Compliance Monitoring Strategy for FY 89
MEMORANDUM MARCH 31, 1988
SUBJECT: Compliance Monitoring Strategy for FY 89
FROM: John S. Seitz, Director
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
TO: Air Management Division Directors
Regions I, III and IX
Air and Waste Management Division Director
Air, Pesticides, and Toxics Management Division
Regions IV and VI
Air and Radiation Division Director
Air and Toxics Division Directors
Regions VII, VIII and X
I am transmitting to you the attached Compliance Monitoring Strategy
( CMS ) for implementation in FY 89. This strategy is the culmination of a
multi-year effort that focused on addressing some very important issues of
the Air compliance program. I feel the CMS makes major strides in guiding
our surveillance activities in a direction that will dramatically improve
As you know, the Compliance Monitoring Strategy will replace the
Inspection Frequency Guidance ( IFG ) in FY 89. The CMS emphasizes
flexibility with accountability. This strategy recommends developing a
comprehensive inspection plan that identifies all sources or source
categories committed to be inspected by the State agency ( means State or
local agency throughout ) during their fiscal year.
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The State inspection plan must address national priorities and may also
include inspections not normally of EPA concern. The plan, to fully utilize
the flexibility offered, will be organized around four groups of sources.
Group I: Traditional stationary sources such as Class A and known
Class B SIP, NSPS, and operating NESHAPs sources.
Group II: Asbestos D&R Strategy contractors.
Group III: Small VOC Compliance Strategy sources.
Group IV: Sources of State concern.
High Points of the New Strategy
New features of the Compliance Monitoring Strategy are the following.
(1) Ability to address local air pollution concerns.
The CMS provides State agencies with the discretion to address
significant local air pollution concerns such as citizen complaints, odor
problems, and other localized toxic, hazardous, and nuisance issues. These
types of concerns may not be national priorities, but are legitimate
resource expenditures under this strategy. Group IV is where local issues
and new State-specific initiatives may be addressed.
(2) Use of inspection targeting.
The concept of inspection targeting provides an approach to systemically
direct resources toward the most significant problems. The approach
employed is a PC-based model using multiple targeting criteria to determine
inspection frequency. The targeting model accepts source specific targeting
data supplied by the State inspector in such areas as plant emissions,
compliance information, and air quality factors. The model assigns values
to these data, and mathematically combines the values to produce a ranking
of sources to be inspected along with the estimated resource costs.
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(3) Account for the total inspection activity.
This strategy will credit a program for its total inspection activity.
The total State inspection resource budget must be provided to EPA for this
key aspect to be accomplished effectively.
(4) Maintain minimum resource expenditure levels in the inspection program.
Minimum resource expenditure levels for Group I sources are defined to
be the average inspection effort over the last three years. The levels for
Group II asbestos D&R contractors are those reported in the SPMS for the
latest fiscal year. Group III resource levels are the minimum number of
inspections required by the Small VOC Source Compliance Strategy or supplied
by the State, whichever is larger. Group IV levels are generally supplied
by the State.
(5) Focus on national priorities.
Each year the Compliance Monitoring Strategy will reflect the Air
program's stated national priorities as identified in EPA's Operating Year
Guidance. These national priorities are encompassed by Groups I, II, and
The responses I reviewed from both State and EPA personnel were
universally supportive of the general approach in the CMS. I thank you for
your time. The kinds of concerns expressed typically revolved around the
1. Targeting model input data may not be known by the inspector.
Since the model's input is often qualitative and is so critical to
effective source compliance understanding, the lack of such data is a key
finding. In addition, experience has shown that such a structured model
helps guide an inspector toward the needed data to carry out effective
source inspections and provides supervisors with valuable management control
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2. More resources ( Regional and State ) will be needed to implement the
CMS with targeting.
Our experience has shown that initially more time is required to
establish the source inventory, to develop a working database, and to
negotiate a plan. However, the initial resource commitment is very
dependent upon the current condition of an agency's database. Thereafter,
the resource burden is greatly reduced.
