AIR CONSTRUCTION PERMITS: CLEVER FUNDAMENTALS March 26, 2020 Vanessa Coleman, Sally Perry W&M Environmental – A Division of Braun Intertec Corporation 972-516-0300 Wh-m.com
VANESSA COLEMAN • Senior Engineer, Compliance & Permitting, South Region • B.E., Civil and Environmental Engineering; University of Detroit, Mercy • Over 12 years experience in environmental compliance for the industrial sector. • Her experience includes program development, implementation and management as well as multimedia permitting and compliance. 2
SALLY PERRY • Senior Scientist, Compliance & Permitting, South Region • B.S., Earth Systems; Stanford University • Over 10 years of experience in environmental permitting and compliance for the industrial sector. • Her experience includes multimedia permitting and compliance in multimedia such as air, water, waste, spill prevention, and chemical reporting. 3
Agenda ▪ The Essential ▪ What we are not covering ▪ Construction Triggers ▪ Permitting Action Considerations ▪ Example Scenarios 4
The Essentials • Why do we do this? Who and what are we protecting? • Smog, acid rain, health hazards – human health and the environment outside of the operation • NAAQS – EPA CAA • Criteria pollutants – NO X , CO, PM, SO 2 , Ozone, Lead • Air pollutants • Sources emit these pollutants • Identify and quantify • A source of a different color • What is a source/facility/unit/process? Always look at the definitions specific to your region! • Does it emit air contaminants? • Examples: metal treating, piping components, surface coating • Air authorizations, permits, registrations, and like are put in place to comply with to ensure your sources meet the NAAQS 5
NSR vs Title V: 3000-foot view New Source Review Title V Purpose Maintain air quality in attainment Consolidate all air permitting areas and bring non-attainment requirements for a major source into areas into attainment a single federally enforceable permit Authorizes Construction & Emissions Operations Timing Completed first & before Initial application - prior to operations construction begins Subsequent – operations may begin prior to issuance 6
NSR vs Title V Many states have a combined construction/operating permit program, others have a 2-permit system Combined Construction and 2-Permit System Operations ✓ TX ✓ PA ✓ MI ✓ FL ✓ AR ✓ MN ✓ LA ✓ OK ✓ IN 7
Triggers, Timing, Construction Oh my • New construction of facility • Facility - a discrete or identifiable structure, device, item, equipment, or enclosure that constitutes or contains a stationary source, including appurtenances other than emission control equipment. • Modify existing facility • any physical change; • change in the method of operation of a facility that: • increases the amount of any air contaminant emitted; • results in the emission of any air contaminant not previously emitted. • changes in method of control; • changes in character of emissions; and • increases in actual emissions or emission allowed to be emitted by the permit (allowable). 8
Triggers, Timing, Construction Oh my • A company replaces a boiler with an identical boiler • Change chemicals used in a scrubber • Route an existing oven exhaust not previously controlled to an existing scrubber because throughput is gong to increase • Move an existing blast booth to a new location inside the same building and add new blast equipment • Depends on how it is currently permitted, but ultimately you are potentially increasing throughput by adding the blast equipment • Adhesive is used in an adhesive machine. The company wants to switch to a stronger adhesive to improve quality. 9
Triggers, Timing, Construction Oh my Side note : 30 TAC § 116.116(a) (Permit Amendments)(other states have similar language): "All representations with regard to construction plans and operation procedures in an application for a permit, ... as well as any general and special provisions attached to the permit itself, become conditions upon which the subsequent permit ... are issued. It shall be unlawful for any person to vary from such representation or permit provision if the change will cause a change in the method of control of emissions, the character of the emissions, or will result in an increase in the discharge of the various emissions, unless application is … to amend the permit ... and such amendment is approved ..." ∴ permitted facility should be constructed and operated as represented in the application – high likelihood most deviations from what was represented in the permit would require a modification ∴ ∴ permit applications just as important as permit itself 10
Triggers, Timing, Construction Oh my An NSR permit is required before construction or modification of a facility begins Yes, but DEFINE “construction” • anything other than site clearance or site preparation • Land clearing, soil load bearing tests, leveling of the area, sewer and utility lines, road building, power line installation, fencing, construction shack building, etc. • HOWEVER, once soil and site are ready for foundations, the first excavation into the readied soil = construction • Equipment can be at the site and stored • No attempt is made to assemble the equipment or to connect the equipment into any electrical, plumbing, or other utility system. • Excavation, form erection, or steel laying pertaining to foundations upon which permit units will rest = construction. • Concrete foundation not required no problem! Earthen dams, placement of piling, soil stabilization, storage tank fills, or retaining structures = construction . 11
Permitting Action Considerations You have determined you need authorization for a I need air new/modified source authorization! Other considerations: ❑ Timing ❑ Location: • • Attainment status Sensitive receptors ❑ Emissions: • • Stack testing This Photo by Unknown Author Usage rate is licensed under CC BY • Engineering calculations • AP-42 • Material balance ❑ Other applicable rules: • State • Federal • • BACT PSD/non-attainment review status • Measurements of • Impact on TV significant air • contaminants NSPS • • MACT Mass cap and trade allowances • NESHAPs • • Achieve performance HAPs 12
Various Permitting Mechanisms Full application Subject to Best Available Control Technology (BACT) Case-by-case Agency administrative and technical review May require: Standard Permits (SPs) Register Emissions increase More prescriptive Two public notices Initial compliance testing Written approval prior to 20 SPs Continuous demonstrations of operations Postings at site Specific, characterized compliance Expires class of facilities Newspaper Public notice Meet all conditions Available to view in public place Emission limits Operate as reflected in registration (if Permit-by-Rule (PBR) Registering – enforceable Register or claim Public comment period applicable); amend when there are changes – 21 industry-type categories; Operating hours registration no longer reflects what is Cannot partially permit a process Boilerplate conditions 108 individual PBRs Modeling represented in application Cannot be used to circumvent permitting Does not expire Draft conditions Negligible sources De Minimis Must meet all conditions Listed sources: 4 categories; 74 individual exemptions Correspond, correspond, correspond De Minimis Rule: Material usage; Effects Screening Typically no paperwork 6 to 9 month approval process Levels Must keep records to demonstrate de minimis Expires every 10 years 13
Client Goals and Objectives When deciding which authorization mechanism is needed, take goals and objectives into account: • Operational flexibility • Start construction and operations ASAP • Want to avoid larger permit • Minimal compliance requirements 14
Determine Baseline: Facts and Figures • Process flow diagram • Overall • Identify potential downstream and upstream bottlenecks • Affected source • Type – equipment, process • Inputs materials and rates • SDSs, EDSs • Processing rates • Outputs – pollutants, control devices • Process description • SOPs • Equipment O&M manuals • Emission calculations • Site figure • Sources identified • Property boundaries 15
Facts and Figures Meet Goals and Objectives Scenario #1: A small metal parts manufacture located in an attainment area currently outsources coating operations. They are looking to grow the business by offering repair services to a select few original parts customers. After the repairs are completed, some coating touch up will be needed. Approximately ½ pint of paint is used per repaired part. Currently, the select customers are looking to contract a combined 20 parts per week. Minimal solvents will be used and is not expected to exceed 50 gallons of use per year. Does the small metal parts manufacturer require air authorization? Yes. Where do we begin? 16
Facts and Figures Meet Goals and Objectives 17
Facts and Figures Meet Goals and Objectives .5 𝑞𝑗𝑜𝑢 𝑑𝑝𝑏𝑢𝑗𝑜 𝑠𝑓𝑞𝑏𝑗𝑠𝑓𝑒 𝑞𝑏𝑠𝑢 𝑌 20 𝑞𝑏𝑠𝑢𝑡 X 52 𝑥𝑓𝑓𝑙𝑡 X 1 𝑏𝑚𝑚𝑝𝑜 = 65 gallons 𝑥𝑓𝑓𝑙 𝑧𝑓𝑏𝑠 8 𝑞𝑗𝑜𝑢𝑡 18
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