Section E of most Indiana Air Operating Permits contain federal air rules and air standards that pertain to your facility. The most common standards included are subparts from National Emission Standard for Hazardous Air Pollutants (NESHAP) or New Source Performance Standards (NSPS). It is very easy to overlook Section E because it is at the end of the permit and is typically only one or two pages long. Because of this covert nature, facilities may fail to give Section E the time and attention it requires, leading to noncompliance, deviations, and/or violations to one’s air permit.
As previously mentioned, Section E is typically comprised of a NESHAP or NSPS subpart and usually takes up one or two pages. The content of those one or two pages consists primarily of a list of NESHAP or NSPS section and paragraph numbers. Unless one is fully knowledgeable of the cited section and paragraph numbers, the list of numbers and letters are essentially meaningless. It is the permittee’s responsibility to research the list of applicable NESHAP and/or NSPS rules from their Section E. That way, one can fully understand what the facility’s responsibilities are to comply with their respective federal rule.
To help illustrate how a typical Section E compares to the respective federal rule, please see the links below. This example is for a permit that is subject to NESHAP Subpart PPPP, which is a subpart for Surface Coating of Plastic Parts and Products.
- Example of Section E
- Actual federal rule text
- Summary chart of federal rule text
A chart like the one seen above is a good way to help you better understand your requirements and obligations.
If you would like help in understanding your list of applicable rules in Section E, give us a call — BCA can help!