Air Pollution Compliance & Permitting Services
Since 1971, Admiral has successfully navigated the air emission permitting and reporting requirements for a wide range of Illinois industrial facilities. Admiral’s highly experienced staff has the knowledge and practical approach to address all of your air emission compliance needs. For compliance with Federal, State, and local air emission regulations, Admiral is second-to-none.
Below is a description of the air emission compliance services we provide. Although the result is always the same…environmental compliance; how you meet your compliance commitments today as well as tomorrow is where our knowledge, expertise, and experience really add value.
Often the first step in meeting air emission compliance regulations is to determine what, if any Federal, State, or local regulations apply to your specific facility and processes.
A properly completed air emission evaluation can potentially streamline, reduce, or even eliminate a facility’s air emission compliance costs. For example, it sometimes occurs that an industrial facility owner or manager believes their plant falls under a particular air emission regulation. However, with an air emission evaluation they learn that this is not the case or that their reporting requirements may be less than what they’ve been doing…thus saving them money and time.
With an Air Emission Evaluation, an experienced Admiral engineer will review your company’s processes and activities; identify point and non-point air emissions; determine if applicable air permits and subsequent reporting is required at the Federal, State, and local level; and identify any air emission limitations that may apply. All of this is done with an eye toward your current facility and processes as well as any planned or future process additions or modifications.
Admiral works closely with industrial clients to properly and efficiently complete the necessary paperwork, data collection, and documentation for a successful permit application submittal; typically to the Illinois Environmental Protection Agency (IEPA). The difference when Admiral undertakes this effort is that we thoroughly explain the ramifications of the permit process and changes so that you fully understand current and future costs, time requirements, and reporting implications. Additionally, we’ll explain the IEPA fee structure associated with the permit and how the dollar amount is calculated.
Admiral's experience and expertise in air permitting and reporting in the State of Illinois, can quickly and efficiently get you through this process with minimal disruptions and frustration.
Construction Permits & Operating Permit Modifications
Industrial equipment, processes, and raw materials change over time. If you have upcoming process changes or additions, a Construction Air Permit from the Illinois Environmental Protection Agency (IEPA) is often required. The following are examples of changes that may affect your IEPA air permit (or the need for your first air permit):
- Process modifications
- New processes, equipment, or storage tanks
- Equipment replacements
- Increased production capacity
- Raw material substitutions, additions, or increases
Process modifications, replacement equipment, decreases in production capacity,
and/or reductions, substitutions, and eliminations of raw materials may also
(possibly) negate the need for an air permit and/or change your permit/reporting
As production expands to meet greater demand, facilities may have plans for process changes or additions. In some cases, it is crucial that a Construction Air Permit be obtained ahead of the changes to lock in potential emission factors and limit the facility's potential emissions. Without this, the IEPA must use maximum emission quantities which can then cause other regulations to be applied; potentially causing severe compliance problems for your facility. The IEPA has been vigorously enforcing these rules and following-up with steep fines.
When a Construction Air Permit is Missed
The reality of air emission permitting is that industrial facilities do sometimes start-up new processes and equipment without realizing the need to submit the required application for a Construction Air Permit. Then, at some later point in time after the process or equipment is already in use, personnel in the organization realize that an air permit may be needed to notify the appropriate agency (typically the IEPA). When this occurs, effective communication with the regulatory agency is paramount to keeping the permit application process focused. Collecting, managing, and providing accurate air emission data and documentation in a format that is understood by regulatory personnel can go a long way to help ensure a successful permit application submittal.
For a case study of the implications of a missed Construction Permit, please review: A Big Regulatory Pitfall: Missing Air Permit
Permit Renewals: CAAPP and FESOP
Permits issued under the United States Environmental Protection Agency (USEPA) Title V Clean Air Act Permit Program (CAAPP) must be renewed every 5 years. Federally Enforceable State Operating Permits (FESOP) are renewed every 5 or 10 years depending on when the FESOP was issued.
Under these rules, it is crucial to submit a complete and timely renewal application to the Illinois Environmental Protection Agency (IEPA). A late renewal application is a violation that will result in monetary penalties and additional noncompliance violations because the facility would be operating without a valid permit.
