Facilities that operate under one or more permits must demonstrate compliance with many different requirements. Because permitting programs can allow for flexibility in proving compliance, facilities may develop their own entity-specific requirements. Using the Compliance Manager module, you can outline a plan for how you will comply with your operating permits.
For additional instruction on managing permits, click the following links or use the scroll bar to scan the page.
Set up a permit requirement profile to document the requirements you establish to demonstrate compliance with a permit. Use the Compliance Manager module to describe and track how you manage these requirements.
You can also document measurable objectives, called tasks, that define how you will comply with your requirements. For example, to comply with a monitoring requirement, you might describe tasks such as sampling, analyzing, and recording the results.
If many or all of a permit's requirements apply to a process unit, assign the process unit to the permit. The software will then identify all the requirements as potentially applicable for the process unit when you set up an applicability analysis. If only some of the requirements apply to a process unit, assign the process unit and those requirements to a common compliance category. During your applicability analysis for a process unit, you can evaluate the permitted requirements along with other rules to determine if they are applicable. For more information on how the software selects potentially applicable rules, refer to Understanding Rule Selection for a Compliance Scenario.
The following work flow outlines the steps you should follow to establish permit requirements and manage them using the Compliance Manager module.
On the Rules form, enter a permit requirement profile.
In the Details section, click the Permit Requirement Profiles option.
In the Requirements section, enter the requirements that must be met to comply with the permit.
On the Requirement Citation Information form, establish tasks that describe what you must do to maintain compliance with each requirement. Optionally, assign compliance categories to requirements.
On the Permit form, set up your operating permit. In the Requirement Profiles section, select one or more permit requirement profiles.
On the Process Units form, assign one of the following:
In the Permits section, assign the permits that apply to the process unit, or
In the Compliance Categories section, assign the compliance categories that apply to the process unit.
On the Compliance Scenario form, evaluate the permit requirement profiles to determine which requirements apply to a specific process unit.
Set up permit requirement profiles on the Rules form. A permit requirement profile defines the requirements that you have developed to comply with an operating permit.
Because the Rules form is also used to enter regulations and policies, many of the sections and fields are not applicable to entering profile requirements and can be ignored. However, a permit requirement profile name and promulgation date are required. This date indicates when the requirements under the permit became effective and allows you to manage changes to your permitted requirements over time. In addition, you must indicate that you are establishing a permit requirement profile in the Details section. Click the Permit Requirement Profile option to specify the type. In the Requirements section, enter the various requirements that will demonstrate compliance with the permit. You can organize requirements under a specific type, such as monitoring or recordkeeping.
Once your requirement profiles have been established, associate the requirement profiles with the appropriate operating permits in the Requirement Profiles section on the Permits form or in the Details section on the Rules form.
To set up requirement profiles
for a permit
Tip: When accessing the Rules
form from the Permits form, begin
with step 3.
Click Data
Entry > Rule Information > Rules in the Navigation
Tree.
The Rules list appears.
Click the New
button.
The Rules form is displayed.
Type the name of the permit requirement profile in the Rule field.
Select the name of the Governing
Body from the list.
If the applicable governing body is not listed, click the Ellipsis
button and add it.
Enter the date the rule became effective in the Promulgation Date field, or click the Calendar button and select the date.
Enter the Last Update Date or click the Calendar button and select it.
Expand the Details section when necessary and click the Permit Requirement Profiles option.
Add other profile information in
the Details section, as well
as the Media, Preamble,
and Definitions sections.
If your operating permits have been established, assign the applicable
permits in the Details section.
Otherwise, define the association in the Requirement
Profiles section on the Permits
form.
Click the Save
button on the form to establish the rule.
The Applicability Criteria,
Requirements, Tasks,
and History sections are displayed
below the Definitions section.
Add profile information in the Applicability Criteria, Requirements,
Tasks, and History
sections.
Enter the requirements that must be met to comply with your operating
permit in the Requirements
section. Define tasks and compliance categories for a requirement
by clicking Assign Compliance Categories
and Tasks to open the Requirement
Citation Information form.
Click the Save button on the form.
Repeat steps 2 through 11 to add other permit requirement profiles.
In the Requirements section on the Rules form, manage requirements for a permit that define what you need to do to comply with the permit. Each requirement must be assigned an effective date that when combined with the following requirement information, can help you with your applicability analyses:
Specify requirement types, such as monitoring, to categorize your requirements.
If a requirement, such as reporting, is to be performed at specific intervals, document its frequency.
Indicate whether a requirement only applies to certain process units that store, process, or otherwise use a certain pollutant material.
The Requirement Citation Information form (accessed via the Requirements section) is used to enter requirements. Reference a specific section in your permit documentation for each requirement.
After you have defined a requirement for a permit, you can establish tasks that describe what you must do to maintain compliance with the requirement. For example, if a requirement is to perform chemical testing at an outfall, you could establish tasks that describe obtaining the sample for testing, packaging and shipping the sample to the lab, performing the analysis, and recording the results. If the permit includes many requirements that apply to various process units or types of process units, you can focus the applicability analysis by assigning compliance categories for the requirements. To define tasks and assign compliance categories for a requirement, click Assign Compliance Categories and Tasks to open the Requirement Citation Information form.
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