Indiana Air Permits

1
Indiana Air Permits

• Presented by
• The
• Indiana Department of Environmental Management
• Office of Air Quality
• Permits Branch

2
The Clean Air Act (CAA)

• The United States Congress passed the first Clean
  Air Act in 1963.
• It provides a Nationwide Air Quality Management
  System
• Congress passed major amendments to the act in
  1970,1977 and 1990

3
The CAA (cont.)

• The act established a system to measure air
  quality and provide for continuous improvement
• It is implemented by the United States
  Environmental Protection Agency (U.S. EPA)
• Indianas air permitting program is approved by
  U.S. EPA

4
NAAQS

• The National Ambient Air Quality Standards
  (NAAQS) set the allowable level of pollution in
  the air for the six Criteria Pollutants
• The six Criteria Pollutants are
• Carbon Monoxide (CO)
• Nitrogen Oxides (NOx)
• Sulfur Dioxide (S02)
• Particulate Matter (PM)
• Lead (Pb)
• Ozone (03)

5
NAAQS (cont.)

• The U.S. EPA determines whether the air in
  Indiana meets the NAAQS for each criteria
  pollutant
• If an area meets the NAAQS, it is considered in
  attainment
• If an area fails to meet the NAAQs for a criteria
  pollutant it is considered nonattainment for
  that pollutant
• The state must develop a plan to improve air
  quality for that pollutant
• This plan includes more stringent emission
  limitations for the pollutant as well as more
  stringent permitting requirements.

6
NSPS

• New Source Performance Standards (NSPS) apply to
  some new sources
• Performance standards set by industry type
• As technology improves, the standards are changed
  to further reduce pollution

7
NESHAPs

• National Environmental Standards for Hazardous
  Air Pollutants
• NESHAPs set requirements for specific industries
  in limiting the release of Hazardous Air
  Pollutants (HAPs)

8
Indiana Air Permitting

• Permits regulate the amount of air pollution that
  can be released by a source
• There are more than 2,000 sources in the State
  that are required to have an air permit

9
Air Permit Process

• Sources send applications to IDEM describing the
  equipment they have and any equipment they want
  to add
• IDEM calculates the maximum air pollution that
  the equipment can emit if it is operated 24 hours
  every day
• These maximum pollution emissions are used to
  determine the level of air permit the source will
  need, the air rules that apply and the air
  pollution controls that must be used

10
Air Permit Process (cont.)

• IDEM drafts the permit that contains all the
  state and federal requirements to control
  emissions
• Lower level air permits are issued directly
• IDEM seeks public comment on draft permits for
  higher level air permits
• IDEM must also send higher level air permits to
  EPA for review and approval.

11
Construction Permits

• Permitting level determined by sources maximum
  potential to emit
• Permit must be issued before the source may begin
  construction of any part of the new or modified
  emissions units
• Minor sources may do some construction activities
  prior to air permit issuance

12
Construction Permits (cont)

• A permit applicant may be able to limit its
  potential to emit to a minor source level by
  agreeing to permit conditions that may, among
  other things
• Limit production or hours of operation,
• Require the use of control equipment that was not
  otherwise required, or
• By shutting down existing equipment.

13
New Source Review (NSR)

• Applies to new major sources of air emissions or
  an existing major source that modifies its
  process such that it will result in a significant
  emission increase
• Requires major sources in attainment areas to use
  the Best Available Control Technology (BACT)
• In nonattainment areas, the major sources of
  criteria pollutants must further reduce emissions
  using Emission Offsets and air emission controls
  that meet the Lowest Achievable Emission Rate
  (LAER)

14
Air Permitting

• Operating Permit types
• Major Source Title V level permit
• Minor Source State Permit
• IDEM issues and enforces permits
• U.S. EPA has continuing oversight over Indianas
  air permit program and enforcement program

15
Air Permit Documents

• Indianas air permits have five main sections
• A Source Summary
• Tells what kind of industry the source is engaged
  in and lists the equipment that is regulated by
  the permit
• B General Conditions
• Provisions that apply to all permitted sources
• C Source Operation Conditions
• Operating conditions that apply to all sources
• D Facility Operating Conditions
• This is the section of the permit that
  specifically regulates the source and requires
  specific controls and limits on emissions.
• E Incorporation of Federal Standards

16
Permit D SectionsFacility Operating Conditions

• Each facility operating section has up to four
  parts
• Emission Limits and Standards
• Compliance Determination Requirements
• Compliance Monitoring Requirements
• Record Keeping Reporting Requirements

17
Compliance Monitoring

• Monitoring helps to ensure that the source stays
  in compliance with its emission limits and
  standards
• Depending on the type of monitoring, permit
  conditions may require monitoring readings to be
  taken continuously, daily or weekly

18
Compliance Inspections

• IDEM can inspect any source at any time
• Sources must keep their records on site so that
  the inspector has immediate access to them

19
Technical Support Document (TSD)

• The Technical Support Document (TSD) provides
  additional information, including air emission
  summaries, proposed modifications, state and
  federal rules that apply, and a summary of
  compliance requirements

20
Public Notice

• IDEM publishes a notice regarding the draft
  permit, seeking public comment
• The public comment period is usually 30 days
• Anyone can request that IDEM conduct a Public
  Hearing regarding a draft permit
• After the public comment period IDEM makes the
  final permit determination
• The final determination includes IDEMs response
  to all written comments

21
Permit Appeals

• Any person who disagrees with an IDEM permit may
  seek administrative review
• Petitions for Review are filed with the Indiana
  Office of Environmental Adjudication