Renewal applications must address process changes at the facility and the applicability of new regulations adopted since the permit was last issued. The renewal period also provides an opportunity to propose changes to the permit conditions and limitations that are more favorable to the facility.
Since the time these regulations came into effect, Admiral's team of experts has been assisting industrial clients through this potentially complicated permitting process. As clients aren't required to go through this effort but once every five years; it is a sound strategic choice to retain an experienced professional to get it done right, the first time.
Illinois Registration of Smaller Sources (ROSS)
NEW May 2013 - The Illinois EPA has been mailing letters to some companies stating that "you may be required to register" under the ROSS Program. They are basing this on recent annual air emissions reporting. However, the agency may not be aware of other factors. Let Admiral determine your eligibility status.
In an effort to streamline Illinois’ Air Permitting Program, in 2012 the Illinois Environmental Protection Agency (IEPA) established an air permitting program for Smaller Sources of air emissions. The program is called ROSS: Registration of Smaller Sources.
Under this program, facilities that currently have Lifetime Operating Permits and emit small amounts of air pollution are likely eligible to register as a “Smaller Source.” Once designated as an eligible source, annual registration under this program is mandatory. The intent of the program is to refocus IEPA staff and resources on the significant air pollution emitters in the State, and not on the smaller sources. As part of the program, Registered Smaller Sources:
- are no longer required to have an IEPA air permit,
- are no longer required to complete the Annual Emission Report or obtain a Construction Permit to add new equipment, and
- must pay an annual fee of $235 as part of an annual registration and re-certification.
The IEPA mailed out information and the registration form to eligible facilities in early 2012. If you did not receive one, and believe you should have, please contact the IEPA directly or Admiral Environmental Services.
Having already done so for a large number of clients, Admiral can complete the registration form for you, including the calculation of annual emissions to certify eligibility. Registration can be completed as soon as you receive the information from the IEPA.
If you would like Admiral to evaluate your operation to determine the applicability under this regulation, please give us a call at 847.228.5355.
Chicago Air Quality Permits
Within the City of Chicago, a permit is required to install, operate, erect, construct, reconstruct, alter or add a piece of regulated equipment or area as defined in the Chicago Municipal Code, Section 11-4-610.
Regulated equipment or area means “any combustion equipment, pollution control device, process equipment, or process area.” In general, this refers to equipment and areas that have a potential to emit any air contaminant into the atmosphere. Neither the size of the facility nor the amount of the air contaminant has any bearing on whether or not you need a permit.
This Chicago permit application also requires a fee of $150 per item being installed.
The equipment will then be included in your facility's Certificate of Operation, which is an annual license (with fee) for your business.
If you would like Admiral to help you comply with Chicago requirements, please give us a call at 847.228.5355.
- For additional Chicago application information, see this User Guide
Annual Emission Reports
The deadline for submittal of the Illinois Environmental Protection Agency (IEPA) Annual Emission Report is May 1 of every year. The annual report is required of all Illinois facilities that have, or should have, an IEPA air permit.
CAAPP Annual Compliance Certifications
If your facility has a permit issued under the United States Environmental Protection Agency (USEPA) Title V Clean Air Act Permit Program (CAAPP), May 1 is the deadline for submittal of the Annual Compliance Certification Form (401-CAAPP Form). The Annual Compliance Certification has significant importance in that the facility's compliance status is to be documented in detail for the previous year.
ERMS Seasonal Emission Reports
Certain facilities located in the Chicago area are required to annually report to the IEPA their emissions of Volatile Organic Material (VOM) for the period of May 1 through September 30. These reports are known as ERMS (Emission Reduction Market System) Reports, and are required for ERMS participating sources, and exempt sources that have accepted an ERMS seasonal VOM limit of 15 tons. If you are required to file, this would be spelled out in the IEPA operating permit.
Admiral's Steve Anderson, PE, is certified by the IEPA as an ERMS Account Officer. If you need to buy or sell ATU credits, we can take care of this for you.
