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What to Report How to Comply

What to Report How to Comply. Barbara Johnson, PE K-State Pollution Prevention Institute Small Business Environmental Assistance Program. Overview. What to report Tips for proper reporting Future additions or modifications General compliance tips. What to Report?. 40 CFR Parts 60 NSPS

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What to Report How to Comply

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  1. What to ReportHow to Comply Barbara Johnson, PE K-State Pollution Prevention Institute Small Business Environmental Assistance Program

  2. Overview • What to report • Tips for proper reporting • Future additions or modifications • General compliance tips

  3. What to Report? • 40 CFR Parts 60 NSPS • 40 CFR Parts 61 and 63 – NESHAP and MACT Standards • Semi-Annual Reports for Title V Permits • Annual Certifications for Title V Permits • Emissions Inventory (both Class I and Class II permits) • Performance Testing (Protocols, Reports)

  4. And to Whom?

  5. Notifications to Whom? *available at www.kdheks.gov/air-permit/download.html

  6. What to Report? READ YOUR PERMIT! (and understand what it says)

  7. What to Report – NSPS • 40 CFR Parts 60 NSPS (New Source Performance Standards). Applies to: • Categories of sources causing significant air pollution of criteria pollutants • New stationary sources of emissions (construction or modification after date standard is proposed) • Control emissions to level achievable by best system of continuous emission reduction

  8. NSPS Components • Emission limits • Standards for visible emissions • Modification provisions • Monitoring requirements • Performance test methods & compliance procedures • Reporting & recordkeeping requirements

  9. Example – Small Boiler NSPS 40 CFR 60.42 subpart Dc • Installed or modified after June 9, 1989 • Heat input capacity is between 10 and 100 MMBTU/hr

  10. Subject to NSPS?(for boilers <100 MMBtu/hr) The boiler was constructed, modified, or reconstructed after June 9, 1989 The heat input capacity of the boiler is between 10 and 100 MMBtu/hr Complete the expedited KDHE boiler form Yes Yes No No The boiler is not subject to NSPS requirements

  11. Evaluating Permit Needs • Identify for all boilers: • Date of installation or modification • Heat input capacity (typically in MMBTU/hour) • Type of fuel (natural gas, fuel oil, etc) • Back-up fuel: evaluate using fuel with greater PTE • Low NOX burner (for natural gas-fired boilers)

  12. KDHE Boiler “Sheltered” Initiative • KDHE is assisting boiler owners w/coming into compliance without incurring a penalty • Applies to companies or institutions that have boiler(s) with heat input capacity between 10 and 100 MMBtu/hr and installed after June 9, 1989 (i.e., those subject to NSPS reporting)

  13. KDHE Boiler “Sheltered” Initiative • Company/institution must evaluate need for air permit/approval • Complete applicable permit applications • Expedited approval or permit • NSPS boiler form • Must be in compliance by September 30, 2008

  14. Tips for NSPS Reporting • Air quality performance test guidelines • www.kdheks.gov/air-permit/forms/ Performance_Test_Guidelines.pdf • KDHE visible emission observation form • www.kdheks.gov/air-permit/forms/KDHE_VE_form.pdf • Performance test companies • www.kdheks.gov/air-permit/forms/stack_testers.pdf • KDHE NSPS notification form • www.kdheks.gov/air-permit/forms/NSPS%20Notification.pdf

  15. NSPS notification form: www.kdheks.gov/air-permit/forms/NSPS%20Notification.pdf

  16. What to Report - MACT • 40 CFR Parts 61 and 63 – NESHAP (Nat’l Emission St’ds for Hazardous Air Pollutants) and MACT (Maximum Achievable Control Technology) Standards. Applies to: • Sources of HAP emissions within certain source categories • Mostly major sources, some area sources

  17. MACT Components • Compliance standards • Compliance dates – often 3 years after rule promulgated • Operation and maintenance requirements • Compliance with emission standards • Notification & conduct opacity or visible emission observations • Availability of records • Performance testing requirements • Monitoring requirements • Initial notification requirements – due 120 days after rule promulgated • Initial Compliance Status Report – due anywhere between 30 days to one year after the rule compliance date • Recordkeeping and reporting requirements • Control device requirements

  18. Tips for MACT Reporting • Initial notification form – send to KDHE & EPA • KDHE spreadsheet template (styrene) • SBEAP compliance calendar (dry cleaners) • EPA Web resources: www.epa.gov/ttn/atw/mactfnlalph.html

  19. www.epa.gov/ttn/atw/mactfnlalph.html

  20. Initial Notification Form

  21. What to Report – Class I Permit • Class I operating permit overview • Semi-Annual Reports for Title V (Class I) Permits • Class I annual certification – CR-02 • Emissions Inventory • Performance testing

  22. Class I Operating Permit Overview for Compliance • Permit Intent – identifies the pollutants that are over the major source threshold to require the operating permit • Facility Description – process units evaluated and description of the facility process

  23. Class I Operating Permit Overview for Compliance con’t • Emission Source Information – detailed emission units description, stack/vent ID, control equipment, and applicable regulations • Applicable Regulations – • Emission Source • Limit or Standard • Monitoring • Recordkeeping and Reporting

  24. Class I Operating Permit Overview for Compliance con’t • Opacity Summary – summarizes opacity requirements from the applicable requirements section • Facility-Wide Applicable Requirements – facility is subject to comply with, if applicable (e.g. Annual Fees, Emission Inventory, Emergency Episode Plans, Chemical Accident Prevention)

