Air permitting regulations apply to all businesses – regardless of size! Adding or expanding a source (equipment or process) with air emissions may require a permit.
A Request for Determination (RFD), Plan Approvals, State-Only Operating Permits, and General Permits are all types of air quality permit applications that EMAP can assist your Pennsylvania small business with.
You can submit a “Request for Determination”(RFD) to your DEP regional office. Sources that fall under certain thresholds are exempt and do not need to file for a permit. Businesses may also use the RFD*Online. Both online and paper formats can be found at www.dep.state.pa.us (keyword: RFD).
Check if your operation is eligible for a DEP General Permit. DEP developed “general permits” for air pollution sources that are similar in operation and emission control requirements. For these specified sources, a business can use a shortened form to apply for both plan approval and an operating permit at once. A general permit describes all air quality requirements applicable to sources in an identified group. Although it is convenient to apply for the general permit, be aware that it can be more restrictive. You must meet all specified conditions and you cannot modify a general permit.
If a general permit is not available for your process, you must obtain permission—known as “plan approval”—before you begin construction or purchase equipment. You will need to file a separate plan approval application with DEP or your local agency for each individual source. Plan approval applications consist of application forms, compliance review forms, proof of municipal notice, and the application fee. Your regional DEP office will review the application and may ask you to submit revisions. Once DEP approves your application, this allows you to install and operate the source on a temporary basis. Depending on your facility, you may need to apply for an operating permit at this point.
After installing the source, you must obtain an operating permit before you begin normal operation. The plan approval allows temporary operation so that DEP or your local agency can inspect the source. If there is not a General Permit to cover all regulated sources at your facility, then you must apply for a facility operating permit. The operating permit may set conditions on how you operate the source(s); for example, limiting the hours of operation, monitoring pressure drop across a scrubber, recording the types of paints applied, or reporting malfunctions of the emissions control device. The permit conditions are based on the plan approval. You will be given the opportunity to comment on your plan approval or permit before it is issued. You also have the right to appeal.
If you are adding a new source of air pollution, you should first check if the source is on the exemption list. If not, you must submit a request for determination, apply for plan approval, and/or apply for an operating permit. DEP will add the new source to an existing permit if you already hold one of the three types of facility wide permits.
There are several types of facility wide permits in Pennsylvania. Whether or not you are required to obtain one depends on the total amount of actual and potential air emissions from your entire facility. If actual emissions from your facility are below certain set levels for various pollutants, you do not need any type of permit.
The length of time varies greatly, depending on the type of permit as well as the facility size, type and location. The best advice is to be prepared and plan well in advance if you think you need a permit. A plan approval or permit can take up to six months to be issued.
Read it over carefully! All permits contain record-keeping and reporting requirements that begin the day the permit is issued.
DEP has exempted some types of air pollutant sources from permit requirements. These exemptions are included on DEP’s Air Quality Exemption List.
By submitting a “Request for Determination” (RFD) to DEP you can receive written verification that your source is exempt.
Understanding which equipment at your facility may be subject to (or exempt from) regulatory requirements
Calculating emissions from all sources
Preparing and submitting a Request for Determination and any required plan approvals or permit applications
Finding alternative materials or processes which may reduce your regulatory burden
Examples of businesses that may require a permit include: