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Environmental Permitting
Permit ApplicationsAirOn November 15, 1990, President George Bush signed into law the Clean Air Act Amendments (CAAA) of 1990, heralding a new era in clean air regulation. The amendments will go further than any previous legislation in attaining national air quality standards and controlling facilities emissions. The central mechanism for achieving the goals of the CAAA is the operating permit, required under Title V. A facility’s emissions will be regulated through such a permit, which will include all applicable control requirements. Facilities operating without a permit or in violation of permit conditions face new civil penalties. Facility owners can face criminal charges and the public can enforce permit terms through citizen suits. The law requires that each state develop a permit program that includes collection of fees to support the state’s program. The Indiana Department of Environmental Management (IDEM) has again notified Indiana Businesses that their Title V air operating permit applications will be due on June 1, 1996 for those included in the first third “call in” and December 14, 1996 for all remaining facilities. In addition, the permit process includes provisions for public participation. Facility participation and levels of permitting will vary based on location, whether it is a major source and which pollutants it emits. Permits will be issued for a set period of time and will need to be renewed before the permit term expires. Industrial Safety and Environmental Services’ team of air professionals brings a wealth of air experience to our clients and prospective clients. Our long-term air experience has been invaluable in assisting our clients with Title V Air Operating Permits, Emission Inventories, Construction Permits, Air Pollution Control Compliance Strategies and Air Compliance Assessments. ISES’ team of air professionals brings a wealth of air experience to our clients and prospective clients. Our long term air experience has been invaluable in assisting many firms in making the difficult choices that can drastically affect the way their business is conducted. In the wake of the 1990 Clean Air Act Amendments, we have been faced with a period of regulatory disarray as state agencies scrambled to put programs in place to comply with the US EPA’s “Title V” mandate. In many instances (including our home state of Indiana) we are left with old state air programs in place alongside the new Title V program. To eliminate confusion, we have prepared a short document explaining the programs and how your business might best comply. If you have not yet entered into the air program appropriate to your business, we’ll be happy to furnish you a copy of this brief explanation. We make every effort to get you into the air program that will represent the lowest cost to you in preparation and state fees, while making sure that you are in compliance. If, however, the “lowest cost” program would be restricting to your business activities, we’ll make sure you know what your options are. We’ll do a walk-through and on-site analysis of your firm with respect to air permitting at no charge; this may give you the information you need to make a decision regarding how to proceed into compliance. Emissions Inventory The first phase of the compliance audit will address the question of “where am I today?’ in terms of actual emissions and emission control requirements. ISES will accomplish this audit in the following steps: Compile a list of emission limitations and other control requirements that affect your facility. The list will address limitations and other control requirements that affect the facility. The list will address limitations or requirements imposed by federal, state and local regulations. 1. Compile a list of control equipment and control techniques in use at the facility to reduce and/or control emissions. In compiling the list, ISES will take note that these control techniques not only include process equipment but also process changes or modifications, enclosure of systems, substitution of raw materials that may result in a reduction of emissions, work practice standards, and operator controls and certification. 2. Following the compilation of steps one and two, ISES will determine the facilities compliance status with existing regulations. 3. For each regulated pollutant, ISES will provide a best estimate of the quantity of pollutants emitted under full operating capacity and “normal” capacity. These estimates (when practical) will be provided on a unit, process, and fugitive-source basis. The list of traditionally regulated pollutants (i.e., VOCs, NOx , SOx), the list of hazardous air pollutants (HAPs) contained in Title III of the CAAA, and the minimum list of 100 extremely hazardous air pollutants that EPA is required to identify will form a sound list of regulated pollutants for immediate consideration.
BACT, RACT, LAER, NESHAP, ENSR, MACT Analysis 1. ISES will perform an assessment for potential new control equipment requirements. In making this determination, ISES will utilize available data sources such as but not limited to; Control Technique Guideline (CTG) documents, and EPA’s clearinghouse for RACT, BACT, and LAER controls. 2. ISES will thoroughly review and analyze CAAA permitting requirements. The review will be conducted with the recognition that states require a compliance plan that calls for periodic certification of Markley Enterprises facility compliance with permit restrictions and conditions. There are requirements in the CAAA for permit fees, monitoring and self-reporting obligations, powers to revoke permits for cause, substantial civil penalties per day violation of permit conditions, and procedures for reopening permits under certain circumstances. 3. ISES assists our clients through the preservation of flexibility. A permit strategy should be developed that will incorporate equipment requirements and operating practices rather than specific numerical limitations. It will be important to develop a strategy that can accommodate changes within a facility subject to the new source review requirements and that contemplates and anticipates future changes in production processes, feedstocks, and products.
Air Construction and Operation Permit applications Major Source Permit Applications WaterStormwater Notice of Intent (NOI) letters National Pollutant Discharge Elimination System Permit Applications Pollution Prevention Plans Wellhead Protection Plans WasteContingency Programs These include releases to air, soil or water. In addition, the provisions of your plan must be carried out immediately in the event of fire, explosion or release of hazardous material. EPA Identification Numbers and Special Waste Permit Applications RCRA Waste Area Closures, Analysis, and Remediation Solid Waste Facility Permit Applications SARA Title III We can offer you “turnkey” service and/or the training required to get and keep you in compliance with the reporting requirements of this act. ComplianceAir and WaterCompliance Audits and Programs · Facility/Unit Compliance Status · Compliance Plan by Facility/Unit · Compliance Schedule · Source ID · Applicable Requirement Name · Applicable Requirement Citation · Emission Unit · Stack/Vents · Pollution Control Equipment · Limitations · Monitoring · Monitoring Frequency · Record Keeping · Record Keeping Frequency · Testing · Pollutants tested for · Test Method · Testing Frequency · Reporting on schedule
Scheduled or Random Mock Inspections WasteCompliance Audits and Programs Scheduled or Random Mock Inspections TestingStack Testing for VOC’s, Particulate, and Metals Stormwater and Wastewater Discharge Testing |