Division of Environmental Quality

Operations Manual

CHAPTER 3 – INSPECTIONS

3.6 Air Pollution Inspections (Revised 01/14)

3.6.1 Air Pollution Control Inspection Procedures | 3.6.2 Asbestos Inspections |
3.6.3 Gasoline Vapor Recovery | 3.6.4 Open Burning Permit Guidance | 3.6.5 Forms and Checklists

3.6.1 Air Pollution Control Inspection Procedures

Purpose and Introduction
Air pollution inspections are conducted at regulated facilities that emit air pollutants. Air pollution inspections are conducted to observe operations, collect information and to evaluate facilities for regulatory compliance.

Air pollution inspections are conducted at facilities that emit  or may be emitting regulated air pollutants. Air pollution inspections are conducted to observe operations, collect information and to evaluate facilities for regulatory compliance.

The purpose of this section of the Operations Manual is to provide basic procedures for conducting air pollution inspections. It expands on information in the Air Pollution Control Program's (APCP), section of the Department Compliance Manual. General information on conducting inspections is found in the Chapter 3.1, General Inspection Procedures. Air Pollution Training Institute (APTI) self-study courses such as Air Pollution Control Orientation, Introduction to Air Pollution Control and Baseline Inspection Techniques are offered on line and must be taken before the inspector conducts inspections. Inspection Procedures and Safety is a lecture course and should be taken when available. Visible emission training and certification must be obtained before inspecting facilities that have particulate or fugitive emissions.

Inspection Selection, Coordination and Timing
The selection of facilities to inspect is based on guidelines in the Air Pollution Control Program's principal activities list. The regional office unit chief or section chief in coordination with the Air Pollution Control Program develops the inspection list.

Facilities should be inspected when the plant is operating under normal conditions. Asphalt batch plants usually don’t operate in the colder months of winter. Concrete batch plants and quarries may also have limited production during these months. Fugitive dust sources should be inspected during typical Missouri weather conditions, not the day after a heavy rain. Inspect grain elevators during harvest season. Coal-fired power plants have periods when they shut down for maintenance, and peaking power plants usually operate in the hotter summer months. The inspector should check the relocation file for portable facilities to make sure they are on site.

Preparation

File Review
The following items should be reviewed:

Items to be taken on the inspection:

Inspection

Pre-entry
The facility should be observed for fugitive dust going beyond the facility’s property boundaries, excess opacity and odors. The inspector should photograph any excess opacity or fugitive dust emissions seen. Dust covering vegetation, parked cars etc., should also be noted and photographed as well. If warranted, a Method 9 visible emission test or nasal ranger reading should be done before entering the plant. If odors are to be investigated, the inspector should first go upwind of the facility to make sure the odors are coming from the facility and not another source. Then, conduct a check for odors downwind from the facility. See the St. Croix Sensory Nasal Ranger instructions for operating the field olfactometer.

A map should be drawn for fugitive, opacity and odor violations. Bearings, wind direction and speed, sun position, distances, street names, test location, etc. should be noted.

Opening conference
The inspector should inform the facility representative that he or she is there to conduct a routine air pollution inspection, provide their credentials and explain the statutory authority to conduct the inspection and state or explain to their office which permits and records will be reviewed at the end of the walk through to allow them an opportunity to gather the documents. Any violations observed prior to entry should immediately be discussed with the facility representative to allow them the opportunity of timely observation and verification of the problem. The inspector should also inform the facility of their rights regarding confidential business information.  The source of the excess emissions or odors should be investigated and noted. After this the inspection can proceed.  Mention that the inspection will flow from process start to end, or in reverse, and note all of the emission points on the emission point log.  The inspector should follow the process from beginning to end.

In most situations it is better to conduct the plant tour prior to the records review.  For example, when the inspector observes excess fugitive emissions from a quarry crushing plant. Another example is a facility that is required by the regulations to cover HAP and volatile organic compound (VOC) containers and has had a history of violating the regulation. The inspector needs to see the facility operating under normal conditions.

The facility tour
The inspection should usually start where the process starts. This flow approach allows the inspector to observe excess emissions and conduct necessary Method 9 tests. After the emission point is evaluated, the inspector should inspect the control device and note operating parameters. These operating parameters should be compared to base line information such as performance test results. Maintenance records on control devices should be reviewed during the walk through as the inspector observes the control equipment.

