It is not unusual for today's EHS professional to be a generalist, managing a site's safety program, conducting sampling for Industrial Hygiene compliance requirements, and facilitating the Environmental Management System. Outside expertise is often used to help meet regulatory obligations. In the realm of environmental, this expertise could support tasks ranging from obtaining a permit to completing compliance reports. However, if the EHS professional lacks the core knowledge of the site requirements, a site could end up with difficult permit conditions, decreased flexibility, and even compliance issues.
To prevent these pitfalls, it is imperative that the EHS professional have a general understanding of why environmental regulations exist, how compliance is typically achieved, and when changes may impact a site's regulatory obligations. Understanding these three elements will enable the EHS professional to manage the entire Environmental Management System more effectively and efficiently, from A to Z.
This paper will focus on air requirements and obligations, but the same tools and concepts can be applied to other environmental aspects, such as waste and storm water.
The Environmental Protection Agency's (EPA) Clean Air Act (CAA) regulates emissions from the installation or modification of manufacturing processes. It assures the public that emissions will be reduced or eliminated through the use of technically and economically feasible options. The EPA uses two programs to manage air permitting, New Source Review (NSR) and the Title V program, and delegate's authority to most states. States are required to submit a State Implementation Plan (SIP) to ensure they meet CAA regulations and issue operating and construction permits to maintain or improve the air quality.
The type of permit issued to a facility depends on the amount of regulated pollutants emitted. Regulated pollutants include ozone (measured as Volatile Organic Compound – VOC), particulate matter (PM), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen dioxide (NO2), lead (Pb), and Hazardous Air Pollutants (HAP). A permit can also be issued if the facility is subject to a federal regulation, such as New Source Performance Standard (NSPS), National Emissions Standards for Hazardous Air Pollutants (NESHAP), etc. Some example of permits that can be issued to a facility are: Title V Operating Permit, Construction Permit, Synthetic Minor Permit, State Permit or General Permit.
