HOMESERVICES ABOUT US CONTACT Air Permitting & Regulatory Compliance Home > Services > Air Permitting Air Permitting & Compliance Services Since 1995, GT has provided air permitting and compliance services to industry and government. These services include air quality modeling, emission inventories, regulatory evaluations, permit negotiations, and enforcement support. We strongly advocate for our clients’ interests to exceed their goals and expectations. We have the sophistication to work with Fortune 500 companies and the cost-effectiveness to work with small businesses. Our Services Title V Permitting Prevention of Significant Deterioration (PSD) Permitting Non-Attainment New Source Review (NNSR) Permitting Minor Source Permitting Air Quality/Air Dispersion Modeling Air Emission Inventories Greenhouse Gas Monitoring Plans & Reporting Risk Management Plans (112r) Startup, Shutdown & Malfunction Plans RACT/BACT/LAER Studies NSPS/NESHAP/MACT Regulatory Assessments Enforcement Support Permit Negotiations Quarterly, Semi-Annual & Annual Compliance Reporting Refrigerant Management Plans Stack Test Programs Facility Inspections & Audits Expert Testimony INDUSTRIES WE SERVE Air Permitting Assessments Many air contaminant sources (emission units) are required to obtain installation or construction permits prior to commencing construction. GT routinely conducts air permitting assessments to assist clients with evaluating whether emission units are exempt from permitting and, if not, what type of air permit is required. Many states offer an extensive list of emission unit activities that are exempt from air permitting requirements. Many of these air permitting exemptions are based on the basic description of the emission unit while others may require de minimis emission calculations to ascertain whether the source is exempt from permitting. Many states offer Permit-by-Rule (PBR) exemptions, Director Exemptions and General Permits to simplify the permitting process and to expedite permit issuance. Emission units that are not exempt from permitting and are located at non-major facilities are required to obtain an installation permit or construction permit sometimes referred to as a Permit-to-Install (PTI) or Permit-to-Install and Operate (PTIO) prior to commencing construction. Some states have a two-step air permitting process that require facilities to apply for a PTI, then later after operation has commenced, to apply for a Permit-to-Operate (PTO). Normally, PTIs remain in effect for the duration of the air contaminant source or until it is modified. Typically, PTOs and PTIOs must be renewed on a 5 or 10-year cycle. Emission units that are not exempt from permitting and are located at major facilities are required to obtain an installation permit or construction permit prior to commencing construction. Major facilities or Major Stationary Sources are facilities with the potential-to-emit (PTE) greater than or equal to 100 tons/yr of a regulated air pollutant; 10 tons/yr of any individual hazardous air pollutant (HAP); or 25 tons/yr of all combined HAPs. Major facilities are also required to obtain a Title V operating permit. Title V operating permits contain the permit terms and conditions for all significant and insignificant emissions units at a major facility. Title V operating permits must be renewed every 5-years. Explore our Air Permitting & Compliance Services Facility-Wide Air Emissions Inventory All facilities regardless of their size should maintain an up to date facility-wide air emissions inventory. Facility-wide air emissions inventories should include detailed uncontrolled and controlled PTE calculations on a lbs/hr and tons/yr basis. Facility-wide air emission inventories help facilities track their major source status. Major facilities or major stationary sources are required to obtain a Title V operating permit and may also be required to evaluate Major New Source Review (Major NSR) permitting requirements such as the Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NNSR) when modifying existing emission units and/or adding new emission units. Facility-wide air emission inventories are also helpful when preparing air permit applications and when preparing air fee emission reports. Air Permit Applications PSD & NNSR Permitting Requirements Air Quality Modeling RACT/BAT/BACT/LAER Studies Air Regulatory Assessments Title V Permitting Air Permit Reports Permit Negotiations Enforcement Support Expert Testimony Stack Testing Programs Greenhouse Gas Reporting Rule GT routinely assists clients with preparing Greenhouse Gas (GHG) reports under the Greenhouse Gas Reporting Rule found in 40 CFR 98. The following facilities must submit annual Greenhouse Gas (GHG) reports regardless of their actual annual CO2e emissions: Electricity generation Petrochemical production Adipic acid production Petroleum refineries Aluminum production Phosphoric acid production Ammonia manufacturing Silicon carbide production Cement production Soda ash production HCFC-22 production Titanium dioxide production HFC-23 destruction processes Municipal solid waste landfills Lime manufacturing Manure management systems Nitric acid production The following facilities must submit annual GHG reports if the facility emits more than 25,000 metric tons of CO2e: Ferroalloy production Lead production Glass production Pulp and paper manufacturing Hydrogen production Zinc production Iron and steel production Suppliers that provide products listed below must submit annual GHG reports: Coal-to-liquids suppliers Industrial GHG suppliers Petroleum product suppliers Carbon dioxide suppliers Natural gas and natural gas liquids suppliers All other facilities that emit greater than 25,000 metric tons of