One of the easiest ways for an EPA or state inspector to find violations is to compare your current operating equipment and emissions with the permitted equipment and emissions. If you do not keep your Air Quality Permit up to date, you run the risk of an inspector finding serious violations – which come with serious monetary fines. This applies to your facility whether your permit is a Title V, Synthetic Minor, or even True Minor operating permit.
If you operate under a Title V Air Quality Permit, you are required to renew your permit every 5 years, and likely have an annual inspection conducted by the EPA or state. With these measures in place, chances are your Air Quality Permit is staying up to date. However, anytime your facility installs new operating equipment or removes/decommissions old operating equipment you should reassess your air emissions.
While adding new equipment or increasing emissions will usually trigger a new air permit modification, there are some exceptions. Most states have minimum emission thresholds that the modification must exceed to trigger an Air Quality Permit modification; below these thresholds, the requirements depend on your State. For some you only need to maintain calculations showing emissions are below said thresholds, but for others, the State may require submission for them to verify no permit update is required.
If your facility removes or decommissions any previously permitted equipment, it can be beneficial to recalculate your facility’s total air emissions without that operating equipment. For Title V facilities, it is possible that without the old operating equipment the facility’s emissions drop below Title V permit limits, your facility can apply for a True Minor permit. Under certain circumstances, it may make sense to take limits with the reduction in operating equipment to apply for a Synthetic Minor permit instead. Transitioning to either a True Minor or Synthetic Minor permit would come with reduced recordkeeping requirements, reduced inspections, and reduced annual fees.
If you operate under a Synthetic Minor or True Minor operating permit, you might be only required to update your Air Quality Permit when your facility either adds new operating equipment or modifies the existing process in such a way that would increase air emissions, such as changing paints to a new paint with greater volatile organic compounds (VOCs) or hazardous air pollutants (HAPs). Without a required renewal time period and reduced/infrequent site inspections, it can be easy to neglect updating your Air Quality Permit.
To ensure your Air Quality Permit is fully covering your facility, periodically ask yourself these questions:
- When was the last time we updated our Air Quality Permit?
- Have we added any new operating equipment that could potentially increase our air emissions?
- Have we changed process materials that could potentially increase our air emissions?
- Have we added any new process control devices (baghouse, dust collector, etc.)?
- When was the last time our facility was inspected?
By asking these questions, you can ensure the facility’s Air Quality Permit stay up to date and reduce the risk of an inspector finding permit violations.
The best way to ensure your Air Quality Permit fully covers your facility is to have an inspection from a qualified individual familiar with the process, Air Quality Permit, and air quality regulations. An inspection from a qualified third-party individual can ensure there are no gaps in the facility’s air permitting. This can save the facility from costly enforcement actions, as it is better to self-report compliance deviations rather than let them be discovered by the EPA or state inspections.
If any deviations from the Air Quality Permit are found, an Air Quality Permit review can determine whether the increased emissions from the deviations can be exempted or if the facility needs to proceed with an air quality modification application.
Conversion Technology Inc. (CTI) has decades of experience in air compliance with the EPA and state environmental divisions. If you believe your facility requires an Air Quality Permit review to assess the coverage of the current Air Quality Permit or would like assistance in preparing an application for adding or removing operating equipment, CTI would be happy to assist in the process. For more information regarding air permit requirements or an Air Quality Permit review, please contact us at (770) 263-6330 or cti@conversiontechnology.com.