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Air Permitting and Compliance

Air Permitting and Compliance. Clean Air Act Basics & Primer Construction Permitting Title V/Operations Permitting Typical Activities Requiring Permits/Permit Modifications Information Needs /Review Process. Air Permitting and Compliance Con't.

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Air Permitting and Compliance

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  1. Air Permitting and Compliance • Clean Air Act Basics & Primer • Construction Permitting • Title V/Operations Permitting • Typical Activities Requiring Permits/Permit Modifications • Information Needs/Review Process

  2. Air Permitting and Compliance Con't. • Emission Quantification, Tracking & Reporting (AETS, 12-Month Rolling Average, Annual Inventories, etc.) • CFC/HCFC (“Refrigeration”) • RMP (PSM Relationship) • General “Air” Summary • Code Of Fed. Reg./General Air Links

  3. Air Permitting and Compliance Clean Air Act Basics • CAA History • NAAQS • NSPS/NESHAP • 1970 Orig. CAA, 1977 CAAA (PSD), 1990 CAA Amendments

  4. Clean Air Act Basics • CAA Dates Back To 1970’s • 1970 CAA Contained NSPS @ Part 60 & NESHAPS @ Part 61 = Risk-Based/Few Perfect Stds. Covering Only 8 HAPS • Great Deal Of Non-Compliance W/ Orig. Intent Of 1970 CAA • Only Handful Of NSPS/NESHAPS Promulgated From 1970 To Mid 1980’s • CAA Amended 1990(Former Pres. Bush)

  5. Clean Air Act Basics Con't. • 1990 CAAA Designed To Curb 3 Major Threats To Human Health & Environ. = Acid Rain, Urban Air Pollution, & Toxic Air Emissions • National Permits Program Established To Make Law Workable & Enforceable • Phase Out Ozone-Depleting Chemicals, Add Research & Development, Add RMP

  6. Clean Air Act Basics Con't. • Encourage Market-Based Principles = Performance Based Stds. (Vs. Risk-Based Stds.) AND Emission Banking & Trading • Set Stds. For Alternative Clean Fuels = I.D. Best Combo Of Fuels & Technology • Limit Fossil Fuel Sulfur Content AND Promote Innovative Control Technology Via Acid Rain Program

  7. Clean Air Act Basics Con't. • Cut U.S. Import Oil Dependency By 1MM Barrels/Day • Promote Energy Conservation Via Acid Rain Program = Utilities Receive Credit For Emission Reductions Via Customer Programs Encouraging Energy Conservation

  8. Air Permitting & Compliance Clean Air Act Primer • Basis For Limits • Ambient Air/NAAQS • Regulated Pollutants, SIP & PSD • 1990 CAAA Overview (Titles I, III & V) = Attain/Maintain NAAQS, HAPs, Ops. Permit • BACT/MACT/LAER • Risk Mgt. Planning (RMP) • Potential To Emit (PTE)

  9. Clean Air Act Primer • Regulation Of Air Emission Sources: Emission Stds., NAAQS • Emission Limits: Lbs/Hour, Tons/Year, Lbs/Ton, Lbs/MMBTU, % Opacity, % Efficiency, etc. • Basis For Limits: 1970 NSPS @ Part 60, 1970 NESHAP @ Part 61, SIP’s, 1990 NESHAP (Stationary Source Categories), Acid Rain @ Parts 73 & 76, Stratospheric Ozone @ Part 82

  10. Clean Air Act Primer Con't. • What Is Ambient Air? That Portion Of The Atm., External To Bldgs., To Which The General Public Has Access --- Typically Site Boundary Outward If Have Perimeter Fencing --- Attainment Demonstrated Via Air Disp. Modeling & Ambient Monitoring • NAAQS: Micrograms/Cubic Meter & Based On “Acceptable Risk” – (1 : 1,000,000 CR) • NAAQS Basis: NAAQS @ Part 50, PSD 1977 CAAA @ Part 52, & State Stds.

  11. Clean Air Act Primer Con't. • Primary NAAQS: Set @ Levels “Allowing An Adequate Margin Of Safety…Requisite To Protect The Public Health” • Secondary NAAQS: Set @ Levels To Protect “The Public Welfare” • Regulated Pollutants: PM-10 (PM-2.5 Soon?), SO2 (Sulfur Dioxide), NO2 (Nitrogen Dioxide), O3 (Ozone/VOC), CO (Carbon Monoxide) & Pb (Lead) --- “Criteria Pollutants” = TSP/PM, SOx, NOx, VOC, CO & Pb (Const. Permits)

  12. Clean Air Act Primer Con't. • SIPs: Attain/Maintain NAAQS, Establish Emission Limits, Review Impacts Of New Growth, Revised As New Regs. Are Passed • PSD: Prevent Sig. Deterioration = Const. Permitting Via 1977 CAAA --- Based On “Potential Emissions”, Regulates Emissions & Ambient Air Quality, Affects Lg. Sources • PSD Goals: Allow Economic Growth While Protecting Air Resources, Protect Public Health & Welfare, & Enhance Air Quality

  13. Clean Air Act Primer Con't. • PSD Review Req.: Ambient Monitoring, Dispersion Modeling, Control Device Review, Additional Impacts, Class I Assessment (Not Title V Class I) = Impacts To Soils, Plant Life, Visibility, --- National Parks, etc. • 1990 CAAA Overview (11 Titles - 3 Main): • *Title I = Attain/Maintain NAAQS • *Title III = HAPs/Air Toxics • *Title V = Permits/Operating Permits

  14. Clean Air Act Primer Con't. • Title I (Attain/Maintain NAAQS): *“Attainment” Of NAAQS Req. For Const. Permitting (i.e., PSD)To Apply *”Non-Attainment” Of NAAQS PSD Not Applicable & Any Proposed Project/Mods. Must Actually Reduce Overall Emissions

  15. Clean Air Act Primer Con't. • Title III (HAPs): *Previous Approach = Risk-Based, W/ Few Perfect Stds., Which Covered Only 8 HAPs *New Approach = Technology-Based Stds., Emission Reductions For 188 HAPs That Apply To “Major” & “Area OR Minor” Sources Of HAPs --- See Link To List Of 1990 CAAA HAPS* & Defn. Of VOC* = I.D.’ed @ End Of Presentation

  16. Clean Air Act Primer Con't. • Title III (HAPs) Cont.: *HAP Emission Source: “Major” Stationary Source = Contiguous Area, Common Control, W/ > 10 TPY Single HAP OR 25 TPY Aggregate HAP --- “Area” Source Is One That Is Not Major (Must Include Fugitive) *MACT: Max. Achievable Control Tech. --- New Sources = Meet Best Controlled Similar Source --- Existing Sources = Ave. 5 Best (>30 Sites) OR Ave. Best 12% (<30)

  17. Clean Air Act Primer Con't. • Title III (HAPs) Cont.: • *Interim MACT (BACT = Best Avail. Control Technology): Transitional Program Until All MACT Stds. Are Issued, Applies To Constructed & Re-Constructed Sources • Title III (Accidental Releases = RMP): • *Risk Mgt. Plans For Listed Chemicals (Flammable & Toxic Lists) That Exceed Threshold Amounts --- “General Duty” Clause --- Extension Of OSHA PSM

  18. Clean Air Act Primer Con't. • Title V (Operating Permits): *Single Enforcement Document To Assist Both Industry & Regulators *Applicability: HAPs @ 10 TPY Single OR 25 TPY Aggregate; Criteria Pollutants 100 TPY --- All Based On Potential To Emit (PTE) = Annual Emission/Actual Hrs. Ops. * 8,760 *PTE: Max. Emissions Continuous Ops. (8,760 Hrs/Yr) W/ No Controls Except Fed. Enforceable Permit Restrictions = NSPS, NESHAP, BACT/MACT/LAER, Permit Cond.

