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.
If your operating permit contains the permit flexibility condition, once per year you must review the list of permitted and exempt sources to determine if anything (e.g., equipment or processes) was added, removed, and/or modified. Modifications also include the use of 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 log and include your emission calculations and other pertinent information.
Whether you have documented changes in the OSIL log or not, you must conduct a review and document this every year by January 31st.
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 log and supporting documentation should be kept with the air permit and made available for review, as requested.
A copy of the completed OSIL log 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.