Given a principal aim of targeting is to be a more focused use of scarce
resources, targeting over time, is expected to realize a resource savings.
A program using targeting should find and correct more problems than a
program that does not. Therefore, resources may actually go further because
of more effective use.
3. The Inspection Frequency Guidance ( IFG ) should remain an option.
We recognize in some cases, as mentioned in the CMS, the current IFG
will be a more viable means for States to meet their inspection commitments.
Therefore, the IFG is the alternate approach. However, we strongly
encourage the use of the CMS with targeting whenever possible. To further
promote the CMS, we intend to monitor, in which States and for what reasons,
the CMS is not used.
One final observation, after reviewing the comments I found a more
comprehensive reading of the strategy should answer any remaining questions.
It became apparent that inadequate attention was given to reviewing the
strategy because so many questions and comments were already answered in the
draft CMS. I will be happy to discuss with anyone issues associated with
implementing and interpreting the CMS, but please read it carefully first.
SSCD has arranged to conduct Regional training ( States may be invited
as well ) in the use of the inspection targeting model and provide on-call
technical support. Please contact Howard Wright at FTS 475-7034 to schedule
training. To effectively coordinate ten Regions training, Mr. Wright would
like to know what Regional dates are suitable for this one day training
session. Please notify him of your preferred dates by April 22, 1988.
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The diskette containing the model along with the Description and
Explanation document will be distributed at the training sessions. For
technical support in the model's operation, please contact Perrin Quarles
Associates, Inc. at 804-979-3700.
cc: Air Compliance Branch Chiefs
Regions II, III, IV, V, VI and IX
Air Programs Branch Chiefs
Regions I, VII, VIII and X
COMPLIANCE MONITORING STRATEGY
The Inspection Frequency Guidance ( IFG ) will be replaced in FY 1989 by
the Compliance Monitoring Strategy ( CMS ), which provides a more flexible
approach for determining State 1/ inspection commitments.
1/ means State or local agency throughout.
The CMS emphasizes flexibility with accountability. This strategy
recommends the development of a comprehensive inspection plan that
identifies all sources or source categories committed to be inspected by the
State agency during their fiscal year.
The CMS has five parts.
The Compliance Monitoring Strategy has five objectives.
- To provide the ability to address significant local concerns where
they differ from national priorities.
- To ensure effective national oversight of the air compliance
monitoring program, to permit its evaluation, and to establish a
- To promote the importance of enforcement presence through effective
compliance monitoring activities.
- To ensure an adequate level of resource commitment.
- To assure emission standards are met through effective use of
compliance monitoring activities.
Sources subject to this strategy, if its flexibility is to be fully
utilized, are the following.
Group I: Traditional stationary sources - class A and known Class
B SIP, NSPS, and operating NESHAPs sources.
Group II: Asbestos D&R Strategy contractors.
GROUP III: Sources subject to the Small VOC Source Compliance
Group IV: Sources of State concern.
The national priorities must be met, or in cases where exceptions are
justified, the rationale for the exceptions must be agreed to by EPA.
Groups I, II, and III will encompass the national priority categories in FY
1989. However, national priorities may change from year to year.
In FY 1989, the national priorities are the following.
- Class A sources emitting VOC in ozone nonattainment areas. ( Group
- Class A1 sources emitting TSP, SO2, CO, or NOx in nonattainment
areas. ( Group I )
- Class A sources emitting any criteria pollutant in attainment or
unclassified areas that have known or suspected compliance
problems. ( Group I )
- Lead SIP and operating NESHAP sources. ( Group I )
- Asbestos demolition / renovation contractors per the revised
Asbestos Strategy dated March 31, 1988. ( Group II )
- Small VOC sources per the Small VOC Source Compliance Strategy
dated July 6, 1987. ( Group III )
Inspection quality under this strategy must be Level II or higher, as
defined by EPA guidance. Furthermore, this strategy will credit a program
for its total inspection activity. That is, this approach will account for
the total federally-funded compliance monitoring effort including, where it
is mutually agreed, the substitution of non-federally regulated source
inspections ( Group IV ) for federally regulated ( Group I ). it will be
necessary to present the rationale for this substitution and to enter only
the substituted Group IV sources into CDS.
