Transcript Air Regulations: Permitting Basics

FET Environmental Primer
Air Regulations: Permitting Basics
Steven Klafka, P.E.
Wingra Engineering, S.C.
Madison, Wisconsin
www.wingraengineering.com
Air Quality Permit Overview
WDNR responsible for permit issuance
USEPA oversight
Construction permits for new sources
Operation permits for existing sources
Wingra Engineering, S.C.
2
Air Pollution “Sources”
1.
2.
3.
4.
1.
2.
3.
Operations Issued Air Quality Permits
Stationary - Process or Point
Stationary - Factory or Facility
Portable - Asphalt Plant
Indirect - Parking Lots and Highways
Not Issued Air Quality Permits
Area - Small Boilers, Wildfires
Mobile - Cars, Trucks, Busses
Off Road – Lawn mowers, Snowmobiles
Wingra Engineering, S.C.
3
Wisconsin VOC Emissions
50
45
40
35
30
25
20
15
10
5
0
Point Sources
Mobile Sources
Area Sources
Contribution (%)
Wingra Engineering, S.C.
4
Air Pollution Sources Issued Permits
Burning of fuels or wastes.
Conveying or handling of dusty
materials like sand, wood shavings, etc.
Evaporation of solvents from painting,
printing, cleaning, gluing, storage, etc.
Chemical processing and reactions.
Wingra Engineering, S.C.
5
Types of Emission Estimates
MTE or Uncontrolled – Need for Permit
Full capacity; 8,760 hrs/yr; 0% collection
Potential – Determines Compliance
Full capacity; 8,760 hrs/yr; Required %
Actual – Reported for Annual Fees
Actual capacity, hrs/yr and % collection
Wingra Engineering, S.C.
6
Sample Permit Calculations #1
Shotblasting Operation with 99% Efficient Baghouse
Capacity = 2 tons per hour of metal
USEPA Emission Factor = 17 lbs TSP/ton of metal
Applicable Discharge Limit = NR 415.05(2) = 3.59 P 0.62
Comparison with General Permit Exemption Thresholds
MTE = 2 tph x 17 lbs of TSP/ton = 34 lbs of TSP/hr
> 5.7 lbs TSP/hr, NR 406 construction permit required
Actual = 34 lbs/hr x (1 – 0.99) = 0.34 lbs TSP/hr
Potential = 3.59 (2) 0.62 = 5.5 lbs TSP/hr
Wingra Engineering, S.C.
7
Types of Emission Estimates
35
30
25
20
MTE/Uncontrolled
Potential/Allowable
Actual
15
10
5
0
Emissions (lbs/hr)
Wingra Engineering, S.C.
8
CONSTRUCTION PERMITS
Must be issued prior to construction or
modification of regulated sources.
NR 406 - Exemptions and Schedules
NR 405 - PSD rules for Large Projects
NR 410 – Fees
NR 411 – Parking Lots and Roads
NR 150 – Environmental Assessment & EIS
Wingra Engineering, S.C.
9
Types of Specific Exemptions
Natural gas-fired boilers < 25 mmbtu/hr
Wood-fired boilers < 5 mmbtu/hr
Paint/ink usage < 1,666 lbs VOC/month
VOC storage tanks < 10,000 gallons
Emergency generators < 3,000 kilowatts
Each state has own specific exemptions.
Wingra Engineering, S.C.
10
Types of General Exemptions
Uncontrolled emissions < all permit thresholds
5.7 lbs/hr of total suspended particles (TSP)
3.4 lbs/hr of particles < 10 microns (PM10)
9.0 lbs/hr of sulfur dioxide (SO2)
9.0 lbs/hr of nitrogen oxides (NOx)
Thresholds for >500 air toxics under NR 445
Use specific exemption first, then general.
Wingra Engineering, S.C.
11
Sample Permit Calculations #2
Paint Spray Booth with 95% Efficient Filters
Actual paint usage = 600 gallons per month
Maximum paint usage = 1.5 gallons per hour
Maximum VOC content = 3.5 lbs VOC per gallon
Maximum solids content = 6.0 lbs solids per gallon
Spray gun transfer efficiency = 70%
Comparison with Specific Permit Exemption Thresholds
Actual = 600 gpm x 3.5 lbs/gal = 2,100 lbs/month VOC
> 1,666 lbs of VOC/month exemption threshold
Wingra Engineering, S.C.
12
Sample Permit Calculations #2
Comparison with General Permit Exemption Thresholds
VOC Emission Estimate
MTE = 1.5 gph x 3.5 lbs/gal = 5.3 lbs/hr
< 5.7 lbs/hr general exemption threshold for VOC
PM10 Emission Estimate
MTE = 1.5 gph x 6.0 lbs/gal x (1 - 0.7) = 2.7 lbs/hr
< 3.4 lbs/hr general exemption threshold for PM10
Conclusion:No NR 406 construction permit is required
based on the general permit exemption thresholds.
Wingra Engineering, S.C.
13
Schedule and Fees
Permit issuance within 2 to 12 months.
30-day public comment period.
Public hearing if requested by public or
applicant.
$1,350 initial application fee
$2,300 to $85,000 permit issuance fee
NR 438 annual emission fee ($35/ton)
Wingra Engineering, S.C.
14
Criteria for Permit Approval
Comply with emission limitations.
Comply with air quality standards using
dispersion modeling analysis.
Standards include the NR 404 National
Ambient Air Quality Standards or NR
445 Acceptable Air Concentrations for
hazardous air pollutants.
Comply with current policies.
Wingra Engineering, S.C.
