Ann O’Brien helps industrial and agricultural companies stay abreast of the regulatory information necessary to remain compliant with federal and state policies. Ann’s most recent series of articles for businesses in the printing or agricultural industries provides advice on air permits and the need for addressing the limits on visible emissions likely specified in their air permits.
Here’s what you need to know about what visible emissions are, how they’re regulated, and how to stay in compliance with your air permit. For other industries, please feel free to contact any SCS office or email us at service.scsengineers.com. We provide our professional services nationwide.
This paper, presented at A&WMA’s 111th Annual Conference details the Tier 4 process and the potential issues that have arisen from conducting a Tier 4. This paper also assesses potential Tier 4 sites, exceedance reporting, wind monitoring, additional SEM equipment requirements, penetration monitoring, notification and reporting requirements, and impacts on solid waste landfills that will use the Tier 4 SEM procedure for delaying GCCS requirements. This paper reviews the changes between the draft NSPS and the final version of the new NSPS that was promulgated.
Click to read or share the paper, and learn about the authors.
This article discusses global air quality and how the collaboration between policy-makers and the scientific community can have a continued positive impact on air quality in the U.S. This collaboration has been the primary cause for the improvements observed in air quality over the past few decades.
U.S. Environmental Protection Agency (EPA) programs, such as the New Source Performance Standards (NSPS), New Source Review, and Maximum Achievable Control Technology standards, have all had a significant impact on improving air quality by lowering the ambient concentrations of NOX, VOC, CO, SOX, and PM.
Some areas, such as southern California, have committed to working toward electrifying the transportation network, implementing more stringent standards on diesel fuel sulfur content, and encouraging heavier utilization of public transportation.
Author: SCS Engineers’ Ryan Christman, M.S., is an air quality engineer and environmental management information systems specialist with experience in the oil and gas industry and the solid waste industry. He is just one of SCS’s outstanding Young Professionals.
Article in Waste360: explains who’s impacted and how to begin managing the costs.
SCS Technical Bulletin: a digest of hundreds of EPA regulatory policy into the information and timelines to act on now.
Article: strategic financial planning to support infrastructure costs.
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“This program directly supports the county’s Roadmap to a Sustainable Waste Management Future by helping businesses to implement recycling programs,” says Leonard. “And not only recycling but waste reduction, as well, all of which, of course, contribute to reducing greenhouse gas emissions, resource management and sustainable materials management.”
…and as waste settles, it can have an effect on equipment,” according to Pat Sullivan of SCS Engineers in this ClimateWire article. As the U.S. EPA focuses on pushing landfill owners into cutting down on methane emissions some worry that a combination of tightening regulations and poor cost analysis might put some smaller landfills out of business.
LANDFILL EMISSIONS: Going to the dump? You might make electricity
Kavya Balaraman, E&E reporter
Reprinted from ClimateWire with permission from E&E Publishing, LLC. Copyright 2016.
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.
SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses:
SCS Engineers’ Tracie Onstad Bills and Leslie Lukacs were both selected to receive the California Resource Recovery Association’s (CRRA) prestigious Service Award this year. According to CRRA Executive Director, John H. Dane, the award recognizes “exceptional individual service to the organization and a contribution of time or resources beyond expectations.” That sounds like an SCSer alright.
Tracie Bills is SCS’s Sustainable Materials Management Director and is based in our Pleasanton, CA, location. She has been on the CRRA board for 10 years and has served in several leadership positions within the organization, including as its President for three years. Her expertise revolves around commercial recycling technical assistance, environmental purchasing, large venue and event zero waste programs, research and sustainability planning, garbage hauler franchise compliance and review, construction and demolition program / ordinance analysis and writing, climate inventory compilation, research and feasibility studies to help clients with comprehensive waste prevention and zero waste programs.
Leslie Lukacs serves as a Sustainable Materials Management Specialist in our Santa Rosa, CA, office. She has been on the CRRA board for 12 years and also served in a variety of leadership positions. She also founded CRRA’s Green Initiatives for Venues and Events technical council and was an instructor for CRRA’s Resource Management Certification Program for 5 years. Leslie specializes in the design and implementation of sustainable materials management and zero waste programs and is a pioneer in the greening of venues and events throughout the nation. Her extensive expertise in the logistics of zero waste, recycling, and composting programs, such as outreach management, business assistance, master planning, waste audits and characterization studies, extended producer responsibility ordinance preparation and implementation, compliance, grant writing, and administration are all key to successful long-term programs.
Both women were selected by the CRRA Board of Directors to be the 2016 recipients of the Service Award. The awards will be presented at the organization’s Annual Conference Awards Ceremony on August 9 in Sacramento.
CRRA is California’s statewide recycling association. It is the oldest and one of the largest non-profit recycling organizations in the U.S. CRRA is dedicated to achieving environmental sustainability in and beyond the state through Zero Waste strategies including product stewardship, waste prevention, reuse, recycling and composting. The organization provides its members with resources to advance local, regional and statewide waste reduction efforts which result in critical environmental and climate protection outcomes. Members represent all aspects of California’s reduce-reuse-recycle-compost economy and work for cities, counties, municipal districts, and businesses as well as hauling companies, material processors, non-profit organizations, state agencies, and allied professionals.