  19. Air Permitting & Compliance Construction Permitting • When Required? “Allowable Emissions” Increase/Decrease OR When Modify Process &/Or Control Equipment (Even “Like Kind” Replacement) = Not One Size Fits All! • Proposed Changes That Increase “Potential Emissions” By The Following (PSD Sig.): *PM @ 25 TPY Or >, PM-10 @ 15 TPY Or >, SOx, NOx, OR VOC @ 40 TPY Or >, CO @ 50 TPY Or >, Pb @ 0.6TPY Or >, Single HAP @ 2.5 TPY/Combined HAPs @ 10 TPY Or >

  20. Construction Permitting Con't. • ”Allowable Emissions” = Emissions Rate Of Stationary Source Calc. Using Max. Rated Capacity Of Source (Unless Fed. Enforceable Limit Applies) AND Most Stringent Of NSPS, NESHAP, SIP, OR Existing Permit Condition(s) • Must Quantify Past Actual To Future Potential = NOT Potential To Potential, etc. • Must I.D. Whether NESHAP Applicable (“Major” Source 10/25 TPY PTE) W/ HAP Increase Of 2.5/10 TPY PTE Proposed

  21. Construction Permitting Con't. • Many Proposed Mods. Involving HAPs Require Some Form Of BACT Analysis = BACT Is Analysis To I.D. Max. Degree Of Emission Reduction Achievable Considering Energy, Env., & Economic Impacts (Other Than Costs) --- Typically $3K To $4K/Ton Pollutant Removed Is Cut Off --- Must @ Least Be As Stringent As NSPS Or NESHAP --- BACT Is An Interim Step Towards MACT/NESHAPS Scheduled For Future But Have Yet To Be Promulgated ---See Proposed Rule ISSN 1521-9402 Link *

  22. Construction Permitting Con't. • Proposed Rule ISSN 1521-9402 * Would Regulate HAP Emissions From Coatings/ Paints Applied To Misc. Metal Parts & Products --- It Would Only Apply To “Major” Sources Of HAPs (i.e., PTE >10 TPY Single HAP OR >25 TPY Of Combined HAPs) • Est. Reg. To Cost Metal Coating Industry $57MM/Year = Added Costs Incurred For “Control” Of Emissions (Capture-&-Reclaim Systems, More Costly Reformulated Subs., etc.) --- Powder Vs. Wet Painting Benefit!

  23. Construction Permitting Con't. • Dispersion Modeling: Is Used To Demonstrate Compliance W/ NAAQS, Is Required For PSD, Is not Typically Performed For Minor Source Permits = Most Likely Not Required For Valmont Locations --- Background AAQ Monitoring • Non-Attainment Permitting: Offsets, LAER, All Other Sources In State Must Be In Compliance, Alternative Sites May Be Assessed To I.D. If Source Could Go To Another Area Reasonably

  24. Construction Permitting Con't. • Application Contents: General Info. About The Source, Process Info., Fuel Combustion Data, & Certification --- Supplemental Info. May Include Air Dispersion Modeling, Control Technology Review (BACT For PSD AND/OR HAPs, & LAER For Non-Attainment Areas), & Class I Impacts Analysis (NOT Title V Class I Terminology)

  25. Construction Permitting Con't. • PSD Permitting Almost Certainly Will Not Be Applicable For Valmont Locations = Requires “Major” Source I.D. Via Const. Permit Regs. = 250 TPY/Criteria Pollutant (Except For The 28 Listed Sources = 100 TPY/Criteria Pollutant) Prior To Const. Event AND Const. Event In & Of Itself Must Be “Significant” Per PSD Thresholds • 8 HAPS Regulated By PSD = Asbestos, Beryllium, Mercury, Vinyl Chloride, Fluorides, Sulfuric Acid Mist, Hydrogen Sulfide & Total Reduced Sulfur

