Workshop L Environmental Regulations Compliance 101 … How Best to Meet the Regs Impacting Your Daily Job Tuesday, March 27, 2018 11:15 a.m. to 12:30 p.m.
Biographical Information Rajib Sinha, P.E., Senior Engineer/Project Manager Trihydro Corporation, 2702 Kemper Road, Cincinnati, OH 45241 513.429.7456 (O) (513) 604-8940 (Cell) Fax: 513.782.4807 RSinha@Trihydro.com Mr. Sinha is a Chemical Engineer and Project Manager with over 25 years of experience in Environmental Consulting and Engineering. Mr. Sinha has provided a wide array of services to industry for compliance with various laws. For eight years, Mr. Sinha led a team of engineers, geologists, scientists, and administrative staff that provided environmental compliance, safety, and Industrial Hygiene services to commercial facilities and governmental clients. This includes projects conducted under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Resource Conservation and Recovery Act (RCRA); Superfund Amendments and Reauthorization Act (SARA); Bureau of Underground Storage Tank Regulations (BUSTR). Mr. Sinha has designed and implemented several systems for treating contaminated groundwater and industrial wastewater and assisted several clients in complying with provisions of the National Pollutant Discharge Elimination System (NPDES) under the Clean Water Act (CWA). He has coordinated his work activity with various disciplines and clients. Mr. Sinha has also served as the Project Leader for research projects at the U.S. Environmental Protection Agency (USEPA) Test & Evaluation (T&E) Facility in Cincinnati, OH. He directs research related to providing safe drinking water with a particular emphasis on systems serving small communities without access to public drinking water systems. Other current projects include development of innovative retrofit devices for stormwater management and watershed management research. Mr. Sinha also develops and manages third-party commercial projects at the T&E Facility. Mr. Sinha has made numerous presentations in conferences as well as published papers in peer-reviewed journals. Mr. Sinha holds a Bachelor of Technology in Chemical Engineering (Jadavpur University), Master of Science in Chemical Engineering (University of Southern California), and a Master of Business Administration (University of Cincinnati). Kris Singleton, Corporate Environmental Engineer SunCoke Energy, Inc., 3353 Yankee Rd., Middletown, OH 513.727.5518 Fax: 513-727-5508 kesingleton@suncoke.com Ms. Singleton has over 25 years of experience in regulatory compliance including environmental, safety and quality management. Ms. Singleton started her career as a project engineer with an environmental and engineering consulting firm in southwest Ohio, gaining experience with air and water permitting as well as environmental compliance plan preparation (SPCC, storm water, hazardous waste management, etc.). Ms. Singleton then moved into the chemical manufacturing industry, progressing from Environmental Engineer to Manager of Quality Assurance and Regulatory Compliance working for several chemical manufacturing companies in West Virginia and Ohio. Experiences included wastewater treatment unit operations, air emissions reporting, leak detection and repair programs, Title V compliance, Continuous Emissions Monitoring Systems (CEMS), and environmental and quality management systems (ISO 14001 & 9001). In 2008, Ms. Singleton joined Dayton Power and Light as Environmental, Health and Safety Engineer responsible for environmental and safety compliance at several coal and natural gas electric generation stations. Ms. Singleton joined SunCoke Energy in 2013 as Environmental Manager for their Middletown, Ohio facility which manufactures metallurgical coke for the steel industry and also produces power using heat recovery steam generators. Currently, Ms. Singleton serves as SunCoke’s Corporate Environmental Engineer where she supports environmental operations at SunCoke’s manufacturing facilities in the U.S. and helps lead corporate environmental initiatives. Ms. Singleton holds a Bachelor of Science degree in Chemical Engineering from the University of Dayton in Dayton, Ohio.
