So I am training some coworker in the air regulations, and took them with me on a Title V permit inspection the other day. A facility requires a Title V permit when they emit 10 tpy of any single hazardous air pollutant, or 25 tpy of any combination of HAPs.
So we arrive at the facility, and begin with records review. We are required to review all Title V required annual and semiannual reports, as well as any specific requirment records and reports for each individual emission source on site. For this particular site, records review took almost 2 hours. Which is not bad.
Next we conducted a facility tour. During the tour, we checked for leaks using a Cosmometer:
We are looking for any emission problems, as well as spills, hazardous wastes, etc during the tour. This lasted about an hour and a half. We did note a few oil spills onsite, but besides that, they were in compliance with their Title V air permit.
Next month, I am inspecting a refinery that is over twice the size of this gas plant. It will take a while to review the permit before we go, so I will be busy.