Workshop G Air Permitting … Major New Source Review (NSR) Changes Impacting How You Do Business in Ohio Wednesday, July 25, 2018 2:45 p.m. to 4:15 p.m.
Biographical Information Mike Burr, Managing Consultant Trinity Consultants 3401 Enterprise Parkway, Suite 340, Beachwood, Ohio 44122 216.278.0500 Fax: 614.433.0734 mburr@trinityconsultants.com Mike currently operates as a Managing Consultant in Trinity’s Cleveland, Ohio office providing support to numerous industries across Ohio, West Virginia, and Michigan. His work involves air dispersion modeling, state and federal air construction permitting, development of emissions inventories, and comprehensive Title V compliance management. Mike serves as a lead air dispersion modeler in Ohio and has specialized experience performing and managing complex air dispersion modeling analyses in support of state and federal construction permits. Mike received a Bachelor’s degree in meteorology from Ohio University and a Master’s degree in atmospheric science from North Carolina State University. William H. Haak, Founder, Haak Law LLC, 12595 Bentbrook Dr., Cleveland, OH 44026 216.772.3532 whh@haaklawllc.com William H. Haak is the Founder of Haak Law LLC – an environmental, health & safety legal and consulting firm based in Cleveland, Ohio. He has nearly 20 years of experience in occupational safety law and worker safety, and nearly 25 years of experience in environmental law (including extensive experience in air pollution control law and multi-media environmental compliance). Mr. Haak practices nationally in the United States and consults globally on all matters related to the EHS field (plus security and crisis management). Mr. Haak graduated from The University of Akron (Business Finance) and Case Western Reserve University School of Law (J.D. with an emphasis on litigation and trial practice). Following law school, he worked as an Assistant Attorney General in the State of Ohio Attorney General’s Environmental Enforcement Section. As counsel to Ohio EPA, Mr. Haak’s practice was focused primarily on civil and administrative air pollution control cases. During his time with the Attorney General’s Office, Mr. Haak resolved civil environmental enforcement actions resulting in civil penalties totaling approximately $4 million. Prior to forming Haak Law LLC, Mr. Haak was Senior EH&S Counsel for General Electric. He supported GE’s Appliances and Lighting Businesses and was engaged in complex air permitting issues for other GE businesses nationwide. Mr. Haak has also been Associate General Counsel – EH&S for Hexion Specialty Chemicals in Columbus, Ohio, and Senior Regulatory Law Counsel for Owens Corning in Toledo, Ohio. He served overseas in the former Soviet Union (Ukraine) as an Environmental Enforcement Specialist with the American Bar Association’s Central & East European Law Initiative ("ABA/CEELI"). Haak is a frequent lecturer to attorneys, engineers, and environmental professionals on topics concerning federal and state air pollution law. In addition, he has taught as an adjunct faculty member at the University of Central Florida in Orlando and Columbus State in Columbus, Ohio. Since 2005, Haak has taught classes focusing on Air Pollution Law and Occupational Safety and Health Law at The University of Toledo College of Law as an Adjunct Professor.
Biographical Information Robert F. Hodanbosi, Chief Ohio EPA, Division of Air Pollution Control Lazarus Government Center, 50 West Town Street, Columbus, OH 43215 614.644.2270 Fax: 614.644.3681 bob.hodanbosi@epa.state.oh.us Bob Hodanbosi became chief of the Division of Air Pollution Control (DAPC), Ohio Environmental Protection Agency (Ohio EPA) in September 1992. His current duties include being responsible for the air pollution control program for the state of Ohio and development of the programs needed to comply with the Clean Air Act Amendments. In 2004, Bob was selected to represent state permitting authorities on the Title V Permit Performance Task Force that was formed by the U.S. EPA's Clean Air Act Advisory Committee. Bob has also had the opportunity to testify at U.S. House and Senate committees on Clean Air Act implications for facilities in Ohio. From May 1987 to September 1992, his position was assistant chief of DAPC and manager of the Air Quality Modeling and Planning Section, DAPC, Ohio EPA. From April 1978 to May 1987, as manager of the Air Quality Modeling and Planning Section, his main duties included: development of the technical support for air pollution control regulations for criteria air pollutants; atmospheric dispersion modeling; air quality designations under Section 107 of the Clean Air Act and, development of new source review procedures. Since the 1980's, Bob has represented Ohio EPA on the Ohio Coal Development Office, Technical Advisory Committee. From January 1977 to April 1978, his position was supervisor of the Environmental Assessment Unit, DAPC, Ohio EPA. The main responsibilities of this position involved the supervising of all air quality evaluation and atmospheric dispersion modeling activities for DAPC. From June 1973 to December 1976, he held a position in the Northeast District Office/Engineering Services Section, DAPC, Ohio EPA. The main function of this position involved the engineering review of air pollution permit applications. Bob is a member of the American Institute of Chemical Engineers and Air & Waste Management Association and is registered as a Professional Engineer in the state of Ohio. Bob has lectured extensively on topics relating to the requirements under the Clean Air Act and the controls needed to meet air quality standards. Bob received his Masters of Science degree in Chemical Engineering at the Cleveland State University in 1977, and a Bachelor in Chemical Engineering at the Cleveland State University in 1973. In addition, he completed post-graduate courses in fluid mechanics and turbulence at the Ohio State University.
