The Importance of Compliance with EPA Method 9
Legal obligations and enforcement for visible emissions observers
Excerpt from Online Visible Emissions Course · Return to course summary »
From the EPA
...visible emission determinations for compliance demonstration or enforcement purposes must be made accurately and must be sufficiently well documented to withstand rigorous examination in potential enforcement proceedings, administrative or legal hearings, or eventual court litigation.
Source: Visible Emissions Field Manual — EPA Methods 9 and 22, Page 2
The importance of compliance
As a visible emissions observer, it is important to realize that the observations you perform are to comply with air pollution laws and regulations. Your organization can face exceptionally large fines if it is not compliant with environmental laws or EPA Method 9. To protect your organization, opacity readings must be accurate and completely documented to be legally defensible.
There are several legal aspects involved in opacity readings:
- Method 9 certification (field and lecture) must be kept current.
- Visible emissions observations must be performed correctly and accurately.
- The VEO form must be completed correctly, including the recording of conditions during the reading.
- VEO records must be maintained and available for audits.
Procedural errors or omissions on the VEO evaluation form or data sheet can invalidate a reading and result in a violation. It is important to carefully follow Method 9 procedures and properly complete the VEO form.
Violations of opacity limits, failure to follow proper procedures, or failure to fill out a VEO form accurately can result in fines of up to $37,500 per source, per standard, per day.
More information about EPA enforcement can be found on the EPA website.