Most industrial facilities have some type of air permit, ranging in complexity from small sources to Title V major sources. These permits spell out general and specific requirements for continued compliance with air quality regulations, including emission limits, emission testing, maintenance and inspection of air pollution control devices, monitoring source/control device operating parameters, recordkeeping, submittal of emissions inventories, and permit renewals.
Regulatory agencies inspect industrial facilities on a routine basis (often annually). For example, the North Carolina Department of Environment and Natural Resources (DENR), Division of Air Quality (DAQ) completes between 1,000 and 1,100 full compliance evaluations each year. Violations identified during these inspections range in severity, from minor violations for deficiencies resulting in little or no harm, not committed willfully or intentionally and often representing a first offense, to serious violations with significant potential for environmental or public health harm, including willful/intentional infractions, sometimes with prior history, resulting in penalties, fines, and even imprisonment.
Permittees often make the mistake of thinking the work is over once they obtain their permit.
Although some violations are specific to an individual limit or regulation applicable to an industry type (e.g., ESHAP/MACT), there are some common mistakes/oversights to avoid that result in violations throughout the regulated community. Failure to meet recordkeeping and reporting requirements continues to be a prevalent issue for facilities throughout United States. Facility operators and managers often tell inspectors, “We are doing the monitoring and or/inspections, but our guys just forgot to record the results.” As a general rule in the regulatory community, if it is not documented, it did not happen, particularly when it is spelled out in a permit condition that the records must be kept. Construction and operation of new equipment, modifications, and facility expansions that involve sources of regulated pollutants that were not identified as needing a permit/permit modification is also a frequent issue. Late submittals of test reports and protocols is another common violation. Failed source tests make up a minority of violations.
An experienced and qualified air permitting consultant can facilitate understanding and compliance.
Permittees often make the mistake of thinking the work is over once they obtain their permit to construct/operate, file the permit, and do not take the time to read and understand the conditions carefully. Permits are typically issued with a period of time to review to understand and concur on conditions before the conditions become final. It is the responsibility of the permittee to make sure he/she fully understands the conditions. An experienced and qualified air permitting consultant can facilitate understanding and compliance. Such a qualified professional can also be helpful in negotiation of permit conditions that streamline compliance efforts and ensure desired operating flexibility, while protecting the environment.
The EI Group can assist permittees with the following services:
- Identifying sources and characterizing emissions;
- Developing permit applications;
- Air dispersion modeling and air quality impacts analyses;
- Evaluating, selecting, and specifying air pollution controls;
- Negotiating favorable permit conditions;
- Incorporating maintenance, inspection, and recordkeeping requirements into facility Preventative Maintenance (PM) protocol/schedule;
- Emissions inventories and permit renewals.
Please contact Mark Cramer, P.E. at mcramer@ei1.com or (919) 459-5229 if you have questions regarding air permitting.