Compliance Program Protects Air Quality

By Jay Morris

Did you know that there are over 1,500 stationary emission sources in Utah, along with several hundred federal and state air quality rules and regulations that cover these sources? When I first started performing air quality compliance inspections, I had no idea! Our program, which includes inspections, compliance assistance, and enforcement, protects the public and the environment from air pollution and assists businesses in meeting the terms of their permit. It’s a win-win proposition that reduces emissions and saves facilities time and money over the long run.

So what’s a stationary source, exactly? Well, it’s pretty much what you would think — an emission source that is sited at a specific location. There are two types of stationary sources: major and minor. A major source has the potential to emit at least 100 tons per year of any criteria pollutant, and a minor source has the potential to emit more than 5 tons but less than 100 tons per year.

The following compliance activities help major and minor sources meet the emission limits established in their permits:

• Monitoring
• Testing
• Sampling
• Record-keeping
• Reporting

These requirements ensure that facilities test their equipment, monitor emissions, and submit regularly scheduled reports to the Division of Air Quality (DAQ) to demonstrate compliance with their permits.

My staff and I work with minor sources. You might be surprised by the different kinds of operations that qualify as minor sources: gravel pits, oil and gas facilities, chemical manufacturers, coal mines, and food processing operations. We even conduct inspections at manufacturing plants for diapers, airbags, and bowling balls!

We typically conduct an inspection of a minor stationary source once every three years. Our staff prepares for an inspection by reviewing all applicable rules, emission tests, compliance reports, and approval orders. Our inspections are unannounced, so naturally, it seems like an inspector always shows up at the most inconvenient time! Once on site, we review all of the rules that apply to the source, review and record the operating parameters, look over the equipment, and request records.

After the source provides the requested information, we write up an inspection memo. This memo indicates whether or not we found the company to be in compliance with all of the rules. For the most part, the companies regulated by DAQ operate in compliance with the rules and regulations that apply to them. For those that are not in compliance, we initiate an enforcement action. This may involve the payment of a penalty, and companies are required to get back into compliance in a timely manner.

Over the past few years, DAQ has implemented over 30 new state rules to reduce emissions from area sources to meet the National Ambient Air Quality Standards (NAAQS) for PM2.5. These rules apply to thousands of area sources. Area sources cover a wide range of small businesses and households, which make compliance inspections a little trickier. The new rules limit volatile organic compound (VOC) emissions in everything from consumer products to adhesives and sealants, surface coatings, degreasing and solvent cleaning operations, and graphic arts operations.

Because the businesses that use these VOC-emitting products are scattered over a wide area and aren’t subject to a minor source permit, we have been actively engaging in education and outreach to ensure that these businesses know about the new air quality requirements and understand the measures they can take to comply with the rules. The addition of these area source rules has made our inspection, compliance assistance, and education outreach efforts somewhat challenging. With a staff of seven inspectors to cover facilities across the state and our minor stationary sources and area sources running into the thousands, all of us have a lot of sites to visit!

The good news is we have one of the highest compliance rates in the country — 95+ percent of our permitted sources meet the requirements of their permits.

Want to learn more about our compliance program? You can visit our webpage or check out the Compliance Activity Summaries that we present to the Air Quality Board each month. If you think a site or a facility is potentially violating its permit, fill out our Electronic Complaint Form or call (801) 536-4000. We appreciate hearing from you, and we investigate all complaints we receive.

I graduated in 1994 from Utah State University with a BS degree in Forest Management. I had a short career as a seasonal forester for the forest service and a couple of private companies in Arizona and Oregon before getting hired at DAQ as an environmental scientist in the compliance section in 1995. I spent 12 years in that job and absolutely loved learning about the many industries in Utah and traveling across the state conducting inspections. In 2007, I became the manager of the minor source compliance section and I’m still here! I work with an amazing staff and because of that, I thoroughly enjoy my job.

I have been married to my best friend for 22 years and I have four really awesome kids (three boys, one girl) ranging in age from 8 to 18. My family does everything together. We love to spend time in the outdoors hunting, fishing, camping, and boating. We also love to play soccer, shoot guns, visit new places, and of course, eat ice cream! We are all ice cream fanatics!