August Mack Newsletter | May, 2017

Overwhelmed by Air Permits? There's more to it than You Might Think.
by Alic Bent

Air permits can be daunting. They can range from a couple of pages to hundreds of pages. Hidden within the many pages are numerous requirements, including recordkeeping, stack testing, preventative maintenance plan (PMP) preparation, and various other requirements. Many facilities could be out of compliance just from a simple lack of understanding. This article is intended to simplify your understanding of the air permit and to provide increased awareness of some of the compliance requirements.

First Section Permit: Source Summary

The titles used to describe the sections and organization of permits vary by state but in general the first section of the permit will have background information on the facility. This section does not list any requirements, but instead is intended to give an overview of the facility. Typically this includes the facility name, location information, SIC code, and a description of the types of emission units being permitted.  Sometimes included in this section is the permit identification number, and the permit issuance and expiration dates.

General Facility-Wide Conditions

The next section provides the conditions and requirements that are applicable on a facility-wide basis and in general are applicable to all permitted facilities within the state. This section will generally include information on the timeframe for submission of a renewal application, revocation, revision, amendment, and modification requirements.

Additionally, this section may include responsibilities of the permittee, pertaining to dates for reports submittal, and the completion and submittal of required plans, including:

·         Annual Compliance Reports

·         Annual Emission Statements

·         Semi-annual Reports

·         Quarterly Reports

·         Preventative Maintenance Plan

·         Emergency Reduction Plan

·         Risk Management Plan

·         Fugitive Dust Control Plan

This section may also have operational requirements including general emission limits and standards such as:

·         Opacity levels must remain under the specified level

·         Fugitive dust emissions cannot leave the property boundaries

·         Open burning is not permitted

·         Asbestos abatement requirements

This section also describes State Agency’s rights with respect to the permit, including the right to inspect and enter a facility, the right to enforce the permit, the right to terminate the permit if any portions of the permit are invalid, and the right to revoke the permit if any permit conditions are not met.

This section may also include requirements for how the permittee must comply with requirements of the permit, including stack testing, compliance monitoring, recordkeeping, and reporting, and how facilities must handle periods of noncompliance.

Emissions Unit Specific Conditions

The main section of the permit details the specific requirements for operating specifically regulated emissions units. Requirements may include, but are not limited to:

·         Emissions limitations

·         Operating conditions

·         Control device operation and maintenance

·         Compliance monitoring

·         Monitoring device conditions

·         Stack testing

·         Reporting

·         Recordkeeping

·         Preventative Maintenance Plans

This section truly includes the bulk of the permit requirements. This is where you will find standards and limitations, such as prevention of significant deterioration (PSD) limits, synthetic minor limits, BACT requirements and state specific standards that are applicable to each emission unit. It will also include all the associated conditions, such as stack testing, parametric monitoring, various inspections, record keeping and reporting, that are required to assure compliance with the emissions limits and standards. If a facility wants to remain in compliance with their permit, it is crucial to stay compliant with the conditions in this section.  Because requirements will be at different time intervals throughout the year, it is suggested that facilities develop, by themselves or with the help of a consultant, a compliance calendar.  For instance, quarterly reports may be required to be submitted on the 30th day of the month following the quarter. However, parametric monitoring may be required daily.  Keeping an air permit requirement compliance calendar is an excellent way for a facility to keep track of requirements throughout the year.

Other Operating Conditions as Attachments

One common error that facilities make is to only look at the main part of the permit, and not the attachments. There could be attachments with fugitive dust control requirements; operations, maintenance and monitoring (OM&M) plans; compliance assurance monitoring (CAM); leak detection and repair programs, and federal maximum achievable control technology (MACT) standards. Most state agencies will not list out the specific requirements of the applicable plans and federal rules in the permit. Only the references to the attachments will be provided. It is the permittee’s responsibility to look at the attachments for the applicable plans and federal regulations to determine what portions of the rules apply to the emissions unit. There could be various requirements in the applicable plans and federal regulations, including stack testing requirements, monitoring requirements, recordkeeping requirements, etc. It is crucial for a facility to look at the attachments for the applicable plans and federal regulations, or else requirements will be missed.

Alic Bent is a project engineer at August Mack Environmental, Inc. in its Indianapolis, Indiana office. He has more than ten years of experience in preparing air permit applications, storm water pollution prevention plans, air emission inventories, spill prevention, containment and countermeasure (SPCC) plans and stack testing. Alic can be reached at 317.916.3124 or via e-mail at

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