Workshop K Air & NPDES P Air & NPDES Permits … rmits … Best Practices & Succeeding in the Best Practices & Succeeding in the Process t Process to Obtain the Best P Obtain the Best Possible P ssible Permit rmit Thur Thursda sday, July 20, 20 , July 20, 2017 10:30 a.m. t :30 a.m. to noon noon
Biographical Information Bridget Morris, Manager, Environmental, Health, Safety, Security & Sustainability VWR Chemicals, LLC, 28600 Fountain Parkway, Solon, OH 44139 440-914-3394 Bridget.Morris@vwr.com Ms. Morris is a Manager, Environmental, Health, Safety, Security and Sustainability for VWR Chemicals, LLC in Solon, Ohio. Ms. Morris has over 20 years of experience in EHS3 compliance with emphasis on Environmental compliance. During this time, she has managed and implemented various EHS3 projects/programs in Ohio and along the Gulf Coast of the US from small R&D facilities to complex petrochemical operations. Ms. Morris holds a Bachelor of Science degree in Chemistry from Southern Arkansas University and an Engineering Management certificate from Louisiana State University. Natalie R Pinheiro, Manager Ramboll Environ US Corporation 5747 Perimeter Drive, Suite 220, Dublin, Ohio 43017 (614) 408-0907 Fax (614) 408-0911 npinheiro@ramboll.com Natalie is a Manager at Ramboll Environ’s Dublin Ohio office and has over eight years of experience in the environmental regulatory compliance and environmental due diligence fields. During this time, she has directed and participated in a variety of projects for industrial clients throughout Ohio and surrounding states to assist them with air permitting compliance and other regulatory permitting programs including EPCRA, SPCC, NPDES, and hazardous waste. Air experience includes preparation of air emission inventories, air toxics modeling, NESHAP and NSPS applicability, preparation and submittal of air permit applications, correspondence with regulatory agencies, and regulatory reporting and recordkeeping for minor and major sources. She has also assisted facilities with non-attainment new source review and best available control technology analyses. Finally, Natalie has assisted numerous clients with understanding their permit terms and conditions, preparing plans and procedures to ensure compliance, and responding to and negotiating with the Ohio EPA regarding notices of violation. Natalie holds a Bachelor of Science degree in Natural Resources from The Ohio State University and a Master of Science degree in Environmental Science from The Ohio State University.
Biographical Information Stephen N. Haughey, Member, Frost Brown Todd, LLC 301 East Fourth Street, Great American Tower, Suite 3300, Cincinnati, Ohio 45202 513.651.6127 Fax: 513.651.6981 ssamuels@fbtlaw.com Steve is a member of Frost Brown Todd and practices in the area of environmental law. He represents clients across the country in regulatory compliance counselling, permit negotiations, wetlands disputes, rulemaking challenges, and in defense of civil enforcement litigation, citizen suits, criminal prosecutions and claims related to contaminated property. Steve has particular proficiency in representing governmental entities and industry in all aspects of storm water and wastewater regulations, including permitting, compliance counselling, rulemaking challenges and enforcement defense, and in local water, sewer and storm water planning and CSO/SSO control plans. His practice also concentrates in the defense of heavily regulated industries, such as iron and steel mills, pulp and paper mills, titanium mills, chemical plants, landfills and food manufacturers. Steve has extensive experience representing Ohio and other Midwestern governmental entities and the industry in the fields of wastewater, stormwater, drinking water and solid waste counselling, litigation, administrative appeals, strategic planning, and civil and criminal enforcement defense. His wastewater practice focuses, in particular, on all aspects of planning, service, treatment and regulation as they apply to owners and operators of POTWs and sewer collection systems. In Ohio alone, Steve represents more than a dozen counties, cities, villages and regional sewer districts, ranging from small satellite sanitary sewer systems to large combined sewer systems. Steve has commented on, negotiated, and, as necessary, appealed more than 100 NPDES permits to various state and federal administrative boards, including the Ohio Environmental Review Appeals Commission and its predecessor, the Ohio Environmental Board of Review, the Pennsylvania Environmental Hearing Board, the Kentucky Environmental Protection Cabinet, the Indiana Department of Environmental Management, the Illinois EPA, the Michigan Department of Environmental Quality, U.S. EPA administrative law judges and the federal Environmental Appeals Board in Washington, DC. In the permitting process, Steve's expertise in water quality standards, wasteload allocation, antidegradation and antibacksliding procedures and stream use designations has enabled him to save owners of POTWs and industrial facilities tens of millions of dollars of unnecessary capital expenditures and annual compliance costs. Steve has been a member of several state wastewater rulemaking advisory committees. He has commented on numerous draft rules for clients and governmental trade associations, and has prosecuted more than a dozen administrative appeals of wastewater-related rules and policies, covering such areas as state water quality standards and stream use designations, TMDL procedures, listings and implementation, CWA 304(l) listings, state antidegradation procedures, storm water and pretreatment requirements, whole effluent toxicity, wasteload allocation procedures, implementation of the federal GLI, and CSO/SSO control strategies and related CMOM requirements. Steve has a B.S. in environmental health and a minor in chemistry, and he interned at an Ohio POTW while in college. He is a frequent speaker on wastewater and stormwater topics to midwestern operators and regularly presents a clinic to managers of POTWs on the basics of water quality-based permitting and negotiation. Steve is a member of the Water Environment Federation and the Ohio Water Environment Association, and is also an affiliate member of the Ohio County Commissioners Association, the Ohio Sanitary Engineers Association and a speaker for the Operator Training Committee of Ohio.
AI R & NPDES PERMI TS … BEST PRACTI CES & SUCCEEDI NG I N THE PROCESS TO OBTAI N THE BEST POSSI BLE PERMI T Best practices at effectively communicating internally & externally – the do’s & don’ts. Paving the way with early meetings with the regulators to discuss your permits & goals. Potential roadblocks & hurdles to consider. Dealing with a short timeline and/ or limited budget. Predicting future issues & impacts on permits. Writing the draft permit & follow up strategies to achieve a quicker permit. Case studies & examples. Bridget Morris Natalie Pinheiro Stephen Haughey Manager Manager Member VWR Chemicals, LLC Ramboll Environ US Corporation Frost Brown Todd MEC_AIR & NPDES PERMITS_BEST PRACTICES IN PERMITTING JULY 20, 2017
AI R PERMI TS W HAT YOU NEED TO KNOW BEFORE OBTAI NI NG A PERMI T • Many companies think that obtaining an air permit in Ohio is a quick and easy process, like getting a routine construction permit. • This is not usually accurate. • These types of permits are specifically written for each facility or source, and at best, the process of obtaining a permit takes at least a few months . • Failure to understand and comply with the Ohio EPA’s permitting requirements can result in serious delays that can cost companies time, money, and lead to violations . • However, with proper planning, the permitting process does not have to be a difficult process. MEC_AIR & NPDES PERMITS_BEST PRACTICES IN PERMITTING JULY 20, 2017
STEPS I N THE TYPI CAL PERMI TTI NG PROCESS INTERNAL FACILITY PLANNING/ COMMUNICATION • Communication between various internal teams (e.g. environmental, production, engineering, sales) • Agreeing on final production rates (which could become final permit limits) • Understanding accurately what emissions will result form different processes • Understanding how changes in production will impact current and future permits (modifications/ major source thresholds) • Planning installation activities around expected permit issuance dates (typically requires at least 6 months for air – although this can take less or more time depending on various factors) • Understanding fees associated with the permit application http: / / epa.ohio.gov/ portals/ 47/ facts/ feeschedule.pdf MEC_AIR & NPDES PERMITS_BEST PRACTICES IN PERMITTING JULY 20, 2017
STEPS I N THE TYPI CAL PERMI TTI NG PROCESS IDENTIFYING THE PROPER PERMIT TYPE • Air • Major Source (PTI/ PTO) • Minor Source (PTIO) • Synthetic Minor Source (PTIO) • Modification • Depending on the type of permit and type of operation, potential or requested emissions may trigger certain state and federal regulatory requirements (e.g. 21-09, 21-07, 40 CFR Part 60 (COMS), 40 CFR Part 63 (lower VOC contents, requirements to install expensive control equipment), BACT/ BAT, CAM, air toxics). • Some facilities have an initial plan for installing equipment that triggers certain permitting thresholds and change plan to avoid becoming subject to certain regulations MEC_AIR & NPDES PERMITS_BEST PRACTICES IN PERMITTING JULY 20, 2017
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