15
Typical Permit Schedule
Week
Week
Week
Week
Week
Week
Week
1 – Submit application to DNR
5 – Receive DNR request for information.
7 – Respond to request for information.
11 – DNR issues draft permit and PD.
12 – Publish notice for public comments.
16 – Public comment period ends.
18 – DNR issues final permit and invoice.
Wingra Engineering, S.C.
16
Expedited Permit Issuance
Pre-application meeting with DNR.
Submit a complete application.
Anticipate DNR application review needs.
Provide emission calculations.
Comply with applicable requirements.
Conduct DNR modeling & risk analyses.
Prepare environmental assessment.
Anticipate public involvement.
Wingra Engineering, S.C.
17
Recent Air Permit Enforcement
$45,000
$45,600
$60,000
$65,000
$71,820
$86,450
–
–
–
–
–
–
Failure to obtain permit.
Exceeded emission limits.
Failure to maintain records.
Failure to obtain permit.
Failure to maintain records.
Failure to raise stack.
http://www.doj.state.wi.us/dls/environpro/news/
Wingra Engineering, S.C.
18
Keys to Successful Air Permits
Stay involved in review process.
Review preliminary permit prior to
official “draft” permit.
Anticipate future production needs and
provide flexibility in permit.
Minimize unnecessary requirements.
Wingra Engineering, S.C.
19
PSD Rules Add Complexity
NR405-Prevention of Significant Deterioration
Applies to new large sources
Applies to modifications of large sources
Additional permit issuance time
Best Available Control Techology or BACT
Pre-construction ambient monitoring
Dispersion modeling for increments & NAAQS
Visibility, growth and vegetation analyses
Wingra Engineering, S.C.
20
PSD Thresholds (tons/year)
Air Pollutant
New Plant
Modification
PM10
100/250
15
SO2
100/250
40
NOx
100/250
40
CO
100/250
100
VOC
100/250
40
Pb
100/250
0.6
Wingra Engineering, S.C.
21
PSD Avoidance
PSD rules uses “potential” emissions.
Permit restrictions on capacity,operating
hours, or collection % are considered.
PSD avoided to save permit issuance
complexity or processing time, or
eliminate control requirements.
Balance restrictions and future growth.
Wingra Engineering, S.C.
22
Anatomy of an Air Permit
Description of source or process.
Emission limitations.
Wis. Adm. Code citations.
Record keeping requirements.
Monitoring requirements.
Testing and certification requirements.
Reporting requirements.
Wingra Engineering, S.C.
23
Sample Air Permit
Wingra Engineering, S.C.
24
Construction Permit References
Jeff Hanson, Construction Permit Leader
[email protected] and (608) 267-6876
Regional DNR Office Air Staff
Air Permit Web Site
http://www.dnr.state.wi.us/org/aw/air/reg/regs.htm
Provides application forms, instructions, issued and pending
construction permits, and modeling guidance.
Wingra Engineering, S.C.
25
OPERATION PERMITS
Application must be filed for existing
regulated sources or prior to expiration
of construction permits.
Title V of 1990 Clean Air Act
Amendments (Congress)
40 CFR Part 70 (USEPA)
NR 407 - Exemptions & Schedules (WI)
Wingra Engineering, S.C.
26
Processes included in Permit
Similar exemption thresholds as
provided for construction permits.
Includes processes which require a
construction permit if built today.
Includes minor processes which exceed
NR 407 Table 2 inclusion thresholds (i.e.
2,000 lbs/yr).
Wingra Engineering, S.C.
27
Types of Operation Permits
FOP or Title V or Part 70 Permit
 100 TPY PM, SO2, NOx, CO, VOC, Pb, Lower TPY for VOC if located
in ozone nonattainment area (SE Wisconsin)
 10 TPY Federal Air Toxic or 25 TPY Combined Air Toxics
 Subject to most thorough review and compliance demonstration.
 Subject to MACT, if available.
 All applications for existing WI sources were due by 1995.
Wingra Engineering, S.C.
28
Types of Operation Permits Cont’d
Federally Enforceable Synthetic Minor Permit
 Limits potential emissions by using operating hours or
production restrictions to remain below thresholds.
 Avoids MACT or other FOP requirements.
 All WI applications were due by 1995.
 Balance FESOP restrictions and future growth.
Wingra Engineering, S.C.
29
Types of Operation Permits Cont’d
SOP – State Only Permit
 Required by state not federal rules.
 Potential emissions less than FOP thresholds (i.e. 100 TPY)
 Only annual compliance reports.
 All applications for existing WI sources were due by 1998.
Wingra Engineering, S.C.
30
Types of Operation Permits Cont’d
Applications for all existing sources in
Wisconsin have been submitted to DNR.
Construction permits for new or
modified processes are replaced with
operation permits prior to expiration or
incorporated into the facility-wide
operation permit.
Wingra Engineering, S.C.
31
Operation Permit References
Keith Pierce, Operation Permit Leader
[email protected] and (608) 267-0562
Regional DNR Office Air Staff
DNR Air Permit Web Site
http://www.dnr.state.wi.us/org/aw/air/reg/regs.htm
Provides application forms, instructions, issued and pending
operation permits, permit application software.
USEPA MACT Web Site
http://www.epa.gov/ttn/atw/eparules.html
Wingra Engineering, S.C.
32
Air Permits in a Nutshell
NR 406 construction permits required prior to
the start of construction or modification.
NR 407 operation permits are for existing
processes, or replace construction permits.
Review permits thoroughly before issuance to
assure accuracy and flexibility.
Wingra Engineering, S.C.
33