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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Orlando, FL June 4-6, 2012
Sulfur Oxides (SOx)
Combustion activities (especially fuel oil)
Particulate Matter (PM, PM10, PM2.5)
Volatile Organic Compounds (VOCs)
Carbon Monoxide (CO)
Carbon Dioxide (CO2)
Hazardous Air Pollutant
203 different chemicals
Smoke Generators / Smokehouses
Diesel Fire Pumps
Cook Ovens / Microwave Ovens
Hot Water Heaters
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?
List of all equipment and capacities processing?
hours of operation,
production rates (tn/yr, tn/d),
types of fuel usage
hours of operation
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?
I can’t see………………… processing?
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’
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