Annual OSIL Reviews are Due January 31: What are they? Do you need one?
Nearly all industrial facilities routinely implement changes to production processes, equipment, and operational conditions to stay competitive in today’s market. These changes are often driven by process improvement initiatives (5S, Lean Six Sigma, etc.) to improve production and eliminate process waste. It is not unusual for these changes to have some level of impact to a facility’s Environmental Management Systems and associated environmental permits.
Fortunately for South Carolina, most air permits (State Operating, Conditional Major, or Title V) contain some level of “permit flexibility”. The permit flexibility condition allows facilities to “undertake minor alterations without a construction permit, or without revising or reopening the operating permit.” How can this condition benefit your facility? You can potentially implement changes without submitting an exemption request or construction permit application to DHEC! However, a detailed air impact review is required as part of the permit flexibility condition and should be included in your facility’s Management of Change process.
An important part of this permit flexibility procedure is recordkeeping. Facilities are required to maintain an on-site implementation log (OSIL) (written or electronic), to document allowable changes under the permit flexibility condition. The “log” is more of a collection of documentation. DHEC provides a form (D-0722) on their website that can be used, but it is not required. If you do not use DHEC’s form, you are still required to evaluate and document the information listed in the form.
If your operating permit contains the permit flexibility condition, once per year you must review the list of permitted and exempt sources and determine if anything (equipment or materials) was added, removed, and/or modified (new paints, new chemicals, etc.). If any discrepancies are found and the change is allowed by the nine flexibility criteria, document this change on the OSIL form.
Whether you have documented changes on the OSIL form or not, you must conduct a review and document this every year by January 31st. This is not the same as completing the DHEC form D-0722! DHEC does not currently have a specific form to document the annual review.
It should be noted that permit flexibility conditions in State Operating Permits and Conditional Major Operating Permits are different from Title V Operating Permits. Title V Operating Permits have operational flexibility allowed under SC Regulation 61-62.70.5(c) and R.61-62.1, Section II.B. Therefore, the OSIL is not typically required in the Title V Operating Permit. However, the air impact review process is very similar to the requirements of the OSIL. An OSIL may be used for Title V flexibility as long as the facility documents any additional requirements.
A completed OSIL form should be kept with the air permit and made available for review, as requested. A copy of all completed OSIL forms and associated documentation is required to be submitted to DHEC every five years from the effective date of the operating permit. In the case of Title V permits, this information must be submitted to DHEC with the next permit renewal application.
Bunnell Lammons Engineering (BLE) can assist with the routine and non-routine environmental tasks required as part of facility operations. BLE regularly conducts air impact reviews to determine if changes can be covered under a facility’s flexibility condition. We also prepare OSILs and associated documentation (emission calculations, air dispersion modeling, etc.). Often a process or equipment change may affect multiple environmental aspects of a facility. Whether it affects air, waste, or water, BLE can support your site-specific environmental compliance needs.