Air Quality Operating Permit Monitoring, Recordkeeping, and Reporting Requirements

Often, the administrative compliance costs of an environmental permit can easily outweigh the costs of engineering controls. Hidden behind the discharge limitations can lurk a commitment to extraordinary labor, instrumentation, laboratory, and management costs. It is important to manage the permit process as you would any other critical component of manufacturing and production.

For example, environmental agencies are working hard to issue facility-wide operating permits, such as Title V and Synthetic Minor Operating Permits, to cover all air-emitting sources at affected facilities. One new element of these facility-wide operating permits calls for more comprehensive monitoring, recordkeeping, and reporting to demonstrate that all emission sources are meeting the requirements.

With these more detailed requirements, you need to be careful that your permit is not overly burdensome, both in terms of costs for testing or installing monitors, or in the time personnel must spend to conduct the required monitoring. In addition to potentially large penalties for noncompliance with the terms and conditions of these permits, the EPA is considering posting the semiannual reports of deviations from Title V facilities on its website.

IES SERVICES
Early on, IES can work closely with you and the agency personnel while your permit is being drafted. Then, IES can assist you with your review of the draft permit to ensure it has the flexibility your operations require, continue negotiations with the regulating agency, develop and implement a costeffective monitoring, recordkeeping, and reporting program, and take turnkey responsibility for conducting the program required in the permit.

Need More Information?

Call or e-mail:
Marj J. Fitzpatrick, QEP (mfitzpatrick@iesengineers.com) or
Robert W. Schlosser, P.E. (rschlosser@iesengineers.com)

610-828-4090 (PA) or 908-904-4300 (NJ)

Web Address: www.iesengineers.com