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Air Permitting November 14, 2001 Keith Jordan Environmental Scientist Sr. OES/Permits Division (225) 765-0201 [email protected] Organization of Permits Division. Air Reviewers by Section. Petrochemical: 11 Level 1: 13 Level 2: 5 Municipal/Commercial: 0

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Air PermittingNovember 14, 2001Keith JordanEnvironmental Scientist Sr. OES/Permits Division(225) [email protected]



Air reviewers by section
Air Reviewers by Section

  • Petrochemical: 11

  • Level 1: 13

  • Level 2: 5

  • Municipal/Commercial: 0

  • Registrations/Certifications: 0


Petrochemical permits
Petrochemical Permits

  • Catalyst Regenerators

  • Ethanol plants

  • Herbicide Manufacturers

  • Organic Chemical Producers

  • Pesticide Manufacturers

  • Refineries


Level 1 industrial
Level 1 Industrial

  • Bulk terminal/storage (petroleum)

  • Oil & Gas exploration, production and development

  • Pipelines

  • Paper mills / Sawmills

  • Ship/boat building & repair (includes ships, boats, barges)

  • Power Generating


Level 2 industrial
Level 2 Industrial

  • Concrete/Asphalt Plants

  • Auto Repair Shops

  • Transportation (Airports)

  • Food Processing Facilities

  • Animal Farms

  • Machine Shops

  • Sandblasting/Painting


Municipal and commercial waste
Municipal and Commercial Waste

  • Municipal Solid Waste Landfills

  • Commercial Hazardous Waste treatment, storage, disposal facilities

  • Municipal Sewage Treatment Facilities

  • Construction and Demolition Debris Landfills

  • Waste Tire Processing



Air permitting universe
Air Permitting Universe

  • Criteria pollutants

    • NOx, CO, SO2, VOC, PM

  • Toxic Air Pollutants

    • Federal and state list, ~200 total

  • “Air contaminants” broad inclusion

  • Universe of Sources

    • ~ 800 criteria pollutant major sources

    • ~ 250 air toxic pollutant major sources

    • Very large universe of minor sources

  • Issue ~1000 permit actions yearly

  • Issue ~1000 other actions yearly

    • Applicability, exemptions, ownership


Air permit program
Air Permit Program

  • 2 Combined Federal Permit Programs

    • New Source Review (PSD, Nonattainment)

    • Operating Permit (Title V, Part 70)

  • History

    • Began air permitting in 1969, “grandfathered” existing facilities

    • Permits utilized to address both state and federal requirements/concerns

    • Preconstruction program approved by EPA in State Implementation Plan (SIP)

    • Title V program approved by EPA in 1995


New source review nsr
New Source Review (NSR)

Encompasses:

Prevention of Significant Deterioration (PSD)

LAC 33:III.509

Nonattainment New Source Review (NNSR)

LAC 33:III.504


PSD

Steps in LDEQ review process


2 determine major source status lac 33 iii 509 b

1. Administrative completeness review (AVT)

  • Don’t forget 1701 forms. They’re the most common request by AVT.

  • Approximately 30 days (60 day regulatory limit).

2. Determine major source status. (LAC 33:III.509.B)

The source is major if:

It is listed in Table A of LAC 33:III.509 and it emits, or has the potential to emit, 100 tons per year or more of any attainment pollutant; or

It emits, or has the potential to emit, 250 tons per year or more of any attainment pollutant; or

Any physical change at an existing minor source, if the change would constitute a major stationary source in and of itself. This modification is not eligible for netting.


3 determine if a modification has occurred

3. Determine if a modification has occurred.

Review not only the source(s) in question, but also any upstream or downstream sources affected by the project.

  • Upstream sources may include additional steam demand from a boiler, increased throughput from tanks, etc.

  • Potential-to-emit of downstream sources may be increased due to debottlenecking.

Can the change be classified as routine repair and replacement?

