Do I have to certify compliance with a construction permit if the unit did not operate during the TVACC Reporting Period?
If the construction permit has been incorporated into the TV permit as listed in number three above, you will need to certify with the TV and the construction permit. 5. Some regulations exempt facilities from complying with opacity limits during periods of startup and shutdown. Why do opacity excursions during these exempt periods have to be listed as deviations in the TVACC and would these excursions be classified as intermittent or continuous compliance? These excursions are excused for bona fide startup and shutdown events. Startup and shutdown are finite periods that must be confirmed as such by the Department. The Department does not document such activities and they must be listed as deviations. Since the opacity standard does not apply during bona fide startup and shutdown events, you could check that the source was in continuous compliance with the opacity standards.
