by Mark Cramer, PE
Most project design/build teams planning new construction or modifications to existing facilities involving sources of air emission understand that these actions require an air permit prior to starting construction. It is also well known that the emissions, air quality evaluations, and application process should start early, as air permitting is typically on a critical path which can impact scheduling. If you find yourself as the lucky delegate responsible for air permitting and arrive at the point of receiving the glorious prize of the long-awaited air permit, finally releasing your team to begin construction, CONGRATULATIONS! You have been victorious, but now what?
Once an air permit is finally received for a project, permittees are often inclined to breathe a sigh of relief and think, “Finally! I am glad that is over and we can begin construction.” However, agencies (and consultants) warn permittees not to just shelf the permit and move forward, but to “READ THE PERMIT CAREFULLY.” Air permits contain legally binding limitations, recordkeeping, and reporting requirements, and it is possible that such documents may contain errors. It is advisable to not only closely check the permit for errors and ensure there are no big surprises, but to also make sure you (the permittee) understand what is required to be in compliance and have a plan to perform the stipulated recordkeeping and reporting.
There is also usually room for negotiation of permit conditions at the time the agency issues a draft and prior to finalization. The permittee need not accept the first draft, but may have an opportunity to propose elimination and/or streamlining some permit conditions. Sometimes, in an honest effort to ensure they are issuing a permit that rigorously maintains the State Implementation Plan (SIP) and stands up to Environmental Protection Agency (EPA) scrutiny, agencies propose multiple, complex emission limits, monitoring, and recordkeeping requirements when simpler means could demonstrate compliance.
Examples of streamlining permit conditions that can simplify efforts for the facility to demonstrate compliance include:
- Calculation and recording emissions of multiple pollutants monthly and tracking on 12-month rolling periods can sometimes be covered by throughput limits on fuels or process materials and tracking these instead.
- When control devices, such as thermal oxidizers are used, proposed limits with recordkeeping for pollutant emissions may be eliminated in favor of monitoring and recording control device parameters (e.g., temperature).
- Limits for individual sources or groups of sources can sometimes be combined/streamlined into facility-wide caps that are simpler to track and easier to comply with.
One manufacturing facility was issued a permit which burdened management with the need to track throughputs of various coating types, inks, and solvents for individual process lines, as well as then calculate monthly and track:
- Uncontrolled throughput of Volatile Organic Compounds (VOCs) and Hazardous Air Pollutants (HAPs), hourly, monthly, and 12-month rolling period;
- Controlled emission of Volatile Organic Compounds (VOCs) and Hazardous Air Pollutants (HAPs), hourly, monthly, and 12-month rolling period;
- Monthly average VOC contents (lb VOC/gallon) for three different coating/ink types; and
- Regenerative Thermal Oxidizer (RTO) operating temperature.
Many facilities with similar control devices can demonstrate that proper operation of the control device alone maintains compliance with all the limits and eliminates the need for all the tracking and calculating, thereby reducing the potential for violations for missing records/reporting. It behooves the permittee to at least ask the question and attempt to streamline conditions to simplify the required ongoing compliance efforts.
Another manufacturing facility was issued a permit including permit conditions requiring both fuel limits and recordkeeping, as well as criteria pollutant emission calculations and monthly/12-month rolling period tracking. One of the permitted sources was a large industrial boiler, capable of firing distillate oil, residual oil, and natural gas. Permit limits for this boiler included a limit for use of residual oil/distillate oil combined, and both hourly and annual emissions limits for criteria pollutants, coupled with other permit conditions to record these emissions monthly and by 12-month rolling period. The emissions factors used in the permit application were the basis for the hourly emissions limits, and the annual residual oil/distillate limit guaranteed compliance with the annual pollutant limits. Therefore, the hourly and annual criteria pollutant limits and all the associated tracking and calculating were duplicative and unnecessary. Recording and tracking the residual oil/distillate oil use to ensure the facility maintains this below the consumption limit should suffice. This same permit contained similarly duplicative emissions limits and tracking requirements for a large diesel generator with a 250,000 gallon/year diesel limit, where tracking the diesel use alone should suffice without the need to calculate and track emissions.
The work is not done when the air permit is issued. It is the responsibility of the permittee to comply with all aspects of the final permit. This requires a good understanding of what is in the permit, followed by rigorous adherence to record the parameters identified for recordkeeping and submit reports on the prescribed schedule.
How Can We Help?
The EI Group, Inc. (EI) employs a team of air quality engineers and scientists with expertise in all aspects of air quality assessment, identification and quantification of regulated pollutants, development of emission control strategies, selection and/or engineering design of air pollution control equipment, regulatory permitting, and demonstration of permit compliance. We can assist in evaluation of projects to conduct air permit applicability assessments and determine if air permitting is required, and if so, what type of permit. If a permit is not required, EI can prepare the documentation citing the exemptions. If air permitting is required, our air permitting expertise spans the full array from State construction and operating permits for minor sources to Title V and PSD major source permitting. We have substantial experience negotiating permit conditions that maximize operating flexibility for our clients, while providing for compliance with regulations and protection of human health and the environment. EI can also assist with recordkeeping and reporting following issuance of the final permit.
If you have questions regarding air permitting or other environmental concerns, please contact Mark Cramer, PE, Senior Engineer with EI, at (919) 459-5229 or firstname.lastname@example.org.