Workshop I Clean Air Act Challenges … Ohio Air Permitting 101 s Tuesday, March 26, 2019 11:15 a.m. to 12:30 p.m.
Biographical Information Terri Sexton, Manager Environmental and Energy Affairs Navistar, Inc., 6125 Urbana Rd., Springfield, OH 45502 937-390-4011 Fax: 937-390-4766 terri.sexton@navistar.com Terri is a corporate Manager of Environmental and Energy Affairs for Navistar, Inc. She manages various environmental and energy projects and programs across the corporation, most recently focused on significant energy conservation, reductions in greenhouse gases and waste, leading to cost reduction. Terri is also currently responsible for EPA compliance in the air and solid waste media at the Springfield Truck assembly site. She has worked in the EHS field for over 25 years including employment at corporate, manufacturing/industrial facilities, wastewater treatment operations, and EPA (RAPCA). Terri holds a masters degree in environmental management systems from Southern Methodist University and a bachelor’s degree in biology and environmental sciences from Wright State University. Terri holds professional certifications as a Qualified Environmental Professional (QEP) and Certified Hazardous Materials Manger (CHMM), and an OEPA and IDEM Class I Waste Water licenses. Terri has been an active A&WMA member since starting her career at RAPCA, always in the Southwest Ohio Chapter and East Central Section, where she is (or has) most recently serving as Vice Chair of each, and later Chair of SWO Chapter. Andrew W. Weisman Regional Air Pollution Control Agency (RAPCA) 117 S. Main St. Dayton, Ohio 45422 (937) 225-4982 aweisman@rapca.org Andy started his environmental career as a consultant with PEER Consultants in Dayton, Ohio from 1987-1991 and continued with Pacific Environmental Services (later became MACTEC) from 1991 – 2001. While with both companies he was a staff engineer/project manager involved in air emissions stack testing and environmental permitting for air, wastewater, storm water and hazardous waste. Andy joined RAPCA in 2001as a permit writer and has also served as an inspector and stack test observer. Andy is currently the Permit and Inspection Group Supervisor at RAPCA and oversees all RAPCA’s permitting, inspection and stack testing activities. Andy is a graduate of the University of Dayton with Bachelor of Science degree in Chemical Process Technology.
Biographical Information Stephanie Madden EHS Technology Group, LLC 2912 Springboro West Suite 101, Moraine, Ohio 45439 (937) 865-3947 smadden@ehstech.com Stephanie is a Project Manager for EHS. Her environmental experience includes 10 years serving in the capacity as both a regulator and an environmental consultant. Stephanie started her environmental career as a permit writer focusing on air permitting and inspections for a variety of industrial sources with the Regional Air Pollution Control Agency (RAPCA). She was also involved with operating and maintaining the national ambient air monitoring network for RAPCA’s 6 county jurisdiction. Stephanie also served as Permit and Inspection Supervisor at RAPCA where she assisted & coordinated efforts with major facility permitting, inspection & compliance issues. She was also responsible for the oversight of the permit and inspection group where she managed agency permitting goals and facility inspection commitments. This included review and final approval of all air pollution permit-to-install, permit-to-install and operate, and Title V permitting in RAPCA’s jurisdiction. Since joining EHS, she has been involved with consulting projects involving air permitting, hazardous waste management, SWP3s, SARA Title III, SPCC Plans, emissions inventories and regulatory applicability analyses for industrial clients in the states of Ohio, Kentucky, Indiana, Alabama, Louisiana, Oklahoma, Georgia, California, North Carolina, Virginia and Texas. Stephanie is a graduate of Wright State University with a Bachelor of Science degree in Environmental Science.
