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FET Environmental Primer Air Regulations: Permitting Basics. Steven Klafka, P.E. Wingra Engineering, S.C. Madison, Wisconsin www.wingraengineering.com. Air Quality Permit Overview. WDNR responsible for permit issuance USEPA oversight Construction permits for new sources

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fet environmental primer air regulations permitting basics

FET Environmental Primer Air Regulations: Permitting Basics

Steven Klafka, P.E.

Wingra Engineering, S.C.

Madison, Wisconsin

www.wingraengineering.com

air quality permit overview
Air Quality Permit Overview
  • WDNR responsible for permit issuance
  • USEPA oversight
  • Construction permits for new sources
  • Operation permits for existing sources

Wingra Engineering, S.C.

air pollution sources
Air Pollution “Sources”
  • Operations Issued Air Quality Permits
  • Stationary - Process or Point
  • Stationary - Factory or Facility
  • Portable - Asphalt Plant
  • Indirect - Parking Lots and Highways
  • Not Issued Air Quality Permits
  • Area - Small Boilers, Wildfires
  • Mobile - Cars, Trucks, Busses
  • Off Road – Lawn mowers, Snowmobiles

Wingra Engineering, S.C.

wisconsin voc emissions
Wisconsin VOC Emissions

Wingra Engineering, S.C.

air pollution sources issued permits
Air Pollution Sources Issued Permits
  • Burning of fuels or wastes.
  • Conveying or handling of dusty materials like sand, wood shavings, etc.
  • Evaporation of solvents from painting, printing, cleaning, gluing, storage, etc.
  • Chemical processing and reactions.

Wingra Engineering, S.C.

types of emission estimates
Types of Emission Estimates
  • MTE or Uncontrolled – Need for Permit

Full capacity; 8,760 hrs/yr; 0% collection

  • Potential – Determines Compliance

Full capacity; 8,760 hrs/yr; Required %

  • Actual – Reported for Annual Fees

Actual capacity, hrs/yr and % collection

Wingra Engineering, S.C.

sample permit calculations 1
Sample Permit Calculations #1

Shotblasting Operation with 99% Efficient Baghouse

Capacity = 2 tons per hour of metal

USEPA Emission Factor = 17 lbs TSP/ton of metal

Applicable Discharge Limit = NR 415.05(2) = 3.59 P 0.62

Comparison with General Permit Exemption Thresholds

MTE = 2 tph x 17 lbs of TSP/ton = 34 lbs of TSP/hr

> 5.7 lbs TSP/hr, NR 406 construction permit required

Actual = 34 lbs/hr x (1 – 0.99) = 0.34 lbs TSP/hr

Potential = 3.59 (2) 0.62 = 5.5 lbs TSP/hr

Wingra Engineering, S.C.

types of emission estimates1
Types of Emission Estimates

Wingra Engineering, S.C.

construction permits
CONSTRUCTION PERMITS
  • Must be issued prior to construction or modification of regulated sources.
  • NR 406 - Exemptions and Schedules
  • NR 405 - PSD rules for Large Projects
  • NR 410 – Fees
  • NR 411 – Parking Lots and Roads
  • NR 150 – Environmental Assessment & EIS

Wingra Engineering, S.C.

types of specific exemptions
Types of Specific Exemptions
  • Natural gas-fired boilers < 25 mmbtu/hr
  • Wood-fired boilers < 5 mmbtu/hr
  • Paint/ink usage < 1,666 lbs VOC/month
  • VOC storage tanks < 10,000 gallons
  • Emergency generators < 3,000 kilowatts
  • Each state has own specific exemptions.

Wingra Engineering, S.C.

types of general exemptions
Types of General Exemptions
  • Uncontrolled emissions < all permit thresholds
  • 5.7 lbs/hr of total suspended particles (TSP)
  • 3.4 lbs/hr of particles < 10 microns (PM10)
  • 9.0 lbs/hr of sulfur dioxide (SO2)
  • 9.0 lbs/hr of nitrogen oxides (NOx)
  • Thresholds for >500 air toxics under NR 445
  • Use specific exemption first, then general.

