Workshop N Practical Tips & Best Practices Navigating the - PDF document

Workshop N Practical Tips & Best Practices … Navigating the Complex Maze of Compliance with a New Air Permit Tuesday, March 24, 2020 2 p.m. to 3:15 p.m.

Biographical Information Amanda Jennings, Managing Consultant Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43082 614.433.0733 ajennings@trinityconsultants.com Amanda Jennings is a Managing Consultant in Trinity’s Westerville, Ohio, office and provides air quality support for several industries in Ohio, including but not limited to, petroleum refining/distribution, chemical manufacturing, surface coating, asphalt processing/shingle manufacturing, and fiberglass and foam insulation manufacturing. She graduated from Ohio University with a Bachelor of Science Degree in Chemical Engineering. Amanda has completed numerous projects over her 15 years of consulting experience ranging from minor and major source state construction permit to install (PTI) or permits to install and operate (PTIO) applications, Fee Emissions Reports (FERs), emissions inventories, Toxic Release Inventory Reports (TRIs), Title V operating permit renewal and modification applications, MACT and GACT general consulting/compliance assistance, and regulatory applicability analyses. Also, she routinely teaches Trinity’s Strategic Air Permitting in Ohio training course. Mark Stammen, Environmental/Safety Engineer Crown Equipment Corporation 40-44 S. Washington St., New Bremen, Ohio 45869 419.629.2311 mark.stammen@crown.com Mark Stammen is an Environmental/Safety Engineer in Crown’s Corporate Office in New Bremen, Ohio, and provides environmental and safety support for Crowns manufacturing and branch operations across the United States. His range of experience and support includes time as a lead Safety Representative of multiple Crown manufacturing facilities. Mark also has extensive experience in environmental permitting, reporting, remediation, plan writing, surveys, and inspections in the following areas: USTs, Wetlands, Endangered Species Surveys, Wastewater, Air, Asbestos, Hazardous Waste, Toxic Release Inventory (TRI), Tier II, Oil Spill Prevention Controls and Countermeasures (SPCC), and Stormwater. He graduated from Bowling Green State University with a Bachelor of Science Degree in Environmental Science Policy and Analysis. Prior to Crown, Mark spent several years working in the electric power generation industry. He is a certified Asbestos Hazard Evaluation Specialist in the States of Ohio and Indiana. Tracie Sorvillo, EHS Manager Sofidel 25910 US 23, Circleville, Ohio 43113 740.983.7806 tracie.sorvillo@sofidel.com Tracie Sorvillo is an EHS Manager at Sofidel Circleville, Ohio, first greenfield site for the Italian based Company and provides Environmental Health and Safety compliance for the facility. She has degrees in Chemical Engineering, Information Technology and obtained her MBA from The Ohio State University. Tracie has managed both Title V and non-Title V air permits during her 12 years of environmental health and safety work. Currently, she has been part of starting up a new tissue facility and managing and creating the tools needed to be in compliance with all the facilities Environmental permitting, health and safety regulations.

MEC Workshop N Navigating the Complex Maze of Compliance with a New Air Permit Amanda Jennings –Trinity Consultants, Inc. Tracie Sorvillo – Sofidel America Mark Stammen – Crown Equipment Corp. Cincinnati, OH – March 24, 2020

Permit Purpose & Timing for Compliance ˃ New installation  Requirements must be met upon startup ♦ Can there be commissioning time (excluded from startup)? ˃ Pros  Extra time to prepare to comply during construction of the source ˃ Cons  All new monitoring and recordkeeping equipment/ templates/ procedures to implement  Limited time to work out any kinks during actual operation

Permit Purpose & Timing for Compliance ˃ Existing emission unit modification  Comply with the new permit upon implementation of the change ˃ Pros ♦ Existing monitoring & recordkeeping may be in place ˃ Cons ♦ Potentially less time may be needed for construction, allowing less compliance prep time

New Permit Pitfalls ˃ Missed initial notifications ˃ Missed/ late reports ˃ Missed test dates ˃ Missing records ˃ Permit expiration ˃ Missed Title V permit updates (? )

Step 1 - Get a Good Permit! ˃ Prepare a good application that allows for maximum operational flexibility  Conservative emission rates or PTE-based limits potentially reduce monitoring and record keeping burden ˃ Carefully review any draft versions of the permit for accuracy, flexibility, and “ zinger” permit conditions  Draft permit is not set in stone – comment and negotiate!