Is the change due to another exemption outlined in the definition of major modification? LAC 33:III.509.B


4 determine if the increase is significant

4. Determine if the increase is significant.

An increase in a pollutant is significant for PSD if:

Facility is a new major stationary source and a pollutant is emitted in amounts equal to or greater than its specified significance level; or

Facility is an existing major stationary source and both the potential increase in emissions due to the modification itself, and the resulting net emissions increase is equal to or greater than its specified significance level; or

Any emissions rate at a new major stationary source (or any net emissions increase associated with a modification to an existing major stationary source) that is constructed within 10 kilometers of a Class I area (Breton Sound), and which would increase the 24-hour average concentration of any regulated pollutant in that area by 1 ug/m3 or greater.


6 review bact

5. Determine the proper contemporaneous period/review netting analysis.

6. Review BACT.

Required for sources that undergo physical change or change in method of operation.

Each BACT analysis is done on a case-by-case basis.

Top-down analysis ranks all available control technologies in descending order of effectiveness.

Sources of information include but are not limited to the RACT/BACT/LAER Clearinghouse.

http://209.42.208.109/rblc/cfm/rbeasy.cfm

Ensure that any reductions claimed are based on actual emissions, NOT permitted emissions.


7 make sure other analyses have been completed

  • Modeling exercises (Patrick Pakunpanya) netting analysis.

  • Source related growth impacts

  • Soils, vegetation, and visibility impacts

  • Class I area impacts (Breton Sound)

  • Toxic emissions impact (Chapter 51 or 112(g), if applicable)

7. Make sure other analyses have been completed.

8. Public notice:

9. Draft Basis of Decision.

30-day public review period

30-day EPA review period

  • Required for all PSD permits.


Nnsr steps in ldeq review process 1 administrative completeness review avt

NNSR netting analysis.

Steps in LDEQ review process

1. Administrative completeness review (AVT)


2 determine major source status lac 33 iii 504 g

2. Determine major source status. (LAC 33:III.504.G) netting analysis.

The source is major if:

It emits, or has the potential to emit, 50 TPY or more in a serious nonattainment parish (see Table 1 in 504); or

Any physical change at an existing minor source, if the change would constitute a major stationary source in and of itself. This modification is not eligible for netting.

Notes:

Fugitive emissions shall not be included in the major source determination unless: The source is listed in Table A on LAC 33:III.509 or the stationary source category is being regulated under Section 111 or 112 of the Act.

A stationary source shall not be a major stationary source due to secondary emissions.


4 determine if the increase is significant1

3. Determine if a modification has occurred. netting analysis.

See definition of modification (PSD section).

4. Determine if the increase is significant.

An increase in a pollutant is significant for NNSR if it:

Occurs at a new major stationary source and VOC emissions are greater than or equal to 50 TPY; or

Occurs at an existing major stationary source, and the net emissions increase is equal to or greater than 25 TPY.

See Table 1 in 504.

5. Review netting analysis if increase is greater 5 TPY.


Like psd ensure that any reductions claimed are based on actual emissions not permitted emissions

6. Determine the proper contemporaneous period. netting analysis.

7. If “netting out,” check to see source has sufficient ERC in the bank.

Currently, sources must have banked ERC to “net out.”

8. Review LAER and/or check to see if the necessary offsets are available.

Like PSD, ensure that any reductions claimed are based on actual emissions, NOT permitted emissions.


9. Public notice: netting analysis.

  • 30-day public review period

  • 30-day EPA review period

  • If NNSR review is accomplished through the Title V process, EPA will have 45 days to review significant modifications.


Title V netting analysis.


Title v
Title V netting analysis.

  • Required for all major sources [LAC 33:III.502].

  • Permits have five year life span.

  • Renewal applications must be received at least six months prior to the date of permit expiration, but no earlier than eighteen months prior to expiration.



Title v permit renewal status
Title V Permit Renewal Status netting analysis.

  • Currently, we have 88 General Permit renewals and 9 Regular Permit renewals in-house.

  • All Title V General Permits will be renewed through TEMPO:

    • First draft of General Permit Templates under review.

    • Regulations are being added to the Requirements Library.

    • Implementation of General Permits renewal program tentatively scheduled for April, 2002.


Title v permit renewal status cont
Title V Permit Renewal Status (Cont.) netting analysis.

  • All Title V Regular Permits will be renewed through current methods.



Initial title v permits status
Initial Title V Permits Status netting analysis.

  • Currently, we have 324 initial Title V Permits under review.

  • EPA has tentatively requested that we issue all remaining permits within 18 months.