The inspection targeting model will be run by States wishing to use the
flexibility this strategy offers to determine the inspection commitment for
Group I sources and those Group IV sources that will be substituted for
Group I source inspections. Inspector-supplied data on emissions, air
quality compliance history, inspection level, inspection time and inspection
frequency are inputs into the model for these sources. The output of the
targeting model is a priority ranking of sources to be inspected with
cumulative resource needs. Attachment 1 provides further details on the
inspection targeting model. Training in the use of the model will be
provided at EPA's Regional Offices upon request.
The asbestos and small VOC source strategy requirements, where
applicable, will be used to determine the inspection commitments for Groups
II and III.
Recognizing the significant departure this strategy is from the IFG, it
is expected to take more than one year for widespread implementation of the
inspection targeting approach. For that reason, Headquarters will closely
monitor the implementation of the CMS to assess progress and to make
necessary adjustments. Therefore, the Regions are required to report in
which States, and for what reasons, the inspection targeting approach is not
used. This information should be submitted annually to SSCD along with each
State's inspection plan.
The strategy requires a minimum inspection resource base ( baseline ) be
established for each group. It will be used by the EPA Regions as a
benchmark to evaluate their States' inspection plan submittals. The minimum
baseline for each State is established in FY 1989 in the following way.
Group I: The average number of inspections from the last three
years, as reported in CDS.
Group II: The number of inspections in the last fiscal year, as
reported in SPMS.
Group III: The number of inspections the Small VOC Source Compliance
Strategy requires, or, supplied by the State, whichever
Group IV: The number of inspections supplied by the State.
The total level, i.e., the summation of the minimum baselines for Groups I-
IV, used to establish the baseline FY 1989 shall not be reduced in
(3) State Inspection Plan Submittal.
Each inspection plan submittal will present how that State will address
national priorities and will justify exceptions to the national priorities.
The plan will also identify specific sources to be inspected, allocate the
total inspection budget among source groups, and cover other issues that are
necessary to meet the Compliance Monitoring Strategy objectives and
The targeting model should be used to determine Group I and specific
Group IV sources to be included in this inspection plan as well as their
priority of inspection. Groups II and III will be addressed by their
national strategy requirements and by the resources allocated to each group.
For other Group IV source inspections, a block resource allocation will be
made by the State in their plan submittal.
These steps will allow the State agency to develop their initial
comprehensive inspection plan, which will be submitted to the EPA Region for
review. To justify exceptions to national priorities, the State must submit
the basis for their decisions, such as the inspection targeting model inputs
(4) Final Inspection Plan Negotiation
The final comprehensive State inspection plan will be agreed to by both
the EPA Region and the State. This plan will result in the State's
inspection commitment to EPA for FY 1989. The resources necessary to
fulfill this commitment are provided by the Section 105 federal grant and
State matching funds.
The final mutually accepted plan will have two parts.
(a) Inspection commitments and associated resource allocations.
- Group I sources will be identified by name.
- Group II contractors will be identified by name.
- Group III sources will be identified by category with the
estimated resources allocated to this group.
- Group IV sources will be identified by name if they are to be
traded off for Group I source inspections, otherwise an estimated
resource allocation will be assigned this group.
(b) Accountability measures such as date to be reported in CDS to
measure the States fulfillment of their inspection plan
commitments. ( see Reporting and Evaluation component ).
The EPA Region and State will use the following to finalize the plan.
- State-supplied input and output from the inspection targeting
model's ranking of Groups I and IV sources.
- National strategies for asbestos D&R and small VOC sources.
- Other EPA-established national priorities.
- State-supplied inspection resource budgets by group.
- Baseline EPA estimates of inspection resource budgets by group.
