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What to Do If You Suspect a Facility is Illegally Emitting Pollution -- Collecting Data Regarding Upset or Malfunction Emissions:
1. For any large facility, request copies of the facility?s Title V compliance certification. You can request this from either U.S. EPA or from the State environmental agency. Large facilities are required to file these once a year. The certification must list all potential violations that have occurred during the year.
2. For any large facility, request copies of facility?s Title V deviation reports. These reports should be requested from the State environmental agency. Deviation reports must identify all potential violations, including those caused by upsets. Facilities should file deviation reports "promptly" after any excess emissions occur. The timing varies by state from 24 hours to 6 months. The reports must include the probable cause of the deviation as well as any corrective actions or preventive measures taken. Some deviation reports may simply include the date of the upset and then reference the state upset report (described below) which may contain more detailed information.
3. Request copies of state upset/malfunction, startup and shutdown reports. Most states require some notification of upset/malfunction, startup and shutdown events. The quality of these reports varies by state. Some states include detailed information regarding emissions, while others include very little useful information. In a few states, such as Texas, upset reports are beginning to be put online. Texas? reports can be found at:
http://www2.tnrcc.state.tx.us/eer/main/index.cfm?fuseaction=searchForm#gotre.
In some states, retrieving these reports may require a tip to the state agency?s file room to actually pull the upset reports from the larger file.
4. Check the National Response Center website. Oil and chemical facilities are required to notify the National Response Center within 24-hours of all accidental releases and many maintenance or shutdown releases. This data includes only the facility?s initial notification. It does not include any corrected or updated data. In addition, facilities do not appear to comply regularly with this reporting requirement. The website is http://www.nrc.uscg.mil/nrchp.html
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