Pennsylvania Air Permitting Issues

If your facility is in the Philadelphia area, then a plan approval is needed if your actual emissions exceed any of the following levels:

• 3 pounds of VOC per hour
• 15 pounds of VOC per day
• 2.7 tons of VOC per year
• 1 ton of Hazardous Air Pollutants per year
• 2.5 tons of a combination of Hazardous Air Pollutants per year

Philadelphia's Synthetic Minor Operating Permit includes facilities whose potential to emit, without taking limitations and/or restrictions, exceed the Title V applicability threshold. Hence, by taking a restriction in the hours of operation, an emission limitation, or any other approved method, a major facility will become a minor facility.

Outside of Philadelphia: If your facility exceeds any of the following limits, then you are required to obtain a plan approval. All limits are expressed in actual emissions.

• 1 ton of Hazardous Air Pollutants per year
• 2.5 tons of a combination of Hazardous Air Pollutants per year
• 8 tons of VOCs per year for any press/equipment AND total VOC emissions are less than or equal to 25 tons per year,
• 1 ton of VOC per year for any press/equipment AND total VOC emissions are greater than 25 tons per year.

If based on the above information you do not need a plan approval, you must still provide a 15-day prior written notice to the Pennsylvania Department of Environmental Protection stating that you will limit VOC emissions to below the plan approval thresholds.

Pennsylvania has a Title V permit program in place. Sources with the potential to emit more than 50 tons of VOC per year, or 10 tons of one hazardous air pollutant (HAP) or 25 tons of a combination of HAPs are required to apply for a Title V permit. The Commonwealth's Synthetic Minor Operating Permit is the same as Philadelphia's. If you are in Philadelphia, Bucks, Chester, Delaware or Montgomery County, then your facility is considered a major source if you emit 25 tons per year of VOCs.