The process is inspected and the production rate should be noted. Some processes have permit production limitations; other processes have restrictions due to performance tests conducted at a particular production rate.

The inspector should be on the lookout for newly installed equipment or equipment not listed on the EIQ or last inspection log. It should be noted in the emission point log whether the process is operating, and any operating parameters of the process equipment and their control devices.

Often the conditions inside a facility will be noisy and communication difficult. The inspector should make a note of questions or comments that were not fully understood during the plant tour so they can be discussed during the closing conference.

When the tour is over, the inspector should review the following items with the facility representative:

The inspector should obtain copies of pertinent documents and records and verify required record keeping. The inspector should be selective; it isn’t necessary to copy all records. Inform the facility representative of the approach to be used to inspect the facility. It is helpful to make a copy of the emission point log for the facility representative to have on the facility tour.

Closing conference
The findings of the inspection should be discussed. If applicable, the possibility of an NOV, NOEE, or LOW should also be discussed during the closing conference. The NOV, NOEE, or LOW should be issued later from the inspector’s office and after a formal review of the findings has taken place. In some instances additional information is required before a decision is made to take enforcement action.  The inspector must make every effort to ensure a facility is aware they are going to receive the NOV, NOEE, or LOW before it arrives at the facility.  As not all facilities are responsive, have full time resident staff, or are open regularly, some exceptions are expected.

The facility representative should be asked to mail or fax documents or records that were not available at the time of inspection. Deadlines should be set for required submittals.

Post-Inspection

Inspection Forms
The comments section of the form should be filled out in a manner that is easily understandable to the facility, the Air Pollution Control Program and the next inspector. The comments are easier to read if they are divided into sections such as construction permits, operating permits, federal regulations, RACT rules, etc.  The Air Pollution Control Program uses a form titled Level II State Source Inspection Form along with the State Source Emission Point Log to document the findings from an inspection.  An electronic version of the form has been updated and is available from the Air Pollution Control Program upon request.  The advantage in using the electronic form will be that you can type in inspection information and the comment section can be expanded. The  inspection form should contain the following information in the comment section of the form:

The inspector should complete the emission point log and provide details on emission units such as the type and capacity of a rock crusher, and whether it is subject to NSPS, Subpart OOO. Another example is a boiler - note the size, fuel type and whether it is subject to the NSPS.

Reports and Enforcement Action Request

Should an NOV, or NOEE be appropriate, a report that meets the requirements of Appendix A - Guide for Writing an Inspection Report located in Chapter 3 of the Operations Manual must accompany the NOV, or NOEE to the facility and to the Air Pollution Control Program.  The report must contain a narrative of items, issues, statements, reasoning behind, and/or other discovery items leading up to and finding the non-compliance issues.  Additional information included in the narrative of the report is at the discretion of the Regional Office and/or the Air Pollution Control Program.  See Section 5.1 of the Compliance Manual for more information on the appropriate use of an LOW, NOV, or NOEE.  An Enforcement Action Request must filled out by the inspector and accompany the referral packet to the Air Pollution Control Program.

Determining actual emissions and potential emissions
There are situations where being able to calculate emissions is helpful. Knowledge of the actual and potential emissions allows an inspector to determine if a facility is subject to MACT, RACT and other standards. The inspector can also determine if a construction or operating permit is needed.

To calculate actual emissions, knowledge of the design capacity of the installation and the actual amount of material processed in a year is required. Calculating potential to emit involves multiplying the design capacity of the installation by 8760 hours per year and taking into consideration federal enforceable permit conditions such as emission limits and the use of air pollution control devices. The EIQ instructions for each form  and 10 CSR 10-6.020 Definitions and Common Reference Tables should be read for more information.  The Permitting Section should be contacted for assistance in determining emissions.

Reinspections
A reinspection may be required in certain situations. For example, to verify that a compliance plan submitted to the department for a violation found during the initial inspection is implemented. This verification is particularly important when the violation affects the environment or area residents.  The reinspection report format will vary depending on amount and type of follow up needed and is at the discretion of the regional office.  For facilities under in enforcement action, APCP will state the report format that is needed along with the request for reinspection. 