This gives EPA a benchmark to assess the State-supplied inspection
(5) Reporting and Evaluation
Improving upon the current IFG, this strategy will emphasize effective
and timely reporting of accountability measures, evaluate each year's
results of plan implementation, and build the resulting recommendations into
guidance for the upcoming operating year.
The principal data management tool EPA will use for evaluating the
implementation of this strategy is the CDS. The specific sources, as well
as data needed for evaluation, should in most cases be tracked in the CDS.
The date that must be kept current and complete in the CDS for Groups I,
II, and III sources and those specific Group IV sources that are substituted
for Group I inspections, consistent with existing CDS guidance, include the
- source identifier and location information.
- current and historic compliance status.
- key enforcement actions such as inspections and source tests
completed, EERs submitted, and malfunction reports.
- pollutant specific classification for all Class A sources and for any
sized VOC source in an ozone nonattainment area.
- nonattainment and attainment status code ( PAQC ).
- pollutant code ( PLLT ).
- air program code.
- inspection flag.
For other Group IV sources that are not of federal concern, a year end
accounting of resources consumed versus the beginning of the year block
resource allocation estimates should be discussed at the time of the plan
evaluation. This is part of the total inspection activity assessment and
provides a complete picture of resource use in the inspection program.
These other Group IV sources are not tracked in the CDS.
Additional mechanisms that will be used to monitor and evaluate the
implementation of this strategy will be the National Air Audit System and
the Section 105 compliance guidelines. The NAAS is presently being revised
to accommodate the CMS. The Section 105 compliance guidelines are under
development and will be issued this year.
In the event that a State and EPA Region cannot work out an inspection
plan using the recommended strategy approach, the current Inspection
Frequency Guidance plus the Asbestos D&R and Small VOC Source Compliance
Strategies will determine the State inspection commitments for the upcoming
year. See Attachment 2 for the full text of the current IFG.
For those States that use the current IFG to identify their FY 1989
inspection commitments, an inspection plan must still be submitted to and
accepted by the EPA Region. These plans will basically be limited to Groups
I, II, and III sources.
The fundamental differences between a State inspection plan developed
using the current IFG and one using the full CMS will be the following.
- Group IV source inspections will generally not be in an IFG-based
- An IFG-based inspection plan will not capture an agency's total
- Specific focus on national priorities is not as well defined in an
IFG-based inspection plan.
While offering this alternate approach, EPA strongly recommends using
the full CMS with inspection targeting whenever possible. However, it is
recognized that for such reasons as the lack of suitable software and
hardware, a small, easily managed regulated community, an adequate resource
base for comprehensive inspection coverage, and an inspection program tied
to an operating permit fee system, the CMS with inspection targeting will
not be universally appropriate.
(1) EPA Headquarters
EPA Headquarters is responsible for the annual implementing guidance for
the Compliance Monitoring Strategy. It will be issued to the Regional
Offices before April of the fiscal year.
In addition, ongoing refinement and training in the use of the
inspection targeting model is Headquarters responsibility. It is expected
that as more agencies become familiar with the value of targeting to their
program, the model will sell itself. After initial training, some level of
ongoing support will be necessary for the users of this tool. Headquarters
will provide that support.
Finally, Headquarters will evaluate and report the previous year's
implementation of the strategy to the Air compliance community in the second
quarter of the next fiscal year. The results will be in incorporated into
the annual implementing guidance and any strategy modifications.
(2) EPA Regional Offices
The Regions are charged with negotiating, approving, and submitting to
Headquarters by August the individual State inspection plans for the
upcoming federal fiscal year. Along with the inspection plans, the Regions
are required to report to Headquarters in which States, and for what
reasons, the inspection targeting approach is not used.
In addition, the Regions must ensure that the applicable sources
scheduled to be inspected per the negotiated inspection plan are entered and
CDS on time. The Regions are also responsible for ensuring the appropriate
data necessary for evaluation are in CDS or are reported to EPA in a
complete and timely fashion.
