Environmental Permitting

Quick Guide to CAA Recordkeeping Requirements


Although federal and state law require record retention for only a specified period (generally 3 to 5 years), it is strongly recommended that legal counsel be consulted before destroying any records.

General NSPS Recordkeeping Requirements

In addition to source-specific NSPS recordkeeping requirements included in your construction and/or operating permit, you must maintain a record of the occurrence and duration of any start-up, shutdown, or malfunction of the facility; any malfunction of the pollution control equipment; or any periods during which a continuous monitoring system (CMS) or device is inoperative.


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NSPS CMS requires semiannual reporting of excess emissions, including:

  • The amount of excess emissions
  • Date and time excess emissions began and ended
  • The process operating during the reporting period
  • Each excess of emissions that occurs during start-up, shutdown, or malfunctions; the nature and cause of any malfunctions; and the corrective action taken
  • Date and time CMS was inoperative and the nature of repairs and adjustments
  • That no excess emissions have occurred and the CMS has not been inoperative, repaired, or adjusted during the reporting period

In addition, all NSPS sources with a CMS or other monitoring device must maintain records of all measurements, performance evaluations, calibration checks, adjustments, and maintenance performed on the systems or devices.

Note: NSPS records must be retained for 2 years.

General NESHAP Recordkeeping Requirements

In addition to the source-specific NESHAP recordkeeping requirements included in your construction and/or operating permit, you must also keep records of the following:

  • The occurrence and duration of each start-up or shutdown that causes excess emissions
  • The occurrence and duration of each malfunction of the required air pollution control and air-monitoring equipment
  • All required maintenance performed on the air pollution control and air-monitoring equipment
  • Actions taken during periods of start-up, shutdown, and malfunction when the actions are different from the procedures specified in your start-up, shutdown, and malfunction plan
  • All information that demonstrates you are conforming to your start-up, shutdown, and malfunction plan
  • Each period during which a CMS is malfunctioning or inoperative
  • All the measurements required to demonstrate that you are complying with a relevant standard
  • All results of performance tests, CMS performance evaluations, and opacity and visibility emissions observations
  • All measurements that may be necessary to determine the conditions of performance tests and evaluations
  • All your CMS calibration checks
  • All adjustments and maintenance you had performed on CMS
  • All documentation supporting your initial notifications and notification of compliance status

Note: The general NESHAP records must be kept for 5 years.


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Additional Requirements for NESHAP Sources with CMS
In addition to your NESHAP recordkeeping requirements, if you have a CMS, you must record:

  • All required CMS measurements
  • The date and time of each period your CMS was inoperative except for zero (low-level) and high-level checks
  • The date and time of any occurrence when your CMS was out of control
  • The specific identification of each period of excess emissions and parameter monitoring exceedances, including those that occur during start-ups, shutdowns, and malfunctions
  • The nature and cause of any malfunction
  • The corrective action you have taken or preventive measures you adopted
  • The total process operating time during the reporting period
  • All procedures that are part of a quality control program you developed and implemented for the CMS

Note: These additional records must be retained for 5 years.

It’s in your best interest to make sure that if EPA or the state requests proof of your compliance, you can produce documents that answer all of their questions. See tomorrow’s Advisor for more CAA records you should be keeping.