ENV-03-108 Upset/Maintenance Emissions Event – Limit Enforcement Actions Through Post Event Documentation and Prior Authorizations

Description:

This paper discusses why upset emissions are a significant concern to EPA and the states. It provides a history of upset reporting and agency discretion related to enforcement action for upset emissions. It discusses how one state, Texas, has adopted a program to conform to EPA guidance and satisfy specific state needs. Finally, the paper presents an example of how one facility uses a few simple tools to properly report upsets and gather the information necessary to prove the upset was truly an unavoidable event.