Compliance Pitfalls/Where Facilities Get Tripped Up: Jesslynn Hale (Trinity Consultants) Arkansas Environmental Federation Air Seminar Presentation

Jesslynn Hale undertook a presentation at the Arkansas Environmental Federation Air Seminar titled:

Compliance Pitfalls: Where Facilities Get Tripped Up (“Presentation”).

Jesslynn has a B.S. in Chemical Engineering from the University of Arkansas and is a Managing Consultant at Trinity Consultants.

The objectives of her Presentation included:

• Identify common compliance pitfalls.
• Understand why they occur.
• Learn practical prevention strategies.
• Reduce enforcement risk.
• Time for questions.

The Presentation initially addressed the events during an Arkansas Inspection which include:

• Records review.
• Site walkthrough.
• Data verification.
• Staff interviews.

Arkansas inspection trends were noted that include:

• Recordkeeping deficiencies.
• Monitoring not aligned with permit.
• Late/inaccurate reporting.
• Permitting misunderstandings.
• Poor internal communication.

The possibility that issues can become subject to enforcement were addressed, describing inspection findings and Consent Administrative Orders.

Pitfalls addressed included:

• Recordkeeping failures.
• Monitoring doesn’t match permit.
• Late or incorrect reporting.
• Opacity issues.
• Changes without evaluation.
• Poor internal communication.
• Inspection readiness or lack thereof.

What inspectors are looking for was stated to include:

• Consistency.
• Transparency.
• Ability to explain compliance.
• Outstanding fees.

Minor issues that are noted to create major impressions include:

• Outdated site maps.
• Air emission sources not labeled.
• Conflicting equipment IDs.
• Not using the most recent permit version.

Things that good facilities do differently/focus on to avoid pitfalls include:

• Compliance systems.
• Internal audits.
• Cross-training.
• Inspection ready files.

Key takeaways were stated to include:

• Most violations are preventable.
• Documentation is critical.
• Administrative issues can drive enforcement.

A copy of the Presentation slides can be found here.