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Disclaimer
The information contained in this site is provided for your review and convenience. It is not intended to provide legal advice with respect to any federal, state, or local regulation. You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

How to Comply

Most metal finishing facilities are required to obtain an air pollution permit and to file for a new permit every five years or sooner. The requirement may be based on federal or state regulations, or both. Also, many regional and local governments have their own requirements.

Federal and state requirements apply to the following types of operations:

  • Facilities covered by the chromium and/or halogenated solvent "MACT" standards,
  • Facilities with operations such as painting in addition to other metal finishing operations,
  • Facilities that use volatile materials such as degreasing solvents,
  • Facilities that use plating chemicals with air toxics,
  • Facilities with a boiler or furnace that use #2 fuel oil,
  • Facilities located in a non-attainment zone for air quality, and
  • Facilities or operations that generate or contribute emissions of one or more of six criteria pollutants:
    • Lead
    • Particulate matter (PM10),
    • Sulfur dioxide (SO2, released from burning #2 fuel oil),
    • Nitrogen dioxide (NOX),
    • Carbon monoxide, and
    • Ozone, (ground level smog).
To determine your requirements and apply for a permit, follow these eight steps.

1. Contact your state and/or local agency or a consultant.
Air regulations are more complex than wastewater or hazardous waste rules and they are frequently revised. Therefore, unless you are an air regulations expert, you probably need some assistance. Your state and/or regional agency is an excellent source of information. To find out who you can contact, use the NMFRCs Air Pollution State Resource Locator .

2. Identify Emissions Sources.
Evaluate your metal facility for all possible air emission sources, including parts cleaning/degreasing, plating, anodizing, painting, and boilers. Evaluate planned activities (new lines or operations) and determine if they will generate any new sources or impact existing sources.

3. Quantify Emissions.
If you have processes, materials or operations that create emissions, you will need to calculate the pounds or tons per year (TPY) of Volatile Organic Compounds (VOC), Hazardous Air Pollutants (HAP) and/or the six criteria pollutants you emit.

These calculations are expressed as the Maximum Theoretical Emissions (MTE) and Potential to Emit (PTE) from your facility. The MTE and PTE are the tons per year of each pollutant that your facility actually or probably emits. The DNR determines whether or not you need an air permit and what type you may need, using MTE or PTE or, in some cases, both. The calculations can be very detailed and complicated.

Minimize use of estimates or assumptions; these will probably not hold up during permit application review. Maintain all calculations and records; your state and/or local government will require supporting information to confirm estimates or ask you to perform source testing. See Additional Resources for references that may help with quantifying your emissions.

4. Review Regulations.
Obtain a copy of the air quality regulations for your state (NMFRCs Air Pollution State Resource Locator ). Review any applicable regulations to answer the following questions.

  • Are all metal finishing facilities in your state required to obtain a permit?
  • Are any processes subject to federal regulations for New Source Performance Standards (NSPS), New Source Review (NSR) requirements, Maximum Achievable Control Technology (MACT) standards or other requirements?
  • Do any other sources have emissions limitations?
  • Are your facilitys emissions large enough to require a permit? For example, in some states, emissions of VOCs less than 10 tons/year do not require a permit.
  • Is the facility located in a non-attainment area? Be aware that some states have VOC emission limitations more stringent than Title V, particularly for heavy industrial and vehicular traffic areas.

5. Determine Your Compliance Status.
Compare your emissions and potential with the regulations. Generally, this requires a review by a professional air pollution consultant.

Your facility will be categorized as an Exempt Source if emissions are below levels that require a permit; Minor (Small) Source if actual and potential emissions are below Title V thresholds for all pollutants; Synthetic Minor (Conditional Major) if actual emissions are below Title V levels, potential emissions are over Title V levels, and the facility is willing to accept federally enforceable operating limitations to guarantee that emissions will remain below Title V thresholds; or Major Source if actual emissions are over Title V levels or the facility would be a Synthetic Minor but is unable or unwilling to accept operating limitations that will guarantee that emissions will remain below Title V levels.

If any emissions sources are out of compliance and cannot be remedied easily, a compliance plan must be established. It may be necessary to work out a compliance schedule with your state agency.

6. Prepare Permit Application.
The next step is to prepare the air quality permit application. If you are a Major Source and preparing a Title V Operating Permit application, several other items are required. Depending on your situation, you may have to propose record-keeping plans, periodic or enhanced monitoring protocols and/or reporting procedures to demonstrate compliance. If you are an anodizer or chromium electroplater, you are subject to Maximum Achievable Control Technology requirements.

7. Submit Permit Application.
If your facility is particularly complex or if emissions are precariously close to Title V levels, submit a draft permit application to your state, if allowed. This will allow the permit review engineer an opportunity to assess your facility/application and make comments or ask questions. It will also give you the opportunity to make changes to the application should any corrections be necessary. When you submit the final application, be sure to include payment for any applicable fees. Depending on the state, you may have to pay an application processing fee or construction/modification fee.

8. Make Preparations to Comply with Permit.
Depending on your situation, you may be required to perform source testing, waste sampling, recordkeeping and reporting to comply with your permit. You may also be required to pay emissions fees.



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