Understanding Your Air Permit
Air permits can be overwhelming to read and understand. A facility’s air permit may include various applicable regulations, stack testing, preventative plan preparations, record keeping, reporting and other requirements. It can be easy to miss a requirement if you do not fully comprehend a permit’s limits and conditions. This article is intended to help you understand the different sections of your facility’s air permit and how to maintain compliance.
The first section of the permit will give an overview of the facility. Typically this includes the facility name, location, type of industry, issuance/expiration dates and a list of air emission units that are regulated at the facility.
General Conditions and Source Operation Conditions
This section of the permit provides the general responsibilities and duties that are applicable on a facility-wide basis and are typically applicable to all permitted facilities within the state. This section will generally include information about the terms of the permit including conditions for its modification, revocation and renewal. This section also includes permitting and enforcement authority, 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 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
Additionally, this section may 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 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 Operation Conditions
The main section of the permit details the specific standards and limitations for the facility’s 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
- Testing Requirements
- Preventative Maintenance Plans
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 compliance conditions, which can include:
- Stack testing
- Parametric monitoring
- Record keeping and reporting
It is critical 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.
Attachments- Federal Rule Requirements and Other Operating Conditions
A 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.
Technical Support Document (TSD)
Some states include a technical support document (TSD) as a part of their permit package. The TSD provides a detailed analysis of all the potentially applicable regulations and requirements and the emissions calculations. The TSD provides an explanation on why the conditions that are placed in the permit are applicable. The TSD is not an enforceable document. The TSD is extremely helpful to a permittee if they are confused about a permit condition.