Q. What are the requirements for Title V permit reporting?

A. Monitoring reports. Reports of monitoring required by a Title V permit must be submitted at least every 6 months. All deviations from permit requirements must be clearly identified in these reports.

Deviation reports. In addition to reporting deviations in periodic monitoring reports, permittees must promptly report all deviations from permit requirements, such as those resulting from upset conditions (as defined in the permit), the probable cause of those deviations, and any corrective actions and/or preventive measures taken with respect to those deviations. Permitting authorities are responsible for defining the term “prompt” and specifying the required timeframe for submitting these deviation reports.

Progress reports. For sources required to have a schedule of compliance to remedy a violation, progress reports must be submitted at least semiannually or on a more frequent basis if specified by the permitting authority. These reports must contain the following:

• Due dates for achieving the activities, milestones, or compliance required in the permit’s compliance plan schedule and the dates when such activities, milestones, or compliance was achieved; and
• An explanation of why any dates within the compliance schedule were not or will not be met and any preventive or corrective measures taken.

Compliance certification. Title V compliance certification reports must be submitted at least annually or on a more frequent basis specified by the permit or permitting authority and must include all of the following information:

• A description of each term or condition of the Title V permit that the certification is based on;
• A description of the method(s) used by the owner/operator of the facility for determining the facility’s compliance status for each permit term and condition during the certification period;
• The facility’s compliance status for the permit terms and conditions covered by the certification, including whether compliance during the reporting period was continuous or intermittent;
• Identification of each permit deviation that occurred during the reporting period;
• Identification as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance (as defined under 40 Code of Federal Regulations (CFR) 64) occurred; and
• Any other facts deemed necessary by the permitting authority for determining the facility’s compliance status.

All reports submitted for compliance with Title V requirements must be certified by a responsible official (as defined under the applicable regulations).

Compliance certifications must be submitted to both the permitting authority and the EPA.

Recordkeeping. Records must be maintained of any monitoring required by a particular Title V permit. These records must include:

• The date, place (as defined in the permit), and time of sampling or measurements;
• The date(s) analyses were performed;
• The company or entity that performed the analyses;
• The analytical techniques or methods used;
• The results of the analyses;
• The operating conditions that existed at the time of sampling or measurement; and
• Support information, such as calibration and maintenance records and all original strip-chart recordings for continuous monitoring systems (if applicable) and copies of all reports required by the permit.

Records must be kept for at least 5 years from the date of the monitoring sample, measurement, report, or application.