AIR REGULATORY COMPLIANCE
VOM Emissions for Solvent Cleaning Operations
On July 27, 2011, the Illinois Environmental Protection Agency (IEPA) finalized important revisions to their Solvent Cleaning regulations (35 IAC 218.187). The rule covers virtually any facility in the Chicago metropolitan area that uses solvent cleaners containing Volatile Organic Material (VOM), including cold cleaning (i.e. parts washers), vapor degreasing, wipe cleaning, spray gun cleaning, equipment cleaning, floor cleaning and tank cleaning. The original regulation is complicated and the changes are also complicated.
The revised rule:
- Extends the compliance deadline until January 1, 2012,
- Changes the applicability threshold from 15 pounds of VOM in any day to 500 pounds per month and exempts many cleaning categories from even counting towards the 500 pounds threshold,
- Loosens several VOM content limits in cleaners and expands the exemptions from the rule, and
- Changes requirements and/or new definitions for specific source categories.
A new certification statement was required to have been submitted to the IEPA by January 1, 2012 for all facilities that have solvent cleaning operations. This requirement is applicable to many facilities that are currently exempted under the rule and those that previously filed for certification under the original rules.
The new certification includes documentation for:
- All of the VOM-containing solvent cleaning operations at your facility, and
- How each cleaning operation will comply with the various solvent cleaning regulatory requirements and limits.
Although many exemptions are listed in the new rule, exempt facilities are still required to submit a certification statement.
Admiral can assist in reviewing your solvent cleaning operations and preparing the new certification with the required backup documentation. If you would like an Admiral expert to evaluate your operation to see how, or if these new regulations impact your compliance requirements, please give us a call.
NESHAP & MACT Compliance
Maximum Achievable Control Technology (MACT) to meet National Emission Standards for Hazardous Air Pollutants (NESHAPs) regulates the emissions of Hazardous Air Pollutants (HAPs). The United States Environmental Protection Agency (USEPA) has made MACT NESHAP compliance a top priority for enforcement through its National Enforcement Initiatives.
Until recently, most NESHAP rules covered only Major Sources of HAP emissions. However, with new NESHAP rules, the USEPA is now increasingly targeting Small Area Sources of HAPs for compliance.
More than 130 source categories are covered by existing NESHAP rules. The entire list of regulated source categories can be found here.
Of the 130 source categories covered under NESHAP rules, 70 are for Area Sources. The Area Source NESHAP categories can be found here. Many of these Area Source NESHAPs are new, and more rules are being proposed by the USEPA.
Admiral routinely evaluates facilities and operations for NESHAP applicability to determine compliance and reporting requirements. If it is determined that NESHAP rules apply, Admiral’s staff has the expertise, experience, and common-sense approach to guide clients through this potentially complex process.
Chicago Area VOM Compliance
The Illinois Environmental Protection Agency (IEPA) has finalized extensive revisions to the Volatile Organic Material (VOM) regulations for the Chicago ozone nonattainment area. These regulations are found in 35 IAC, Part 218.
The revised regulations will affect many industrial source categories, including:
- Users of industrial cleaning solvents
- Printing on flexible packaging
- Lithographic printing
- Letterpress printing
- Coating of paper, film and foil
- Coating of metal furniture
- Coating of large appliances
- Coating of miscellaneous metal products
- Coating of plastic parts
- Coating of auto & light duty truck assembly
- Fiberglass boat manufacturing materials
- Miscellaneous industrial adhesive application
Facilities in these source categories may be subject to lower VOM limitations, new reporting requirements, and potentially new air pollution control requirements. The compliance deadlines were in 2010 or 2011, depending on the applicable regulatory section.
Admiral Environmental can evaluate your operations and determine your compliance and reporting requirements.
Reciprocating Internal Combustion Engines (RICE) Compliance
The initial filing deadline has passed.
The United States Environmental Protection Agency (USEPA) has passed regulations regarding stationary reciprocating internal combustion engines (RICE), including emergency and non-emergency generators. This regulation covers almost all industrial facilities that have emergency generators – even facilities that are not required to have an air permit.
For more information, see our
Special Notice on this.