Workshop L Environmental Regulations Compliance 101 … How Best to Meet the Regs Impacting Your Daily Job 1
Your Presenters Rajib Sinha, P.E. Senior Engineer and Project Manager Trihydro Corporation Cincinnati, Ohio Kris Singleton Corporate Environmental Engineer SunCoke Energy Middletown, OH 2
Course Objectives • Overview of Major Environmental Regulations • Applicability Triggers $97,000 this year for CAA • State Variations CWA almost $54K RCRA was almost $72K • Avoid Brain Overload Title 40 Code of Federal Regulations (CFR) = 1,700 Parts 50 States + Local Regulations 3
Major Environmental Statutes Laws Behind the Regulations • Clean Air Act (CAA) • Clean Water Act (CWA) • Resource Conservation and Recovery Act (RCRA) • Safe Drinking Water Act (SDWA) • Emergency Planning, and Community Right‐to‐Know Act (EPCRA ) • Superfund Amendments and Reauthorization Act (SARA) • Toxic Substances Control Act (TSCA) • Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 4
Clean Air Act (CAA) and Clean Air Act Amendments (CAAA) 5
Major Provisions of the Clean Air Act • National Ambient Air Quality Standards (NAAQS) • State Implementation Plans (SIP) • New Source Review (NSR) • New Source Performance Standards (NSPS) • National Emission Standards for Hazardous Air Pollutants (NESHAP) • Risk Management Program (RMP) • Protection of Stratospheric Ozone (Refrigerant Management) • Title V Operating Programs (Title V) Clean Air Act 6
Clean Air Act Federal Permit Programs (Title I) P revention Criteria Pollutants N ational • Carbon Monoxide S ignificant • Nitrogen Dioxide • Sulfur Dioxide A mbient D eterioration • Ozone Precursors Attainment (VOCs + NO x ) A ir • Particulate Matter (PM) N ew • Lead Q uality S ource S tandards • State Implementation R eview Plans (SIP) • New Source Review Non-Attainment 7
Clean Air Act Federal Pre‐Construction Permit Programs PSD (Attainment Area) NSR (Non‐Attainment) Area Minor Source Minor Source • PTE < 250 TPY (Site Wide) • Generally PTE <100 TPY • PTE < 100 TPY (28 Industries) • Lower thresholds depending on NA severity • New Source/Modification Extreme – Severe – Serious – Marginal • < 100/250 Tons = No PSD – Moderate Permit • Modifications can require Major Source permit if significant increase • New Source PSD permit Synthetic Minor • Major Modification Triggers • Limits on Production } < 15 Tons for PM up to No PSD • Hours of Operation < 100 Tons for CO Permit 8
Clean Air Act Federal Pollutant Standards (Title I) • Criteria Pollutants N ew • New/Modified Industrial Sources • ~ 90 New Source Standards S ource • Boilers • Printing Presses P erformance • Surface Coating Operations • Kraft Pulp Mills S tandards • Residential Wood Heaters • Bulk VOC Storage Tanks 9
Clean Air Act Federal Pollutant Standards (Title III) N ational • 40 CFR 61 Original HAPs: • Arsenic • Mercury E mission • Radionuclides • Asbestos S tandards for • Vinyl Chloride • Benzene • New/Existing Sources H azardous • Size ‐ Capacity ‐Throughput Triggers • Source Standards. Examples: A ir • Beryllium Machine Shops • Benzene at Chemical Plants P ollutants • Asbestos Demolition/Renovation 10
Clean Air Act Federal Pollutant Standards (Title III) • 40 CFR 63 – 1990 CAAA M aximum • ~ 188 HAPs • Major Source Triggers A chievable • PTE Single HAP > 10 TPY • PTE Combined HAP > 25 TPY • ~115 Major HAP Sources C ontrol • Surface Coating – Chemical/ Manufacturing/Aerospace T echnology • Area HAP Sources • Applies to facilities that do not exceed major source trigger individually. • Examples: Halogenated Degreasing; Boilers; RICE 11
Clean Air Act Title V Permits • Site‐Wide Umbrella Permit (All T&Cs in One Place) • Identify All Sources Applicable Regulations • Deviation Reporting ‐ Qtr/Semi‐Annual/Annual • 5‐Year Renewal • Permit Triggers • PTE > major source threshold for any air pollutant • > 100 TPY “default” • >10 or 25 TPY for HAP or combined HAPS • Non‐major sources subject to NSPS or NESHAP • Acid Rain Sources (Coal Utilities) Clean Air Act 12
Minor Source Permitting • Issued by the State • Must obtain permit prior to construction • Some exceptions to requiring a permit: • De minimis examples – 10 lbs/day, less than 1 TPY HAP in Ohio • Permanent exemption example – heaters and dryers < 10 mmBtu/hr • Source Specific Operating Agreements (SSOAs) ‐ Indiana State requirements can vary widely! Clean Air Act 13
State Air Permits Differences OH KY IN Title V Permit (Authority) Registration Synthetic Minor (FESOP) Permit by Rule (PBR) Air Toxics Program Permit to Install/Operate (PTIO) General Permits State Origin/Operating Permit Source Specific/Minor Source Permit Letter of Exemption Trivial Activities/Exemptions < 10 TPY < 10 Lb/Day PTE Based Exemptions Range Table < 2 TPY single HAP < 1 TPY HAPs < 5 TPY Combo HAP 14
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