Air Permitting 101 – What and Why

This week’s article is going to be very short as last week was a short week for us. Today’s topic, similar to last week's on stormwater, tends to draw confusion for many young consultants and those in industry. What makes this an even more complicated subject is every state has its own versions of the regulations and there are even different regulations based on industry type.

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The state of Minnesota does a good job summarizing today’s topic in very basic terms. The first part of below, slightly modified, comes from their Pollution Control Agency’s website.

The Environmental Protection Agency (EPA) also has a handout called “The Plain English Guide to the Clean Air Act – EPA” which gives a good explanation on where all this stems from and why, Clean Air Act (CAA).

What is an air permit?

Any facility that emits air pollutants above certain levels is required to have an air quality permit.?Another way of saying this is that any activity that produces any form of emissions may require an air permit: dip tank fumes, furnace exhaust, diesel generator exhaust, vapors from a tank farm, painting, sandblasting, etc. Air permits are legally binding documents that include enforceable limits on air emissions, which the owner/operator must comply with. Some permits are general, covering similar types of facilities, for example, smaller sand and gravel operations; some are individual, covering a specific facility, such as a power plant.

Permits specify how facilities must operate pollution control equipment, the pollutant limits they must meet, how to monitor, and how to report their emissions. Permits are designed to protect human health and the environment by limiting pollution, and so our air quality remains within state and federal standards.

How do permits protect health?

Air permits limit the amount of air pollution allowed from a “stationary source.” To clarify, this means something like a paint booth, a blasting booth, furnace stack, etc. Federal law does not allow the owner/operator to build or modify a stationary source unless they can demonstrate the project will not cause or contribute to a violation of the National Ambient Air Quality Standards, which are developed to be protective of public health. Furthermore, in most cases, owners/operators must provide public notice of their proposed projects. Air permits are enforceable documents.

How you can get involved in air permitting?

All federal or state permits for major air emissions sources have a public comment period, during which anyone can submit written comments on the proposed permits; however, there are smaller more general permits that do not require public notice as long as an owner/operator complies with a set of a prescribed set of criteria. In other cases, the public may request a public hearing to discuss the issuance of a particular permit.

Simplified process:

• Emission source identified
• Facility determination of the type of air permit [Permit by Rule (PBR), New Source Review (NSR), Title V, etc.]
• Prepare administrative and all other additional forms that are required to be submitted to the State/EPA for review/approval
• As needed, complete process flow diagrams for the operation that is requesting air permit approval
• As needed, draft site-specific diagrams of facility
• Calculate short term and longer-term emissions from the facility
• Correspondence with agency(ies) to gain approval on air quality permit
• Public Notice (Not always required)
• ?Signs may be required to be posted at each entrance of a facility
• Professional Survey to assist with air permitting process (rare)
• Attorney fees for additional negotiations with the public if required

Generally, from start to finish for a single small source, these take from 30-90 days. However, complicated facility-wide permits, e.g., new powerplant or refinery, or a major single source falling under Title V can take considerably longer. What that means, is until one has their permit issued, no activities utilizing the source can be used.

For a complete listing of archived blogs and compliance insights, click here. Past blogs cover training requirements, clarification on additional confusing elements within the above rules, and much more.

We are here to help solve your compliance questions and challenges. Need some compliance assistance, or just have a question? Please email John K. Carroll III ([email protected]) Associate Managing Director – Compliance Services or call at +1 281-320-9796.

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