(3) State Agencies
The State agencies are responsible for providing information and for
running the inspection targeting model, where applicable. They are also
responsible for meeting the commitments of their negotiated inspection
plans. Finally, the State agencies are responsible for ensuring the
appropriate data are reported in a timely and complete fashion to the
Regional Office or directly into CDS.
When preparing an inspection plan submittal, it is recommended the State
use the inspection targeting model for ranking Group I sources, and those
Group IV sources that may be substituted for Group I source inspections, on
a State-wide level. The inputs and results are then presented at the
inspection plan negotiation meeting with EPA.
For local districts that have direct Section 105 grantee status, it is
recommended that such districts be ranked using the inspection targeting
model separately from other districts in their State. In such a State, the
State-wide ranking should be an aggregation of individual local grantee
district rankings with the rest of the State. However, as a general
practice, running district by district rankings and aggregating them to the
State level is discouraged. To do this diminishes a management benefit of
the inspection targeting model that allows identifying where current
resource distributions may need reallocation.
The EPA Headquarters contact for this strategy is Howard Wright. He can
be reached at (202) 475-7034. The contractor for the inspection targeting
model is Perrin Quarles of Perrin Quarles Associates, Inc. He can be
reached at (804) 979-3700.
Further Details on the Inspection Targeting Model
The inspection targeting model is jointly funded by Regions V, VIII, and
SSCD. It is being piloted in Michigan and Colorado. These efforts have
provided a refined product ready for more widespread application.
The model is a computerized program which ranks sources for inspection
priority based on information supplied by State agency inspectors. It
currently runs on a standard XT or AT personal computer and on an Apple
MacIntosh. Approximately 3 megabytes of storage capacity and 512 RAM are
required to run the program for a 2,500 source database. The program is
menu-driven and requires no special computer knowledge.
What Information is Needed to Use the Model?
Targeting data for each source normally include:
- Source identification and classification information
- Size data ( for targeted pollutants )
- Last inspection results
- Other recent compliance history ( to the extent available )
- The inspector's assessment of potential upset conditions at the source
( with four options )
- The inspector's rating of O&M practices at the source ( with four
- NAAQS attainment status
- Relative contribution of the source to air quality problems ( with
four options )
- Whether there are multiple compliance problems and/or multiple
- The desired inspection frequency for the source
- The required inspection time and relative inspection difficulty for
- Other unique targeting considerations that the inspector feels should
be considered, as well as the inspector's own rating of the source's
inspection priority ( on a 1 to 4 scale ).
What is Needed to Implement the Program?
The following steps are necessary to start up and maintain the program.
- Compile a list of sources that will be eligible for inspection
The State must identify all NSPS and NESHAPs sources and all sources
over a minimum size ( e.g., 10 tpy actual uncontrolled emissions ).
Inspectors should review this list to make sure that important sources have
not been omitted. This review may occur when the inspectors are completing
individual data forms. Our experience has shown for the typical State, this
pre-screening of the inventory may take 10 working days of total inspector
time during the initial year.
- Prepare targeting data forms for each source included on the targeted
Basic source identification information can be compiled by
administrative staff using information normally available in agency reports,
emissions inventories, and the like. A data form for each source may be
partially filled out by administrative staff, then forwarded to inspectors
responsible for the individual sources. Compliance and other unique
targeting information would be provided by the inspectors.
To minimize misinterpretation and inconsistency among inspectors and to
ensure maximum efficiency, a half-day meeting or work session should be
scheduled to review the data form and answer questions. All inspectors
should participate. The forms should then be filled out by the inspectors,
and checked by a designated reviewer or manager.
If all inspectors participate, the initial meeting and data form
completion process should take no more than 3 working days for each
- Enter targeting data into the computer program.
After targeting data forms have been completed, computer entry may be
performed by clerical staff. Initial entry should be made by one person,
then checked by another person to ensure accuracy. Experience indicates
that initial data entry should require an average of approximately 2 minutes
per form and verification should require approximately 1 minute per form.
- Generate ranking and planning reports.
