Ask us anything about compliance. We strive to provide you with the information you need to help you make sound compliance decisions.

 

Emissions Inventory

How do I know whether I have to prepare an emissions inventory?

Requirements for the submission of emissions inventories vary depending upon the state in which the emission units are located. Most states require submittal on an annual basis to report emissions that have been generated during the prior calendar year. Some states require an emissions inventory only when specifically requested. An emissions inventory is generally required for any site that has potential emissions equal to or greater than 100 tons per year of any criteria pollutant. Smaller amounts of hazardous air pollutants may trigger reporting requirements. Sites located in non-attainment areas are also generally subject to reporting requirements at lower emission rates.

Permits

What is the process for obtaining a permit?

While all states have similarities in permitting requirements, they all have specific forms and procedures for submitting a permit application. Each state-specific requirement must be satisfied before a permit is deemed “administratively complete”. The typical time frame for obtaining a permit is three to six months from the time an administratively complete application is submitted to the agency. The time frame for obtaining authorization is generally shortened significantly for proposed construction projects with resulting emissions below the levels that require a permit.

Why should I use Argent to help me obtain a permit?

Argent has prepared hundreds of permit applications and possesses a comprehensive understanding of overall regulatory compliance. Argent environmental consultants ensure that the owner/operator will not be burdened with any unnecessary requirements while also ensuring that no applicable requirements are overlooked. Applications are prepared accurately and completely to eliminate delays that inevitably result when regulators are forced to request additional data or clarification. Our meticulous attention to detail in the permit application and review of the draft permit has resulted in reduced costs and excellent compliance for our clients. Argent has reduced or eliminated regulatory compliance burdens for numerous clients.

Risk Management Plan

Who requires a RMP (Risk Management Plan)?

A stationary source is covered by the RMP rule if it has a process containing greater than the defined threshold quantity of a regulated substance at any time. Argent has prepared Risk Management Programs for various industries and evaluated several of the available models. We can prepare an RMP that is clear and concise and assist with implementation and training to ensure ongoing compliance.

How does the RMP relate to the Process Safety Management program?

A program level 3 RMP is required for processes subject to the OSHA PSM regulation as well as for any process classified under one of ten NAICS codes. Many elements of the PSM can be incorporated into the RMP.

How can Argent help me prepare the RMP?

Argent has prepared Risk Management Plans for various industries and evaluated several of the available models. Our environmental consulting team can prepare an RMP that is clear and concise and assist with implementation and training to ensure ongoing compliance.

Title V

What is the purpose of the Title V permit program?

The federal operating permit program codifies all of the requirements of the Clean Air Act into one enforceable document. It is through the Title V permit that provisions of the CAA will be enforced, e.g. acid rain rules, compliance assurance monitoring, air toxins, etc. The Title V permit is to be one source that contains all emission limitations, operating restrictions, operating requirements, and testing, record keeping and reporting requirements.

Who requires a Title V permit?

All major sources of air pollution must obtain an operating permit. Permits are also required for sources subject to new source performance standards, sources subject to national emissions standards for hazardous air pollutants, sources subject to the acid rain provisions, and any other source in EPA-designated categories.

What is required after I get the Title V permit?

The Title V permit program was not intended to create new regulations but instead to codify existing regulations. The Title V permit program requires detailed record keeping and reporting to verify continuous compliance. In addition to penalties that can be assessed for noncompliance, under Title V additional penalties can be assessed for not self-reporting any noncompliance

How can Argent help me with the Title V program?

Argent has prepared hundreds of Title V permit applications. We are committed to making regulatory compliance as painless as possible for our clients and we have consistently achieved this goal. Argent environmental consultants have worked with numerous state agencies in the development of Title V programs and we have successfully pursued regulatory interpretations that have resulted in simplification for owners of the permits.

Nonattainment permit

Who needs a NNSR permit?

Proposed construction of a site or modifications to an existing major site in nonattainment areas are subject to Nonattainment New Source Review (NNSR) permitting if potential emissions of the pollutant(s) for which the site is not in attainment are above the “major” threshold definition for the nonattainment area.

Can Argent help me obtain a NNSR permit?

Argent is recognized by several state agencies and numerous clients as a leader in air compliance issues. We prepare permit applications that are technically complete and thorough. Our environmental consulting team also maintains regular communications with agency personnel and stays abreast of regulatory developments. This has resulted in quick approval of permits and minimized compliance requirements for our clients.

Hazardous Air Pollutants (HAP)

Are HAPs regulated differently than other air pollutants?

EPA is mandated under Title III to identify the chemicals that have to be brought under control and the categories of major sources of these chemicals. Each source category must have Maximum Achievable Control Technology (MACT) standards developed to significantly reduce emissions of these toxic pollutants. MACT standards are implemented through National Emission Standards for Hazardous Air Pollutants (NESHAPS).

Can I avoid being subject to the MACT requirements?

To avoid MACT requirements, major sources must agree to enforceable restrictions that will keep actual emissions of HAPs below 10 tons per year of any listed pollutant and 25 tons per year of any combination of listed pollutants. This may be done by restricting hours of operation, installing control equipment, or implementing process modifications that eliminate or reduce the quantity of HAPs present. An analysis of each source should be conducted to determine the consequences of compliance with the applicable NESHAP against actions that would be necessary to avoid being subject to the standard. In many cases, actions required to comply with the MACT standards will result in emissions of HAPs falling below the major source definition.

Can Argent help me with my HAPs problem?

Argent has coordinated implementation and compliance actions for MACT standards at chemical plants and other facilities and assisted other sources with compliance through reporting, permit preparation, and thorough documentation of compliance requirements to assist plant personnel. Our personnel understand regulatory requirements and the reality of field operations. This combination has resulted in Argent environmental consultants consistently satisfying our clients and reducing compliance costs.

Dispersion Modeling

What is “Dispersion Modeling”?

Air dispersion modeling is used to predict off-property concentrations resulting from emissions of air pollution. Equations and algorithms representing atmospheric processes are incorporated into various computer models, which enable the modeler to enter pertinent data, such as emission rates and distance parameters. The model calculates atmospheric concentrations of a pollutant at specific points, or receptors, near the source(s) being evaluated.

When do I need to conduct dispersion modeling?

Most state environmental agencies require some degree of modeling analysis as part of the air permit application process. It is important to determine the level of air pollution concentrations from an emissions source in order to evaluate the effect those emissions will have on the air quality in the vicinity of the source. Agency staff use modeling results to determine whether a facility is operating or will operate in compliance with state and federal standards, and whether its operations may result in negative health effects on persons living or working in the area.

Why should I have Argent assist me with air dispersion modeling?

Argent uses EPA’s most current version of Air Dispersion Models and a graphical software package to perform refined air dispersion modeling. Our approach to modeling consists of (1) collecting all needed information about the facility, such as point parameters, exact location, and emission rates, to produce the most accurate results; (2) performing preliminary modeling to determine whether refined modeling is required; (3) if necessary, performing a refined modeling analysis according to the guidelines of the state in which the facility is located; and (4) producing a finished report for the environmental agency or agencies and for the client. Argent environmental consultants have performed refined modeling in several states for various types of facilities.

If you have any questions about compliance or a regulatory question in general, call us and we can help.