  26. Construction Permitting Con't. • “Non-Attain. Area” - Area That Is Not Meeting NAAQS (i.e., CA Trip Reduction Reqs. If >30-40 People – Ozone/Smog, etc.) • “Attainment/Non-Attainment” Status Are On A Pollutant By Pollutant Basis • Overall Reduction Of 10% To 50% Req. = Can Be Costly & Prevent New Industry From Entering Or Existing Industry From Expanding Operations In A Particular Area • Ultimately, The NAAQS Would Be Achieved Over Time

  27. Air Permitting & Compliance Operations Permitting • When Is An Operating Permit Required? *These Are Generally State Specific Req. Based From 40 CFR Part 70 • Various Permit Types W/ Assoc. Req. Exist *Class I Or Title V Major = >100 TPY (PTE & Actual) PM/TSP, PM-10, SOx, NOx, & CO; Pb >5 TPY; HAP (Single) >10 TPY; & HAP (Combo) >25 TPY *Class II Syn. Minor, Voluntary, OR FESOP = PTE > “Major Source” & Actuals < “Major”

  28. Operations Permitting Con't. *Class II Minor Or Small Source Permit = PTE < “Major Source” W/ Actuals <50% “Major Source” Thresholds OR < “Significant Increase Thresholds” By PSD/Pre-Const. Permit Thresholds *VOC General Permit Alternative In Some States = Actuals Remain < Class I VOC/HAP *No Permit Req. = When PTE & Actuals Either Under “Major Source” Thresholds OR Both Are < “Sig. Increase Thresholds” By PSD/Pre-Const. Permit Thresholds

  29. Operations Permitting Con't. • Permit Limits & Content: Citation Authority For Each Applicable Req., Future Req., Alternative Operating Scenarios, Permit Shield, Monitoring & Record Keeping Req., Voluntary Limits & Expiration Date = Typically Effective For 5 Year Period • ”App. Shield” = Allows Facility To Operate W/O Permit While App. Being Reviewed • “Permit Shield” = Protect Facility From Enforcement So Long As Comply W/ Existing Permits

  30. Operations Permitting Con't. • Federal Enforceability: Ensures Conditions Placed On Emissions Are Enforceable By EPA & Citizens (Ops. Permit, Limits By Rule, General Permits, & Const. Permits) • Applicable Req.: A Provision, Std., Or Req. In Any Reg. Or Statute As Applied To An Emission Unit = Emission Limits, NESHAPs, Air Quality Permits/Regs., etc. • Compliance Determination/Demo Plan

  31. Operations Permitting Con't. • Operational Flexibility, Agency Review, Completeness Determination, Draft Permit, Public Involvement, Public Participation & Confidentiality, Title V Fees

  32. Air Permitting and Compliance Typical Permitted Process & Control Equip. • Process Equipment *Equipment For Cutting Of Metal, Welding, Grinding, Sawing, Metal Surface Prep (i.e., blasting, Caustic Degreasing, etc.), Surface Coating Ops. (I.e., Anodizing, Galvanizing, Painting (Dry & Wet), Fossil Fuel Combustion Equip. (i.e., Nat. Gas, Propane, etc.), Storage Tanks, Some Maintenance Activities, Adhesives, Cleaning, Marking, Aerosols, etc.

  33. Air Permitting and Compliance Typical Permitted Process & Control Equip. Con't. • Control Equipment *Bag house Filter Systems, Cartridge Filters, Cyclones, Bag Filters, Submerged Welding, Water Table Cutting, etc.

  34. Air Permitting and Compliance Primary Pollutant(s) For This Industry/Process(es) • Volatile Organic Compounds (VOCs) • Hazardous Air Pollutants (HAPs) • Particulate Matter (TSP, PM, PM-10, etc.)

