Tips for Getting Your 2020 GPLPE Registration Together - CT Department of Energy and Environmental Department (DEEP) Air Compliance

December 18, 2019

 

 

Companies located in Connecticut could be facing some significant heavy lifting related to upcoming air permitting renewal and deadlines. Specifically, as part of the Title V program, the General Permit to Limit Potential to Emit (GPLPE) from Major Stationary Sources of Air Pollution is set to expire November 8th, 2020. This permit enables facilities to limit their air emissions (i.e. emitters of NOx, SOx, CO, PM, and VOCs) to below major source (i.e. Title V) thresholds. Types of sources that may be subject to the Title V Program can include Fuel-Burning Combustion Equipment (i.e. boilers, engines), Batch or Continuous Chemical Processes, Asphalt Plants, Non-metallic Mineral Processing Plants, Gasoline Storage Facilities, etc.

Although this deadline is a year out, there is significant work that goes into pulling this together, preparing your facility to renew its registration application for the GPLPE program as soon possible is highly recommended.

Additionally, if your source does not fall within the GPLPE category, a Title V Air Permit still may be required due to your facility’s quantified air emissions. These permits are issued to individual, major sources of air pollution (i.e. emitters of NOx, SOx, CO, PM, and VOCs) are tailored to a specific site, and expire every 5 years from the date of issuance.

Some Tips and Considerations for Preparing for your General Permit to Limit Potential to Emit (GPLPE) Application or determining if you are subject: 

  1. Review the last 5 years of your facility’s annual “actual” aggregate emissions to determine if you fall within the appropriate category - criteria pollutant emissions are below 50% of Title V thresholds or they are up to but no more than 80%.
  2. Title V Thresholds:
    • 100 Tons Per Year of any air pollutant that is not a Greenhouse Gas;
    • 50 Tons Per Year of Volatile Organic Compounds (VOCs) or Nitrogen Oxides (NOx) in a serious ozone non-attainment area;
    • 25 Tons Per Year of VOCs or NOx in a severe ozone non-attainment area;
    • 10 Tons Per Year of any Hazardous Air Pollutants (HAPs), 25 Tons Per Year of any combination of HAPs.
  3. Review your air emission sources to determine if there are any new sources that should be included in the renewal.
  4. Actual and Potential emissions must be quantified and included in the application for every air emission source on site.
  5. Emissions rates must be determined using specific data depending on if your facility falls  below 50% of Title V thresholds or up to but no more than 80%.  For example, if your facility falls within the 50% range, emission data sources shall be determined from the following list, in the ascending order, if available:
    • Continuous Emissions Monitoring (CEMs) data;
    • Stack Test Data;
    • Equipment Manufacturer Data derived from EPA-approved emission testing;
    • EPA’s AP-42, AIRS, or EIIP emissions data;
    • If none of the above are available, the emission data must be approved by DEEP.

 

Does the GPLPE apply to your facility?

Facilities covered under the permit program have the following guidelines:

  • Sites are subject to GPLPE if their aggregate criteria pollutant potential emissions are equal to or greater than Title V source thresholds AND their aggregate criteria pollutant actual emissions are less than 50% or up to but no greater than 80% Title V thresholds.  More information on GPLPE applicability can be found here.
  • The GPLPE limits total air emissions from the premises to the 50% and 80% levels.
  • Recordkeeping, Monitoring, and Reporting requirements differ depending on if the facility is registered under the 50% or 80% thresholds.

 

If you require the application forms for the GPLPE permit program, all documents can be found through CT DEEP Air Permit Application Page.

Completing, authorizing and submitting compliance forms can be an arduous, time-consuming task for facilities that are running around the clock. At GeoInsight, our team of compliance experts are available to help your facility through the process, from collecting to documents to finalizing all materials prior to submitting to the CT DEEP. If your facility has any questions concerning the issuance and submittal of compliance permits, feel free to reach out to one of our many industry experts. 

 

For more information – contact us!

 Marryt Longobardi

MTLongobardi@geoinc.com | Phone: 860.894.1022