A ranking report may be generated by simple menu driven computer
commands. The length of time required to generate the report is dependent
on the number of sources and the computer capability. A typical XT
processor at 6 mh without a math coprocessor will normally process a 500-
source database in 2-3 hours. The printing of the report may be generated
in 10-30 minutes depending on the speed and type of printer and computer.
These time requirements are significantly reduced by using a 80286 or 80386
based computer system.
- Maintain the database.
Once established, the database may be fairly easily maintained. As new
inventory, compliance, or air quality data are obtained, these may be
entered directly into the computerized database by inspectors or field
support staff. It is also possible to edit the hard copy form for data
entry by clerical staff.
Maintaining the program may be accomplished in a single annual update,
or it may be accomplished as new data are obtained ( e.g., immediately
following an inspection ). Editing and reentry require less than one-half
of the time per form that was required for initial completion and entry.
The model itself is easy to use for anyone. It was designed for use by
inspectors and managers with very limited computer skills. There is a help
file accessible at any time as data are being input.
When the ranking and estimated inspection times are coupled with the
known resource base, the actual sources planned to be visited annually can
easily be determined. As a result, an inspection plan is born. This plan
can serve the State agency as an effective management tool for its own
inspectors as well as serve to meet the EPA's Compliance Monitoring Strategy
Final refinement of the targeting model is completed. It is available
to all EPA Regions for your testing and familiarization prior to
implementation in FY 1989. It is on a floppy disk with accompanying
documentation and will be distributed at the time of the Regional training.
Headquarters will continue to support this activity with on-call technical
Inspection Frequency Guidance
The inspection is the primary compliance assurance method presently
available in the air program for validating source performance. Therefore,
EPA believes it is imperative that an effective inspection program be
implemented in all States. The following guidance on the expected frequency
of inspections is intended to balance the need for a nationally-uniform data
base to enable an evaluation of the effectiveness of the program with the
needs of State and local agencies to make optimal use of their limited
resources to address the varied and unique air quality problems faced by
each State and locality.
CRITERIA FOR INSPECTION
The frequency of an inspection shall be determined by which requirements
are applicable ( SIP, NSPS, NESHAPs ) and, for SIP and NSPS sources, by
whether the source is a Class A1 or A2 source. In cases where more than one
program requirement is applicable, the source must be inspected based on the
highest frequency of inspection for any of the applicable requirements. It
is imperative that all sources be identified by source classification ( if
applicable ) and appropriate air program ( SIP, NSPS, NESHAPs ) and that
these data be duly entered and maintained in EPA's Compliance Data System
( CDS ).
DEFINITION OF AN INSPECTION
For the purpose of this guidance, a minimally-acceptable State or local
compliance inspection ( Level II ) is an onsite visit to the operating
source to assess compliance with at least applicable federal air pollution
control requirements. At a minimum, a compliance inspection must be
performed for all federally-regulated air pollutants emitted by the source.
Also, a source that is regulated for visible emissions should be evaluated
using an acceptable reference method. Where a source is federally-regulated
for more than opacity, a compliance inspection involving only a visible
emissions observation is not generally considered to be a minimally-
acceptable compliance inspection.
As part of the minimally-acceptable source compliance inspection, an
inspector must record the process operating conditions and, if appropriate,
the control device conditions to determine if any significant change has
occurred since the last inspection or any process or control operation
outside normal or permitted conditions has occurred. It is expected that
minimally-acceptable compliance inspections would also include at least an
operations log check of process and control equipment including continuous
emission monitoring systems logs. It should be noted that these
requirements for a minimally-acceptable inspection do not require the direct
measurement of operating conditions by the inspector.
CLASS A1 SIP SOURCES
All operating Class A1 SIP sources regulated under the Clean Air Act
shall be inspected annually. Annually is construed to mean at least one
onsite visit is made to each such source between October and September,
corresponding to the federal fiscal year.
