STEP 1: Develop a permit with your facility conditions in mind
When applying for a permit, get involved in the process and communicate your facility conditions to the regulatory authority. Many regulatory requirements mandate a specific method of compliance. However, if permit conditions are not practicable for your facility, alternative compliance methods may be approved. Ensure that any alternative methods are effective, based on sound reasoning, and enable your facility to demonstrate compliance with the permit requirements.
STEP 2: Know your permit
After your permit is approved, it is important that you read it thoroughly. Understand the requirements of the permit. Ensure that you are aware of the monitoring and recordkeeping requirements of the permit. Your facility must demonstrate compliance with discharge standards, as well as, monitoring data and recordkeeping standards.
STEP 3: Collect and Document Data
Ensure that you have an understanding of the data you collect and that the data can be used to demonstrate compliance with the permit requirements. If the data indicates that compliance was not met, correct the issue and document corrective actions. Maintain your data in an accessible location and be prepared to explain how the data was collected.
STEP 4: Prepare for inspection day
If an inspector lands on your doorstep, be confident that you have taken the steps necessary to maintain compliance with your permit. Ensure that you are prepared for an inspection by having permit documents and associated records in an accessible location. Be prepared to explain the methods you use to maintain compliance with the permit requirements and use your collected data to demonstrate said compliance.
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