If your business’s processes result in air emissions of any kind, you should familiarize yourself with proposed changes to the NY State Air Emission Regulations [(DEC General Process Emission Sources (6NYCRR Part 212)]. The modifications, which could take effect later this year, would change the procedure for obtaining a New York State Process Air Emission Permit. (Comments regarding the proposed changes can be sent to the NYS DEC by 2/17/15. A. copy of the full proposed regulation is available at: http://www.dec.ny.gov/regulations/100007.html.)
Should changes go into effect, facilities with existing permits will have to comply with the new Part 212 rules when modification or renewal applications are submitted to the DEC. However, new emission sources will be required to comply upon issuance of new permits.
Overview of Changes
While the letter rating system will still be used, arriving at your company’s environmental rating would become more complex, and may require additional modeling, including determining the Annual and Short-term Guidance Concentration values (AGC/SGC) of your emission source based on air dispersion modeling analysis. High Toxicity Contaminants, as listed in the proposal, will have a mass limit for annual air emissions that must either be obtained, or demonstrated that the required level of air cleaning specified in the rules are met by your process air emission sources. The rules will also lower the compliance threshold for non-criteria air contaminants from 1 pound/hour to 0.1 pound/hour. Other changes, including new definitions, and coordination of Part 212 to the Federal New Source Performance Standards and the National Emission Standards for Hazardous Air Pollutants, are included in the new rule.
If you’re feeling overwhelmed by these proposed changes, discussing your situation with an environmental consulting professional can alleviate uncertainty and ensure your existing and future air emissions processes comply with the NYS DEC rules. Walden has the experience and know-how to help you navigate any new regulations and obtain required permits so your company will be in full compliance. Give us a call—we are here to help.