EHS Support assisted an aerospace manufacturing facility in Ohio with a complex air permitting challenge identified during a voluntary environmental audit. As part of the audit, we conducted a comprehensive potential-to-emit assessment, which demonstrated that the facility exceeded major source thresholds for hazardous air pollutants and Title V air permitting, despite not holding any air permits at the time.
The company proactively disclosed this information to the Ohio Environmental Protection Agency (Ohio EPA) under the protections of the state’s audit privilege law and engaged legal counsel to support the process.
EHS Support worked closely with the client and their legal team to evaluate permitting pathways to avoid Title V and major source classification. Together, we developed and implemented a facility-wide synthetic minor strategy that successfully capped emissions below major source thresholds, allowing the facility to avoid Title V permitting and several state and federal regulations. Additionally, EHS Support conducted air toxics dispersion modeling to demonstrate that off-site impacts were below Ohio EPA’s Maximum Achievable Ground Level Concentrations.
Throughout the application process, EHS Support supported the facility with Ohio EPA’s audit disclosure investigation, including facility inspections, extensive data analysis, and agency correspondence. As a result, the facility was able to avoid Title V permitting and secured a Federally Enforceable Permit-to-Install and Operate (FEPTIO) from Ohio EPA. The permit was issued with very limited monitoring, recordkeeping, and reporting requirements.
Employing a synthetic minor strategy allowed the facility to avoid applicability of the Aerospace Maximum Achievable Control Technology (MACT) standards, several state regulations, and potential civil penalties. Following issuance of the permit, EHS Support continued to support the client with ongoing compliance with FEPTIO requirements and other relevant regulations, including the Reciprocating Internal Combustion Engine MACT and the National Emission Standards for Hazardous Air Pollutants Area Source Standards for Plating and Polishing Operations.