CONTROLLING THE AIR QUALITY IN YOUR FACILITY: Meeting Permitting and Recordkeeping Requirements

State and local regulations govern the permissible levels of certain emissions. Those requirements dictate when a facility owner needs a permit. Permits and registrations are legal documents that facility owners and operators must follow. Air permitting requirements are largely dictated by environmental laws (rather than workplace safety laws). Federal, state and local agencies may each have different types of permits or registrations, based either on the potential and actual emissions emitted by a facility or on the capacity of certain equipment (e.g. the amount of kW for a generator or MMBTU/hr for a boiler).

An air facility registration is a type of certificate usually applicable to smaller facilities, where contaminants emitted or equipment used are at levels that do not exceed thresholds requiring a permit. Typically, a registration to the authorities having jurisdiction is not an extensive document to produce. It may require completing a couple of pages with information about the facility and the controls in place.

A permit on the other hand, is typically a more complex application. This comprehensive document describes the regulatory requirements that apply to a facility and the methods that the facility is using to demonstrate compliance with those requirements. It might require more detailed emission calculations, descriptions of process controls and a detailed compliance plan.

Permitting requirements may be dictated by the type of equipment in use. For example, in New York City, a boiler operating at over 4.2 million BTUs/hr may require one type of permit. A boiler under that threshold may require a different type of permit or a registration. In a similar vein, a non-emergency generator larger than 450 kW may require a permit. A generator below that level may require only a registration. A permit covers every potential hazard in a facility.

TYPES OF PERMITS YOU MAY NEED

Companies may be required to submit multiple permits, if their operations and emissions trigger different requirements at the federal, state and local levels. For example, a facility operating in New York City may have four types of permits to pursue.

These include:

  • USEPA Title V Permit: The 1990 Clean Air Act amendments set forth the requirement that major industrial sources of air pollutants must obtain operating permits. These permits detail for each covered facility all the applicable emission control requirements. Implementation of these requirements affects more than 15,000 industrial sources of air emissions, as well as state and local air pollution control agencies.
  • State Air Permit or Registration: States may develop unique requirements and procedures tailored for their air quality needs, as long as the program is at least as stringent as USEPA’s requirements. The NYSDEC has one such program.
  • Local air permit: The NYCDEP requires that industrial facilities have a permit due to various categories of exhaust. Other municipalities in the State may not require the same level of permitting. However, businesses in New York City may need a state permit in addition to their city permit.
  • Other applicable permits: Companies performing certain types of work in a building (for example work that puts holes through the roof, walls, etc.), will generally require a building department permit. A fire department permit may also be required if work involves, for instance, the use of flammable chemicals.

REPORTING AND RENEWING

To maintain compliance with a permit, companies may need to perform some level of reporting on a quarterly, semi-annual or annual basis. This reporting may include either submitting an actual reporting document to the authorities having jurisdiction or simply generating the data and maintaining it on site for a certain number of years. Permits typically must be renewed every three to ten years, so it is important to have this information on hand.

This ongoing reporting can also help keep air quality and, consequently, workers’ health and safety front of mind at a facility. By working with a partner with air quality expertise who assists in strategically planning for accurate testing, successful controls, and regular reporting, organizations can focus on the manufacturing work that they do best.

Click here to download our full Air Quality Guide: Controlling the Air Quality in Your Facility: What You Need to Know About Your Regulatory Requirements and Options for Compliance.

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