We encounter many questions when it comes to air: What might one mean when they say air? Is your air a potential concern for your employees? Is your air a concern for the environment? Are your processes or daily activities at your facility emitting contaminants into the air? Are you emitting too much contamination into the air?
Air means many things to many people – it surrounds us all; we need it to survive but it can also make us sick. From an environmental perspective, “air help” can mean vapor encroachment or fence line monitoring. From a permitting and compliance perspective, air help can mean something as minor as a claimed permit by rule (PBR – a permit not requiring registration here in Texas), to a registration-required PBR, to a New Source Review (NSR) permit, to a full-blown Title V permit. From a safety or industrial hygiene perspective, air help revolves around employee exposures to contaminants or hazards in the form of indoor air quality, personal monitoring, confined space atmosphere monitoring, or a handful of other services.
Much of the time, the assistance required depends on the goal of the project: what you are trying to address such as meeting a regulation’s requirements or developing a safety program, or what you are prevent from happening such as an air emissions accidental release to the environment or an employee death from hazardous vapors. Further, if you have a new piece of equipment or a new process, you might need to determine if you need air permitting to document and control emissions into the environment and legally operate the equipment and then you might also need see if a the new activities are exposing your employees to harmful levels of contaminants. The issue is that there is not one decision tree or pathway to determine the type of air permitting required or assessment that is needed. However, air permitting and industrial hygiene assessments often overlap.
Industrial Hygiene Assessments
From an industrial hygiene (IH) perspective, the need for an assessment often stems from an employee complaint or observation but there are also standards that require periodic monitoring or providing proof that your activities meet certain employee protective levels of contaminants. An example may be an employee who smells an odd odor. This odor may be from a chemical they or using or it could be something that was brought into the work area, such as new carpet or furniture. This issue may either be addressed my industrial hygiene personal exposure monitoring or an indoor air quality assessment.
We complete many indoor air quality assessments that derive from employee observations. Most of the time, these complaints do not make it to OSHA but are informal observations. Indoor air quality assessments typically address an uncomfortable environment (temperature, excess humidity, odor, ventilation, etc.) or complaints of headaches, problems breathing, or other “minor” symptoms (we completed an assessment several years ago prompted by client employees raising a concern about cooling tower chemicals and mist causing them hair loss).
We were recently contacted by a client with an employee complaint about the dust at his facility causing breathing problems. Our consultants worked closely with the client to ensure that we fully understood the situation and ultimate project goals and had all the information necessary to determine the appropriate testing and analysis that would meet the client’s needs and determine what limits or action levels our consultants would need to compare the results to. The direction of the project changed several times and required consultation with TCEQ and OSHA representatives before we could nail down a scope.
IH assessments can be built around one of the many OSHA standards, complaints, (and in some cases, insurance requirements), and can often be designed based on a quick conversation but does require consideration of multiple factors, including number of employees, types of activities being completed and the controls in place, and a review of applicable Safety Data Sheets (SDSs).
On the air permitting side, owners and operators of emission sources (present at most industrial facilities) must comply with all applicable air quality regulations. Between NSR, Title V, PTE, registration, permits, de minimis, PSD, non-attainment, major, synthetic minor, true minor, state rules, federal rules, and more, each authorization mechanism, governed by a variety of regulatory statues, has specific compliance, technical, operational, emission and/or control requirements. Also, as is the case with chemical facilities and coating operations (just to name a few, for example), more than one regulatory statute can apply in addition to authorization.
As dizzying as all this sounds, the root of all air quality programs is who, what, where, and how much. Whether you are looking to modify operations by increasing production, adding new equipment, or are in the early stages of discussing construction of a new facility, an air permitting authorization is likely needed before any construction begins. The ultimate question, “how much?” will determine which authorization mechanism is right for your specific situation.
This is the point where finding the right environmental consultant can be of great assistance. In addition to helping you understand regulatory applicability, Braun Intertec has a reputable track record of assisting clients with their permitting needs and tailoring them to match their business goals. Are you looking for maximum flexibility? Maybe you are willing to sacrifice flexibility for an authorization with less reporting and compliance requirements? Whatever your goals are, our consultants can take goals into account and provide you with options that not only meet the regulatory requirements and provide you with the required authorization, but position you in an optimal place for sustainable compliance.
Before you reach out to an environmental consultant, or if you’re feeling confident and decide to DIY it, some fundamental information is needed to help facilitate the initial conversation and information is needed to make a decision on the right air pathway for your facility and operations.
Join us with several of our in-house experts, Sally Perry, Conan Read and Nick Foreman on May 27 for a live webinar, Navigating the Invisible World of Air: Exposure Assessments to Permitting. We will discuss the various types of environmental permitting and compliance and industrial hygiene related air projects that might apply to your facility and what type of information you will want to have at your disposal for each.
Nick Foreman Group Manager, Permitting & Compliance – Safety and IH Services
P: E: [email protected]