  35. Air Permitting and Compliance Typical Activities Req. Permits/Mods. • Include But Not Limited To Following: *Installation Of Additional (New Or Used) Process OR Air Emissions Control Equip. *Mod. Existing Process OR Control Equip. *Projects To Increase Production Capacity = “Debottleneck” *Product Substitutions

  36. Air Permitting and Compliance Typical Activities Req. Permits/Mods. Con't. *Acquire Additional Production Locations *Promulgation Of New Reg. Requirements = New NSPS, NESHAP, etc. *Unable To Maintain Compliance W/ Existing OR New Permit Limits

  37. Air Permitting and Compliance Info. Needs/Review Process • Includes But Not Limited To Following: *General Project Description, Anticipated Timeline, Facility Location, Facility Contact W/ Telephone #, etc. *Existing Process Flow Diagram Including Processing Equip., Control Equip./% Eff., Equip. Aspirated, Aspiration Flow Rates, Processing Rates, Emission Points, Raw Material Inputs, Waste(s) Generated, etc.

  38. Air Permitting and Compliance Info. Needs/Review Process Con't. *Proposed PFD W/ Process Equip., Control Equip./% Eff., Process Rates, Raw Material Inputs, Waste(s) Generated, etc. *I.D. Of Substances (Name & Part #) Utilized In Process, Copies Of MSDS For Each Substance, I.D. Quantity Of Each Substance Used For Previous 12-Month Rolling Time Frame, Hours Of Operation For Subject Process(es), Projected Operating Schedule (Hrs/Day, Days/Week, & Weeks/Year), etc.

  39. Air Permitting and Compliance Info. Needs/Review Process Con't. *More Detailed Info. May Be Req. After Initial Evaluation Procedures = Plot Plan Showing Proposed Equip. Location, Engineering Design/Selection Calcs. (Plans & Specs.), Mfg. Info., Stack Location, Stack Diameter/Height/Gas Exit Velocities, Scale, Property Lines (Or Provide Distance To Nearest), Fuel Type(s) W/ Related Equip. Capacity, Equip. Aspirated, Aspiration Flow Rates, etc.

  40. Air Permitting and Compliance Emission Quantification/Tracking/Inventory • When Is An Emissions Inventory Typically Required? = Most States Req. Quantification Of Emissions On An Annual Basis W/ Report Development & Submittal • For Most Part, Title V Major Sources Not Only Quantify Emissions & Report, They Also Pay Annual Emissions Fees (Specified $/Ton Of Pollutant) = $/Ton Calculated Following Submittal Of All Emissions W/ Dept. Budget Divided By # Of Tons To Back Into The $/Ton Figure

  41. Air Permitting and Compliance Emission Quantification/Tracking/Inventory Con't. • Reports Cover The Previous Years Emissions, May Have $/Ton Or Some Fixed Pricing Based On Permit Level/Type, & Utilities Were Successful In Lobbying For Caps/Pollutant (i.e., 4,000 Tons Max.) • Emissions Oftentimes Req.’ed To Be Determined On Daily, Weekly, Or Monthly Basis & Tracked As 12-Month Rolling Ave. = Doc. To Verify In Compliance W/ Permit Limits @ Time Of Inspections W/ Permit Established To Meet NAAQS, etc.

  42. Air Permitting and Compliance Emission Quantification/Tracking/Inventory Con't. • AETS Developed To Help Address Tracking @ Larger Sites = Data Mgt. System Based On Stores Inventory --- As Items Are Checked Out, They Are Considered Emitted (VOC & HAPs) = Able To Tie To Particular Permit Limit, Emissions Unit, etc. --- See Link To AETS @ End Of This Presentation * • Wally Bell Presentation On The AETS W/ Req.’s For Implementing @ Off-Site Locals = Call Him, AETS Use Instruc., etc.

  43. Air Permitting and Compliance Emission Quantification/Tracking/Inventory Con't. • Emission Factors Published By EPA, etc. From Data That Has Been Obtained Over Time May Assist W/ Emission Quantification = May Be Used As Basis For Permit App., May Alleviate Stack Testing Req.’s, etc. • Links For These Emission Factor Databases Are Provided @ End Of The Presentation --- Provided For: AP-42 *, AIRS/FIRE *, etc.

