-03) or if the emissions are considered “De minimus” (emits less than 10 lbs/day of air pollutants or less than 2000 lbs/yr of hazardous air pollutants and can’t be subject to federal rules like NESHAPS).
Assuming you have the required permits, organize the permits and all records associated with them to insure that they are up to date and complete.
As stated in the previous blog, the Division of Air Pollution Control does conduct its own inspections. It can be based on a complaint or just a routine inspection.
During the opening meeting the inspector will ask about the facility process, describe the records he or she wants to review and discuss air permit statuses. Then a facility walk-through will be conducted.
During the facility walk-through the inspector will be looking for:
- Visible emissions and off-property odors
- Records required by air permits
- Ensure everything that needs an air permit has one
Visible emissions include stack emissions (the opacity of the emissions coming out of the stack) and fugitive emissions (non-stack visible plumes).
The records check includes:
- Paint and solvent usage, and VOC content of the materials
- Fuel usage and fuel types
- Material throughput, production rates
- Pollution control equipment monitoring and maintenance records
- Emission test results (if required)
Common Air Pollution Violations include:
- Installing and operating equipment without obtaining proper air permits
- Not maintaining records required by permits
- Exceeding permit limits
- Not maintaining air pollution control equipment
Be prepared for an inspection by:
- Identifying your air pollution sources and determine if they are exempt or need a permit
- Keeping air permits and required records in an accessible location (computer records are OK)
- Being aware of any visible emissions and/or odors from your facility
- Maintaining air pollution control equipment
- Ceasing any open burning
TKEC can provide regulatory assistance to companies to help them be prepared for an inspection.