October 25, 2016
By:
Walter G. Wright
Category:
Arkansas Environmental, Energy, and Water Law
Arkansas Environmental, Energy, and Water Law
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Benjamin Holden, P.E., undertook a presentation at the Arkansas Environmental Federation Convention entitled Avoid the Deviation: The Art of Compliance (“Presentation”).
Mr. Holden is an Air Services Engineer with GMBc & Associates.
The focus of Mr. Holden’s presentation was Clean Air Act permit deviations. He addressed different types of deviations which included:
- Unavoidable Deviations
- Preventable Events and Deviations
- Deficient Records
- Inaccurate Permitting
- Poor Communication
- Lack of Knowledge of Requirements
The Presentation included a “Case Study” that addressed issues at a facility such as:
- Inaccurate permitting
- Deviations during inspections
- Missed reporting deadlines
- Deficient recordkeeping
- Inadequate communication between production and environmental staff
- Poor relations with regulators
For each of the Case Study “issues” a potential solution was discussed. For example, in addressing “Inaccurate Permit Representation” a suggested solution included:
- Site Visit/Internal Audit
- Take notes of all potential sources and stacks (including non-regulated sources)
- Take pictures
- Update permit (if needed)
- Document all sources and non-sources
- Add physical signs to equipment and/or stacks with permit source number and description
- Include all information in compliance manual
Potential solutions for the other issues included:
- Deviations During Inspections – Permit Review/Document facility compliance methodology
- Missed Reporting Deadlines – Compliance Calendar/Include all routine actionable items
- Deficient Recording – Tracking Spreadsheets
- Inadequate Communication - Involve management/Require all product changes go through environmental review/Environmental review of all capital projects/Routine review of projects between corporate and facility environmental staff, etc.
- Poor Relations with Regulators – Compliance Manual/Keep records accessible
A copy of the slides from Mr. Holden’s presentation can be downloaded here.
A link to the GMBc & Associates website is below.
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