3.6.2 Asbestos Inspections

Regulatory Citations
The Missouri Air Conservation Law, Chapter 643 RSMo., provides the statutory authority for inspecting asbestos activities. Areas of the statute specific to asbestos may be found in Chapter 643.225-643.265.

The regulatory authority for conducting asbestos activities is found in three regulations, 10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants (3)(M) National Emission Standard for Asbestos, 10 CSR 10-6.241 Asbestos Projects-Registration, Notification and Performance Requirements; and 10 CSR 10-6.250 Asbestos Projects-Certification, Accreditation and Business Exemption Requirements.

The “no stricter than” provisions in the Air Conservation law prohibit state regulations from being more stringent than those set forth in the Clean Air Act and regulations. Inspectors need to be careful to ensure that none of the statutory language in the Air Conservation law that appears more stringent than the federal National Emission Standard for Asbestos is cited in violations. Also, 10 CSR 10-6.240 - Asbestos Abatement Projects was found to be more stringent than the federal regulation and has been rescinded.

The asbestos inspection form Asbestos Inspection Report - Demolition/Renovation Part A: General Information (Form 780-2130) currently in use for compliance inspections only addresses the requirements of 40 CFR Part 61, Subpart M, National Emission Standard for Asbestos, or NESHAP. The department has delegated authority to implement and enforce only these requirements. Some of the training you will receive (the 40-hour Contractor/Supervisor) will cover several specific areas of “state of the art” work practices. These work practices are generally reflective of the Occupational Safety and Health Administration (OSHA) asbestos requirements found in 20 CFR 1926.1101. Contractors should be using these work practices so you need to have a good understanding of how an abatement project should be conducted in order to be fully compliant. While you cannot enforce any requirements other than those of the NESHAP, you should be able to recognize and comment or make recommendations towards ensuring regulatory compliance. Noncompliance with OSHA standards may be referred to the appropriate OSHA district office.

Asbestos Training and Equipment
In order to conduct a qualified compliance inspection or complaint investigation, staff must be adequately trained and have the resources necessary to complete the job. Staff whose duties include inspection of asbestos abatement projects or investigation of asbestos complaints must complete both the 40-hour Asbestos Contractor/Supervisor and the 24-hour Asbestos Inspector courses. Lists of training providers may be found on the Air Pollution Control Program’s Asbestos home page. Upon successful completion of these courses the Air Pollution Control Program will provide occupational certification for both disciplines. Copies of the certificates must be carried during field activities. Staff must also participate in annual refresher training for both disciplines. Medical monitoring, respirator fit testing and medical clearance to wear a respirator are also required. Respirator fit test results must also be carried during field activities. An adequate amount of on the job training with experienced staff must also be provided.

The Environmental Protection Agency, (EPA), Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) have web resources for obtaining asbestos information. The EPA also maintains the Applicability Determination Index (ADI) for researching a variety of regulatory issues, including asbestos. Be advised, some of the guidance on the ADI has been superseded. Some useful Web addresses is available at:

Equipment
Inspectors must be equipped with a kit containing items such as a flashlight, waterproof marker, spray bottle, disposable rubber gloves, hammer, pry bar, screwdriver, utility knife, small trowel, tape measure, sample containers, wet wipes for decontaminating tools, duct tape, spray adhesive and respirator wipes. Disposable protective clothing such as Tyvek® should be carried. Steel toed shoes, a hard hat and camera must also be available. Copies of the federal and state regulations must be available for reference during an inspection.

Inspection Report Content
Complete all applicable portions of the inspection report. Complete as much of the report as possible prior to the inspection. This information is available from the project notification. Copies of all inspection reports are to be provided to the source or abatement contractor. The requirement for providing written reports may be found in the Missouri Air Conservation Law, Chapter 643 RSMo.

If Notices of Violation are issued they need to accompany the inspection report. For instances where violations are noted but inspector discretion is used, a Letter of Warning should accompany the report. All LOW’s should require a written response. A failure to respond or an inadequate response would warrant issuance of a Notice of Violation. Deficiencies noted during inspections or investigations that could potentially lead to a violation must be documented, along with the inspector’s guidance for addressing the deficiency.

