Air Emission Workshop -

Air Emission Workshop -

Air Quality 102 Sponsored by Kansas Small Business Environmental Assistance Program 1-800-578-8898 1 Agenda

Welcome and introductions (questions) Air regulation overview Potential to emit (PTE) Limiting PTE Networking lunch Calculate your PTE 2 3 K-States Pollution Prevention Institute (PPI) PPI staff operate SBEAP in

partnership with KDHE. PPI services are Multimedia (air, waste, water) Free to small- and mediumsized businesses Confidential Non-regulatory PPI special projects enhance SBEAP services. 4 Small Business Environmental Assistance Program Provides air-focused technical

assistance to Kansas small- and medium-sized businesses Environmental regulatory compliance Emissions reduction and pollution prevention Permitting and reporting requirements All states have a similar program. 5 Small Business Environmental Assistance Program SBEAP services are provided via

Environmental hotline (800-578-8898) On-site visits Targeted regulatory or industry-specific workshops Publications (hard copy or electronic) Newsletters: AIRlines, EnviroLines Fact sheets, manuals E-tips Web-based resources and training 6

Questions or comments? Environmental Hotline 800-578-8898 7 Clean Air History 1273 King Edward I bans sea coal in London 1881 Chicagos first smoke-control law 1945 Pittsburgh smoke-control program 1947 Los Angeles Air Pollution Control District establishes smoke and SO2 regulations 1948-1954 several smog-related deaths

1955 - Congress passes the Air Pollution Control Act (first commitment of federal funds - $5M) 1963 Clean Air Act 1970 Clean Air Act Amendments (EPA formed) 1990 Clean Air Act Amendments of 1990 8 London fog incident of 1952 9 10 CAA 1970 Risk-based standards

SOx NOx CO PM10 Lead Ozone Technology-based standards for point sources 11 CAAA 1990 Contains 11 titles, including Title I: Ambient air quality standards Title III: Hazardous air pollutants (HAPs)

Title V: Operating permits 12 Kansas Air Quality Regulations KAR 28-19-1 -- 801 The Kansas Air Quality Act (KAQA) implements elements of the 1990 Clean Air Act Amendments. It is administered by the Kansas Department of Health and Environment (KDHE) Bureau of Air and Radiation (BAR). 13

What must you evaluate? KAQA applicability and compliance Existing sources that are not permitted Proposed sources Existing sources that are permitted, when modifying or adding new equipment 14

Kansas air operating permits Construction permits or approvals (registrations) Class I operating permits (true major sources) Class II operating permits (potential major, actual area sources; limits PTE) Class III or registrations no longer in effect 15 Major source Stationary source with potential emissions of 100 tons/yr or more of regulated pollutant

(e.g., NOx, SOx, PM10, VOC, CO) 10 tons/yr of any single HAP 25 tons/yr of any combination of HAPs 16 Potential to emit (PTE) This is the maximum design capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation shall be treated as part of the design Control equipment Hours of operation Amount of material

Stored Combusted Processed 17 PTE assumptions 24-hour operation, 365 days per year Operate at maximum capacity No pollution control devices or practices Bottlenecks can limit the PTE

18 Quiz Question If your facility only operates one shift, why calculate emissions as though you operate 24/7? 19 Quiz Answer Facilities are regulated based on their design not their

actual hours of operation. Production levels could change, and emissions would increase within existing facility. 20 Emission source any machine, equipment, device, or other article or operation that directly or indirectly releases contaminants into the outdoor atmosphere. Emission unit any part or activity of a stationary source that emits or would have the potential to emit any regulated pollutant or any pollutant listed under 42 U.S.C. 7412(b) of the federal Clean Air

Act. 21 What are emissions? Stack emissions Fugitive emissions (if a federally designated fugitive emission source) Other emissions 22 Identify each emissions unit A unit is an activity that emits or has the potential to emit. Emission units do not have to be

connected to a stack or vent. The entire facility can be viewed as an emissions unit. 23 Frequently overlooked emission sources Bleed valves Compressors Degassing (line, pump, vessel) Steam traps Process vents Pressure-relief

Cooling towers Loading operations Solid wastes Storm water runoff Wastewater collection and treatment Transfer operations 24

Emissions from activities Conveyors Tank truck loading and unloading Valves and vents Wastewater treatment plant emissions Material storage and transfer Evaporation Wind erosion

Haul roads 25 Other emissions to consider Degreasing tanks Welding activities Pumps Painting

Cleanup 26 What to leave out Categories of Exempt Activities

Fuel use Upkeep and maintenance Production operations Finishing operations Storage tanks Wastewater collection and treatment Cleaning operations Residential activities Recreational activities Health-care activities Miscellaneous 27

Quiz Question Do you calculate emissions from welding operations? 28 Quiz Answer Only if HAPs are emitted as a result of the welding. 29 PTE calculation methods

Material balance Emission factor Stack tests Other approved method 30 Steps for calculating PTE Identify each emission unit List all possible pollutants Quantify emissions (tons/year)

Material balance Emission factors 31 List all possible pollutants Nitrogen oxides (NOx) Sulfur oxides (SOx) Carbon monoxide (CO) Volatile organic compounds (VOCs) Particulate matter 10 microns or less (PM10) Hazardous air pollutants (HAPs) 32

Quantify emissions Material balance Emission factors EPAs AP42 factors Trade organization studies Performance tests 33 Fuel consumption Emissions from combustion can be calculated based on the fuel and equipment used. Rated heat capacity can be used.

