Gary Jones, Assistant Vice President, Environmental, Health, and Safety Affairs, Printing Industries of America, offers tips for air permit compliance.
Air permit compliance involves two steps. The first is obtaining a permit and the second is meeting the terms and conditions identified in it. Obtaining the permit requires the preparation of an air emissions inventory that identifies the equipment that emits pollutants, determining the rate and amount of pollutants emitted, and submitting the necessary forms.
Once received, there are five very important actions to take to ensure that you remain in compliance.
Step 1: Read Your Air Permit
Be familiar with your permit and consider it a “living document” that needs to be kept up to date. Once you receive your final permit, highlight your requirements and note specific tasks required.
Step 2: Identify Your Specific Requirements
The Applicable Emissions Limitations and/or Control Requirements section of your air permit outlines your facility’s specific requirements and operational limitations. Following these specifications will dictate compliance. Emission limits and operational restrictions are typically based on rules, and the permit will identify the applicable rules and requirements. Reading the referenced rules will provide information about a specific air permit requirement.
Step 3: Identify and Assign Your Compliance Tasks
Your permit may identify the specific tasks that must be performed to demonstrate compliance. For example, a permit that limits the amount of ink applied daily may require that the facility maintain a daily or monthly usage log. Determine how your facility will meet the compliance requirements and who is responsible for each task.
Step 4: Communicate and Train Staff
It is important that appropriate staff are aware of your facility’s permit requirements, especially those involved with permitted equipment or processes. For example, if your permit restricts the number of hours equipment can operate, it is important that the operators are aware. If your permit requires specific monitoring, it is essential that staff conducting the monitoring are properly trained on the equipment and collect adequate data.
Step 5: Establish an Effective Recordkeeping System
Inadequate recordkeeping and reporting is a common violation of an air permit. Establish a system to identify, assign, and track your permit requirements. Some facilities develop spreadsheets, while others may use more sophisticated tools, such as an environmental management system or compliance tracking software.
Summary and Conclusion
Understanding how to comply with your air permit can be confusing. However, not understanding the requirements of your air permit can lead to violations. If you need more help, contact the PIA EHS team at [email protected]inting.org or 800-910-4283.