Asbestos Inspections
The most frequent oversight in using the state inspection checklist is the failure to verify the individual who conducted the asbestos inspection of the building or work area was properly certified. If the asbestos inspection report is not on-site during the abatement or demolition project either the contractor or building owner should be requested to provide, at a minimum, a copy of the summary sheet, the certificate of the inspector and bulk sample results. Lists of currently certified inspectors, supervisors, workers and registered contractors, forms and technical bulletins may be viewed at the asbestos home page. A complete copy of the report will be requested if suspect materials are noted and are not included in the scope of abatement work or will not be removed prior to demolition. The state or local inspector must ensure sampling has been performed on all suspect materials to be impacted by the project. For demolition projects, these materials must be analyzed and the results provided prior to the onset of demolition.

Narrative comments will be provided to accompany the checkboxes of the report. Ideally, any reviewer should be able to visualize the project as the state or local inspector saw it. Those topics covered in the 40-hour asbestos supervisor course are areas to inspect and comment on. The inspector needs to be familiar with these areas and should reference their course material as needed. The manual for EPA’s Course #350 NESHAP Asbestos Inspection and Safety Procedures is also an excellent reference. Detailed comments must be included when violations are observed or when verbal warnings are conveyed. If the project involves gross removal inside containment and no viewing window is provided, the inspector should enter containment. If viewing windows are available and allow adequate observation of the area and work practices, entry inside containment is not necessary.

If violations are observed they shall be documented in writing, properly photographed and samples collected. The written description and photographs will establish the types and quantities of asbestos materials involved and all responsible parties. Inspectors will use proper sampling techniques including wetting sample material, respiratory protection and protective clothing such as gloves, suits, foot coverings or hard hats. Sample containers may include plastic film canisters, zip lock bags or plastic tubes from coring equipment. A proper Chain of Custody must be prepared and kept for all sampling events. Used gloves and wipes must be properly packaged and disposed of as solid waste. You must collect samples to support a violation that a specific material contains asbestos.

Documentation
All documents reviewed, taken or prepared by the inspector will be noted and related to specific inspection activities. Examples would include air monitoring results, daily logs, worker certifications, sample or photograph locations, worker or supervisor comments or work plans.

Observations
Drive around the site and try to establish the magnitude and location of the project within the facility.

Make note of areas to visit (job trailer, waste storage area, active work areas and areas already abated, waste load out area, negative air machine exhaust locations).

Look for visible emissions to the outside air (debris around the waste storage area, outside the entrance to the work area or waste load out areas).

Gaining Entry
Conduct the inspection during normal working hours or whenever the project is scheduled. Advance notice may be necessary to gain access to buildings that are to be demolished.

If requested, provide your asbestos occupational certificates and respirator fit test results.

Abatement Inspections

Waste Area Observations

Post-abatement Inspections
Inspection of an abatement project where the contractor has completed work shall reveal no friable asbestos containing materials that have been missed or debris from abated materials. The regulations are specific that all regulated asbestos containing material shall be removed prior to demolition or renovation. There is no distinction in work quality between a building that is to be torn down versus one that is to be reoccupied. Materials that are discovered shall be photographed, sampled and well documented. The contractor and owner are to be advised of these materials and to return and properly remove them.

Demolition Inspections
A complete copy of the asbestos inspection report done on behalf of the owner or operator is necessary to conduct an inspection prior to demolition of a building. Make sure all suspect materials have been identified. Randomly look in areas that are frequently overlooked. These areas may include above drop ceilings, in pipe chases or wall cavities where pipe risers may occur, beneath subfloors, duct boots at floor heat registers, lighting fixtures, roofing materials and caulks. If you discover suspect materials that have not been sampled or included in the asbestos survey, point these out during the inspection and include in your report. Request copies of the sample results from these suspect materials. Demolition should not occur until your concerns have been addressed. If nonfriable materials are to remain in the structure the issue of potential friability should be discussed, and documented, with the owner or operator. Familiarity with solid and hazardous waste requirements is also recommended.

