TRICORD Presents on the Consolidate Air Rule (CAR) at AWMA
Recently, TRICORD team members presented “What Can the Consolidate Air Rule (CAR) for SOCMI Do for You?” at the Air and Waste Management Associate (AWMA) Louisiana Section Annual Conference. Presenters Larry Poche and Kelly Jean Bradberry and a guest Speaker, Lauren Jean Rucinski from Keen Miller, discussed this little known regulation abbreviated CAR.
The presentation included hidden jewels that may just help facilities with SOCMI sources consolidate:
- Burden reduction to a typical facility.
- Clearer text and a single set of consistent requirements.
- Easier to understand requirements/leading to
fewer varying interpretations:
- By enforcement personnel, and
- By regulated entities.
- Combination of all semi-annual reports into a single semi-annual report.
- Exceedance reports for monitored parameters are submitted semiannually as opposed to after each occurrence.
Examples of CAR savings opportunities compared to referencing subparts (1) included in the presentation were:
- Relaxed Seal Gap Inspections
- CAR allows 2 extensions of 30 days versus referencing subparts allow 1 extension to empty a vessel, remove it from service and repair it or perform seal gap measurements.
- CAR does not require prior approval for the extensions versus referencing subparts do.
- CAR requires inspection records much less in-depth unless a problem is detected versus referencing subparts requires records of the condition of each tank’s component inspected.
Is your interest peaked? You can view the presentation HERE, or contact Kelly Jean Bradberry at Kelly.Bradberry@TricordConsulting.com