CO2e and have aggregate maximum rated heat input capacity of stationary fuel combustion units at the facility greater than 30 MMBtu/hr must submit annual GHG reports. CO2e emissions must be calculated following the procedures outlined in the rule. Annual GHG reports are due by March 31st of each year and must be submitted through US EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) available through US EPA’s Central Data Exchange (CDX) electronic reporting website. Risk Management Plans In response to the 1984 Bhopal, India methyl isocyanate chemical accident that killed over 2,200 people, Congress incorporated Section 112(r) into the 1990 Clean Air Act Amendments requiring US EPA to develop regulations that prevent and facilitate emergency response to chemical accidents at facilities that use certain hazardous substances. The Chemical Accident Prevention Provisions which included the Risk Management Plan requirements were published in the Federal Register on June 20, 1996. The federal Chemical Accident Prevention Provisions can be found in 40 CFR 68 and Ohio’s Chemical Accident Prevention Provisions can be found in OAC Rule 3745-104. The RMP program contains a list of 77 acutely toxic chemicals with thresholds ranging from 500 – 20,000 pounds and 63 flammable gases and volatile flammable liquids with thresholds of 10,000 pounds. An owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must submit a Risk Management Plan (RMP). There are three degrees of plan complexity identified as Program 1, 2 and 3 with program 1 being the least complex and 3 being the most complex. To qualify for a Program 1 plan, the facility must meet each of the following criteria: 1. The process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following: (a) death; (b) injury; or (c) response or restoration activities for an exposure of an environmental receptor. The distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations. To qualify for a Program 2 plan, the facility does not meet the criteria of a Program 1 or 3 Plan. To qualify for a Program 3 plan, either of the following criteria is met: The process is in NAICS code 32211, 32411, 32511,325181, 325188, 325192, 325199, 325211, 325311, or 32532; or The process is subject to the OSHA Process Safety Management Standard found in 29 CFR 1910.119. Program 1 plans must include the following: Executive Summary as required by 40 CFR 68.155 Registration as required by 40 CFR 160 Offsite consequence analysis as required by 40 CFR 68.165 5-year accident history as required by 40 CFR 68.168 Certification as required by 40 CFR 68.185 Emergency response program and exercises as required by 40 CFR 68.180 Program 2 plans must include the following: Executive Summary as required by 40 CFR 68.155 Registration as required by 40 CFR 160 Offsite consequence analysis as required by 40 CFR 68.165 5-year accident history as required by 40 CFR 68.168 Certification as required by 40 CFR 68.185 Emergency response program and exercises as required by 40 CFR 68.180 Prevention program as required by 40 CFR 68.170 Program 3 plans must include the following: Executive Summary as required by 40 CFR 68.155 Registration as required by 40 CFR 160 Offsite consequence analysis as required by 40 CFR 68.165 5-year accident history as required by 40 CFR 68.168 Certification as required by 40 CFR 68.185 Emergency response program and exercises as required by 40 CFR 68.180 Prevention program as required by 40 CFR 68.175 RMP must be reviewed, updated and submitted at least every 5 years. RMP must be submitted electronically to US EPA’s RMP*eSubmit available through US EPA’s Central Data Exchange (CDX) electronic reporting website and a hardcopy or electronic copy on compact disk must also be sent to Ohio EPA. Contact GT if you need assistance with preparing, reviewing or updating your RMP. GT Environmental Provides Facility Plans, Compliance Assessments and Audits Startup, Shutdown and Malfunction Plans (SSMP) 40 CFR 63.6(e)(3) requires facilities subject to a Maximum Achievable Control Technology (MACT) standard to prepare a Startup, Shutdown and Malfunction Plan (SSMP). The SSMP must describe, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The purpose of the SSMP is to: (1) ensure that, at all times, regulated process(es) including air pollution control and monitoring equipment are operated and maintained in a manner to minimize emissions and (2) ensure that the facility is prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize emissions. Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Under the SSMP, the facility must maintain records that indicate whether the actions taken during each startup, shutdown or malfunction event were consistent with the SSMP. If the records indicate the actions taken were inconsistent with the SSMP then the facility must notify the agency either verbally or in writing within 2 working days and must submit a letter report within 7 working days in accordance with §63.10(d)(5). The facility is not required to submit the SSMP to the agency but must make the plan available at all times for review and copying by the agency. The facility may update the SSMP without prior approval from the agency. The facility must retain copies of all versions of the SSMP for a period of at least 5 years. Upon written request, the facility must provide a copy of the SSMP to the agency. Refrigerant Management Rule Compliance Due Diligence/Environmental Inspections & Audits GT Environmental Can Help Your Organization Find out how our team can assist your facility by completing our contact form and our professionals will answer your questions and put together a plan to achieve your goals. 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