In our continuing series about auditing and how it can be similar to an annual physical, we will discuss an often overlooked area; a deep dive into air permitting. Just as an annual physical may gloss over some of the more specific parts of the body, air permits can also sometimes be overlooked but doing so can lead to a potential problem in the long run.
Every year, the Doctor asks a list of questions, such as, “Has anything changed in your immediate family’s health (diagnosed with diabetes, heart disease, ADHD)? Who lives at your home? Do you have any pets? Do you have any concerns at the moment? In a similar fashion, prior to an air audit, the auditor will send you a list of questions. Do you have an air plan approval? Do you have air emissions tracking sheets? Do you have a control device? All of these questions help the Doctor/Auditor get an overview of your health/facility and any specific areas that may be of concern.
Your responses become the roadmap for the auditor. If you stated you do not have an air plan approval, the auditor may request a listing of how much solvents are used onsite to determine if the facility needs to further evaluate/justify whether a plan approval is needed or if there is an exemption that excludes a facility from obtaining an air plan approval. The auditor will check if you are maintaining documentation that states how you are complying with the regulation or why your facility meets the listed criteria exemption.
As with your annual checkup, the more symptoms/details you can provide to the Doctor increases their ability to provide you with advice on what you need to do to maintain a healthy lifestyle. Are there warning signs that you may not have noticed with your air permits?
Your volatile organic compound (VOC) emissions from a small process is approaching permitting level
The state updated their Regulated Toxic Air Pollutant (RTAP) list and you missed the notice
EPA has finalized a regulation that applies to you
An emergency generator was installed at your facility and was not self-certified
Emission statements were not submitted
These are some of the most common findings found during an air audit. What happens if you don’t see the warning signs or you ignore them for too long? The small warning signs can compound each other to create one larger issue. Just like your health, it is good to go through the annual checkup to help catch the small warnings before it becomes a larger issue and is too late to be fixed.
Just like there are apps to track your health on your phone, computer, or other electronic device, CAPACCIO’s EHS DashboardTM can help you track your facility’s data making an audit by the state or federal inspectors that much easier. Learn more about the dashboard at www.ehsdashboard.com.
For more information on air permits or other air compliance related questions, please contact Lynn Sheridan, EIT, at 508-970-0033 ext. 122 or by cell at 774-249-2565 or email firstname.lastname@example.org.