Permits to Install/New Source Review
Rule 201 of the Michigan Air Pollution Control Rules requires a person to obtain an approved Permit to Install for any potential source of air pollution unless the source is exempt from the permitting process. Does your business have paint or other coating application booths, storage tanks, printing presses, boilers, soil remediation projects, plating operations, degreasers, ovens, or any other process that may emit air pollution? If so, your facility may need to complete an Air Use Permit application.
Clean Air Interstate Rule (CAIR) Budget Permits
The United States EPA's Clean Air Interstate Rule (CAIR), which uses a cap and trade system to reduce sulfur dioxide (SO2) by over 70 percent and nitrogen oxides (NOx) by over 60 percent from 2003 levels, applies to electric generating units and to non-electric generating units formerly subject to the NOx Budget Permit program. Michigan implements the federal requirements through state regulations. Michigan's Rule 821 requires subject sources to obtain and operate in compliance with a CAIR Annual NOx Budget permit and/or CAIR Ozone NOx Budget permit. Rule 420 requires subject sources to obtain and operate in compliance with a CAIR SO2 Budget permit. All CAIR Budget permits must be issued and renewed in keeping with Michigan's Renewable Operating Permit program procedures.
Under the Clean Air Act, the U.S. EPA is required to develop standards for industrial categories of "major" sources of hazardous air pollutants (HAPs) that require the application of maximum achievable control technology (MACT). Section 112(g) requires a "case-by-case MACT determination" by the Air Quality Division if a major source is constructed or reconstructed before the U.S. EPA issues a MACT regulation for that particular source category. Section 112(j), commonly referred to as the "MACT hammer," requires a case-by-case MACT determination if U.S. EPA fails to promulgate a standard within 18 months after the scheduled date.