Environmental Permitting

CAA Recordkeeping Cheat Sheet

Chemical Accident Prevention Provisions Records

If you own or operate a stationary source subject to the chemical accident prevention provisions (40 CFR 68), you must maintain sufficient records to support the implementation of the requirements.

Note: The recordkeeping requirements for prevention of accidental releases are 5 years, unless otherwise specified.

Title V Operating Permit Records

If you are subject to Title V, in addition to your source-specific recordkeeping requirements included in your Title V operating permit, you must monitor and record:

  • The date, place as defined in the permit, and time of sampling or measurement
  • The date the analyses were performed
  • The company that performed the analyses
  • The analytical techniques or methods used
  • The results of such analyses
  • The operating conditions existing at the time of sampling or measurement

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In addition, Title V sources subject to compliance assurance monitoring (CAM) must maintain records of monitoring data, monitoring performance data, corrective actions taken, any written quality improvement plan required, and any activities undertaken to implement a quality improvement plan.

Note: Title V operating permit sources must maintain records, including CAM records, for 5 years.

Checklist for Title V Permits: Here’s a checklist to help you audit air requirements at your facility, determine your facility’s categorization, detail necessary permit information, and explore emissions limits and other standards that apply to the final permit.

Required Acid Rain Program (Title IV) Records

Every acid rain permit is a portion of a larger Title V permit. In addition to the recordkeeping requirements included in your operating permit, requirements for notification, recordkeeping, and reporting include:

  • Submission of monitoring plans
  • Written notifications of monitor certification tests
  • Report of certification test results in a “certification application”
  • Records of emissions data, operating data, and other information
  • Records of periodic performance evaluations of the monitoring equipment, including daily calibration error tests, daily interference tests for flow monitors, and semiannual (or annual) relative accuracy test audit and bias tests
  • Quarterly reports of emissions, operating, and monitor performance data

Note: Acid rain program records must be retained for 3 to 5 years.


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General Requirements for ODS

If you take part in any of the various activities involving ozone-depleting substances (ODS), you must maintain appropriate records as follows:

  • Those producing, importing, or exporting Class I or Class II ODSs:  extensive data related to the substances produced, imported, or exported since the last quarterly report
  • Owners of refrigeration recovery or recycling equipment: technician certifications
  • Reclaimers: the entities sending material for reclamation, the quantity sent, the quantity reclaimed, and the quantity of waste products
  • Sellers of refrigerants: invoices with the name of the purchaser, date of sale, and quantity purchased
  • When disposing of small appliances, MVACs, and MVAC-like appliances, you must keep copies of signed statements guaranteeing removal of refrigerants.

Owners of appliances containing 50-plus pounds of refrigerant must keep servicing records with the date and type of service, as well as the quantity of refrigerants added. You must keep all records of refrigerants purchased and added to these appliances if you add your own refrigerant.

Note: All records for ozone-depleting activities must be dated and kept for 3 years.

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