  25. Class I Operating Permit Overview for Compliance con’t • Opacity Monitoring – methodology used to perform qualitative assessments and/or Method 9’s, when required • Requirements which will become effective during the term – any new regulation(s) that weren’t applicable at the time of the issuance but will become effective during the 5 year permit term

  26. Class I Operating Permit Overview for Compliance con’t • Permit Shield – conditions that are deemed in compliance with applicable requirements of the Kansas Air Quality Program as of the date of permit issuance • Test, Monitoring, Recordkeeping, and Reporting – guideline(s) to assure compliance with the terms and conditions of the permit

  27. Class I Operating Permit Overview for Compliance con’t • Temporary Replacement of Internal Combustion Engines – guideline(s) and provision(s) for when an internal combustion engine is authorized to operate pursuant to the terms of this permit is out-of-service because of repair or maintenance • Reporting of Deviations from the Permit Terms – unless a different period is specified in this permit, guideline(s) for reporting deviations from the requirements of this permit

  28. Class I Operating Permit Overview for Compliance con’t • General Provisions • K.A.R 28-19-11 • K.A.R 28-19-752a • K.A.R 28-19-753 • Permit Term and Renewal • Compliance • Compliance Certification • Emergency • Inspection and Entry • Permit Amendment, Modification, Reopening, and Changes not requiring a permit • Duty to provide information • Duty to supplement • Other Permit and Approvals; Applicability • Submissions

  29. Tips for Semi-annual Report • Copy permit conditions • Indicate whether or not in compliance • Review permit for new qualitative assessment language (see next slide) • Report deviations • KDHE technical guidance documents – BAR 2005-01 www.kdheks.gov/air-permit/forms/2005- 01_KAR_28-19-11.pdf • KDHE technical guidance documents – BAR 2006-01 www.kdheks.gov/air-permit/forms/2006- 01_Reporting_Deviations.pdf • KDHE example semi-annual report www.kdheks.gov/air-permit/forms/Example_SemiAnnual_Report.pdf

  30. Qualitative Assessments • Initial Permits • All sources listed • Required 2 Method 9’s per year and qualitative assessments • Opacity monitoring requirements detailed in the applicable requirements • Procedures provided in Facility-Wide Applicable Requirements section

  31. Qualitative Assessments (con’t) • Renewal and New Permits (as of mid 2005) • No source list (except sources subject to 40% opacity requirement) • Facility must determine which sources require assessments • Monthly qualitative assessments by a knowledgeable observer • Procedures provided in Facility-Wide Applicable Requirements section

  32. Example semi-annual reportwww.kdheks.gov/air-permit/forms/Example_SemiAnnual_Report.pdf

  33. What to Report – Class I Permit • Annual Certifications for Title V (Class I) Permits • KDHE CR-02 form • Provides certification of facility compliance status of each condition of the permit • If non-compliance – summarize nature, duration, and frequency • Submit to KDHE and EPA Region VII

  34. Annual Certificationwww.kdheks.gov/air-permit/forms/CR-02_Annual_Certification.pdf

  35. What to Report – Emission Inventory Annual Emissions Inventory • Class I Permit or applied for Class I • Due June 1 • Can submit electronically – need password • Forms for mailing available on Web • Class II Permit • Due April 1 • Forms available on Web, specific to industry • Class II Permit-by-rule, 50% actual emissions • Due February 15 • Reminder letter sent in December – no forms sent

  36. Tips for Air Emissions Inventory Reporting www.kdheks.gov/emission/EmInfaq.html

  37. What to Report – Performance Tests Performance testing: • Required by NSPS, MACT, other (RACT) • Required by Acid Rain regulations • Required by other Kansas regulations • Required by State Approvals/Permits and/or an enforcement actions • Protocols – due 30 days prior to testing • Reports – due 60 days after testing or specified in the subpart • Read permit conditions

  38. Tips for Performance Testing www.kdheks.gov/air-permit/forms/Performance_Test_Guidelines.pdf

  39. Performance Test Report Requirements

  40. Future Additions or Modifications • Evaluate PTE for new or modified equipment. • If increase in PTE exceeds construction approval or permit thresholds, submit application. • Thresholds: www.sbeap.org/publications/ airqual.pdf • Forms: www.kdheks.gov/air-permit/download.html

  41. When to Notify • Air construction approval/permit • New emission source • Increased emissions due to expansion or process change • Prior to start of construction or modification

  42. Tips for Construction Permits www.kdheks.gov/air-permit/forms/Informational_Sheet.pdf

  43. Tips for Construction Permits www.kdheks.gov/air-permit/forms/Pre_Construction.pdf

  44. When to Notify • Operating permit • New emission source • Increased emissions due to expansion or process change • Notify KDHE • New – one year after initial start up • Existing • Class I – one year after initial start up • Class II – six months after initial start up

  45. Other Reporting Emergency Generators • Emergency generator definition • Used only for back-up power (not to offset peak energy usage) • For PTE calculations, assume 500 hours/year • All emergency generators should be registered with KDHE • Expedited form available

  46. Expedited Form www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

  47. Other ReportingChange of Ownership/Operator/Name Notification

  48. KDHE/SBEAP Compliance Assistance • Encourage emission sources to: • Notify KDHE, if subject to any applicable regulations • Understand and comply with applicable regulations • Reduce air pollutant emissions beyond minimum requirements • How? • Conference/workshop presentations • Webcasts • Mass mailings • Telephone consultations • Site visits

  49. Who performs inspections? • BEFS – KDHE district office personnel through a Memorandum of Understanding with BAR • Major and synthetic minor sources • Local partners • Johnson County • Sedgwick County • Shawnee County • Wyandotte County • US EPA Region VII (Limited)

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