Workshop E Best Practices in Air Permitting & Best Practices in Air P rmitting & Compliance … In Compliance … Invaluable Guidance luable Guidance on Ho on How t w to Establish P Establish Potential t ntial to Emit Emit (PTE) f (PTE) for Y r Your F ur Facility cility Wednesda dnesday, July 19, 20 July 19, 2017 2:45 p.m. t 2:45 p.m. to 4:15 p.m. 4:15 p.m.
Biographical Information William J. Bruscino, C.M., Columbus Office Manager Trinity Consultants, 110 Polaris Parkway, Suite 200, Westerville, Ohio 43085 614.433.0733 Fax: 614.433.0734 bbruscino@trinityconsultants.com Mr. Bruscino manages air quality permitting and compliance services for industries such as refining, chemical manufacturing upstream and midstream oil and gas, and general manufacturing. His experience includes Title V and PSD permitting in EPA Regions IV, V, and VI as well as compliance assessments and implementation projects. Mr. Bruscino has recently been directing efforts for numerous energy audits required by the Boiler MACT rule as well as general 3 rd party compliance audits throughout the state of Ohio. He has also assisted multiple facilities in establishing Title V and minor source air compliance programs including environmental management information system (EMIS) implementations. Mr. Bruscino currently manages Trinity’s Columbus, Ohio office and is a member of the Air & Waste Management Association. He received a Bachelor’s degree in chemical engineering from the University of Cincinnati. Jarod W. Gregory, Consultant, Trinity Consultants 1717 Dixie Hwy. S. Ste. 900, Covington, KY 41011 859-341-8100 jgregory@trinityconsultants.com Jarod Gregory is a Consultant in Trinity Consultants’ Greater Cincinnati/Northern Kentucky office. He provides a wide array of support and solutions to both Kentucky and Ohio clients including state and federal air quality permitting, NSPS and MACT compliance assistance, emission inventory development, and TRI reporting. He focuses primarily on air quality support for the chemical manufacturing and refining industries. He holds a B.S. in Chemical Engineering and M.S. in Environmental Engineering from the University of Cincinnati. Lisa Roberts, Environmental Manager, WILD Flavors, Inc. 1261 Pacific Ave., Erlanger, KY 41018 859-342-3778 FAX: 859-342-3795 lisa.roberts@adm.com Ms. Roberts is the environmental manager for the US locations of WILD Flavors, Inc., part of Archer Daniels Midland’s Wild Flavors & Specialty Ingredients Division. Prior to her role with WILD she was environmental manager of the ADM oilseed processing complex in Valdosta, GA. She started at the Valdosta location in 2007 as a production engineer, then served as the Environmental, Safety and Food Safety Coordinator before focusing on environmental compliance. Before joining ADM she was an engineer in Kentucky Division for Air Quality’s Emissions Inventory section. Ms. Roberts graduated with a B.S in Chemical Engineering from the University of Kentucky in 2005.
27 th Annual Conference on Air & Water Permits – Environmental Permitting in Ohio Workshop E – Best Practices in Air Permitting & Compliance – Potential to Emit Focus July 19, 2017
How fast did you drive here? Evan Klein, Road and Track http://www.roadandtrack.com/car‐culture/a25775/almost‐infamous‐2015‐lamborghini‐huracan/
How fast did you drive here? Distance Speed Time SPEED D R T LIMIT 35 (mi) (mi/hr) (hr) 17.5 35.0 0.5 195.0 65.0 3.0 17.5 35.0 0.5 SPEED LIMIT 12.5 25.0 0.5 65 242.5 53.9 4.5 What is the potential to emit (PTE)? SPEED LIMIT Emission CO 35 EXIT Distance Factor Emissions SPEED LIMIT (mi) (g/mi) (lbs) 25 17.5 6.400 0.247 195.0 9.500 4.084 17.5 6.400 0.247 12.5 6.300 0.174 242.5 9.061 4.8 lb/yr At 4.5 hr/yr Potential Emissions => 9,250 lb/yr At 8,760 hrs/yr 4.6 tpy At 8,760 hrs/yr
