Facilities with sources of emissions covered under air quality permits issued by the Kentucky Division for Air Quality (DAQ) are required to routinely prepare reports for submission.  An Annual Compliance Certification (ACC) is due every January no later than January 30th.  The purpose of the ACC is to validate compliance by documenting conformance with permit terms and conditions, documenting whether compliance was continuous or intermittent, and documenting if any emission units were under construction during the reporting period.  Semi-Annual Monitoring Reports (SAMR) are due no later than January 30th for the second six months of the previous year and no later than July 30th for the first six months of every year.  SAMR must include a summary for monitoring performed and any deviations from permit requirements during the reporting period.  Both reports require notification that no monitoring was conducted for any emission units subject to permit requirements that were under construction and not operational during the reporting period.

Both the ACC and the SAMR are to be submitted electronically via onestop.ky.gov which is the new preferred method.  If unable to submit electronically, the reports should be mailed to the local DAQ regional office.

A training workshop for air compliance reporting is planned for January 11, 2018 at the Department for Environmental Protection’s office in Frankfort.  For more information about the workshop including registration, please visit the Kentucky Division of Compliance Assistance’s website. Registration is available through January 9, 2018.

Facilities subject to air quality permitting requirements are provided an opportunity to compare actual operations to permitted emission sources during preparation of compliance reports.  It is good practice for environmental managers to periodically review facility operations including any recent changes to make sure your air quality permit reflects actual operations since permits are typically issued to cover a 5-year period.  If changes are planned in the future (e.g., expansion of production; replacement of old equipment), facility managers would undoubtedly want to understand if those changes could impact potential emissions and whether there is a need to revise the air quality permit to maintain compliance with air quality regulations.

Note:  Facilities located in Jefferson County with Title V Air Quality Permits or Federally Enforceable District Origin Operating Permits are subject to reporting provisions of the Louisville Metro Air Pollution Control District as listed in Regulation 2.16 or Regulation 2.17.

Daniel Hardin is a Project Engineer at Smith Management Group.  Daniel and his co-workers at SMG routinely help clients review air quality permits and prepare air quality permit applications.  Daniel can be reached at 502-587-6482 or danielh@smithmanage.com.