  44. Air Permitting and Compliance CFC/HCFC ("Refrigeration") • Industrial Process Refrig. Leak Repair Regs.= “Process”, “Commercial” & “Comfort Cooling” Are Regulated (Section 608 CAA) • Need I.D. All Units W/ > 50 Lbs Max. Charge Capacity, I.D. Specific CFC/HCFC Put Into System, & I.D. How Determined Max. Charge (i.e., Calc., Mfg. Specs., etc.) • All Service On Coolant Loop(s) Require Cert. & Documentation = Obtain Records For Last 2 Events CFC/HCFC Were Added

  45. Air Permitting and Compliance CFC/HCFC ("Refrigeration") Con't. • Determine Which Classification Applies/ System = “Industrial” & “Commercial” @ 35% OR “Comfort Cooling” @ 15% Leak Rate Triggers Respectively • Calc. Annual Leak Rate Per Formula On Pg. D-1 Of Compliance Guidance Doc. (See Link @ End Of Presentation) = Need I.D. Time Between Last 2 Cooling Loop Service Events Where CFC/HCFC’s Were Added

  46. Air Permitting and Compliance CFC/HCFC ("Refrigeration") Con't. • Follow 6-Pg. Refrig. Leak Repair Flow Chart @ Very End Of Guidance Doc. = If Annual Leak Rate W/in Req. Specs., Document To File (May Need Do Again W/in Next 30 Days) --- If Not, Need Address Leak Repair, Retrofit/Retire Option That Applies & Is Desired • Determine Course Of Action To Complete Required Mods. W/in Specified Time Frame(s) (i.e., 30 Days To Fix, Dev. Plan, ~1 Year For Retrofit/Retire Option, etc.)

  47. Air Permitting and Compliance CFC/HCFC ("Refrigeration") Con't. • Air (Vs. Water) Cooled Compressors Have Eliminated Water Discharges But May Now Be Subject To This Req. --- Look @ ARS Chillers, Office Bldg. Cooling, etc. • See Link For Identification Of Class I & II Ozone Depleting Chemicals W/ Assoc. Labeling * AND Refrigerant Usage Requirements * --- Appliances (i.e., @ Stationary And Motor Vehicle Systems) Are Regulated During Use, Servicing & Disposal = Goal To Prevent Loss To Atmos.

  48. Air Permitting & Compliance Chemical Accident Prevention (RMP) • Risk Mgt. Planning (RMP) = Do Not Believe Too Great Impact To Valmont But Need To Be Aware Of Reqs. --- For Example, Propane “Stayed” @ Present, HCl 37% Conc. & > @ 15,000 lbs, & Fuming H2SO4 @ 10,000 lbs are reg. • List Each Of 66 Flammable & 77 Toxic Substances That Require Planning If Trip Respective Thresholds (i.e., 10,000 Lbs For Flammables & 500 To 20,000 Lbs For Specific Toxic Compounds)

  49. Air Permitting & Compliance Chemical Accident Prevention (RMP) • “General Duty Clause” Is Another Way That One May Be Drawn Into Being Regulated Even If Do Not Meet The Defn. For Being Covered = Essentially A “CYA” For The Regulators Should A Problem Occur Outside Of The Reqs. For Being Regulated • Bhopal, India, etc. Catastrophes Were Primary Drivers For This Regulation • Problem W/ Info. Reqs. & Terrorism!

  50. Air Permitting & Compliance Chemical Accident Prevention (RMP) Con't. • 3 Parts = Hazard Assessment, Emergency Response Program & A Prevention Program • Perform Hazard Assessment Using Worse Case & Alternative Releases To Determine Endpoints, Release Scenarios, Meteorological Conditions, Screening Approach (“Look-up” Tables), &/OR Refined Modeling

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