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Air Permitting and Compliance. Smithfield Foods Environmental Conference Orlando, FL June 4-6, 2012. Nitrogen Oxides (NOx) Combustion activities Sulfur Oxides (SOx) Combustion activities (especially fuel oil) Particulate Matter (PM, PM10, PM2.5) Combustion activities Rendering activities

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Air permitting and compliance

Air Permitting and Compliance

Smithfield Foods

Environmental Conference

Orlando, FL June 4-6, 2012


Nitrogen Oxides (NOx)

Combustion activities

Sulfur Oxides (SOx)

Combustion activities (especially fuel oil)

Particulate Matter (PM, PM10, PM2.5)

Combustion activities

Rendering activities

Cooking operations

Volatile Organic Compounds (VOCs)

Combustion activities

Rendering operations

Carbon Monoxide (CO)

Combustion activities

Carbon Dioxide (CO2)

Combustion activities

Hazardous Air Pollutant

203 different chemicals

Conventional Pollutants


What are some typical air pollution sources for meat processing?

Boilers

Smoke Generators / Smokehouses

Parts Washers

Diesel Fire Pumps

Emergency Generators

Cook Ovens / Microwave Ovens

Rendering Cookers

Hot Water Heaters

Biogas Flares

Control Equipment: Scrubbers /Baghouses


Review Air Permits processing?

READ YOUR PERMIT

Know what all your air pollution sources are at your plant. ANYTHING WITH A STACK! Is it exempt? If yes, where is the written explanation of the exemption?

Document Permit Requirements/Due Dates/Frequency/Whose Responsible

Ensure appropriate records are kept!

IMPORTANT: When does the permit expire. You won’t get a new permit tomorrow


Gap Analysis processing?

  • For emission sources without permits – assure that exemption requirements are met. Be prepared to prove to a regulator that the source is exempt!!!

  • Review new production initiatives – need an air permit?



List of all equipment and capacities processing?

Allowable emissions

Limits:

hours of operation,

production rates (tn/yr, tn/d),

types of fuel usage

Records Requirements:

hours of operation

production throughputs

fuels used

monthly emissions

throughputs: flow rates, pressure drops, other monitoring information

operations and maintenance plan

Requirement to perform stack test, annual emissions inventory, report accidents / excessive emissions / etc

Requirement to perform annual boiler tuning (good idea anyway)

Requirement to have O&M Plan. Basically how to operate and take care of all your air permit related equipment.

What is in a typical air permit?


On Going Requirements processing?

  • Review potential to emit calculations annually

  • Conduct actual emission calculation annually

  • Review maintenance and inspection records for air pollution control devices


I can’t see………………… processing?

Opacity

  • EPA Method 9 Certified

  • Develop an opacity SOP/EMP

  • Most states have general opacity statutes of 20%


ODORS.......... processing?

  • Date & time of complaint

  • Name, address & phone # of complainant

  • Weather conditions (wind speed & direction, temperature, overcast, rainy, or sunny)

  • Findings if any discernable odors beyond property boundary

  • Investigation notes from specific complaint

  • Date & time of inspection

  • Inspection conducted by:


UNDERSTAND processing? YOUR PERMIT (and its referenced regulations)

DOCUMENT ALL REQUIREMENTS:

LET WEBEMS BE YOUR FRIEND

Use ‘Monitoring and Measurement matrix’

Use ‘Operational Control matrix’

Use ‘Document Control matrix’

Use ‘Record Retention matrix’

Use ‘Training matrix’

TRAIN

VERIFY THAT THE RECORDS ARE ROUTINELY KEPT

VERIFYTHAT THEY ARE FILED APPROPRIATELY

VERIFYTHAT THE MONITORING IS CORRECT (competence)

VERIFY THROUGH AN OUTSIDE AUDITOR (VENDOR?)

100% Compliance 100% of the Time


Questions
???Questions??? processing?


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