Unsafe structures
Competent local or state officials should make Unsafe Building Declarations. These officials may include local building or code officials, law enforcement or fire department personnel. In some cases department staff may need to make or agree with this decision. If possible, owners or operators of unsafe or damaged structures should have them inspected prior to demolition. If a building is only partially damaged but is to be completely demolished, the structurally sound portion should be inspected. Asbestos removal from this part of the building may be required. The damaged or unsafe portion should be wetted during demolition and inspected once the debris is on the ground. The discovery of friable or damaged nonfriable asbestos containing materials commingled in the building debris may result in all of the waste being considered as asbestos containing waste. Decontamination and segregation of large items such as steel beams or intact portions of roofing or wall sections may be possible.

Landfill Inspections
Landfill operators must comply with §61.10 (Source reporting…), §61.153 (Reporting), and §61.154 (Standard for active waste disposal sites). EPA has produced an inspection form that can be used in landfill inspections. Keep in mind, most active landfills are subject to a federal New Source Performance Standard for non-methane organic compound emissions and may have a Part 70 or Intermediate Operating Permit. Inspections at landfills should include NESHAP, NSPS and any permit requirements. Also, the Solid Waste Management Program typically conducts quarterly inspections at active sanitary landfills. You may want to coordinate inspection activities with staff doing solid waste work

3.6.3 Gasoline Vapor Recovery

Purpose
The purpose of this section is to establish uniform procedures for conducting Gasoline Vapor Recovery Inspections in the St. Louis Non-Attainment Area and the Stage I Testing and Inspections in the Kansas City Area.

Application
This procedure applies to all department personnel involved in the inspection of stage I, and or stage II, vapor recovery systems at gasoline dispensing facilities (gdf’s) located in the St. Louis non-attainment area, and the Kansas City maintenance area. The basic inspection procedures will follow the guidelines of Chapter 3.1 “General Inspection Procedures” while allowing for the uniqueness of the Vapor Recovery Inspection/Enforcement Rules, and Air Program Policies.

The state rule that applies to the gdf’s in the St. Louis area vary a great deal from those in the Kansas City area. While some of the equipment and procedures are the same, the St. Louis area has much more detailed inspection requirements than the Kansas City area, which results in more training and more responsibilities for the St. Louis inspectors. This requires that this section of the Operations Manual have separate procedures for vapor recovery inspections in St. Louis and Kansas City.

St. Louis Gasoline Vapor Recovery

Kansas City Vapor Recovery Stage I Inspections

Delivery Surveillance
St. Louis and Kansas City have the same requirements for Stage I deliveries to facilities by tanker truck except for the facility storage tank size requirements. Drivers are required to use one three-inch vapor return line per four-inch product line used for the delivery on any storage tank required to have the Stage I System. The tanker is to be tightness-tested annually by a test contractor that must follow all criteria and standards established by Method 27, appendix A, 40 CFR Part 60 and 40 CFR part 63.426(e). The owner is required to submit the test results to Air Pollution Control Program for a Missouri Sticker that is to be placed on the upper left portion of the back of the delivery vessel.

An NOV is to be issued to the driver and the delivery company for failure to comply and automatically referred to Air Pollution Control Program for enforcement action. Inspectors are encouraged to stop and visit with drivers whenever they observe a delivery whether they are in violation or not. This gives inspectors the opportunity to talk to drivers, answer any questions they have, and to thank them for doing a good job if they are correct.

Inspection Selection and Coordinating

Pressure/vacuum valve tests are scheduled as needed as determined by the database or when new valves are installed.

Inspector Training

General Inspection Procedures
There are several different types of Vapor Recovery Inspections. Each has its own inspection criteria and goals. St. Louis and Kansas City have different rules, but they have the same type of inspections. The types of inspection are:

Preinspection Procedures

Equipment
The inspector will collect and organize all equipment that may be needed for conducting the type of inspection planned. The test contractor is required to supply the test equipment; however, SLRO and KCRO do have some of the test equipment that they can take with them as a backup. The following is a list of equipment specifically for vapor recovery inspections and testing. The inspector may wish to refer to the General Inspection Procedure section of this manual for additional equipment they may want or need.

Forms
The inspector will have all forms and information sheets for the type of inspection planned. These include:

Available from Air Pollution Control Program:

Available from Regional Offices:

Record Review
The regular inspections do not require any review of facility files prior to the inspection, because the inspection is to determine the condition of the facility system and equipment at the time of the inspection. The inspector will review the original inspection and enforcement reports to remind them of the defects found and any tag outs at the facility during the original inspection when preparing for the reinspection
.
Test and construction inspections in St. Louis will require a review of the current permit file to review permit applications and fee payment prior to the inspection.

