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Non-Compliance Event Notification Reporting

On July 20, 2005, the District released an Advisory summarizing the reporting requirements for notifying the District of non-compliance. A non-compliance report must to be sent to the District when a source:

  1. Intends to continue operating for a short time after system upset or breakdowns, while repairs are being made;

  2. Is under the Title V program and thus is required to promptly report all deviations from permit conditions; and/or

  3. Uses continuous emissions monitoring systems (CEMS) or continuous monitoring systems (CMS).

Non-compliance reporting generally does not apply to sources that are shut down when any operating condition is not in compliance (i.e., they do not operate unless all required operating conditions are being met).

The District has prepared these documents for better understanding of reporting requirements and to improve reporting in the future.

  1. Non-Compliance Event Requirements — A summary of air pollution reporting requirements for deviations, and includes a discussion of malfunction reporting, and a discussion of excess emissions during source startup and shutdown.

  2. Non-Compliance Event Notification Form and Instructions
    Non-Compliance Event Notification Electronic Form (Word Version)
    Non-Compliance Event Notification Electronic Form (PDF Version)

    Non-Compliance Event Notification Electronic Form Instructions
  3. Startup, Shutdown and Malfunction Events— A summation of U.S. EPA policy on startup, shutdown, and malfunctions, and a discussion of local, state, and federal considerations on opacity exceedances during startup or shutdown.

    For further information or clarification of non-compliance reporting issues, contact Todd Nishikawa by email or at 530-745-2322.

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