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Air Pollution Source Permitting. For Boat Manufacturers The Boat Manufacturing MACT  an EPA Workshop February 8, 2002 IBEX conference Ft. Lauderdale Convention Center. Nationwide Permitting…. A Boat Manufacturing facility that is subject to the NESHAP standard 40 CFR 63 Subpart VVVV

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Air Pollution Source Permitting

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Air Pollution Source Permitting

For Boat Manufacturers

The Boat Manufacturing MACT

 an EPA Workshop

February 8, 2002

IBEX conference

Ft. Lauderdale Convention Center


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Nationwide Permitting…

A Boat Manufacturing facility that is subject to the NESHAP standard 40 CFR 63 Subpart VVVV

  • is a major source of hazardous air pollutants (HAPs)

  • and should already have a Title V (Part 70) Permit.

    However, at this point in time, unless it is also

    a major source of volatile organic compounds

    (VOCs) there may not be much more than

    recordkeeping requirements in the permit.


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Nationwide Permitting (cont’d)…

  • Reopening of the Title V Permit for Cause when additional requirements become applicable.

    • Title V permits with expiration dates of August 22, 2004 or later, must be reopened and significantly modified by February 22, 2003 to include the NESHAP requirements.


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Nationwide Permitting (cont’d)…

  • Reopening of the Title V Permit for Cause when additional requirements become applicable (cont’d)…

    • Proceedings to reopen and reissue a permit

      • shall follow the same procedures as apply to initial permit issuance, and

      • shall affect only those parts of the permit for which cause to reopen exists.


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Nationwide permitting (cont’d)…

  • In order to escape complying with the NEHSAP regulations, an existing facility that is currently a major facility has until the compliance date of the NESHAP (August 23, 2004) to become permitted as a non-major (area) source.

  • If a facility uses the material consumption option described in

    Sec. 63.5686(b) to demonstrate that it is not a major source, the facility must start keeping records no later than

    August 23, 2003.


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Florida Permitting for Area Source Boat Manufacturers

  • Permitting Options

    • Federally Enforceable State Operation Permit (FESOP)

    • Air Construction / Air Operation Permits

    • Non-Title V General Permit

  • Exemption


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Florida Permitting for Area Source Boat Manufacturers(cont’d)

  • Permitting Options (cont’d)

    • Federally Enforceable State Operation Permit (FESOP)

      • Good choice for a facility that is currently a major source and wants to become an area source

      • Good choice for an existing area source that has never had an air construction permit and can not qualify for a General Permit.


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Florida Permitting for Area Source Boat Manufacturers(cont’d)

  • Permitting Options (cont’d)

    • Air Construction / Air Operation Permits

      • Good for a new area source facility thatcan not qualify for a General Permit.


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Florida Permitting for Area Source Boat Manufacturers(cont’d)

  • Permitting Options (cont’d)

    • Non-Title V General Permit (GP) for “Polyester Resin Plastic Products Fabrication”

      • Good for most area sources.

      • Gap in material consumption applicability criteria for General Permit and applicability of NESHAP.

        • GP limit: 38 tons per year (tpy)

        • NESHAP limit: less than 50 tpy


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Florida Permitting for Area Source Boat Manufacturers(cont’d)

  • Permit Exemption (No Permit Required)

    • Generic Facility Exemption if the facility emits or has the potential to emit …

      • Less than 1 tpy of any hazardous air pollutant;

      • Less than 2.5 tpy of total hazardous air pollutants;

      • Less than 25 tpy of CO, NOX, and SO2;

      • Less than 1000 pounds per year of lead; and

      • Less than 10 tpy of any other regulated pollutant [example: Volatile Organic Compounds (VOCs)]

        …and there are no unit-specific applicable requirements.


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For further information

call…


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Florida Permitting Authorities

District Air ProgramsPhone #

West Palm Beach 561-681-6600

Ft. Myers941-332-6975

Orlando407-894-7555

Tampa813-744-6100

Jacksonville904-807-3300

Pensacola850-595-8300


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Florida Permitting Authorities(cont’d)

Local Air ProgramsPhone #

Broward County954-519-1220

Dade County305-372-6925

Palm Beach County561-355-3070

City of Jacksonville904-630-4900

Orange County407-836-1447

Hillsborough County813-272-5530

Sarasota County941-378-6128


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