An Annual Compliance Certification (ACC) is a reporting mechanism used to let IDEM know if your facility is in continuous compliance or intermittent compliance with your operating air permit. An ACC is required if your company has a FESOP or a Title V Air Permit. The ACC is due July 1st of each year (except for facilities located in Elkhart, Lake, and Porter Counties which have an April 15th deadline). It can be taxing going through one’s air permit page by page to ensure compliance; that is why BCA provides site-specific, permit-specific Annual Compliance Certification Checklists for facilities to document our review of a facility’s permit compliance.See the example here of BCA’s ACC Checklist and here for BCA’s Corrective Action Report. If you would like BCA’s assistance in putting one together, please let us know
Further, BCA staff have put together a list of the most common sections where facilities trigger intermittent compliance with one’s permit:
1. Section E – Not every facility has a Section E. Section E of Indiana air permits contain federal air rules and air standards that pertain to your facility. The most common standards included are subparts from National Emission Standard for Hazardous Air Pollutants (NESHAP) or New Source Performance Standards (NSPS). It is very easy to overlook Section E because it is at the end of the permit and is typically only one or two pages long. Because of this covert nature, facilities may fail to give Section E the time and attention it requires, leading to noncompliance, deviations, and/or violations to one’s air permit.
2. Preventative Maintenance Plan (PMP) – Most facilities are required to prepare and implement a PMP per Section D of their permit per 326 IAC 1-6-3. Make sure your facility has written copy of the PMP that an IDEM inspector can readily view, and make sure your facility can demonstrate that the PMP is followed.
3. Daily Pressure Drop or Flow Readings — Facilities with a scrubber, RTO, baghouse or a number of other types of control devices may need conduct daily readings of pressure drop, differential pressure or flow. Some days these may be missed, or some days they may be recorded outside of range without an appropriate corrective action documented. Some of those missed days may actually be days without production, so make sure to look through production records first to cross reference prior to marking down a deviation for yourself. If a corrective action was not identified for days the reading was out of range, we suggest digging a bit dipper to find the root cause of this issue to make sure it does not continue to cause deviations.
PUBLICATION DATE: March 29, 2017
AUTHOR: Melissa Paar, Project Manager