Permitting Finishers Under the Clean Air Act Amendments

Increased demand for environmental protection and worker safety has placed a significant burden on more than 5,000 electroplating and surface finishing facilities nationwide. They must maintain regulatory compliance while remaining competitive. At the forefront of the incredible mass of federal and state regulations are the 1990 Clean Air Act Amendments (CAAA). Due to the nature of the business, anodizers and electroplaters (especially those using hexavalent chromium) have been and will continue to be targeted as contributors to toxic air emissions. With the CAAA, companies are forced to evaluate their emissions to determine their facility's air quality status under Title V. Many facilities that were exempt from permitting in the past or were considered Minor Sources are now required to obtain new air quality permits. This is due to newly established Hazardous Air Pollutants (HAPs) or changes in state regulations.

It is essential that you correctly prepare a permit application. These eight fundamental steps will help you permit your finishing facility accurately and completely.

AIR QUALITY PERMITTING PROCESS

1. Identify Emissions Sources.
Evaluate your facility for all possible air emission sources: plating, anodizing, painting, fuel-burning equipment. This includes less obvious sources such as solvents used in parts cleaning and other fugitive emissions not emitted from a specific stack or vent. Determine if any planned activity will generate any new sources or modify existing sources.

2. Quantify Emissions.
Determine actual and potential emissions from each source using material balance calculations, source testing data, accepted emission factors, manufacturers' documentation, representative testing data from similar processes or other methods accepted by your state. Do not use estimates or assumptions, if possible. Your state will require supporting information to confirm these estimates or ask you to perform source testing.

3. Review Regulations.
Obtain a copy of the air quality regulations for your state. Review any applicable regulations to answer the following questions.

Are any sources at the facility exempt from permitting?

Do any sources have emissions limitations?

Are any sources subject to federal regulations for New Source Performance Standards (NSPS), New Source Review (NSR) requirements, Maximum Achievable Control Technology (MACT) standards or other requirements?

Are your facility's emissions large enough to require a permit? For example, in some states, emissions of VOCs less than 10 tons/year do not require a permit.

Is the facility located in a non-attainment area? Be aware that some states have VOC emission limitations more stringent than Title V, particularly for heavy industrial and vehicular traffic areas.

4. Determine Compliance Status.
There are several techniques for evaluating compliance.

Some states perform plume dispersion modeling analysis or require applicants to do so to determine concentration of certain pollutants (air toxics) at ground level. It is best to perform the analysis yourself, before the state knows of any compliance problems. Failing a plume dispersion model can be corrected sometimes by simple modifications to emissions points, such as increased stack height, increased exhaust flow rate or removal of rain caps.

By comparing emissions levels to applicable air quality regulations, you should determine if all sources of air pollution at your facility are in compliance. Sources whose emissions exceed state or federal emission limits are more difficult to correct. Pollution control equipment may need to be installed, or some change in the process may have to be made.

If any emissions sources are out of compliance and cannot be remedied easily, a compliance plan must be established. It may be necessary to work out a compliance schedule with your state. Do not blindly submit a permit application without knowing your facility's complete compliance status. You may be subject to enforcement action for every year your facility operated out of compliance.

5. Evaluate Title V Status.
In the second step, you should have calculated actual and potential emissions for each source at your facility. Potential emissions are not computed by simply scaling actual emissions at your current operating schedule to 8,760 hr/yr. Potential emissions are those emissions that would occur if a source operated on a continuous basis, at its maximum capacity and without any pollution control devices. Even if your facility has a process that is included in your current air permit but is not operated, its potential emissions must be considered when calculating potential emissions.

Your facility will be categorized as an Exempt Source if emissions are below levels that require a permit; Minor (Small) Source if actual and potential emissions are below Title V thresholds for all pollutants; Synthetic Minor (Conditional Major) if actual emissions are below Title V levels, potential emissions are over Title V levels, and the facility is willing to accept federally enforceable operating limitations to guarantee that emissions will remain below Title V thresholds; or Major Source if actual emissions are over Title V levels or the facility would be a Synthetic Minor but is unable or unwilling to accept operating limitations that will guarantee that emissions will remain below Title V levels.

6. Prepare Permit Application.
The next step is to prepare the air quality permit application. If you are a Major Source and preparing a Title V Operating Permit application, several other items are required. Depending on your situation, you may have to propose record-keeping plans, periodic or enhanced monitoring protocols and/or reporting procedures to demonstrate compliance. If you are an anodizer or chromium electroplater, you may be subject to Maximum Achievable Control Technology requirements.

7. Submit Permit Application.
If your facility is particularly complex or if emissions are precariously close to Title V levels, submit a draft permit application to your state, if allowed. This will allow the permit review engineer an opportunity to assess your facility/application and make comments or ask questions. It will also give you the opportunity to make changes to the application should any corrections be necessary. When you submit the final application, be sure to include payment for any applicable fees. Depending on the state, you may have to pay an application processing fee or construction/modification fee.

8. Make Preparations to Comply with Permit.
Depending on your situation, you may be required to perform source testing, waste sampling, recordkeeping and reporting to comply with your permit. You may also be required to pay emissions fees.

It has become nearly an impossible task for facilities to keep up with all of the environmental, health and safety requirements to achieve and maintain compliance. With Air Quality Control issues on the minds of legislators and the public, federal and state agencies are paying closer attention to the plating and surface finishing industry. Facilities must quantify their emissions, determine how they are classified under Title V and begin the permitting process.