brent blanchard (8:29)<\/strong><\/p>\nyeah. i mean, the best way to avoid an issue is to go through those construction permits when they get them and sit down with the facility and make sure that they understand, you know, what record keeping, what operating limits they need and maybe help them develop the forms or some type of data recording device, whatever they need. it varies with the industry and how involved they want to be in it, but try to develop all those things once you have that construction permit in hand so that they are in compliance, to begin with, and if they fall out of compliance, the best thing to do is contact us right away and work to come up with a strategy to come back into compliance. i mean, the worst thing to do is to try to cover it up because then know that opens up an a-whole-nother set of regulations and can get kicked up to the state level or epa level. it’s best to avoid all that if you can.<\/p>\n
jeff walters (9:27)<\/strong><\/p>\nso we’ve talked about construction permits a little bit. have we really dove into some of our operational permit issues and concerns, or are we overlapping here a little bit?<\/p>\n
operating permits\u00a0<\/strong><\/h3>\nbrent blanchard (9:37)<\/strong><\/p>\nthey do overlap in that your operating permit referred to as the title five permit, is really a compilation of all the construction permits that have been issued to that facility. for compliance, those that have a title five permit have to certify that they are in compliance with their monitoring requirements. if they’re not, they have to submit additional forms stating what units are out of compliance, why they’re out of compliance, and when they’ll be back in compliance.<\/p>\n
and then, once a year, they have to submit an annual compliance statement in which they go through and list every requirement that that facility has in regards to air permitting, and then has to state that either they were in compliance full-time or part of the time. if they were out of compliance at any time, they have to submit the forms on which emission units were out of compliance, why they were out of compliance, how long they were out of compliance, and if they’re still out of compliance when there’ll be back into compliance.<\/p>\n
jeff walters (10:36)<\/strong><\/p>\nif a facility is out of compliance are the counties or dnr or epa requiring the facility to shut their operations down at any time?<\/p>\n
brent blanchard (10:47)<\/strong><\/p>\nthat would be very rare. normally it depends upon the type of violation that it is. is it an emission violation, or is it a record-keeping violation? if it’s a record-keeping or you violate your operating limits without exceeding the emission limit, then you can usually get by with a revised construction permit or some type of compliance plan that you can submit. it’ll have benchmarks in there on what you’re going to do, when you’re going to do it, and how long it would take you to come back into compliance.<\/p>\n
jeff walters (11:20)<\/strong><\/p>\nokay. so, what are some of the biggest issues that we have with construction permitting these days?<\/p>\n
common problems with air permitting<\/h2>\n
brent blanchard (11:26)<\/strong><\/p>\nyeah. i’d say probably the biggest frustration right now, not only for the client but also for dnr, is the pm 2.5 dispersion modeling because there’s such a narrow window between the background levels and the national ambient air quality standard that it’s really hard to get your process to fall into that range. \u00a0so you end up with a lot more facilities having to model for 2.5. if they exceed that limit it used to be, you could raise the stack and other things like that, which were fairly simple fixes that really don’t work for 2.5. you still end up with these hot spots, and it’s frustrating for the client and also for dnr. i mean, the dnr can’t issue the permit if it’s going to violate the standard, and in most cases, they help you come up with the different scenarios to try to get it to pass.<\/p>\n
that is one of the biggest issues right now.<\/p>\n
jeff walters (12:27)<\/strong><\/p>\ni recall several years ago, we had a client that was frustrated with dnr because they didn’t have rules, but they had guidance. is that still the case today?<\/p>\n
brent blanchard (12:39)<\/strong><\/p>\nyeah, that really doesn’t seem to be a major concern as what it was. there are still guidelines out there, and it stems more from epa than it does from the dnr. epa is the one that comes out with the guidance, and then dnr will have to adopt it, and they really can’t adopt the guidance. they need a firm rule in order for the dnr to adopt it and then enforce it.<\/p>\n
jeff walters (13:02)<\/strong><\/p>\nwhat are some of the foreseeable changes you anticipate in the air permitting realm in the next six months, a year, three years, or five years?<\/p>\n
future of air permitting\u00a0<\/strong><\/h2>\nbrent blanchard (13:10)<\/strong><\/p>\nat the state level, i would anticipate a bigger push to put more things online. right now, that is an option. i would see them trying to make that mandatory. like they did the title five permitting, and then at the federal level, they’re also pushing more towards paperless accounting systems. and i would anticipate with the new administration that we have that the greenhouse gases will become a bigger issue, and i could see them do a big push to make those a regulated pollutant.<\/p>\n
jeff walters (13:42)<\/strong><\/p>\nwho do you think will be the next client or industry that will start dipping their toes in the air-permitting world? we discussed that a little bit earlier about post-derecho and various entities wanting to have emergency generator backup. what else do you see in the future?<\/p>\n
brent blanchard (14:02)<\/strong><\/p>\nwhat i see would be continuing growth in the data centers like facebook here in altoona. they have a hundred diesel backup generators with amazon moving in and microsoft on the south side of des moines and dallas county. it’s because here in iowa, we have a fairly cheap water supply, which is major for them. for the cooling part of it, we have stable and fairly cheap electricity. also, we do not have earthquakes, so i could see more of those types of facilities moving into the area.<\/p>\n
i probably just want to remind the clients that, you know, the construction permit is a pre-construction requirement, and you have to have that permit in hand before you initiate construction or begin operating the equipment. you know, that those facilities trying to get the jump on that is where you see, you know, probably the greatest number of nov issues.<\/p>\n
jeff walters (15:01)<\/strong><\/p>\nbrent, i thank you for your time today talking about the world of air permitting. i learned quite a bit today, and i appreciate the time. thank you.<\/p>\n","protected":false},"excerpt":{"rendered":"
air quality permitting & compliance in compliance with the epa\u2019s clean air act, any facility that emits air pollutants above specified levels must obtain an air quality permit. permits can be general or individualized and specify pollutant limits, how industrial facilities must operate equipment to control pollution, and how to monitor and report emissions. compliance […]<\/p>\n","protected":false},"featured_media":26203,"parent":0,"menu_order":19,"template":"","format":"standard","categories":[29,28,26,25],"class_list":["post-17731","podcasts","type-podcasts","status-publish","format-standard","has-post-thumbnail","hentry","category-land-development","category-municipal-engineering","category-世界杯足球比赛预选赛
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