by Mark Cramer, PE
As an environmental consultant who specializes in assisting industrial clients with air permitting services, I get several calls per year from environmental compliance managers along the lines of the following:
- – Management desires to add a new process/modify an existing process/add new equipment.
- – The unit(s) have already been purchased and will be delivered to the site next week/month/real soon.
- – I need to make sure we have any permits we need and are in compliance with all environmental regulations ASAP!
This starts the process of frantically gathering as much information as possible in order to determine if regulated air pollutants will be emitted and if the facility may need an air permit. Technical questions are posed, and the industry compliance contact must then go back to his/her team to compile the information. This takes time. Once answered, the new information often raises new questions, and details eventually must come together to identify:
- – Does the new process/modification/equipment emit regulated air pollutants?
- – If so, what quantities (potential and anticipated actual)?
- – Do existing regulatory exemptions apply that alleviate the need to obtain an air permit?
Just evaluating emissions often takes one to four weeks. If an air permit is required, development of the application may take two to six weeks for a simple application, or maybe as long as two to three months for a complicated application. Once submitted, agencies desire at least three months to review an air permit application prior to issuing an air permit to construct. Construction may not begin until receipt of a permit to construct. This places evaluation of whether or not an air permit is required and the application process on the critical path. A general recommendation is that companies should start this air permitting evaluation at least six months before desired construction is to begin.
The following characteristics of a project are indicators that regulated air pollutants may be emitted that require evaluation:
- – A fuel (or anything else) will be burned.
- – Organic solvents and/or coatings will be used.
- – The process has vents/stacks that vent outside.
- – The process produces dust.
- – The project has a control device, including dust collectors (e.g., baghouse, filters, etc.).
I often hear things like, “our project will have a dust collector, so the emissions will be no big deal.” That may be the case, but determination of whether or not a permit modification is required often depends on the estimated potential, uncontrolled emissions. We then go down a path of trying to determine what the uncontrolled emissions would be, starting with why was the particular dust collector selected/how was it sized? This often results in, “that is the dust collector the vendor recommended for this unit we purchased.” That answer does not meet the requirements for an air permit application or getting an agency to agree an air permit is not required, and a quantified estimate will need to be developed.
How We Can Help
EI Can Help Best if Enlisted Early in the Planning Process. We are available to work with you and your project team to evaluate projects for the potential to emit regulated air pollutants and determine air permitting requirements, preferable during the early design stage. We have air quality engineers and scientists with expertise in all aspects of air quality assessment and permitting. We can 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 ranges the full array from State construction and operating permits for minor sources to Title V and PSD major source permitting.
Should you have questions regarding air permitting or other environmental concerns, please contact Mark Cramer, PE at (919) 623-1833 or firstname.lastname@example.org.