How fast did you drive here? Distance Speed Time SPEED D R T LIMIT 40 (mi) (mi/hr) (hr) 17.5 40.0 0.4 195.0 80.0 2.4 17.5 40.0 0.4 SPEED LIMIT 12.5 35.0 0.4 80 242.5 66.1 3.7 What is the potential to emit (PTE)? SPEED LIMIT Emission CO 40 EXIT Distance Factor Emissions SPEED LIMIT (mi) (g/mi) (lbs) 35 17.5 6.900 0.266 195.0 16.000 6.878 17.5 6.900 0.266 12.5 6.400 0.176 242.5 15.138 7.6 lb/yr At 3.7 hr/yr Potential Emissions => 18,112 lb/yr At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr
Evan Klein, Road and Track http://www.roadandtrack.com/car‐culture/a25775/almost‐infamous‐2015‐lamborghini‐huracan/
How fast did you drive here? Distance Speed Time SPEED D R T LIMIT 180 (mi) (mi/hr) (hr) 17.5 180.0 0.1 195.0 180.0 1.1 17.5 180.0 0.1 SPEED LIMIT 12.5 180.0 0.1 180 242.5 180.0 1.3 What is the potential to emit (PTE)? SPEED LIMIT Emission CO 180 EXIT Distance Factor Emissions SPEED LIMIT (mi) (g/mi) (lbs) 180 17.5 60.00 2.315 195.0 60.00 25.794 17.5 60.00 2.315 12.5 60.00 1.653 242.5 60.00 32.1 lb/yr At 1.3 hr/yr Potential Emissions => 208,576 lb/yr At 8,760 hrs/yr 104.3 tpy At 8,760 hrs/yr
General Provisions PTE Definition Per 3745‐15‐05(A) Potential to emit or potential emissions shall mean the amount of emissions of an air contaminant which would be emitted from a source during a 24-hour calendar day or calendar year basis, whichever is applicable, if that source were operated without the use of air pollution control equipment unless such control equipment is, aside from air pollution control requirements, necessary for the facility to produce its normal product or is integral to the normal operation of the source. Potential emissions shall be based on maximum rated capacity .
Permit to Install PTE Definition Per 3745‐31‐01(VVVV) Potential to emit means the maximum capacity of an emissions unit or stationary source to emit an air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the emissions unit or stationary source to emit an air pollutant, which includes any federally regulated air pollutant , including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source.
Title V Permit PTE Definition Per 3745‐77‐01(CC) Potential to emit means the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source .
How fast did you drive here? Distance Speed Time Distance Speed Time Distance Speed Time D R T D R T D R T (mi) (mi/hr) (hr) (mi) (mi/hr) (hr) (mi) (mi/hr) (hr) 17.5 35.0 0.5 17.5 40.0 0.4 17.5 180.0 0.1 195.0 65.0 3.0 195.0 80.0 2.4 195.0 180.0 1.1 17.5 35.0 0.5 17.5 40.0 0.4 17.5 180.0 0.1 12.5 25.0 0.5 12.5 35.0 0.4 12.5 180.0 0.1 242.5 53.9 4.5 242.5 66.1 3.7 242.5 180.0 1.3 What is the potential to emit (PTE)? Emission CO Emission CO Emission CO Distance Factor Emissions Distance Factor Emissions Distance Factor Emissions (mi) (g/mi) (lbs) (mi) (g/mi) (lbs) (mi) (g/mi) (lbs) 17.5 60.00 2.315 17.5 6.400 0.247 17.5 6.900 0.266 195.0 9.500 4.084 195.0 16.000 6.878 195.0 60.00 25.794 17.5 6.400 0.247 17.5 6.900 0.266 17.5 60.00 2.315 12.5 6.300 0.174 12.5 6.400 0.176 12.5 60.00 1.653 242.5 9.061 4.8 lb/yr At 4.5 hr/yr 242.5 15.138 7.6 lb/yr At 4.5 hr/yr 242.5 60.00 32.1 lb/yr At 4 Potential Emissions => 9,250 lb/yr At 8,760 hrs/yr Potential Emissions => 18,112 lb/yr At 8,760 hrs/yr Potential Emissions => 208,576 lb/yr At 8 4.6 tpy At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr 104.3 tpy At 8
Importance of Source Classification First question in determining applicability to air regulations and/or permitting requirements: “What is my source classification?” Key concepts to understand to answer: Meaning of term “source” Distinguish between source classification based on ♦ date of construction/modification ♦ emissions
Multiple Uses of Term “Source” Different criteria for different regulatory programs Need to understand the underlying regulation or permitting program being considered In context of air permitting programs, “source” typically refers to the facility In context of particular air regulations (e.g., NSPS, NESHAP), “source” typically refers to specific subset of equipment at a facility
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