If you have an air permit, you might have thought you were going to avoid an annual inspection this year due to the COVID-19 pandemic. Well think again. In June 2020, Ohio EPA released guidance on their plans to conduct Virtual Site Visits. Yes, I said Virtual Site Visits.
Ohio EPA district offices and local air agencies are just now beginning the process of rolling out these Virtual Site Visits (VSV). The good news is these VSV will only be conducted on a limited basis.
Ohio EPA plans to conduct a pre-meeting by phone or video conference that will discuss all logistics to ensure a successful VSV. The VSV may require Teams, Zoom, Google Chrome, Microsoft Edge, camera, phone, headset, and earbuds. The actual VSV will be conducted using a live stream application (e.g. Teams or Zoom) in combination with photographs. You will be asked to live stream portions of the facility during the VSV. GT assumes the live streaming will be conducted using a cell phone or tablet camera. GT understands that neither the agency nor the company will be permitted to record the live stream. Prior to the VSV, Ohio EPA will also ask you to provide copies of your plant records.
During the pre-meeting, you may want to discuss the following issues or concerns… Confirm that the VSV livestream will not be recorded especially if you have security and confidentiality concerns. Do you have adequate cell phone and WiFi coverage throughout the plant? Many plant areas require the use of ear plugs or earmuffs; these will make communication in these areas almost impossible. Many areas of the plant are dark, and video and photographs may be of little use or even misleading. You may also want to consider the safety concerns associated with walking around a plant while holding a camera and talking/listening at the same time.
Could 2020 get any stranger? What is next, site visits using agency robots?
A copy of Ohio EPA’s June 2020 guidance on VSV is available here.
Please contact Ron Hansen, Owner/Principle Consultant at (614) 794-3570 Ext 121 or rhansen@gtenvironmental.com about GT’s air permitting and regulatory consulting services.