Written by Sarah Langeliers, Senior Engineer in BBJ Group's EHS Regulatory Compliance Practice
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If you are building a facility or adding new equipment to an existing facility and there is potential for pollutants to enter the atmosphere, you may need an air permit. It’s difficult to come up with a “how to” for air permit applications when there are over 130 state and local air permitting agencies in the U.S.¹, and each agency has its own regulations, requirements and forms. However, there are certain steps to the permitting process that hold true no matter where you are.
When clients contact me regarding an air permit application, the number one question I receive is, “How long will this take?” (The number 2 question is, “How much will this cost?” But that’s a story for another day.) Timeframes vary widely based on source status and regulatory requirements, but whether the answer is two months or two years, the following process will help keep the application on track and facilitate timely application submittal and permit receipt.
Compile a list of all equipment and processes planned for your facility that have the potential to emit air pollutants to the atmosphere. Many agencies refer to these equipment and processes as emission units. For example, equipment that combusts fuel (such as boilers, furnaces and back-up generators) has the potential to emit air pollutants. Process examples include spray painting, sand blasting, gasoline dispensing or rock crushing.
Once your list is complete, compare it against your local agency’s list of exempt activities. This will allow you to set aside emission sources that don’t need to be included in Step 2. But you still want to have this equipment documented in your notes to show that it was evaluated against air quality regulations.
Once emissions sources have been identified, you need to calculate the potential to emit (PTE) for each pollutant associated with the source. Potential emissions are not the emissions your facility actually generates on a daily basis; they are emissions your facility could potentially generate when operating at maximum capacity. For a boiler, this would mean 24/7 operation at full-fire.
There are many resources available for emissions calculations. Many state and local agencies have tools, and the Environmental Protection Agency (EPA) publishes AP-42, a compilation of air emissions factors. Equipment manufacturers may also be able to provide emissions data. Depending on the complexity of your source and emission units, it may be more practical to engage the help of the agency or a consultant for this step.
Now that you have the PTE for each air pollutant, the results can be compared to the appropriate emissions thresholds for your local permitting agency. And based on this comparison, you’ll be able to classify the source. The naming convention for source types and the corresponding application requirements vary from agency to agency, but generally speaking there are three categories: true minor, synthetic minor, and major.
True minor sources have emissions below major source thresholds without limiting production or operations. Synthetic minor sources achieve emissions below major source thresholds through the implementation of enforceable limits, such as hours reductions. Major sources have emissions above major source thresholds regardless of whether or not limits are in place.
It is important to note that major source thresholds are typically 100 tons per year for each criteria air pollutant and 25 tons per year for combined HAPs; however, local attainment status with the National Ambient Air Quality Standards (NAAQS) can result in lower thresholds. For example, the Chicago area NOx and VOC thresholds will likely be lowered soon as a result of the ozone severe non-attainment designation. But once again, that’s a conversation for another day.
So now you have your emission units list, your PTE calculations and your source classification. Time to complete the appropriate air permit application. Applications vary widely across agencies, so a good starting point is the local air district website. Most have all application forms available online, and some permitting agencies even allow sources to apply online, although this benefit is typically restricted to minor sources.
As with every other aspect of air permitting, application requirements vary. However, you can count on the following requirements to be present:
There may be additional requirements such as control technology analyses or dispersion modeling depending on the size of the source and other local regulatory requirements.
Speaking of complete, the purpose of an air permit application is to give the agency enough information about your equipment, processes and emissions to write a permit that enables you to comply with all applicable regulations. The agency cannot do this if your application is not complete. In order to receive your permit in a timely manner, it is critical to give the agency an application package that contains all elements specified in the application form. In addition, many agencies have a regulatory issuance clock that doesn’t start ticking until an application has been deemed administratively and/or technically complete. Therefore, be sure to read the application carefully and include all requested information, especially if you’re in a hurry to get that equipment up and running.
Communicate with the agency while you are developing an application. Communicate with the permit writer once your application is assigned. If you are using a consultant, communicate with your consultant throughout the process. As with application completeness, I can’t stress this enough. If you have questions regarding application requirements, don’t hesitate to ask. Agency personnel and consultants are there to help. And remember: Communication goes both ways. If the agency requests more information, try to respond in a timely manner. A successful permitting process is the product of all parties working together towards a common goal.
Did you notice all 5 steps start with C? Hopefully this will help make them memorable.
Air permit applications range from simple to extremely complex, so there’s no way to cover all aspects in a single blog. However, you can listen to the recently held webinar (or download the slide deck) that discusses this topic in detail.