MasterMold, LLC makes component parts for manufacturers of recreational vehicles, utility equipment, and agricultural equipment who use the components in their end products. Because of the wide variety of industries and customers it serves, MasterMold must be poised to respond to its customers’ growth by increasing production levels on demand.
Executive Vice President Jon Butts manages environmental compliance at three production facilities. “Environmental management is just one of the many hats I wear,” says Butts. MasterMold has multiple environmental needs. Permitting is high on Butts’ list, and so is passing routine inspections.
To help MasterMold meet its environmental compliance needs, the SCS Engineers team assessed the company’s air permitting needs with an eye toward future increases in customer demand. The team helped turn around a permit application quickly so MasterMold could continue to meet its customers’ production expectations without interruption and remain compliant with environmental rules and regulations. Butts stated:
Then SCS Engineers helped me collect and organize data for emission calculations in one place. They created an easy-to-use tool that my staff updates monthly so we’re prepared for an on-site inspection anytime. I can demonstrate compliance, pass inspections quickly, and get back to focusing on my customers.
Butts got the opportunity to test the new tool during the company’s latest inspections. MasterMold has undergone routine inspections by the Wisconsin Department of Natural Resources (WDNR) and the U.S. Environmental Protection Agency (USEPA). Both agencies checked the company’s compliance status with its air permit at its largest plants. “I had everything organized right at my fingertips,” Butts says. “I was ready for the inspections. I now know exactly where all of our emissions come from and exactly how they change over time.”
Thanks to the tool SCS Engineers helped me build, MasterMold passed its latest inspections in just a few hours with no citations. I’m confident I will pass on-site inspections and gain and grow inspectors’ trust in MasterMold’s business practices. Now I’m in a position to influence the process, take proactive steps, and partner with my inspector instead of responding reactively.
—Jon Butts, Executive Vice President, MasterMold, LLC | Johnson Creek, WI
Article by Cheryl Moran, CHMM
Technological advances in traditional printing and the advent of digital printing can make it more challenging to know when you need an air permit and which permit is best for your operations.
There are two main activities that may trigger air permitting – construction and operation; each of these comes with its own permitting requirements. Always check to see if you are required to apply for a construction permit before bringing new equipment on site. Once a source is installed, an operating permit will be necessary, which is the focus of this article.
Federal Title V operating permits (also referred to as Part 70 permits) are required for any facility that is considered a “major source” of air pollution. For purposes of operating permits only, a major source is a facility that has the potential to emit (PTE) more than 100 tons per year (tpy) of any criteria pollutant; volatile organic compounds (VOC), carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter less than 10 microns (PM10), or more than 10 tons of any individual hazardous air pollutant (HAP) or more than 25 tpy of combined HAPs . Permitting thresholds are lower for facilities located in non-attainment areas.
Some facilities take limits on material throughputs, hours of operation, or emissions in order to artificially lower their PTE to qualify for a Federally Enforceable State Operating Permit (FESOP). These permits are also called “synthetic minor” permits.
Facilities that do not exceed federal permitting thresholds may still need to acquire a state operating permit. State permitting programs have more options than ever before and several states are summarized below.
All “emission units” are required to secure an air permit, or register with the Illinois EPA, even very small sources of air pollution. An “emission unit” is any piece of equipment located at an emission source that has a potential to emit air pollution. Registration of Smaller Sources (ROSS) is for operations that emit less than 5 tpy of combined criteria pollutants. Sources with a potential to emit more than 5 tpy, but whose emissions are less than the threshold for a FESOP, may qualify for a “life-time” operating permit.
Visit for more information on the Illinois EPA permitting program.
ROP Type A Registration Permit is for facilities with actual emissions of less than 25 tpy for criteria pollutants and 6.25 tons per year for HAPs.
ROP Type B Registration Permit is for facilities with actual emissions of less than 50 tpy for criteria pollutants and 12.5 tpy for HAPs.
ROP C Registration Permit for Printers is only available to printers. To qualify for this permit, emissions of each criteria pollutant are limited to 25 tons per year, and HAPs are limited to 12.5 tons per year.
General Operation Permit (GOP) for Printers applies to digital, screen, lithographic web printing (both heatset and coldset), and lithographic sheetfed printing.
Source Specific Operating Agreement for Surface Coating or Graphic Arts Operations is available to printers with total VOC and HAPs that do not exceed 15 lb/day (7 lb/day in select counties).
Permit by Rule may be used for facilities that qualify for an operating agreement with criteria pollutant and HAP emissions that do not exceed 20% of the major source limits.
Find more on the Indiana permit options at http://www.in.gov/idem/airquality.
Whether you are applying for a state operating permit, or a federal operating permit, all applications will go through your state environmental regulatory agency.
 For construction permitting purposes, the thresholds that define a “major source” are typically higher than the operating permit thresholds.
Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.
Ann O’Brien is a Project Manager with SCS Engineers. During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
This is the third and final article in a series of our interview with representatives from the U.S. Environmental Protection Agency (EPA), Mary Wesling and Robert Lucas, both of whom have extensive experience with Risk Management Plan – RMP implementation and enforcement. The interview continues the discussion of recognized and generally accepted good engineering practices – RAGAGEPs, Process Safety Management – PSM, and EPA resources for help.
Jake Tilley is part of the SCS Tracer Environmental team of RETA certified professionals who work with clients in food service and industrial food and beverage processing.