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Permitting for Small Sources of Air Emissions: Know Your Options

Sources of Air Emissions

Even if your facility is a small source of air emissions, you may still need an air permit or authorization depending on your state or local air permitting authority. When dealing with permitting, you often need to consider not only the amount of air emissions your operations generate, but the amount your operations could generate. Each state or local air permitting authority has different statutes or rules that govern what is required of small sources of air emissions.

Changing Standards

Additionally, these statutes and rules often change. For example, due to recent changes to Minnesota state permitting rules, some small sources that were previously regulated by permit no longer require a permit or pay emissions fees. The Minnesota Pollution Control Agency (MPCA) now has additional categories of “conditionally exempt sources” that include auto-body refinishing, coating, woodworking, concrete manufacturing, and gasoline service stations. These types of sources are still subject to technical standards, but the standards are designed to be simpler and easier to follow than a permit. They also allow sources to avoid the paperwork and cost of an air permit. The MPCA site has additional information on this new option.

Similarly, at the federal level, policy changes within the last few years affect what emissions standards may apply to existing sources that emit a class of pollutants called hazardous air pollutants (HAPs). This change has also allowed some small sources to no longer require air permits or to qualify for less complicated air permits. The former policy, commonly known as the “once in, always in” policy, authorized that once a source was a major source of HAPs, it must always be a major source of HAPs, and therefore require a Title V permit. Under the revised interpretation, sources that lower their emissions or take limits below certain levels are no longer required to be major sources and may no longer require a Title V permit.

Permitting Options

The recent rule modifications mean that for small sources like auto-body repair shops, wood-working operations, or miscellaneous coating operations, knowing the right type of permit or authorization for your business may not be so simple. Our consultants can help you determine if you need an air permit and make sure that you are taking advantage of any changes that offer regulatory relief.

Don’t forget — even as a small source, you may be subject to hazardous waste, tank, or spill prevention requirements depending on the chemicals you use and store on site.  Braun Intertec has expert environmental consulting professionals that can help you navigate these regulatory programs so that you have all the proper environmental permits, plans, and licenses in place.

Learn more about the air permitting process in our recent blog posts “Air Permits: Breaking Down the Decision Process” and “How to Determine the Right Air Permitting Mechanism for your Facility”

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