There are four permissible exceptions to the Class A1 annual inspection
requirement. The first is for sources whose operations are seasonal in
nature ( e.g., alfalfa dehydrators ) and which do not operate more than 90
days per year. This operating time restriction does not need to be included
in a permit for a source to qualify. However, the nature of its business
should clearly preclude the source from operating more than 90 days per
year. To qualify for this exception, a seasonal source should be well-
controlled, should not have a history of noncompliance, and should not be
located in a nonattainment area for a pollutant that is the determining
pollutant for the Class A1 classification. All seasonal sources must in any
event be inspected at least once every five years.
The second category is for Class A1 SIP gas-fired combustion facilities
( gas turbines, boilers, and internal combustion sources ) which are
regulated only for sulfur dioxide emissions and which can operate in
compliance with the sulfur dioxide emissions limitations without controls.
The third category is Class A1 NSPS and PSD gas turbines that are
regulated only for NOx emissions. An annual compliance determination for
these sources can be accomplished through record checks without an annual
onsite inspection of equipment.
The last category is oil-fired or coal-fired industrial boilers which
are Class A1 SIP sources only because of their sulfur dioxide emissions and
which can operate in compliance with the sulfur dioxide emission limitations
without either controls or use of low sulfur fuel.
To be excepted, sources in these latter three categories should not have
a history of noncompliance. All excepted sources shall be inspected at
least once every five years.
Exceptions to the annual inspection requirement should be communicated
by the Regional Office to EPA's Stationary Source Compliance Division
( SSCD ) at the start of the inspection year and the data base properly
adjusted by the Regional Office for subsequent analysis and reporting.
Regional Offices are encouraged to discuss with SSCD any novel issues which
may arise in their discussions with their States.
CLASS A2 SIP SOURCES
Except as noted below, operating Class A2 sources regulated under the
Clean Air Act shall be inspected biennially. However, a State may propose a
modified inspection scheme to its EPA Regional Office which presents at
least the same level of resource commitment but which the State believes is
responsive to the needs of its air quality program. This can consist of any
combination of additional Class A1 SIP inspections, Class A2 SIP
inspections, and inspections of other sources regulated under the Clean Air
Act. This could include Class B SIP sources in those areas where they are
particularly significant. EPA Regional Offices and their States are free to
establish whatever approach is best suited to their situation as long as the
following conditions are met:
- SSCD must receive information copies of such agreements at the
start of fiscal year.
- The State must demonstrate that the modified approach is based on
at least the same resource expenditures as would be required to
inspect all Class A2 SIP sources on a biennial basis.
- All operating Class A2 SIP sources must be inspected at least once
every five years.
Any operating NSPS-subject source which is Class A1 in size shall be
inspected at least once every federal fiscal year. All other NSPS sources
shall be treated as Class A2 sources.
All operating nontransitory NESHAP-subject sources shall be inspected at
least once every federal fiscal year.
ALTERNATIVES TO CONDUCTING PERIODIC ONSITE INSPECTIONS
An alternative to an onsite visit for purposes of satisfying inspection
frequency guidance by the State for an SIP or NSPS source is the use of
continuous emission monitoring Excess Emission Reporting ( EER ) on a
quarterly basis in lieu of periodic inspection requirements. An EER is a
suitable alternative to an onsite inspection if EER data from the source is
at least equivalent to the information that could be obtained from a
minimally-acceptable inspection as previously defined. EER data must be
submitted for all pollutants emitted by the source for which the source is
regulated. The intended use of the EER alternative must be agreed upon
between the State and the EPA Regional Office and EPA must receive the name
and CDS numbers of all sources covered by the alternative.
Another alternative to an onsite inspection is available for sources
whose compliance is based solely on the characteristics of the fuel oil
burned ( typically percentage of sulfur in the fuel ). This alternative is
an inspection of the fuel oil supplier's records and a sampling of the
supplier's product. To realize the saving of inspector time, a source's
fuel oil suppliers must be known and fixed over time. If a source purchases
fuel oil from the spot market, has many suppliers, or has suppliers which
are not easily monitored by the State, this alternative may not be
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