Air Quality: Inspectors Ensure Permit Compliance

By Cindy Beem

Ever wonder how the Division of Air Quality (DAQ) confirms that a facility is satisfying the requirements of its permit? Each permitted facility has to comply with a very long list of conditions that protect air quality, including the installation of specific pollution-control equipment, compliance with emission levels established in the permit, monitoring, record-keeping, and systematic reporting. Our Compliance Section inspects facilities on a regular basis to ensure that they are meeting the conditions in their permit.

My job is to inspect major sources of air pollution that operate under a Title V Operating Permit  and/or Approval Order. I am assigned to inspect one refinery, one university, power plants, manufacturers, incinerators, and landfills. Depending on the complexity of the permit, it takes me anywhere from a half day to several days to prepare for a site visit. To prepare for my inspection, I review the permit and/or any approval orders, check to see if new federal regulations apply, verify required reports have been submitted on time, and draft an inspection checklist. If needed, I will consult with the DAQ permit writer for the facility to see if there are any additional issues that need to be addressed during the inspection.

Most air quality inspections are “no notice,” meaning the facility isn’t told in advance that we’re coming. Before I enter the site, I perform an overall visual observation from the road to look for any potential opacity exceedances. Then I check-in and meet the appropriate contact person, usually an environmental manager or a health and safety director. We discuss the purpose of my inspection, and the contact person goes over the site-specific safety requirements.

The most important aspect of my inspection is working safely. So I don my safety gear in preparation for the site walk-through. I systematically walk through the facility to verify that plant processes and emission control equipment are installed and are operating according to the permit requirements. I also check whether the facility has installed any unapproved equipment. A major focus of my inspection is to take Method 9 visible emissions observations on all emission points to verify that the facility is in compliance with its opacity limits.

After my walk-through, I sit down with the contact person and perform a detailed inspection of their records. If the facility is required to do continuous monitoring for emissions, I examine the data to see if there are any data gaps. Some facilities have a calibrated monitoring system that schedules data collection, and I look at that data as well. I carefully scrutinize the facility’s monitoring records and compare them with the allowable emissions contained in their permit. At the close of my inspection, any potential deviations from the permit and/or approval order and corrective actions are discussed with the contact person and, if needed, the plant manager. The contact person receives a copy of my visible emission observations and compliance status notes.

I mail the company a compliance advisory for any potential permit deviations that were found during my inspection or report review. Areas of non-compliance can range from minor record-keeping and reporting deviations to exceedances of emissions or operating limits. Based on the facility’s response to the compliance advisory, DAQ may issue a notice of violation (NOV), warning letter, or no further action letter. Occasionally, the facility will request a meeting to discuss the compliance advisory further. If the facility is found in violation of its permit and/or approval order, I track the facility to ensure that it has implemented all corrective actions and ascertain when it has come back into compliance. DAQ has a penalty policy that is used to address fines for violations.

In addition to my inspections, I investigate complaints about air pollution problems or breakdowns. I look into these complaints, determine the nature and extent of the problem, prepare documentation of the findings, and consult with citizens on the status of the complaint.

I love my job and enjoy the opportunity to work with a wide variety of permitted facilities across the state. Providing educational and technical assistance for facilities and public outreach is also an important part of my job. I believe that the more informed the regulated facilities and the public are about preventing air pollution, the better our air quality will be.

If you believe that a facility may be violating its permit, DAQ wants to know about it! You can call us at (801) 536-4000 and speak with the inspector assigned to the facility or use our electronic complaint form. Curious about what we do? We provide monthly reports on our website of our compliance activities, including inspections, compliance actions, and settlement agreements.

I have worked as an inspector for DAQ for over twenty years. I am a certified fitness instructor and specialize in teaching the MELT Method, offering a Thursday fitness class for employees at DEQ and the Department of Human Services. I enjoy healthy cooking and love animals, particularly my horse and dog. I practice natural horsemanship with my thoroughbred whenever I get the chance. My husband and I have a 20-year-old daughter with Downs Syndrome who attends post-high school learning center. She has a high brown belt in karate and specializes in self-defense move.