Maximum rated fuel consumption can be used. 34 Material balance Product in = product out (assumes constant inventory) Example: solvent cleaning Solvent purchased = emissions Material balance can be applied to individual unit, activity, or entire source process. 35 Air construction permits

(Preconstruction approvals) Prevention of Significant Deterioration (PSD) permits Significance levels 100 ton/yr PTE for listed sources 250 ton/yr PTE for all other sources Construction permits KAR 28-19-300(a) Construction approvals KAR 28-19-300(b) 36 Construction permits when? If PTE threshold is met because of New construction

Modification of existing emission unit Change in method of operation Emissions unit is major HAP source or incinerator 37 What ISNT a modification? Routine maintenance, repair, or replacement Switching fuel specific cases Increase in production rate or hours as long as not prohibited by permit Change in ownership

38 Construction approvals (registrations) when? Emissions exceed thresholds Emissions unit is subject to NSPS NESHAP/MACT 39 Class I permits Combines all air quality requirements into single permit (corrects and modifies previous permits and approvals)

Requires sources to review and correct air quality requirements Requires annual air emission inventory submissions 40 Class I permits (cont.) Establishes recordkeeping, monitoring, and testing requirements Establishes semi-annual reporting and annual compliance certification Federally enforceable 41

Class I permit who needs it? Major source Affected source Subject to New Source Performance Standard (NSPS) Subject to 112(r), prevention of accidental releases Designated by the secretary 42 Quiz Question I think our facility needs a permit and I dont think we have one but Im not sure.

What do I do? 43 Quiz Answer Work with us and KDHE. KDHE will work with you but if legally required to impose a fine, they will have to do it. Still, better to get it resolved right away. 44 Class I renewals KDHE has a special form for Class I renewal applications.

New forms may be required if operations have significant changes. Submit application six to18 months prior to expiration of current permit. Contact KDHE for more information. 45 Limiting PTE Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of the design if the

limitation or effect it would have on emissions is federally enforceable. 46 Common methods of reducing PTE Pollution prevention Limit process rates Limit hours of operation Limit amount of material processed or combusted

Add pollution control equipment Emission limit required by a regulation Combination of these 47 Regulatory limits Regulations that are part of the state implementation plan (SIP) Class II permits New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP/MACT) Other federal regulations

48 Class II (synthetic minor) permits General Class II permits General rock crushers Permit-by-rule Reciprocating engines Organic solvent evaporative sources Hot-mix asphalt 50% actual 49 Class II permit emission levels Actual emissions (blue), potential emissions (red)

120 110 100 90 80 70 60 50 40 30 20 10 0 1 HAP

Multi HAP VOC 50 Federally enforceable permit conditions The condition must be permanent, quantifiable, and otherwise enforceable. The source must be able to meet its business needs while operating under the permit conditions. 51

Class II general permits Source proposes restrictions used to limit emissions Material purchased, used, or processed Hours of operation Control equipment Other restriction KDHE has specific forms for several processes and equipment. Recordkeeping 52 Class II Permit Application

Process/Equipment Description Form 53 Class II rock crushers (PM10) Special case of Class II permits Applies to portable or stationary facilities Select dry or controlled operation 54 Class II permit-by-rule for reciprocating engines with capacity less than

730 HP, or 550 kW, or 5.1 million Btu/hr input Or, limit hours or fuel input and maintain records 55 Class II permit-by-rule for organic solvent evaporative sources that purchase or use less than (in any consecutive 12-month period) 9 tons of VOCs or HAPs 90 tons of VOCs, or 22.5 tons of combination of HAPs, or 9 ton of a single HAP, and maintain records

56 Class II organic solvent evaporative sources Facility must Maintain on-site records, updated monthly Submit annual report of usage Report to KDHE if exceeds 85% of any restriction in a quarter Submit compliance plan if fails to meet any requirement 57

Example Calculations Solvent evaporative source 58 Recordkeeping varies look at your permit Rolling 12-month totals Total is calculated every month Not based on calendar year, based on last 12 months Example: total as of March 31, 2007 would be sum of emissions from April 1, 2006 through March 31, 2007

Quarterly totals these are based on calendar quarters, which end in March, June, September, and December 59 Class II permit-by-rule for hot-mix asphalt Control particulate emissions Limit production to <250,000 ton (12month rolling total) Maintain records 60 Permit-by-rule, 50% rule

For facilities with actual emissions less than 50% of major source thresholds For facilities with actual emissions between 25% and 50% of major source thresholds 61 NESHAP/MACT 1970 Section 112 provisionsnational emission standards for hazardous air pollutants (NESHAP) EPA had to identify hazardous air pollutants (HAPs) and identify standards to prevent any adverse human health effects with ample margin of safety. All were risk-based.

