Inspections

Under state statutory authority of RSA 125-C:6, VII, NHDES staff conduct periodic inspections of facilities that emit air pollutants. Many of those facilities have been issued a permit to operate by the air permitting program. The Air Resources Division’s Compliance Assessment Section has the responsibility of ensuring that a company which holds air permits remains compliant with the requirements set forth in the permit. The inspection may be an on-site visit at a facility or an off-site review of facility records. The purpose of an inspection is to determine if a facility is complying with applicable federal and state statutes, rules and permit requirements. In addition, changes to the facility or new or replacement equipment could initiate the need for changes to the permit and the need for an inspection.

How often does NHDES conduct inspections?

In accordance with the EPA’s Clean Air Act Stationary Source Compliance Monitoring Strategy, NHDES conducts an On-Site Full Compliance Evaluation (FCE) for permitted sources as follows:

• Title V Permitted Sources - at least once every two years
• Title V Permitted Mega-Sites - at least once every three years
• Synthetic Minor 80 Source (SM-80) - at least once every five years

Title V Permitted Mega-Sites are extremely large, complex facilities subject to the Title V permitting program. Synthetic Minor 80 Sources (SM-80) are facilities that either have the potential to emit or actually emit pollutants close to the major source thresholds.

What does an On-Site Full Compliance Evaluation include?

A review of all required reports or other documents, and to the extent necessary, the underlying records. This includes all monitored data reported to the regulatory agency (e.g., continuous emissions monitoring system (CEM) and continuous parameter monitoring reports, malfunction reports, excess emission reports). It also includes a review of Title V self-certifications, semiannual monitoring and periodic monitoring reports, and any other reports required by permit.

• An assessment of control device and process operating conditions as appropriate.
• A visible emission observation as needed.
• A review of facility records and operating logs.
• An assessment of process parameters such as feed rates, raw material compositions, and process rates.
• An assessment of control equipment performance parameters (e.g., water flow rates, pressure drop, temperature, and electrostatic precipitator power levels).

During the FCE, the inspector confirms compliance with permit conditions, identifies any deficiencies and provides assistance to help the company understand permit conditions and if needed, correct deficiencies.  In addition, during a tour of the facility, the inspector will identify any new equipment or processes which may also be subject to permitting requirements.