Workshop I – Ohio Air Permitting 101 Basics of Air Permitting 28 th Annual Sustainability & EHS Symposium Cincinnati, Ohio March 26-27, 2019 Presented by: Stephanie Madden, EHS Technology Group Terri Sexton, Navistar Andy Weisman, RAPCA
Presentation Overview Permitting Basics Permit Exemptions & Application Process Complying with a Permit
Key Definitions Emission unit: Each separate operation or activity that results or may result in the emission of any air contaminant Sometimes used interchangeably with “source”
Key Definitions (cont’d) Air Contaminant: Means particulate matter, dust, fumes, gas, mist, radionuclides, smoke, vapor or odorous substances, or any combination thereof. Does not include uncombined water vapor Potential to Emit (PTE): Used to determine applicability of many regulations Maximum capacity of an emissions unit or stationary source to emit an air pollutant under its physical and operational design Generally assumes operation at 8,760 hours/year Generally does not consider the use of air pollution control equipment Can include emission limiting factors if they are made part of an enforceable permit
Key Definitions (cont’d) Modification : Any physical change in, or change in the method of operation of an air contaminant source that results in an increase in allowable emissions Includes emission of a new pollutant Includes relocation of the source to a new site (but generally not within the existing facility) Does not include routine maintenance, routine repair, and routine replacement (be careful regarding interpretation of “routine”) Must get a permit
Permitting - Overview Permits are the primary tool for EPA to regulate industry Two basic categories of air permits: Installation/Construction Called a Permit to Install (PTI) Operating (“major” sources only after June 2008) After June 2008, non-major sources receive a combined Permit to Install/Operate (PTIO) Major Sources receive a Title V Operating Permit
Ohio Permits ACTIVITY Construction Facility / Classification Operation Modification Permit to Major Title V Install Minor Permit to Install/Operate
Major Source Thresholds Construction Permits Attainment Area Non-Attainment Area Categorical Industry ≥ 100 TPY ≥ 100 TPY Non-Categorical Industry ≥ 250 TPY ≥ 100 TPY “Categorical Industries” includes any one of 28 listed in OAC 3745-31-01(LLL) Operating Permits All Areas Criteria Pollutants ≥ 100 TPY Any Single HAP ≥ 10 TPY Combined HAPs ≥ 25 TPY
Threshold Comments Any source that is not a “major source” is considered a minor source. Determination is typically made based on Potential to Emit (PTE) Sources can voluntarily limit emissions to less than major source levels Voluntary limits on PTE must be contained in an enforceable permit condition Source is known as a “Synthetic Minor”.
Synthetic Minor Synthetic Minor: A permit in which a company accepts voluntary emission limits in order to avoid major source status Limits can be on one emission unit or over entire facility Permit will impose record keeping/reporting requirements to “prove” that source is staying below major source thresholds
Permit Exemptions Permanent PTI Exemptions Found in OAC 3745-31-03 Based on process-type Examples: Boilers < 10 mm BTU/hr. Maintenance Welding Aqueous Parts Washers No notification required OEPA added several new exemptions in May 2016
Permit Exemptions (cont’d) De Minimis Exemption Found in OAC 3745-15-05 Exempts sources with PTE < 10 lbs./day (PM, SO2, NOx, OCs, CO, Lead, etc.) If PTE is > 10 lbs/day, but actual emissions are less than 10 lbs./day, can maintain daily records to prove exemption Sum of similar sources can’t be > 25 TPY Emits < 1 tons/year any HAPs or combination of HAPs No notification required Keep documentation of applicable exemption.
Streamlined Permits Permit by Rule (PBR) Found in OAC 3745-31-03 Standard permit terms written into regulations Must notify OEPA with 1-page form 45 different sources are listed; adding regularly Typical activities covered are: emergency electrical generators; resin injection/compression molding equipment; small crushing and screening plants; soil-vapor extraction and soil-liquid extraction remediation activities; auto body refinishing facilities; gasoline dispensing facilities; natural gas fired boilers and heaters; and printing facilities
Streamlined Permits (cont’d) General Permit Found in OAC 3745-31-29 (05/29/2014) Set of “pre-written” permit conditions for commonly found sources Must submit a (streamlined) application Available for the following : Aggregate Processing Boilers Digester Operations Dry cleaning Operations Mineral Extraction Miscellaneous Metal Parts Painting Lines Oil and Gas Well-Site Production Operations Paved Roadways and Parking Areas Portable Diesel Engines (Compression Ignition Internal Combustion Engine) Ready Mix Concrete Batch Plants Storage Piles Tub Grinder Unpaved Roadways and Parking Areas
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