Stages of Living with a Permit ˃ Working draft permit (? ) ˃ Draft permit (? ) ˃ Final permit ˃ Compliance demonstration ˃ Changes to permit

Draft or Working Draft Permit Stage ˃ Must review permit at this stage – best opportunity to get a permit that you can live with ˃ Permits that go “ direct final”  There is no official draft stage  Will the agency allow you to review a working draft version of the permit? ˃ Permits that go “ draft” & then “ final”  Will the agency also allow you to review a working draft version of the permit?  Additional, 30-day public comment period

What to Look for in a Draft Permit? ˃ Correct applicable requirements  Does it match application?  Exemptions properly documented? ˃ Duplicative or overlapping requirements  lb/ MMBtu & lb/ hr limits for same pollutant  One limit more stringent than another? ˃ Incorrect internal references ˃ Compliance demonstration methods  Are they accurate (e.g., units)?  Correct test methods  Feasibility?

Final Permit Stage ˃ Review to make sure comments incorporated ˃ Identify all changes vs. previous version of permit Do not j ust file that permit away! It’s time to live with your permit each & every day.

Title V Operating Permit Updates ˃ Ohio Title V source - example ˃ Don’ t forget that newly issued permits to install (PTIs) must be incorporated into your Title V permit! Off-permit change (e.g., new install)  Minor permit modification  S ignificant permit modification  ˃ Beware: There are some instances where operation of a new/ modified source can be prohibited until a revised Title V permit is issued final! For example, maj or NS R / PS D proj ects 

Step 2 - Read Your New Permit! ˃ Read and understand your permit (it is a contract & a living document!) ˃ Highlight “ action items” (as opposed to factual statements) ˃ Put reporting/ recordkeeping due dates on your calendar

Permit Structure ˃ S tandard or General Terms and Conditions Permit expiration  General deviation reporting requirements  Malfunction reporting requirements  General recordkeeping (e.g., 5 years)  ˃ Facility-Wide Terms and Conditions S ynthetic minor limits  ˃ Emission Unit-S pecific Terms and Conditions Description  Limits – emission limits, control requirements, &  operational restrictions Testing requirements  Monitoring\Record keeping\Reporting requirements 

Emission Limits, Control Requirements, & Operational Restrictions – Considerations ˃ Understand the units (lb/ hr, lb/ MMBtu, tpy, gr/ dscf, ppm, lbs/ gal, % opacity, % control, etc.)? ˃ What is the averaging period? S hort-term or long-term (instantaneous,  6-minute, hourly, monthly, annual, etc.) Rolling or block average  ˃ Are there allowable exceptions? May be hidden in the rule language  e.g., startup, shutdown malfunction  The answers to these questions are key to developing an effective compliance demonstration plan!

Don’t Forget Initial Notifications! ˃ General permit condition often requires initial notifications to the S tate, such as: Construction starts  Construction complete  Equipment placed in operation  Equipment reaches target production rate 

Initial Notifications ˃ May be hard to see! ˃ S tandard/ general terms ˃ Incorporation by reference

Compliance Assurance Requirements ˃ Testing  Implies direct measurement of emissions using a defined reference method  If required/ as required ˃ Monitoring  Implies reading an instrument or gauge (including a CEMS / COMS ) ˃ Record keeping  All other paperwork associated with permit

Testing Pitfalls ˃ Not being prepared Ports not in correct position  Operating schedule coordination poor (100% load vs.  partial load) No recording of production variables during test  ˃ Errors Math errors  S loppy field work, hand-written records  ˃ Inappropriate test methodology VOCs – are all accounted for?  Condensable/ Filterable particulates  ˃ Results are questionable Make no sense (variability run-to-run)  No correlation to other test results 

Monitoring Considerations ˃ What does the regulation specify? What to monitor  Frequency  Parametric or emissions  Prescribed method or device  Accuracy and/ or reliability requirements  Calibration requirements  ˃ Explore alternatives & customize ˃ Plan to automate associated record keeping? ˃ Test drive prior to compliance date