Recently, I have seen several air permitting pitfalls. These things happen, whether in Indiana, Illinois, Kentucky, Michigan, Wisconsin, Ohio, or beyond. I have permitted throughout the US and these things aren’t isolated to one area. I thought it best to share some of these. Many people think that once a permit is established, they don’t have to do anything but what they THINK that the permit says (emission limits, monitor, maintenance, records, and reports). However, an air permit is and should be treated as a breathing document. In order to stay in those permit limits, you have to stay on top of ALL changes at your site that MAY affect the air permit. Here are a few examples:
Coatings and Formulation Changes – This includes painting, cleaning, undercoating, foams, fiberglass, or any physical or chemical constituent of a product. Typically, there are multiple suppliers needed to manufacture a product and not all of them notify you when their product formulations change. So, when one does (or you change manufacturers), it is important to verify that the “new” product used emits more particulate matter, volatile organic compounds, OR hazardous air pollutants than the worst case formulation that you have listed in your permit calculations and emission limits. As long as it’s below limits IN ALL 3 POLLUTANTS, nothing is required. Where the best environmental managers miss it is with PM in spraying applications. They instinctively look at VOCs & HAPs, but overlook the PM. Unless you are staying on top of these changes which happen often, you could have a deviation and not even know it if that product exceeds ONE number.
Material Changes – Aside from the above, other raw material changes CAN affect an air permit also. Engineering, Quality, Purchasing, and Production people are masters at trying to find a cheaper, better product that will pass product integrity tests or state/federal certification requirements. However, they aren’t always the best at keeping the environmental guy in the loop. Communication, coincidently, is the root of many problems in your company, not just those issues that are environmentally-related. But, if a specification calls for a certain metal in an ASTM standard then 10 years later it changes, now that material may have higher lead (Pb) or manganese (Mn) levels. When you melt, form, or prep that material now, you may have higher HAP levels that requires a permit modification.
Another example of material changes affecting air permits is engineers switching from metal to fiberglass. The ‘glass’ worked great for the application, but they have to sand and cut it first. This added a particulate matter emission unit that previously just slapped the piece into place and screwed it in.