A bulletin produced by Nebraska Department of Environmental Quality's
Air Quality Division
Nebraska Department of Environmental Quality
April 2009
Ask the AQ Lady: Temporary Shutdown Requirements

Dear Air Quality Lady:

Due to crazy fluctuations in ethanol demand, our ethanol plant is going to shut down temporarily. We expect the shutdown to be only for a few months. Do we have to do anything special or send any reports to NDEQ?

Dear Ethanol or Bust:

If you are planning to shut down your facility temporarily, we recommend you send us a notification. Be sure to include the circumstances for the shutdown and the approximate length of time you expect the shutdown to continue.

You will need to maintain your equipment during the shutdown to ensure that the equipment is kept in working condition. Keep a maintenance log and periodically inspect the equipment. Perform maintenance in accordance with the manufacturer’s instructions, especially for equipment that will be idle for a length of time.

Even though you are shutting down temporarily, you must still comply with all of the terms of your permit or any other requirements of Title 129 – Nebraska Air Quality Regulations, especially if you want to begin operating again. This includes keeping and maintaining records and submitting all required reports. If you have been issued an operating permit this includes your certification of compliance reports and deviation reports. If the Department requests an emission inventory from you, you must submit one, even if you report zero emissions. If you have not applied for an operating permit, be sure to meet timely submittal requirements for doing so in accordance with Title 129.

We request that once you plan to begin operating again, you let us know by submitting a notification. Note that any excess emissions due to the startup or shutdown of the equipment will also need to be reported (per Title 129 Chapter 35).

Taking these types of actions described above demonstrates that the intent of the shutdown was temporary and helps to assure compliance with all permits and regulatory requirements.

There are many scenarios involving shutting down a facility. Each scenario is unique and will be evaluated on a case-by-case basis, but, at a minimum you should follow the guidance provided above. If a facility is considering a shutdown, they should contact the NDEQ Air Quality Division at (402) 471-2189 and to discuss their particular scenario. Additionally, we’ve only covered the air quality requirements, so be sure to consult with the other NDEQ programs to see what they require.

Have a burning question? Send it to the Air Quality Lady at Melissa.ellis@nebraska.gov.

For more information, contact

Nebraska Department of Environmental Quality
1200 "N" Street, Suite 400
P.O. Box 98922
Lincoln, Nebraska 68509
(402) 471-2186 FAX (402) 471-2909