Air Quality Permitting & Reporting

The Clean Air Act calls for states and the EPA to address multiple air pollution problems through programs promoting industry flexibility and accountability. The act regulates emissions from stationary and mobile sources, with key examples including criteria pollutants such as ozone, VOCs and particulate matter, and hazardous air pollutants like heavy metals, and pesticides.

New Source Review (NSR) Permits encompass three types of requirements, with a source needing to meet one or more of them:

• Prevention of Significant Deterioration (PSD) permits – Required for new major sources or a major source making a major modification in areas that meet the National Ambient Air Quality Standards.
• Nonattainment NSR permits – Required for new major sources or major sources making a major modification in areas that do not meet one or more of the National Ambient Air Quality Standards.
• Minor source permits – For pollutants from stationary sources that do not require PSD or nonattainment NSR permits.

Title V permits must be obtained by any major source, defined as a source with actual or potential emissions at or above the major source threshold for any “air pollutant.” The major source threshold for any air pollutant is 100 tons/year—this is the “default value.” Lower thresholds apply in non-attainment areas, but only for pollutants that are in on-attainment. The major source thresholds for “hazardous air pollutants” (HAP) are 10 tons/year for a single HAP, or 25 tons/year for any combination of HAP. The EPA generally has not required non-major sources to obtain Title V permits.

Local permitting is delegated from the EPA to the California Air Resources Board (CARB). Local air districts, including AQMDs and APCDs, also issue permits, including “Authorization to Construct” before installing or altering any emissions equipment. Included is a final Permit to Operate (PTO), which requires compliance with federal, state, or local regulations, emissions inventory reporting, and toxics analysis, as well as occasional GHG review.

Although often associated with hazardous materials reporting, Risk Management Plans (RMPs) are also regulated under the Clean Air Act, Section 112(r), which aims to prevent accidental releases of hazardous substances into the air. Facilities that store regulated substances over threshold quantities must develop and submit an RMP to the EPA, detailing worst-case scenarios, emergency response protocols, and mitigation efforts.

These requirements often apply to industrial operations already engaged in air permitting—especially when storing or processing chemicals with potential airborne impact. In California, this program is further enforced by local implementing agencies under the CalARP (California Accidental Release Prevention) Program.

Pacific Engineering & Consulting can help determine if your facility falls under RMP requirements and develop a compliant plan. If your operations involve regulated substances, especially in pressurized or volatile forms, it’s worth evaluating your facility’s obligations under both air and hazardous materials regulations.

Looking for more detailed support with RMPs? Visit our Hazardous Materials Disclosure Reporting page for a deeper breakdown of related services.