In Kansas City, a records review prior to the test inspection or the P/V testing may be needed to determine compliance and response time of the facility.

Site Inspection Procedures
The inspection procedures will follow the basic guidelines as reference in the General Inspection Procedures with variations generated by the differences for Vapor Recovery inspections noted in this section. The inspector will at all times remember to be courteous and respectful to the facility personnel and the customers.

St. Louis

Regular Inspections

Reinspections
Upon notification from the facility that all repairs have been made if equipment was taken out of service, the inspector will return to the facility for a reinspection. The Vapor Recovery Rule allows four working days to do this reinspection. However, the Unit policy is to complete these “Tag Out” reinspections within 24 Hours of notification of repairs.

If a facility had defects, but no equipment was taken out of service, or had equipment out of service, but did not contact the inspector with notification of repairs being made, a reinspection will be done after 15 days from the date of original inspection.

The inspector will review unresolved inspections and NOV/NOEEs weekly to determine when reinspections are to be done. The inspector will pre-print inspection forms for all facilities needing to be re-inspected prior to going to the field to do those reinspections.

Operating Permit Test Inspections

Construction Inspections

Kansas City

Stage I Inspections

Five-Year Stage I Test Inspections

Two Year P/V Valve Tests

Post Inspection Procedures
The Final Interview will start as soon as the inspector completes the inspection and the related paperwork. The procedures are the same in St. Louis and Kansas City with variations depending on the type of inspection and what was found during the inspection.

Regular Inspections
The inspector will give the facility representative an explanation of the facility diagram to make it easier to locate and repair any defects found. This will be followed by a detailed explanation of the defects found during the inspection. The inspector will then explain any enforcement action taken and the procedures for resolving the issues. In St. Louis, the inspector will leave a handout (NOV/NOEE Procedures Handout) that outlines the enforcement procedures, the reinspection date, and the phone number to call for reinspections or questions.

The inspector will ask the representative to sign the NOV/NOEE as proof that the facility received it. The facility copy of the inspection form and the NOV/NOEE will be given to the facility. The inspector will offer one last chance for questions before leaving.

If the facility had no defects, the inspector will thank them for maintaining their facility and encourage them to continue what they are doing for the air quality in St. Louis or Kansas City.

Test Inspections
The inspector will indicate that the facility passed and sign the inspection form. A copy of the inspection form can be left with the contractor. Unless the facility fails, there may be no need to discuss the test with the owner.

Office Procedure and Data Management
Upon returning to the office the inspector will follow office procedures for entering any updated information concerning the facility name and address, ownership, and any other information changes found during the initial interview into the facility database.

The inspector will note the facility code number, the county, and the reinspection date on the NOV/NOEE form.

The inspector will complete a tracking slip for the inspection or reinspection and paperclip it to the white copy of the inspection and NOV/NOEE form, if any, and place them in the “Completed Inspection” letter tray. If the issues have been resolved, the inspector will include the yellow copies in that packet. If the issues are not resolved the inspector will clip a new pre-printed inspection form to the yellow copies and place them in the inspector’s slot in a vertical file next to the inspection tray.

The Unit Chief will review the inspection forms periodically during the month and confirm the accuracy of the data entry. The yellow copies of all resolved inspections will be clipped to the tracking slips for those inspections and forwarded to Data Entry to be entered in the PTS and NOV tracking systems. Data Entry will return the tracking slips to the Unit Chief and the inspection forms will be placed in the facility file. The Unit Chief will hold the white copies and tracking slips for unresolved inspections until they are resolved.

Permit Procedures for St. Louis
The SLRO has the responsibility to review and write all Vapor Recovery Operating and Construction Permits for all facilities in the Non-Attainment Area. The St. Louis City and St. Louis County Health Department Air Programs submit the applications and test results from facilities in their area to SLRO for review and processing. Facilities in Jefferson, Franklin, and St Charles Counties submit the permit applications to SLRO and all test oversight is done by SLRO personnel.