Wingra Engineering, S.C.

sample permit calculations 2
Sample Permit Calculations #2

Paint Spray Booth with 95% Efficient Filters

Actual paint usage = 600 gallons per month

Maximum paint usage = 1.5 gallons per hour

Maximum VOC content = 3.5 lbs VOC per gallon

Maximum solids content = 6.0 lbs solids per gallon

Spray gun transfer efficiency = 70%

Comparison with Specific Permit Exemption Thresholds

Actual = 600 gpm x 3.5 lbs/gal = 2,100 lbs/month VOC

> 1,666 lbs of VOC/month exemption threshold

Wingra Engineering, S.C.

sample permit calculations 21
Sample Permit Calculations #2

Comparison with General Permit Exemption Thresholds

VOC Emission Estimate

MTE = 1.5 gph x 3.5 lbs/gal = 5.3 lbs/hr

< 5.7 lbs/hr general exemption threshold for VOC

PM10 Emission Estimate

MTE = 1.5 gph x 6.0 lbs/gal x (1 - 0.7) = 2.7 lbs/hr

< 3.4 lbs/hr general exemption threshold for PM10

Conclusion:No NR 406 construction permit is required based on the general permit exemption thresholds.

Wingra Engineering, S.C.

schedule and fees
Schedule and Fees
  • Permit issuance within 2 to 12 months.
  • 30-day public comment period.
  • Public hearing if requested by public or applicant.
  • $1,350 initial application fee
  • $2,300 to $85,000 permit issuance fee
  • NR 438 annual emission fee ($35/ton)

Wingra Engineering, S.C.

criteria for permit approval
Criteria for Permit Approval
  • Comply with emission limitations.
  • Comply with air quality standards using dispersion modeling analysis.
  • Standards include the NR 404 National Ambient Air Quality Standards or NR 445 Acceptable Air Concentrations for hazardous air pollutants.
  • Comply with current policies.

Wingra Engineering, S.C.

typical permit schedule
Typical Permit Schedule

Week 1 – Submit application to DNR

Week 5 – Receive DNR request for information.

Week 7 – Respond to request for information.

Week 11 – DNR issues draft permit and PD.

Week 12 – Publish notice for public comments.

Week 16 – Public comment period ends.

Week 18 – DNR issues final permit and invoice.

Wingra Engineering, S.C.

expedited permit issuance
Expedited Permit Issuance
  • Pre-application meeting with DNR.
  • Submit a complete application.
  • Anticipate DNR application review needs.
  • Provide emission calculations.
  • Comply with applicable requirements.
  • Conduct DNR modeling & risk analyses.
  • Prepare environmental assessment.
  • Anticipate public involvement.

Wingra Engineering, S.C.

recent air permit enforcement
Recent Air Permit Enforcement
  • $45,000 – Failure to obtain permit.
  • $45,600 – Exceeded emission limits.
  • $60,000 – Failure to maintain records.
  • $65,000 – Failure to obtain permit.
  • $71,820 – Failure to maintain records.
  • $86,450 – Failure to raise stack.
  • http://www.doj.state.wi.us/dls/environpro/news/

Wingra Engineering, S.C.

keys to successful air permits
Keys to Successful Air Permits
  • Stay involved in review process.
  • Review preliminary permit prior to official “draft” permit.
  • Anticipate future production needs and provide flexibility in permit.
  • Minimize unnecessary requirements.

Wingra Engineering, S.C.

psd rules add complexity
PSD Rules Add Complexity
  • NR405-Prevention of Significant Deterioration
  • Applies to new large sources
  • Applies to modifications of large sources
  • Additional permit issuance time
  • Best Available Control Techology or BACT
  • Pre-construction ambient monitoring
  • Dispersion modeling for increments & NAAQS
  • Visibility, growth and vegetation analyses

Wingra Engineering, S.C.

psd thresholds tons year
PSD Thresholds (tons/year)

Wingra Engineering, S.C.

psd avoidance
PSD Avoidance
  • PSD rules uses “potential” emissions.
  • Permit restrictions on capacity,operating hours, or collection % are considered.
  • PSD avoided to save permit issuance complexity or processing time, or eliminate control requirements.
  • Balance restrictions and future growth.

