What's next for MON?

The MON compliance date has past and you've just submitted your Notification of Compliance Status Report. Now is the time to be 100% certain that you are in compliance. Make certain your site is performing the necessary monitoring, recordkeeping and reporting. Conduct an audit now before there is an agency inspection and prior to submitting the first Certification of Compliance report, while there is time to make adjustments.

Best practices for MON compliance include the following:

  • Have a third party conduct an objective compliance audit using EPA protocols;
  • Implement automated data management systems prior to the February 28th, 2009 Semi-annual compliance report;
  • Integrate MON requirements into the Title V permit; and
  • Minor sources should be on the lookout for the Chemical Industry Sector Area Source MACT.

Concerned about an Inspection?

The EPA Office of Enforcement and Compliance Assurance (OECA) has designated compliance with Air Toxic Standards one of their highest national priorities for fiscal years 2008–2010. EPA regions have been training staff to conduct facility inspections of MON MACT compliance, and we have been told that MON audits are commencing now.

Solution

Reduce your risk of fines and negative publicity, contact Dixon Environmental for an objective, informed and detailed review of MON compliance.

Want to improve the efficiency of compliance management and reporting?

Facilities are required to track numerous compliance data points, investigate incidents, and report deviations. Aging disparate software and spreadsheets may not be the best way, particularly when something changes, like the spreadsheet "owner" retires.

Solution

Improve organizational efficiency, streamline data management and reporting, and implement task tracking and alerts and give managers the tools they need to do more with less. Ask about our technology risk assessment and request a MONITOR demonstration.

Considering integrating MON Requirements into the Title V permit?

The requirements for integrating MON into your Title V permit vary by state, and often depend on the renewal date for your Title V permit. Typically, incorporating the MON requirements will require completing an application for a significant permit modification. If time allows, combine this task with your Title V renewal or other permit modifications in order to improve efficiencies.

Solution

Email info [at] dixonenvironmental [dot] com and request a webinar on integrating MON into Title V for your organization. Dixon Environmental has nationwide experience integrating MON requirements into facility Title V permits, and we provide comprehensive services to complete permit renewal applications.

Do you have a facility that complied with the MON by becoming an Area "minor" Source?

These facilities will be subject to the Chemical Industry Area Source MACT standard which will be proposed by EPA shortly. EPA is under direction to promulgate this rule by the end of 2008, and has already referred to as a "mini-MON".

Solution

Join our Chemical Industry Area Source MACT email distribution list! Email your contact information to info [at] dixonenvironmental [dot] com with a request to stay informed about Area Source MACT issues. We will keep you informed of regulatory developments and recommendations for compliance.