We recently came across an article in Pollution Engineering that highlights an important issue for all major facilities - air fines and how to avoid them. It is everyone's responsibility to ensure compliance and the best way to do so is by educating yourself and your team and by networking with others in the industry. Below highlights the main points from the article, but please visit the link above for a more detailed approached.
1. Compliance is a team effort and the best preventive measure is to keep the entire team aware and fully briefed on where the facility stands in regards to compliance. With everyone in the know, compliance becomes a vested interest and a shared responsibility.
2. A basic review of your facility's Title V permit, a federally enforceable document that provides parameters on plant emissions, is a good first start. A review of the basic allowable permissions contained in the permit will lead the way.
3. Set a date for a frequent (yearly) review of the Title V permit. This will help flag inconsistencies and avoid further inspections and notices of violation (NOV).
4. Get to know your local inspectors and do not hesitate to ask them for guidance. Ask them informative questions about what common violations they have seen lately and what others in the industry are doing to keep in good standing.
5. Check out the following websites: The EPA's Acid Rain Inspectors Guide and the Clean Air Markets Division.
6. To help keep abreast of changing regulations, join an association membership and attend industry events (conferences, seminars and tradeshows). Organizations such as the ABMA, CIBO and others update their members on a continual basis.
7. Subscribe to the U.S. Environmental Protection Agency's Monthly Digest Bulletin. This e-magazine can be subscribed to by emailing usaepa@govdelivery.com.
8. Show pride in maintaining compliance and recognize and reward employees for their efforts in maintaining compliance.
9. When evaluating vendors for stack testing, check their references, inquire about their experience in performing the tests needed to stay in compliance, and make sure that their work is conducted to the highest standards. Ask vendors if they are a Qualified Stack Test Individual, or QSTI.
10. Let your customers know about your compliance goals and your efforts to maintain "green" in your facility. Also promote this message to your stakeholders in the community.
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