WHAT TO EXPECT WHEN THE INSPECTOR ARRIVES Edward Horst, NMED-AQB
PROCEDURES • Introductions and presentation of state issued credentials • State the purpose of the visit • Request permission to conduct an inspection • Commence inspection • Conduct a closing conference
THE INSPECTION • Procedure: • Opening Conference • Verification of Permit Terms and Conditions • Overview of the status of Terms and Conditions • Facility Walk Through • Closing Conference
OPENING CONFERENCE • Procedure: • Administrative Information • Facility Entry • Entry Conference • Entry conference Participants • Statutory authority to enter site and conduct inspection
VERIFICATION OF PERMIT TERMS AND CONDITIONS • The inspector will review: • Section II – Registration Process • Section III – Facility Operating Requirements • Section IV – Monitoring, Recordkeeping and Notification Requirements • Section V – Changes that Prevent Meeting the General Permit Requirements
EXAMPLES OF RECORDS TO BE REVIEWED • The following records will be reviewed: • Actual hours of operations • Beginning of daily operation for each applicable day • Ending of daily operation for each applicable day • All monitoring requirements • set out in Subsection IV. A. of the permit • Weekly total production • Monthly 12 month total production.
EXAMPLES OF RECORDS TO BE REVIEWED • Number of haul truck trips per day • including materials delivery and product • Fuel delivery manifest • the type of fuel • number of gallons purchased • The quantity and frequency of water or surfactant application to haul roads
EXAMPLES OF RECORDS TO BE REVIEWED • The frequency of haul road sweeping • (if paved) • Other haul road control measures • (if used) • Copies of the manufacturer’s (or applicant’s proposed) maintenance and operating requirements and records demonstrating conformance with said requirements • Copies of documentation that substantiates compliance with the requirement in subparagraph III.F.2.e.
FACILITY WALK-THROUGH • A walk-though of the facility is conducted so that the inspector becomes familiar with the flow of the operation • Purpose: • To verify that the equipment being used matches the equipment on the facility’s permit • To perform opacity reads (if the inspector finds it necessary) • Interview employees (if the inspector finds it necessary)
CLOSING CONFERENCE • At the conclusion of the inspection, the inspector will conduct a Closing Conference. • Purpose: • Inform the facility personnel any areas that were found to be inconsistent with any of the Permit Terms or Conditions, or Areas of Concern (AOC)
CLOSING CONFERENCE • Cont.: • If the inspector has determined that there are AOCs present a Post Inspection Notification (PIN) will be given to the permitted or their representative • The PIN will list permit terms/conditions and or regulatory citations that appear to be potentiallly non-compliant
SOMETHING TO KEEP IN MIND • Most of the facilities permitted under the GCP Process WILL NOT see an air inspector if those facilities are being “GOOD NEIGHBORS AND STEWARDS OF THE ENVIRONMENT” • Citizen complaints attribute to nearly EVERY INSPECTION that the New Mexico Air Quality Bureau conducts on GCP Permitted
IT ALL COMES DOWN TO Have respect for your neighbors, their property, quality of life, and health If there are questions concerning terms and conditions in your permits or if you need clarification Please contact us