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You have identified equipment and processes at your facility that are sources of air pollution, and submitted applications for these sources to Ohio EPA or your local air agency. Now that you have received your air permit, have you met all your regulatory requirements under Ohio EPA’s air program? Not exactly.
Your air permit is your written authorization from Ohio EPA (or local air agency) to install and operate equipment or conduct activities that release pollutants into the air. Your permit includes all conditions and requirements to operate your air pollution source in accordance with state and federal air quality requirements. This article will help you understand common air permit requirements and steps you can take to improve your compliance.
Your air permit combines your specific requirements for installing, operating, monitoring, recordkeeping, and reporting into one document. Be familiar with your permit and consider it a “living document,” to keep updated. Once you receive your final permit, highlight your requirements and note specific tasks required. If you don’t understand something in your permit, you can contact Ohio EPA’s Division of Air Pollution Control, your local air agency, or the Ohio EPA’s confidential compliance assistance program for assistance.
The Applicable Emissions Limitations and/or Control Requirements section of your air permit outlines your facility’s specific requirements. While each air permit is different, some common requirements are summarized below:
Limits or restrictions on the way a piece of equipment operates. For example, a permit may specify a maximum number of hours that a piece of equipment can operate or may require specific conditions to operate.
Limits the maximum amount of air pollutant that can be emitted. Emission limits can be source-specific or can apply facility-wide.
Requires specific activities to demonstrate compliance with specific permit requirements. This can include requirements for pressure drop readings, visible emission checks, etc.
Specific information and records to demonstrate compliance with permit requirements. Recordkeeping can be associated with specific emission units or can be facility-wide. It can include such items as inspections, material usage logs, maintenance records, etc.
Specific information and records that are required to be provided to Ohio EPA or the local air agency. Most permits require annual reporting, but more frequent reporting may be required.
Emission limits and operational restrictions are typically based on rules; your permit will identify the applicable rules and requirements. Reading the rules referenced in your permit will provide you information about a specific air permit requirement.
Your permit may identify the specific tasks that must be performed to demonstrate compliance. For example, a permit that limits the number of gallons of coating applied daily may require that the facility maintain a daily coating usage log to demonstrate compliance. Determine how your facility will meet the compliance requirements and who is responsible for each task. Many facilities find that creating a list of requirements and outlining specific tasks to comply with these requirements is helpful.
It is important that appropriate staff are aware of your facility’s permit requirements, especially those involved with the equipment or process that is permitted. For example, if your permit restricts the number of hours equipment can operate, it is important that the operators are aware of this. If your permit requires specific monitoring, it is essential that staff conducting the monitoring are properly trained on how to operate the monitoring equipment and collect adequate data. Also, ensure all new staff are trained on your facility’s requirements to maintain compliance with your permit.
Inadequate recordkeeping and reporting is a common violation of an air permit. Establish a system to identify, assign and track your permit requirements. Review your records along with other aspects of your permit, making sure you meet each specific requirement and you have the appropriate documentation. If you have multiple air permits, it may be helpful to organize your permits and compliance records together. Some facilities develop spreadsheets or tracking forms, while other may use more sophisticated tools, such as an environmental management system or environmental compliance tracking software. Never underestimate the importance of good recordkeeping as a key component of complying with your permit.
Understanding how to comply with your air permit can be confusing. However, not understanding the conditions and requirements of your air permit can lead to violations. If you need more help, contact Ohio EPA’s Office of Compliance Assistance and Pollution Prevention for free and confidential technical assistance at (800) 329-7518.
Incorporating your air permit into your daily operations is an effective way to maintain compliance.
Division of Environmental and Financial Assistance
Compliance Assistance Hotline: (800) 329-7518
Funding: (614) 644-2798 ~ Fax: (614) 644-3687 ~ Contact Us
Compliance: (614) 644-3469 ~ Fax: (614) 644-2807 ~ Contact Us
Mailing Address: P.O. Box 1049, Columbus, OH 43216-1049
Street Address: 50 West Town Street, Suite 700, Columbus, OH 43215
Report a Spill, Release or Environmental Crime
(800) 282-9378 or (614) 224-0946
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