Due to lowered regulatory thresholds, a wide
variety of facilities can now require air emissions permits. These
include:
- Printing operations
- Auto body shops
- Asphalt plants
- Industrial facilities with boilers
- Incinerators
- Landfills
- Industrial facilities with air pollution
control equipment
- Certain types of construction projects
- Facilities with diesel engines and/or emergency
generators
- Construction Processing Equipment used at
multiple sites
Any time a new facility is to be built, or if
additional equipment is to be placed at this service, it should be
determined whether or not an air emissions permit is needed. A number of
years ago, permitting thresholds were high, but, currently, due to
incursions of National Ambient Air Quality Standards, in many localities,
some types of facilities emitting as few as several pounds per day of
particulates (dust) or volatile organics, require air emissions permits.
If permit applications are not filed in a timely manner, construction can
be stopped and fines can be levied.
How complicated are air permit applications?
The complexity of air permit applications depends
directly on the type of air emissions source being permitted. Some types
of permit applications are relatively simple, for example, those for small
paint booths, or, those for low horsepower diesel generator engines. Other
permit applications can be more complicated, particularly for new
facilities with multiple sources, or for existing facilities undergoing
major changes in equipment, or equipment replacements. Regulations which
need to be complied with are both on the federal and state level, and need
to take into account one or more of the following programs:
- Pennsylvania Air Regulations
- EPA Air Regulations
- Prevention of Significant Deterioration Program
- New Source Performance Standards, BAT and/or SOTA requirements
- Title V Permit Requirements
- Requirements for Emissions Offsets, when in a National Ambient Air
Quality Standard non-attainment area, for certain emissions
parameters.
How long does it take for permit applications to
be processed and approved?
In addition to taking a matter of weeks or months
to prepare most air permit applications, regulatory agency processing and
approval times are variable, depending principally on the number of
programs and/or regulations under which the permit will need to be issued,
and depending on whether the facility is or is not a major source, and the
complexity of an industrial plant and/or a number of sources or permit
modifications involved.
Another factor is whether or not the emissions
contain Hazardous Air Pollutants (HAPs).
These are certain pollutants which are specially regulated. Where HAPs are
present, maximum achievable Control Technology may be required. Generally,
it takes 90 to 120 days for processing and approval of the most
straightforward permit applications. Where there are complex air sources,
or where there may be public involvement, permitting can take from six
months to a year. Air permit applications should be prepared well in
advance of any specific needs to install new equipment, or upgrade
existing equipment.
RT Experience
RT’s Staff has experience in a wide variety of
air permitting situations, from small sources with particulate filters, to
larger sources, involving Title V permits, and even including those
requiring Prevention of Significant Deterioration permit approvals.
Facilities at which our staff has experience include sludge incineration,
asphalt plant emissions permitting, food production, dyeing products
manufacturing, remediation systems air emissions, paint booth and air
emissions and large scale mobile equipment painting/manufacturing.
