Potential to Emit as a Vehicle for Flexible Permitting

摘要

Malt-O-Meal Co. operates a cereal production facility in Northfield, Minnesota. The facility has approximately 140 particulate emission points, many with potential emission rates below one ton per year and none greater than ten (10) tons per year. Emission factors for most operations are not available Because ot the number of operations, modifications are common and therefore, so is the need for permit action. This in turn results in delays for the company and utilizes state resources for multiple changes with minor impacts. Because of the number of emission points, actual emissions tracking is not a " realistic alternative. To streamline modifications and maintain minor source status, a type of flexible permit that uses potential to emit tracking is proposed. The permit sets a cap on the potential to emit and allows the facility to make changes without permitting as long as the potential to emit cap is not violated This procedure maintains flexibility while providing the state with assurance that the facility is not expandin-without adequate regulation. Potential to emit tracking should be considered as a flexible permit alternative for similar businesses with many small emission points.