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Federal and State rule require that the responsible official (RO) signing the Title V annual compliance certification certify its accuracy based upon information and belief formed after “reasonable inquiry.” EPA has issued guidance highlighting that “reasonable inquiry” includes identifying the methods and any other material information used to determine compliance status of each permit term […]

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Can anyone at the facility sign the air permit applications, compliance certifications, or deviation reports? The answer is in the Clean Air Act regulations, complex, strict, and can have serious consequences if not implemented correctly. Following is the definition of Responsible Official in federal and state regulations: Responsible official means one of the following: (1) […]

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In Pennsylvania, just like other States, there are thresholds — below which a source, or an equipment, is considered exempt from the requirements to have a permit before installation. Pennsylvania DEP’s air quality permit exemptions are listed in document number 275-2101-003. Google it! Every facility should have a copy of the permit exemption list as […]

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EPA published a final rule to establish notification for retrospective reporting of chemicals on the TSCA Inventory that were manufactured or imported during the 10-year period; between June 2006 and June 2016. The purpose of the rule is to “reset” the TSCA inventory maintained by the EPA. Here are the highlights: The rule requires manufacturers […]

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The Environmental Protection Agency (EPA) is revising existing hazard classes to conform to the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard. Current 311/312 hazard categories: Fire Sudden Release of Pressure Reactive Immediate (Acute) Delayed (Chronic) New 311/312 hazard categories: Many states have their own software for hazardous chemical inventory reporting. Other states use […]

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