Air Permitting and Compliance Smithfield Foods Environmental Conference Chicago, IL July 2013
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 READ YOUR PERMIT Know what all your air pollution sources are at your plant. ANYTHING WITH A STACK! Is it exempt? If yes, prove it in writing? 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 • 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 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 • 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………………… Opacity • EPA Method 9 Certified • Develop an opacity SOP/EMP • Most states have general opacity statutes of 20%
ODORS.......... • 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 YOUR PERMIT 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 VERIFY THROUGH AN OUTSIDE AUDITOR (VENDOR?) 100% Compliance 100% of the Time
RICE RULE Mostly Effects EMERGENCY GENERATORS Maintenance Records Oil Monitoring Maintenance Plans Minimize Pollution