Question description
There’s a good summary of the EPA Title V permitting process at ERA’s Environmental Compliance Management Blog. (Links to an external site.) One function of the Title V permitting process is that members of the public get a chance to review and comment or complain about facilities that may be emitting pollutants, and may voice their concerns to EPA. Now, keep in mind that any combustion source, such as an emergency generator, will emit carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), and particulate matter (PM10), so if your facility merely has large or many emergency generators or other combustion sources from steam generation or equipment, it is possible that the facility may need a Title V permit. This is determined by calculating the potential to emit those pollutants using emission factors and estimating the annual emissions of those pollutants as if the operations ran 24/7/365. If the total is more than 100 tons per year, or if a total of 10 tons/year for a single Hazardous Air Pollutant (HAP) or 25 tons/year for any combination of HAPs, a Title V permit is required (see Who Has to Obtain a Title V Permit?). (Links to an external site.)
Because most facilities don’t operate 24/7/365, EPA has a provision for what is called a “synthetic minor” source permit. These are governed primarily at the state level, but there’s also a provision for tribal authorities to have synthetic minor source permits (see True Minor Source and Synthetic Minor Source Permits). (Links to an external site.) Basically, under certain conditions, a facility can self-impose restrictions so that its potential to emit (PTE) never exceeds 100 tons/year. The synthetic minor permit is a little easier to apply for and comply with, but, at least for the tribal synthetic minor source permits, EPA says, “you must comply with the same public participation requirements and the same procedures for final permit issuance and administrative and judicial review found at 40 CFR 49.157 and 40 CFR 49.159, respectively.” (https://bit.ly/2HYBZIt (Links to an external site.)). Each state’s rules may be different.
If your facility is located in a community, sometimes there might be community members who actively oppose adding any pollution sources to their neighborhoods. There are even guidelines for communities and community groups to review and understand the permits and the process (see The Proof is in the Permit). (Links to an external site.) If you aren’t familiar with the terms NIMBY, BANANA, and CAVE, look them up as they are relevant to this discussion.
Research and discuss some guidelines for communicating with a community surrounding your facility if the public review process would be needed. Review the reading assignments on risk communication. How can the environmental health and safety professional help the company and the community come together to ensure that (1) operations can continue, (2) that the emissions are limited to the lowest amount possible given the operation that needs to occur, and (3) helping the company and the community understand the level of risk associated with emissions? What ethical considerations are there when presenting, or not presenting information about the facility and emissions to the public?
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