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SMG POV
Due date for the Kentucky Air Quality Permit Compliance Reports for 2013
WRITTEN BY
Kyle Hagen, P.E.TAGGED
As annually required for facilities in Kentucky (excluding facilities in the Louisville Metro Air Pollution Control District) with current Kentucky Air Quality Permits, two compliance reports are due by January 30, 2014 to the Kentucky Division for Air Quality (DAQ). The first is the Semi-Annual Monitoring Report that is required to summarize the facility operations during the 2nd half of 2013 (July through December 2013). This report is used to document the performance of required monitoring and to inform the DAQ of any deviations from monitoring parameters such as permit limits. The second required report is the Compliance Certification Form (form DEP7007CC) that is required to summarize and certify the facility’s compliance with the terms and conditions contained in their permit for the period of January through December 2013. The intent of this reporting requirement is for the facility to annually audit, confirm, and ensure compliance with air regulations and the permit. Both of these reports are required to be certified by a “responsible official” who meets the definition found in the Kentucky regulation 401 KAR 52:001 Section 1 (62). For most facilities the semi-annual report is only required to be submitted to the DAQ Regional Office listed on the front of each facility’s permit. For State-Origin minor source and FESOP conditional major facilities the annual Compliance Certification Form is due to the DAQ Regional Office only; however, for Title V Synthetic Minor and major source facilities the annual Compliance Certification Form is due to both the DAQ Regional Office and the Air Enforcement Branch of U.S. EPA Region 4 in Atlanta. Please consult your permit to verify the specific reporting requirements and report recipients.
One change this year to the submittal process is the ability for the reports to be submitted either by hardcopy as in the past or electronically online using the DAQ eForm system for submittal to the DAQ Field Operations Branch. The eForm system can be used by navigating to the following website: https://dep.gateway.ky.gov/eForms/Default.aspx?FormID=34
Please contact Kyle Hagen at (859) 231-8936 ext. 118 or by email at kyleh@smithmanage.com for more information or help preparing your reports.
FEATURED PROJECT
PROBLEM
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG'S APPROACH
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
MG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
RESULTS
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.