Courts directed EPA to determine safe air pollutant levels without technological or cost concerns. 1990smaximum achievable control technology (MACT) Congress saw setting health-based standards as too long and difficult, so initiated new technology-based standards. 62 NESHAP/MACT sources Generally major HAP sources, with a few exceptions New sources must install Best Available Control Technology; comply upon startup Existing sources must meet emission

limits of top 12% of controlled units; comply within three years of promulgation 63 General MACT requirements Initial notification Recordkeeping and reporting Malfunctions plus periodic startup and shutdowns must be reported. KDHE has adopted all MACT standards through July 1, 2003 (K.A.R. 28-19-750); submit reports for these to KDHE, copying EPA. List of MACTs 64 Area Source MACTs coming soon Autobody refinishing Fabricated metal products Paint stripping operations Plating and Polishing

65 Kansas Air Operating Permits Construction Permits or Approvals Construction, Modification, or Operations change yes Subject to PSD? Much review is required PM

PM10 PM (ag) SOx CO NOx Lead VOC no yes yes no

25 15 100 40 100 40 0.6 40 yes KDHE Construction Permit File for

Operating permit within one year of commencing Operations IF NEEDED before beginning operations Exceed Permit PTE Thresholds? Tons/year

No approval or permit needed KDHE IF NEEDED: File for Construction Operating permit 180 days Approval Already a major HAP source or incinerator?

yes no Subject to no NSPS or NESHAP/MACT? yes no exceed Approval PTE Thresholds?

PM 5 lb/hr PM10 2 lb/hr PM 2.5 (ag) 5 lb/hr SOx 2 lb/hr CO 50 lb/24hr NOx 50 lb/24hr Lead 0.1 lb/hr VOC (JO, WY) 15 lb/24hr

VOC (JO, WY) 3 lb/hr VOC (others) 50 lb/24hr 66 Kansas Air Operating Permits Class I Permits Major source PTE? yes 100 tpy criteria pollutant 25 tpy combination

of HAP 10 tpy single HAP no Affected Source? (acid rain) no Subject to NSPS? yes yes yes

(which requires Title V permit?) Class I Operating Permit no Subject to NESHAP that requires Title V? Check Class II applicability

no Major Source Actual? yes no yes Establishes Recordkeeping Monitoring Testing

Semiannual reporting Annual compliance certification Federally enforceable Designated by Secretary? no No Permit Required Subject to 112(r) only? yes

RMP and other requirements may apply 67 PTE Major Source? Go back to Class I no no

(100 tpy criteria pollutant 25 tpy combo of HAP 10 tpy single HAP) BUT Actual emissions are less? Kansas Air Operating Permits Class II Permits yes Can reduce PTE by physical or operational

capacity? yes Solvent evaporative emissions? yes (< 90 tpy VOC, 22.5 tpy HAPs 9 tpy HAP) Solvent Evap. Permit-by-rule no Emissions from reciprocating engines?

yes Recip. Eng. Permit-by-rule (<730 HP, 5.1 MMBtu, or 550 kW) no yes H.M. Asphalt Permit-by-rule Hot-mix asphalt facility?

(<250K ton, control PM) no Rock crushing? Class II Permit (set indiv. facility restrict. Can include control equip.) yes Rock Crusher General permit

(size limits, wet or dry) no no Total actual emissions less than 50% of major thresholds? (<50 tpy criteria, 12.5 tpy HAPs 5 tpy HAP) yes 50% Permit-by-rule 68

Kansas City Requirements Reasonably Available Control Technology (RACT) Johnson and Wyandotte counties Issued when counties exceed federal ozone standard restrictions remain in place Auto and light-duty truck surface coating Bulk gasoline terminals Petroleum refineries Printers Misc. metal parts coating 69 Jo &Wy County Requirements Cleaning/degreasing solvents

Commercial bakeries Gasoline volatility 70 Kansas City Landmarks 71 Kansas City Good Ozone Day 72 Kansas City Bad Ozone Day

73 Possible Controls Phased reduction in NOx emissions Sources with actual emissions >1,000 tpy Sources with actual emissions >100 tpy 74 Summary

Calculate PTE Identify emission sources Decide how to limit emissions Apply for a permit if needed NESHAP/MACT Kansas City requirements 75

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