DPPEA Compliance & Enforcement Assistance P2 (efficiency improvement)

1. DPPEA Compliance & Enforcement AssistanceP2 (efficiency improvement) • Sources of requests for assistance • NOVs – DAQ letter • Enforcement Situations • Regional Office Requests • DOC requests

2. DPPEA Approach 1. We can not change the rules. 2. We may be able to help find a better solution to your problem. 3. We can help setup systems and procedures to prevent recurrences. 4. In the course of reviewing the problem, we try to discuss ways and means to improve the efficiencies of their processes and/or emission control methods. *If complying with the permit is difficult/too time consuming, etc., we’ll help “streamline” the requirements to make it manageable.

3. Specifically…. • Understanding their air permit • Why do you have an air permit: proper level. • Compliance during startup/shutdown/malfunctions • 2Q 0800 section • Title V and MACT compliance • Toxics regs and alternatives • PSD and NSPS situations • Non-attainment areas • Enforcement alternatives

4. Compliance Assistance • Recordkeeping/Work Practice Standards: You must do them • Set-up, maintenance, presentation • Provide computerized systems – smaller than Reg Net • Care of records

5. Compliance Assistance • Reports to DAQ – requested form, electronic submissions, 12 mo. running totals •  How to stay prepared for an inspection & avoid NOVs •  Efficiency improvements •  Ovens/tenter frames/high tech analyses • Spraying operations – HVLPs

6. In Summary… • Understanding the compliance/enforcement processes and alternatives • Review their situation for possible “better” solutions • Help them understand why they are in their situation • Help them make their “case” • Help them get set-up to avoid recurrences