Whether constructing a new industrial facility, expanding production, or modifying operations, owners and operators may be subject to air quality permitting requirements. Industrial sources must be designed, constructed, and operated to comply with all applicable air quality regulations. Air quality permitting requirements exist within a range of regulatory programs, including state and local codes, and federal programs such as New Source Review and the Title V operating permit program. Each permitting program has associated technical requirements such as emissions quantification, control technology evaluations, air quality analyses (including regulatory dispersion modeling), ambient air and meteorological monitoring, emission standards applicability, and compliance assurance.
Trinity Consultants can assist with all phases of the air permitting process. We have completed thousands of permitting projects and our experience translates into accurate, timely permit applications that are strategically crafted for maximum flexibility, and expert negotiations with regulatory agencies, streamlining the permitting process.
New Source Review
The federal New Source Review (NSR) program requires that new and modified major sources undergo rigorous air quality analyses and receive a permit prior to commencing construction on any physical changes or changes in the method of operation. The analyses must demonstrate the implementation of appropriate pollution control technology and maintenance of air quality standards. NSR is a constantly evolving program, at both the state and federal levels. To determine NSR applicability, Trinity identifies and characterizes emissions from the equipment that comprise the regulated source. Using this information, along with U.S. EPA attainment designations, Trinity performs a thorough regulatory review to determine applicability and requirements of Nonattainment New Source Review (NNSR), Prevention of Significant Deterioration (PSD) regulations, and state construction permitting requirements. Trinity then works with its client to develop a permitting strategy that will enable the project to proceed in a timely manner, while optimizing operational flexibility and minimizing costs.
Nonattainment NSR (NNSR) Requirements
New or modified major sources in areas designated as nonattainment with National Ambient Air Quality Standards (NAAQS) may be subject to NNSR. If potential emissions from a modification exceed threshold quantities and the facility is a major source of emissions, Trinity’s technical staff will conduct an emissions netting analysis. Emissions netting considers previous emissions changes (within a defined period) at an existing major source to determine if the proposed modification can avoid classification as a major modification. If NNSR is triggered by a project, Trinity will conduct the required Lowest Achievable Emission Rate (LAER) control technology assessment (or the less stringent Best Available Control Technology (BACT) assessment in certain limited circumstances).
Other NNSR requirements include locating and purchasing emissions offsets from other permitted sources that have certified emissions reduction credits, as well as demonstrating that the benefits of the project significantly outweigh the environmental and social costs imposed as a result of the chosen location, size, or production processes. In addition to assisting with permitting requirements, Trinity also supports clients with identifying and negotiating the purchase of offsets.
Prevention of Significant Deterioration (PSD)
New or modified major sources located in areas designated as attainment with NAAQS are subject to PSD review if emissions or net emissions exceed certain threshold quantities. Assessing PSD applicability is a complex undertaking based on volumes of guidance and policy issued by EPA over the program’s history. Trinity’s depth of experience with the PSD program supplies our clients with the nuanced insights needed to develop the optimal permitting strategy. Like NNSR, PSD regulations allow major sources to “net” out of PSD review, should that be practicable. Projects triggering PSD review require a best available control technology (BACT) analysis and extensive air dispersion modeling that addresses issues such as complex terrain, direction-specific building downwash, and visibility impairment and regional haze impacts in designated Class I areas. As a cornerstone of its technical skill set, Trinity has the specialized expertise to conduct the most challenging dispersion modeling analyses.
Obtaining a PSD permit in a timely, cost-efficient manner requires a thorough understanding of the entire PSD program. Our extensive experience with the PSD program helps save clients thousands of dollars in permitting costs and opportunity costs that could result from delays in the start of construction.
- Regulatory applicability analyses
- Permit strategy development
- Emissions quantification
- Emissions netting analyses
- Permit application development
- Compliance management tools
- Compliance certification assistance
- Control technology evaluations
- Emissions trading assistance
The Title V program is a federally enforceable operating permit program for significant sources of air emissions, as defined by certain annual threshold levels. Subject sources must submit permit renewal applications every five years to update regulatory applicability and address changes at emission units at the facility. In addition to renewal applications, facilities may also be required to submit Title V permit modification applications if they undertake new construction, make changes in source operations, or become subject to new or existing regulations (e.g., a NESHAP regulation).
In addition to the permit requirements, the Title V program shifted the burden of demonstrating compliance from the regulatory agency to the facility. Compliance demonstration and certification may be a significant undertaking depending on company processes, regulatory requirements, and the efficiency of the company’s recordkeeping and reporting methodologies. Trinity Consultants has prepared more than 850 initial Title V operating permit applications, permit renewal applications, and permit modification applications in all ten EPA regions. Trinity's depth of experience benefits clients in developing Title V permit applications that maximize operational flexibility while assuring monitoring, recordkeeping, and reporting efficiency. Our experience in preparing permit modification applications across all industries allows Trinity to bring unique insight to each engagement and to develop the most beneficial strategies based on client needs.
Trinity built its reputation for excellence on air quality expertise. Air permitting is the foundation of our business and our staff of air quality experts is one of the largest in the country. Our focus on air quality and commitment to ISO 9000-based quality management has resulted in project delivery systems designed to complete jobs on time, accurately, and within budget.
Contact your local Trinity office at (800) 229-6655 for assistance.