New Air Permitting Regulations May Impact Your 2013 Permit Renewal

There are several new state and federal air quality regulations potentially applicable to your operations which may need to be identified in your air permit renewal application. These new air regulations are likely not identified in your current air permit because they were finalized after your operating permit was issued. In particular, the EPA mandated NESHAP rule imposes work process standards on certain existing combustion sources and emissions limits on new sources for most engine owners who are a part of a peak shaving program or use their engines as part of their business operation to limit hazardous air pollutants (HAPs).

Some of the new federal air quality regulatory requirements that may need to be addressed in your permit renewal application include:

U.S. EPA’s Internal Combustion Engine NESHAP Rule – Stationary reciprocating internal combustion engines (RICE), such as emergency generators or diesel fire pumps, are subject to new operation and maintenance standards (e.g., annual oil/filter changes) effective in 2013. Large, non-emergency engines (e.g., rock crusher or water pump engines) or certain large emergency generators that participate in demand response programs are also subject to new emissions standards and may be required to be retrofitted with catalyst systems.

U.S. EPA’s Boiler NESHAP Rule – Existing oil-fired, biomass and coal-fired boilers are required to undergo routine “tune-ups” to minimize carbon monoxide (CO) emissions effective 2014. Larger boilers must also undergo a one-time energy assessment that evaluates the efficiency of the boiler and related steam/hot water systems. Facilities with these types of boilers are subject to initial notification, work practice, and recordkeeping requirements effective 2014.

Other recent state and federal air quality regulatory requirements that may need to be addressed in your permit renewal application include:

U.S. EPA Greenhouse Gas (GHG) Reporting and Permitting Rules – Effective 2011, air permit applicants have been required to include GHG emissions (i.e., CO2, methane, nitrous oxide and certain fluorinated compounds) in permit applications. The federal mandatory greenhouse gas reporting program (40 CFR Part 98) requires that certain sources with large GHG emissions must report their annual emissions to EPA. The federal “Tailoring Rule” also requires large GHG sources to obtain air construction permits prior to making facility modifications.

PA’s Adhesive VOC Regulation – Effective January 1, 2012, PA DEP’s new adhesive and sealer regulation (25 PA Code 129.77) applies to many facilities using adhesives or sealers in manufacturing operations. The regulation limits the volatile organic compound (VOC) content of certain adhesives and imposes new recordkeeping and monitoring requirements.

If you have questions about your air permit, the preparation of GHG inventories and GHG management systems, or compliance management systems, please contact Gavin Biebuyck, Principal, Air Quality Services at 610.375.9301.