Wingra Engineering, S.C.

anatomy of an air permit
Anatomy of an Air Permit
  • Description of source or process.
  • Emission limitations.
  • Wis. Adm. Code citations.
  • Record keeping requirements.
  • Monitoring requirements.
  • Testing and certification requirements.
  • Reporting requirements.

Wingra Engineering, S.C.

sample air permit
Sample Air Permit

Wingra Engineering, S.C.

construction permit references
Construction Permit References
  • Jeff Hanson, Construction Permit Leader hansojc@dnr.state.us and (608) 267-6876
  • Regional DNR Office Air Staff
  • Air Permit Web Site

http://www.dnr.state.wi.us/org/aw/air/reg/regs.htm

Provides application forms, instructions, issued and pending construction permits, and modeling guidance.

Application Forms & Instructions:

ftp://www.dnr.state.wi.us/DAW/AM/permits/AppForms/

Issued & Pending Operation Permits:

ftp://www.dnr.state.wi.us/DAW/AM/permits/OpPermit/PmtDocs/

Wingra Engineering, S.C.

operation permits
OPERATION PERMITS
  • Application must be filed for existing regulated sources or prior to expiration of construction permits.
  • Title V of 1990 Clean Air Act Amendments (Congress)
  • 40 CFR Part 70 (USEPA)
  • NR 407 - Exemptions & Schedules (WI)

Wingra Engineering, S.C.

processes included in permit
Processes included in Permit
  • Similar exemption thresholds as provided for construction permits.
  • Includes processes which require a construction permit if built today.
  • Includes minor processes which exceed NR 407 Table 2 inclusion thresholds (i.e. 2,000 lbs/yr).

Wingra Engineering, S.C.

types of operation permits
FOP or Title V or Part 70 Permit

100 TPY PM, SO2, NOx, CO, VOC, Pb, Lower TPY for VOC if located in ozone nonattainment area (SE Wisconsin)

10 TPY Federal Air Toxic or 25 TPY Combined Air Toxics

Subject to most thorough review and compliance demonstration.

Subject to MACT, if available.

All applications for existing WI sources were due by 1995.

Types of Operation Permits

Wingra Engineering, S.C.

types of operation permits cont d
Types of Operation Permits Cont’d
  • Federally Enforceable Synthetic Minor Permit
  • Limits potential emissions by using operating hours or production restrictions to remain below thresholds.
  • Avoids MACT or other FOP requirements.
  • All WI applications were due by 1995.
  • Balance FESOP restrictions and future growth.

Wingra Engineering, S.C.

types of operation permits cont d1
Types of Operation Permits Cont’d
  • SOP – State Only Permit
  • Required by state not federal rules.
  • Potential emissions less than FOP thresholds (i.e. 100 TPY)
  • Only annual compliance reports.
  • All applications for existing WI sources were due by 1998.

Wingra Engineering, S.C.

types of operation permits cont d2
Types of Operation Permits Cont’d
  • Applications for all existing sources in Wisconsin have been submitted to DNR.
  • Construction permits for new or modified processes are replaced with operation permits prior to expiration or incorporated into the facility-wide operation permit.

Wingra Engineering, S.C.

operation permit references
Operation Permit References
  • Keith Pierce, Operation Permit Leader pierck@dnr.state.us and (608) 267-0562
  • Regional DNR Office Air Staff
  • DNR Air Permit Web Site

http://www.dnr.state.wi.us/org/aw/air/reg/regs.htm

Provides application forms, instructions, issued and pending operation permits, permit application software.

  • USEPA MACT Web Site

http://www.epa.gov/ttn/atw/eparules.html

Wingra Engineering, S.C.

air permits in a nutshell
Air Permits in a Nutshell
  • NR 406 construction permits required prior to the start of construction or modification.
  • NR 407 operation permits are for existing processes, or replace construction permits.
  • Review permits thoroughly before issuance to assure accuracy and flexibility.

Wingra Engineering, S.C.