Indiana Air Permits
Presented by
The
Indiana Department of Environmental Management
Office of Air Quality
Permits Branch
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
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)
• Indiana’s air permitting program is approved
by U.S. EPA
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)
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.
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
NESHAPs
• National Environmental Standards for
Hazardous Air Pollutants
• NESHAPs set requirements for
specific industries in limiting the
release of Hazardous Air Pollutants
(HAPs)
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
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
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.
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
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.
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)
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
Indiana’s air permit program and enforcement
program
Air Permit Documents
Indiana’s 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
Permit D Sections
Facility Operating Conditions
Each facility operating section has up to
four parts
1.
2.
3.
4.
Emission Limits and Standards
Compliance Determination Requirements
Compliance Monitoring Requirements
Record Keeping & Reporting Requirements
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
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
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
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 IDEM’s response to
all written comments
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