  • As part of our agreement, DEQ must implement a schedule of permit issuance deadlines and submit it to EPA.

  • We will send out letter to all affected companies and ask for suggested schedule per company.


Title v permit renewal status cont1
Title V Permit Renewal Status (Cont.) netting analysis.

  • Suggested schedule will give companies time to update each application while giving DEQ time to issue permit.

  • I will be primary contact for this project:

    Keith JordanEnvironmental Scientist Sr.

    OES/Permits Division(225) [email protected]


Other Permit Actions netting analysis.


Other permit actions
Other Permit Actions netting analysis.

  • State Permits

  • Title IV (Acid Rain Permits)

  • Emissions Banking (ERCs)

  • Exemptions

  • Variances

  • Name/Ownership Changes

  • Determinations


Air permit content
Air Permit Content netting analysis.

  • Origin and Description

  • Facility wide emission limits

  • Site specific requirements (specific conditions)

  • Applicable regulatory standards

  • Testing, monitoring and reporting requirements

  • Lb/hr and ton/year limits by emission point by pollutant


Common errors in applications
Common errors in applications netting analysis.

  • Failure to use actual to potential to determine the increase for a project - particularly common if permitted limits do not have to be modified.

  • Contemporaneous reductions based on potential-to-emit rather than actual emissions (2-year annual average).

  • Including paper changes (i.e., decreases based on emission factor changes, stack test results, etc.).

  • Addressing sources that were never constructed.


Common errors in applications cont
Common errors in applications netting analysis.(Cont.)

  • Taking credit for all reductions where baseline was above permitted limits.

  • Failing to consider only increases when determining if a netting analysis is required.

  • Failure to include 1701 form when required. This is the most common request by Application Verification.


Suggestions to facilitate process
Suggestions to facilitate process netting analysis.

  • Complete an adequate IT analysis, with special attention to the alternative sites analysis.

  • Submit application as far in advance as possible.

  • Include detailed reference or background information with application.

  • Alert permit writer of any unusual situations or concerns.


Suggestions to facilitate process cont
Suggestions to facilitate process netting analysis.(Cont.)

  • Don’t underestimate public interest in the proposed facility or project. Hold informational meetings with community if necessary.

  • Notify permit writer of any changes in company’s priority of the application, particularly if the construction schedule has been delayed. Please. . .

  • Submit LPDES application and air application concurrently.

  • If possible, the Department prefers to hold joint air and water public hearings.


Air monitoring and reporting
Air Monitoring and Reporting netting analysis.

  • Stack testing

    • As required by rules

    • As determined appropriate

  • On-going monitoring of operating parameters, specific to source

  • Monitoring and Compliance reporting

    • 7 days, quarterly, semiannual, annual

    • Must report any emission exceedance, any permit deviation

    • Major sources must certify compliance status annually

  • Annual reporting of actual emissions


Air quality modeling
Air Quality Modeling netting analysis.

  • Permit application review includes dispersion modeling

  • Federal PSD and Nonattainment

  • State air toxics modeling protocol

    • Designed to assure compliance with Louisiana Ambient Air Standards

    • Includes cumulative modeling of surrounding sources


Performance indicator for deq permitting
Performance Indicator for DEQ Permitting netting analysis.

  • Based on “410-day Rule” (RS 30:2022 & LAC 33:I.Ch 15)

  • Quarterly & FY goals for final permit decisions, based on applications for new facilities & major mods reaching 410-day deadline

  • Goal for FY 2000-2001: 75%

  • Actual: 80%


Public participation process improvements
Public Participation Process netting analysis. Improvements

  • Created Central Public Records Room, 4th floor

  • Provided public access to ALPS, 4th floor

  • Created Public Notice Web page

  • Working with State Library Association to improve document handling at libraries

  • Combined public hearings


Public participation process response to comments
Public Participation Process netting analysis.Response to Comments

  • The PP Group maintains records of all individuals who submit written comments or provide oral comments at public hearings.

  • When a final decision is made, Permit Writers send notice of response to comments and basis for decision to all commentors.


Air Permitting netting analysis.November 14, 2001Keith JordanEnvironmental Scientist Sr. OES/Permits Division(225) [email protected]


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