Workshop L New to EHS/101 … Air Permitting Basics Including Defining an Emissions Unit Tuesday, March 24, 2020 11:15 a.m. to 12:30 p.m.
Biographical Information Christopher T. Hage, Global Innovation HS&E Leader The Procter & Gamble Company, Winton Hill Business Center, 6105 Center Hill Avenue, Cincinnati OH 45224 513-634-1566 hage.ct@pg.com Chris started his career with Hampshire Chemical Company, a subsidiary of W.R. Grace, in 1995 as an HS&E Staff Engineer at their Lima, Ohio manufacturing facility, which produced chelates. In 1997, Chris joined Procter & Gamble at the Lima, Ohio plant, where he held numerous positions including liquid laundry and fabric enhancer process engineer, site quality assurance systems manager, and site environmental leader. In 2003, Chris joined Rohm & Haas as an HS&E Staff Engineer at their Cincinnati, OH manufacturing facility, which produced PVC stabilizers, asphalt additives, and catalysts. In 2008, Chris rejoined Procter & Gamble and for the next 11 years held numerous HS&E roles supporting manufacturing plants globally across the Fabric & Home Care, Chemicals, and Fragrances Business Unit and Baby Care, Feminine Care, and Family Care Business Unit. Chris is currently a Global Innovation HS&E leader who ensures project initiatives are delivered to manufacturing facilities in a manner that ensures HS&E compliance and leads the North American Environmental Core Team which is responsible for environmental capability at our manufacturing facilities. Chris is the proud graduate of three different universities. He received a B.A. from Rollins College in Winter Park, Florida in 1991. He received a B.S. in Chemical Engineering from Washington University in St. Louis, Missouri in 1993. He received a M.E. in Environmental Engineering from the University of Florida in Gainesville, Florida in 1995. Demonstrating his strong passion for coaching and teaching, Chris also received his AYA teaching Certificate in Physical Science/Physics & Chemistry from Bluffton University in 2005 and participated as an Adjunct Professor at the University of Northwestern Ohio. Courtney Zimmer, Environmental Health Safety Specialist Ball Metalpack 2850 Charter Street, Columbus, Ohio 43228 614-969-0416 Courtney.Zimmer@ballmetalpack.com Courtney started her career at August Mack Environmental, Inc. as a Compliance Specialist in Lewis Center, Ohio. In this position, she assisted various commercial and industrial facilities with environmental assistance. She worked to ensure facilities- maintained compliance for federal, state, and local requirements and regulations. This included a wide range of projects including, EPCRA Section 312 and 313 reporting, NPDES permitting and compliance, SWPP plans, SPCC, auditing, and air permitting and air reporting. Since then, Courtney is now an Environmental, Health, and Safety Specialist at Ball Metalpack, LLC in Columbus, Ohio. Here she acts as the main environmental contact across all the Ball Metalpack facilities. She works at ensuring environmental compliance and best practices are put in place and being maintained while assisting with environmental reporting. Courtney holds a Bachelor of Arts degree, with a major in Geography of Environment and Society and a minor in Environmental Laws and Policies from The Ohio State University.
Biographical Information Hope Manning, Senior Project Manager/Multi-Media Leader Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7238 hmanning@eqm.com Hope has over 16 years of technical and compliance management experience in the environmental field in both consulting and industry. She has been involved in a broad range of programs including air compliance and permitting, NESHAP Boiler GACT compliance, NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting, and auditing. Currently Hope leads the Multi-Media group at EQM which is comprised of individuals who have expertise in air, water, SPCC, and EPCRA reporting. She is also the primary environmental auditor for EQM. Prior to her joining EQM in 2015, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for over 50 locations in over 15 states. These activities included assisting in minor and major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University of Cincinnati. Bob Kuklentz, Directing Consultant, All4 Inc. 2393 Kimberton Rd., Kimberton, PA 19442 610.933.5246 x124 rkuklentz@all4inc.com Mr. Bob Kuklentz has 30 years of professional experience in multiple disciplines of environmental management in industry including 17 years in printing and packaging and 3 years in chemical specialties manufacturing. This includes all phases of industrial environmental management. He has worked in numerous states and Ontario, Canada. In his role in the printing and packaging industry, Mr. Kuklentz was instrumental in the significant reduction of VOCs corporate-wide through the conversion to water-based printing inks, reduction or elimination of VOC containing cleaning solvents, improved management processes and procedures, and partnerships with key suppliers. In his consulting role at ALL4, Mr. Kuklentz has managed multiple large and complex new source review (NSR) air permitting strategy and application projects in several states. Several examples include the permitting of multiple combustion turbines in an ozone non-attainment area, permitting of numerous boilers and industrial processes, permitting of facility-wide modifications at petroleum refineries, and numerous projects in the printing industry. Mr. Kuklentz also has extensive rule compliance and applicability experience including NESHAP’s and NSPS. This experience spans a wide range of industries including pharmaceutical, refining and consumer products manufacturing. Mr Kuklentz also serves as the assistant chief of the Chester County, PA Hazardous Materials Response Team and has over 25 years of emergency response experience.
Air Permitting Basics Including Defining an Emissions Unit Chris Hage, Global Innovation Leader, Procter & Gamble Bob Kuklentz, Directing Consultant, All4 Hope Manning, E&C Director, EQM Courtney Zimmer, Environmental Health & S afety S pecialist, Ball Metalpack Workshop L - 1 March 24, 2020
Air Permitting Workshop L - 2 March 24, 2020
40 CFR Part 60 – New S ource Performance S tandards Federal 40 CFR Parts 61/ 63 – National Emissions Rules for S tandards for Hazardous Air Pollutants 40 CFR Parts 51/ 52 – New S ource Review Air 40 CFR Parts 72-78 –Acid Rain Program Permitting 40 CFR Parts 70/ 71 –Title V Permitting Program Workshop L - 3 March 24, 2020
S tates Authority States have primacy Have permitting authority S tate Implementation Plans (S IP) S ource of most of permitting requirements. Workshop L - 4 March 24, 2020
Putting it All Together Federal Requirements (NS PS , NES HAP/ MACT , Acid Rain) Federal Programs State (S tratospheric Requirements Ozone (S IP) Protection, RMP) Facility Permit Workshop L - 5 March 24, 2020
New Construction New Construction What Modification of existing equipment Modification of existing equipment Requires a Increase in production Increase in production Permit Change in formulation Change in formulation Workshop L - 6 March 24, 2020
What type of permit do I need? New S ource Review Construction Permits – LARGES T PS D Maj or S ource/ Maj or Modification Thresholds 100 tpy for any listed source category 250 tpy for any other source category Pollutant-specific thresholds for modifications NNS R Maj or S ource/ Maj or Modification Thresholds 100 tpy Pollutant-specific thresholds for modifications Title V Operating Permit – LARGE Maj or source thresholds 100 tpy for any air regulated pollutant (lower for non- attainment areas) 10 tpy for a single HAP or 25 tpy for any combination of HAPs Other triggers = NS R Permit, Acid Rain Program, NS PS standards, most NES HAP/ MACT standards Workshop L - 7 March 24, 2020
What type of permit do I need? Federally Enforceable S tate Operating Permit (FES OP) – MEDIUM For synthetic minor sources S ite has taken a federally enforceable restriction (such as operating restrictions or emission limitations) to maintain potential emissions less than Title V maj or source thresholds S tate Operating Permit (PTI/ PTO/ PTIO) – S MALL For natural minor sources Everything Else (Registration, Permit-by-Rule, Exemptions) Workshop L - 8 March 24, 2020
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