BOP Program Statement 1605.01 § 24

a. Air Emissions Inventory. The SA and Facilities Manager must conduct an Air Emissions

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Inventory to identify all air emissions and determine if air permits are required. The Air

Emissions Inventory must be updated every time new emissions equipment is added or removed

from the institution. Associated permits must be modified as required within the permit.

b. Air Permits. The Facilities Department and other affected departments must provide the SA

with copies of air emissions permits held by the institution, e.g., boiler operating permits,

emergency generator permits, spray booth operating permits, and drying oven emission permits.

The SA must review the permits and develop a compliance checklist for each emission source.

To make such determinations, the SA will research state air emissions regulations and contact

state regulatory authorities.

Pre-construction and construction permits may be required for construction and renovation

projects involving an air emission source (e.g., new construction or renovations involving

boilers, spray booths, or emergency generators). These requirements must be reviewed during the

project planning stage. New equipment cannot be purchased, and designs are not finalized until

permits are obtained.

The Safety Administrator must be informed of each construction or renovation project during the

early planning stage. They inspect obtained permits, unless contract language specifies the

contractor obtains the permits.

If permits are obtained by the contractor, a copy of the construction permit must be provided to

the SA and Facilities Manager prior to equipment installation. If required, operational permits are

obtained before the equipment is turned over to the Bureau and prior to equipment startup.

Title V of the CAA requires an institution-wide air emissions permit for facilities that are major

sources of regulated pollutants and synthetic minor permits for lesser sources. The air emission

inventory is used to determine permit applicability and requirements. Air emissions inventories

must be kept indefinitely and revised when emission sources are added or removed.

c. Air Emissions Source Inspection. For institutions with an air permit, OSHD staff must

inspect emission sources and associated records monthly to ensure compliance. Uncorrected

discrepancies must be reported in the monthly safety and environmental report. Discrepancy

resolutions must be documented. Recurring discrepancies must be presented at the Institution

Environmental Management Committee meeting for corrective and preventative action.

Annually, the SA must review the air emissions permit program using required checklists.

Documentation must be kept by the OSHD for at least four years.

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