When the Unit Chief receives the applications, they are reviewed for completeness, entered into the PAMS Database, and forwarded to the Vapor Recovery Engineer to be written. The engineer reviews the paperwork for compliance and completeness then writes the permit, saving it as a file on a common drive. The application is then sent back to the Unit Chief who prints the permits and checks for accuracy. The permits are sent back to the engineer with a permit request memo for review and his signature or initials. The engineer then copies the entire packet and sends them to APCP for review and the Director’s signature.

The signed permits are returned to SLRO. The city and county personnel are notified the permits are ready to pick up. Permits for SLRO facilities are sent with cover letters to the individual filing for the permit.

Inspection Reports to APCP
The APCP requires that inspections, tests, and permit paperwork related to Vapor Recovery be submitted on a regular basis. Enforcement issues such as improper Stage I Deliveries will be referred to APCP Enforcement as soon as possible following Department procedures.

The report includes the white copies of the resolved inspection, NOV/NOEE, reinspection packets, a database generated list of all facilities inspected that month, and a summary sheet detailing the number of inspected facilities, the number of defects found, and a list of facilities that are being referred for enforcement.

Stage I Surveillance Procedures
Inspectors in the St. Louis and Kansas City areas are encouraged to watch for tanker deliveries of gasoline and stop anytime they observe a delivery being made. The inspectors will present their ID Card or business card to the driver and identify themselves. If the driver is doing a correct delivery, the inspector will thank him/her and proceed on their way. If the delivery is not in compliance, the inspector will stop the delivery and advise the driver as to how the delivery should be made. If the driver cannot comply, the delivery is ended.

The inspector will take photographs of the improper delivery and get the driver’s name, the company and the truck information. He will also check for the trailer sticker and the Method 27 test results.

An NOV can be issued to the driver on site or the inspector may choose to return to the office to write the NOV for the driver and an NOV to the delivery company to send to the company owner following Department policy. Copies of the NOVs, the cover letters, photographs, and an Enforcement Action Request will be sent to APCP for enforcement.

3.6.4 Open Burning Permit Guidance

Open Burning Permits
Open burning permits may be issued by regional offices under the authority of 10 CSR 10-6.045(3)(A)5.A., (3)(A)5.B., (3)(A)10.  for the open burning of yard waste, certain trade wastes, untreated wood waste and for land clearing of tree trunks, tree limbs and vegetation when required by (3)(A)4.  Permits issued under these provisions shall include any special conditions and provisions as determined appropriate by the issuing regional office.  The Air Pollution Control Program encourages regional offices to include any recommendations from the local fire authority and that the regional office consider the following special conditions, as appropriate, for the situation at hand:  day/time limitations, on-site supervision, use of an air curtain destructor, setback conditions or written waivers from nearby occupied structures.  The regional office may also deny permit applications based on local agency, fire department, police department or sheriff’s department information or a determination that the individual or business may reasonably cause or has caused a health or environmental risk. 

The Air Pollution Control Program encourages regional offices to use the following criteria when determining the timeframe for permit expiration:

Open Burning permits may be issued under 10 CSR 10-6.045(3)(C) to commercial tree trimming operations and municipal tree trimming operations on an annual basis.  Again, the Air Pollution Control Program encourages the regional offices to include any recommendations from the local fire authority and that the regional office consider the following special conditions, as appropriate, for the situation at hand:  day/time limitations, on-site supervision, use of an air curtain destructor, setback conditions or written waivers from nearby occupied structures.  As annual permits issued under 10 CSR 10-6.045(3)(D) require the usage of an air curtain destructor and setback distances of at least 200 yards from the nearest occupied structure (or waivers from the owner/operators of such structures), the Air Pollution Control Program strongly encourages the incorporation of these particular requirements for permits issued under this section (10 CSR 10-6.045(3)(C)).  The regional office may base their determination as to incorporating these requirements on the following factors:

Annual burn permit holders using air curtain destructors should be expected to conduct an annual Method 9 test to document compliance and provide the results as a condition of obtaining a permit for the next year.

3.6.5 Forms and Checklists

Items listed below that do not appear as Web links are available through the Air Pollution Control Program.

Asbestos

Gasoline Vapor Recovery - forms and checklists

Gateway Vehicle Inspection Program

Available from APCP:

Available from Regional Offices: