By Paul D. Hansen, P.E.
As a responsible manufacturer, your work is never done. Work stoppages and penalties aren’t an option. Only pure and simple regulatory compliance will do.
Constantly questioning your Title V and Prevention of Significant Deterioration (PSD) obligations can keep you dancing in uncertainty when you should be working. But in the real world, projects shift, and every expansion or upgrade to a current project threatens your current existing permitting strategy. When it comes to air pollution compliance, where do we begin? How can we give ourselves the best chance at a smooth project all the way to completion?
As an ENR top 200 environmental firm, PPM Consultants can guide your project through the best and smoothest path toward compliance by helping you to fully grasp your Title V and PSD prevention obligations. To prevent costly and time consuming improvisation later on, you’ll need to accurately anticipate a project’s direction among many other factors.
Here are just a few ways in which to gauge your appropriate air permitting requirements moving forward.
Conduct an Accurate Emission Inventory
Though it may sound obvious, the best place to start is usually at the beginning. It’s hard to know where you’re going if you don’t know where you already are. For air quality permitting, the beginning is a comprehensive emission inventory.
As the foundation for all air permitting, your emission inventory will tell you what regulations apply to your facility. Is your facility already a major source of hazardous air pollutants (HAPs)? Where do stand with regard to Title V and PSD thresholds? An accurate emission inventory (key word being “accurate” here) will inform multiple aspects of your project moving forward.
Without an accurate emission inventory at the start, you risk something of a cascade failure in which an easily corrected problem is made even worse. In the long run, operating without this knowledge can easily cost you time, money, opportunity, and a whole heap of anxiety.
Don’t “Juggle” Permits
Typically, a PSD permitting project can take 6 months to a year (or more) to complete. For this reason, some facilities sitting at the edge of a potential PSD applicable project may continue taking operational or emissions limits to avoid time and expense. Some facilities may even take limits just to avoid the added regulatory and reporting requirements that come with being a major source of HAPs.
The biggest problem with “juggling” permits is that it will eventually catch up to a facility if it continues to expand. As the old saying goes, it’s unwise to “rob Peter to pay Paul.” Otherwise, your facility may find itself stuck with complex and inflexible permits.
If a facility has been taking strict limits as it continues to grow, there’s always a chance that it could exceed the permit limits and commit a violation. At that point, facilities can expect not only enforcement action, but also a forced permitting process under extra state, local, and even EPA scrutiny.
Hire a Trusted Consulting Firm
Environmental regulations are constantly shifting. Keeping track of your Title V and PSD prevention regulations can often feel like building a heavy structure on a bit of shoreline.
When considering a PSD applicable project, PPM can assist in determining if “anti-PSD” limits are the right move by providing insight on the potential implications. PPM will familiarize itself with the facility, its capabilities, and any future plans to help make the best determination possible.
PPM’s experienced professionals come from a wide range of backgrounds, including industry, government, and industry service providers. This allows PPM to provide a recommendation that has been viewed in multiple lenses and, in most cases, is based on experience with other clients of a similar nature.
From emissions inventories, to permitting, to air dispersion modeling, PPM can help your facility through complete compliance support. When the stakes are this high, why wonder about regulations when you can hire someone who knows?
Right Permit, Bright Future
Regulatory uncertainty is not a necessary state. PPM Consultants can learn everything there is to know about your facility and Title V/PSD Prevention permitting project and can use this information to make a completely informed recommendation. To start at the beginning, you might consider starting by calling PPM Consultants today.
PPM Consultants knows PSD and Title V from A to Z
Like other regulations, proper air permitting may seem daunting when all it really requires is a steady, informed, and capable guiding hand. To start your PSD prevention project off right, or to understand more about Title V requirements, call PPM Consultants at 1-800-945-4834 or visit us online here. You don’t have to untangle regulatory language by yourself. PPM is here to translate existing law into actionable steps.