We all know that there are countless regulations for air emissions, such as in AP-42 from the EPA or from state and local regulators. The permitting process is relatively straightforward when there are existing regulations for the operations you are trying to permit, but what should you do when there aren’t?

The best practice is to find the next closest thing when there are no specific guidelines or factors. When doing so, correspondence with the regulator is very important.

Ensure that open lines of communication are established with the appropriate regulator so you can work with them to permit your operations. Justifications for your methodology and any calculations will greatly help in the process as well. If no factors are available, use manufacturer data or stack testing.

For example, one of our clients in Texas wanted to permit a solids loading operation into a closed vessel, but there were no guidelines for this specific kind of loading from the EPA or TCEQ. There are, however, guidelines in AP-42 for solids loading into storage piles. We used this as our guideline since its the next closest thing and justified how and why we were doing so.

We worked with the Texas Commission on Environmental Quality (TCEQ) on behalf of our client to ensure everything they needed was submitted and the appropriate justifications were made. The operations were permitted in a timely manner just like any other permit through TCEQ.

If you have operations you need to permit but aren’t sure how or if you found the right guidelines, the team at RECES Environmental would be happy to assist. Feel free to contact Kevin Moin by email at kmoin@reces-llc.com or by phone at (281) 529-5087 to discuss how we can help you permit your operations.

Together we can abide by all regulations!