HAAK LAW LLC Environmental, Health & Safety Legal and Consulting Services 28 th Annual Conference on Air & Water Permits – Environmental Permitting in Ohio Workshop G – Air Permitting … Major New Source Review (NSR) Changes Impacting How You Do Business in Ohio July 25, 2018
Environmental Permitting in Ohio Workshop G Bob Hodanbosi Ohio EPA Division of Air Pollution Control July 25, 2018
What is Major New Source Review (NSR)? Attainment/Nonattainment Areas Prevention of Significant Deterioration (PSD) Permitting Nonattainment New Source Review (NNSR) Permitting Bonus Material
Permits required under the Clean Air Act: Major New Source Review (NSR) includes: ◦ Prevention of Significant Deterioration (PSD) in attainment areas ◦ Non Attainment NSR in non attainment areas Can include both “new major” or “major modification” If the emissions are large enough (over trigger levels), then a “Major New Source” permit is required
Criteria pollutants are classified as attainment, unclassifiable or nonattainment An attainment area is designated as “attainment” or “unclassifiable” for the National Ambient Air Quality Standards (NAAQS). A nonattainment area is one officially designated as nonattainment An area can be attainment/unclassified for some pollutants, and nonattainment for others.
Geographic areas where U.S. EPA has designated the area as attainment or non classifiable. Applies for only the attainment pollutant and precursor emissions (VOCs for ozone, NOx and SO2 for PM2.5). Some areas violate standards and are not yet designated nonattainment - PSD still applies
Geographic areas where U.S. EPA has designated the area as nonattainment. Applies for only the nonattainment pollutant and precursor emissions. Official designation determines regulatory path - If nonattainment areas attain standards, redesignation process is slow, NNSR applies until area designated to attainment
Pollutant Primary Source Attainment Status Carbon Monoxide cars and trucks Attainment Nitrogen Oxides any type of combustion, Attainment utilities, industrial boilers, vehicles Lead individual industrial facilities Isolated maintenance Sulfur Dioxide coal fired power plants Isolated nonattainment Ozone sources of NOx and Attainment for 2008 hydrocarbons, including standard; Columbus, cars, trucks, utility boilers, Cincinnati, and painting operations, Cleveland areas refineries nonattainment for 2015 standard Particulate Matter coal fired boilers, cement Lorain/Cuyahoga plants, steel making Counties nonattainment operations (in process of redesignation)
Sulfur Dioxide PM2.5 Nonattainment Nonattainment areas Area
Implementation Timeline 8-hour standard – 0.70 ppm (avg. of 4 th high over 3-yrs) June 4, 2018 – US EPA finalized non-attainment areas (effective August 3, 2018) ◦ Attainment demonstration due August 3, 2020 ◦ Ohio’s areas designated marginal non-attainment (attainment date- August 3, 2021)
PSD Goals Important Terms Applicability Requirements of PSD
Designed to protect air quality in attainment areas Allow economic growth Protect public health and welfare Preserve, protect, and enhance air quality in special areas
Attainment ◦ 28-source category? >100 ton/yr ◦ Not 28-source category? > 250 t/y
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