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Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

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Page 1: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Maricopa CountyAir Quality Department

Compliance Division – Inspections/NOVsSteve Depenbrok

Compliance Division Manager

Page 2: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Inspection Purpose

• Primary goal:

– conduct unbiased inspections of air pollution sources and determine compliance with rules, regulations and permit conditions

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 3: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Inspection Purpose

• Source compliance RESULTS:

– less air pollution

– less work for both inspector and source

– focus returns to primary duty of conducting inspections

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 4: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

What training do compliance inspectors receive before they undertake inspections?

• New inspectors familiarize themselves with air pollution control rules and regulations

• Most training is one-on-one

• With an experienced inspector or supervisor present, new inspectors begin to lead simpler inspections

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 5: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

• As an inspector gains confidence and competency, inspectors then begin to conduct inspections on their own

• It is a progressive, educational process

• It takes a full year plus for an inspector to become familiar with inspecting numerous source types

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

What training do compliance inspectors receive before they undertake inspections?

Page 6: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

How is the decision made to issue NOVs?Are they ever rescinded?

• Many NOVs are written in the field by the inspector upon discovery of what is perceived by the inspector to be a clear violation

• Other NOVs regarding more complex cases are issued from the office, based on a full and fair evaluation of the facts

• NOVs are rescinded if flawed

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 7: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

What can companies do to obtain additional information on an NOV?

• When the violation is discovered on site during the inspection, the inspector will explain the violation before leaving the site. If the explanation is unclear, ask questions

• If the violation is mailed from the office, the source can call the inspector for an explanation of the violation

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 8: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

• AQ inspectors will not recommend any specific action(s) to the source to correct violations

• Source responsibility to determine how to best rectify the violation

• The source can also contact the department’s Business Resource Center for assistance

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

What can companies do to obtain additional information on an NOV?

Page 9: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

What does MCAQD expect as an appropriate response to an NOV?

• The simple answer is for the source to correct the violation and ensure it does not recur

• Many work practice violations can be corrected at the time of the inspection before the inspector leaves the site, and, although the violation is issued, it is resolved before leaving the site

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 10: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

• Other violations will require a source to submit some type of documentation to the inspector shortly after receiving the violation to verify compliance has been achieved.

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

What does MCAQD expect as an appropriate response to an NOV?

Page 11: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Compliance Status Notification vs. NOV

• With very, very few exceptions, all documented violations result in the issuance of a NOV

• CSNs are issued on a case-by-case basis

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 12: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

On what basis is the decision made to refer an NOV to Enforcement?

• It is the department’s policy that ALL NOVs are referred to Enforcement

• Enforcement Division is the forum where cases are discussed

Maricopa County Air Quality DepartmentProtecting our most vital natural resource - air

Page 13: Maricopa County Air Quality Department Compliance Division – Inspections/NOVs Steve Depenbrok Compliance Division Manager

Maricopa CountyAir Quality Department

Compliance Division – Inspections/NOVsSteve Depenbrok

Compliance Division Manager602-506-6739

[email protected]