Installation of new equipment or the purchase of a previously owned business may require an air construction permit from your state. Each state is different in what is required in a permit application. The turnaround times vary, but you can expect a 30 to 90 day wait on the permit, depending on how complex it is. It is best to get a professional assessment as soon as the project or property purchase is being considered.
This is only required for a major source (Greater than 100 tons emissions/year for any criteria air pollutant like particulates or VOC’s and 10 tons/year for a single Hazardous Air Pollutant (HAP) or 25 tons/year from all HAP’s included in a list of about 200 chemical compounds. An operating permit is also required for a PSD (prevention of significant deterioration) permit.
States require emission inventories of certain size sources on a regular basis. An emission inventory is a summation of all facility emissions during a calendar year. Some states require annual emission inventories. Others, like Iowa, require annual inventories from a major source and tri-annual inventories from minor sources. Each state has their own forms or online process for submission. Very small sources often do not have to submit an inventory.
Facilities that have construction or operating permits are often required to track their emissions, usually a rolling 12-month basis. This requires some monthly measurements such as fuel usage or chemical product purchases – typically a facility can count emissions using purchased inventory rather than actual inventory use. Purchased inventory is much easier to use.
Currently, there are 135 National Emission Standards for Hazardous Air Pollutants (NESHAP) The list can be found here. Each NESHAP has specific compliance requirements, often with required management practices, measurements, and reporting. NESHAP requirements will be included in any facility construction or operating permits. However, if a new NESHAP is established or one is revised during the permit duration, it is up to the facility to know that and revise any permits accordingly.
Facilities using Class I or Class II CFC/HCFC’s are required to use EPA certified technicians to service equipment using these substances. Facilities are wise to have their own specific refrigerant management plans to assure proper leak reporting, documentation on equipment removal and disposal, and verification of technician qualifications.