Air Permits 101 Dustin Duhon Air Permits Division

Air Permits 101 Dustin Duhon Air Permits Division

Air Permits 101 Dustin Duhon Air Permits Division Louisiana Department of Environmental Quality What Are Permits Designed To Do? What Are Permits Designed To Do? Achieve and Maintain Air Quality Standards Communicate Operational Requirements to the Permittee and the Public Provide a Standard by Which Compliance is Judged

PERMIT APPLICATION COMPONENTS Permit Application Components What is in a Permit Application Form? Main Application Form Emissions Inventory Questionnaire (EIQ) sheets Regulatory Analysis Certifications Attachments Environmental Assessment Statement (EAS) Supporting Calculations

Source ID No.: Descriptive Name of the Source LAC 33:III 509 2103 2104 2111 2113 2116 2123 5 9 LAC 33:III.Chapter 11 13 15 22 29 51 53 56 59

KEY TO MATRIX 1 (Applicable) The regulations have applicable requirements that apply to this particular emissions source. This includes any monitoring, recordkeeping, or reporting requirements. 2 (Exempt) The regulations apply to this general type of emission source (i.e. vents, furnaces, towers, and fugitives) but do not apply to this particular emission source. 3 (Does Not Apply) The regulations do not apply to this emissions source. The regulations may have applicable requirements that could apply to this emissions source but the requirements do not currently apply to the source due to meeting a specific criterion, such as it has not been constructed, modified or reconstructed since the regulations have been in place. Blank The regulations clearly do not apply to this type of emission source.

For each Emission Point ID Number: List each regulation that applies. Arrange the requirements imposed by each regulation according to the headings provided below. Repeat this process for each regulation that applies to each source. State-only Requirements should be noted as such in the appropriate column. No.: Applicabl e Requirem ent Compliance Method/Provision

Requirements that limit emissions or operations Requirements that specify monitoring Requirements that specify records to be kept and requirements that specify record retention time Requirements that specify reports to be submitted Requirements that specify performance testing - Complian Averaging ce Period/Freque Citation ncy

State Only Requirem ent Certifications Responsible Official All permit applications and permitting action applications Must be qualified to sign [LAC 33:III.502] Can designate Duly Authorized Representative using form: http://www.deq.louisiana.gov/portal/tabid/2758/Default.aspx Professional Engineer Necessary for Part 70 permits only Must be Registered Professional Engineer in LA (other

states are not acceptable) Environmental Assessment Statement (EAS) Required for new Part 70 permits and/or major modifications (PSD/NNSR) Must be submitted to local governmental authority and designated public library at no cost to them Can be required for others at LDEQ discretion Five questions found in Section 26 of Title V application

Supporting Calculations Should be based on (from most reliable to least reliable) 1. 2. 3. 4. 5. 6. 7. Continuous Monitoring Data Source Specific Stack Tests Manufacturer Supplied Emission Factors Mass Balances

EPA Emissions Estimation Tools EPA Complied Emission Factors Best Engineering Judgment Supporting Calculations Should be clear LDEQ can understand Member of the public can understand Consult Section 1.2.3 of Louisiana Guidance for Air Permitting Actions http://www.deq.louisiana.gov/portal/DIVISI ONS/AirPermits.aspx MAJOR REGULATIONS

Major Regulations Louisiana Air Quality Regulations [LAC 33:III] New Source Performance Standards [40 CFR 60] National Emissions Standards for Hazardous Air Pollutants [40 CFR 61 and 40 CFR 63] National Ambient Air Quality Standards (NAAQS) Louisiana Air Quality Regulations [LAC 33:III] State administers its own air quality program Regulates emissions of criteria pollutants and surrogates (PM10, NOx, CO, VOC, SO2, Lead)

Regulates emissions of Toxic Air Pollutants (LAC 33:III.Chapter 51) New Source Performance Standards [40 CFR 60] Typically applies to New Sources Reconstructed Sources Modified Sources Technology-based limitations Other federal regulations are generally more stringent

New Source Performance Standards [40 CFR 60] Boilers 40 CFR 60 Subpart D Applies to > 250 MMBTU/hr Fossil Fuel Fired Boilers constructed after 8-17-1971 Opacity, PM, SO2 and NOx standards Opacity and PM standard fossil fuel or fossil fuel + wood SO2 liquid or solid fossil fuel with or w/o wood NOx gaseous, liquid, or solid fossil fuel with or w/o wood Monitoring SO2, NOx and either O2 or CO2 CEMS Only gaseous fossil fuel no COMS or SO 2 CEMS If performance test shows < 70% NOx standard no NOx CEMS If no NOx or SO2 CEMS, then no O2 or CO2 CEMS

New Source Performance Standards [40 CFR 60] Boilers 40 CFR 60 Subpart Db Applies to > 100 MMBTU/yr steam generating units constructed after 6-19-1984 PM, SO2 and NOx standards Opacity and PM coal, oil, and/or wood SO2 Coal and/or oil NOx coal, oil, and/or natural gas, unless fossil fuel is limited to less than 10% annual capacity factor. Monitoring SO2 CEMS (with exceptions)

Opacity COMS NOx CEMS (with exceptions) New Source Performance Standards [40 CFR 60] Boilers 40 CFR 60 Subpart Dc Applies to > 10 MMBTU/yr and < 100 MMBTU/yr steam generating units constructed after 6-9-1989 Opacity, PM and SO2 standards Opacity coal, wood, or oil PM coal or wood SO2 coal or oil Monitoring

SO2 CEMS (with exceptions) Opacity - COMS New Source Performance Standards [40 CFR 60] Tanks 40 CFR 60 Subpart K Applies to tanks that store petroleum liquids > 40,000 gallons and < 65,000 gallons between 3-8-74 and 5-19-78 >65,000 gallons if between 6-11-73 and 5-19-78 Floating roof or vapor recovery system > 1.5 psia and < 11.1 psia = floating roof or vapor recovery system > 11.1. psia = vapor recovery system

Monitoring Product stored, period of storage, and maximum true vapor pressure New Source Performance Standards [40 CFR 60] Tanks 40 CFR 60 Subpart Ka Applies to tanks that store petroleum liquids > 40,000 gallons between 5-18-78 and 7-23-84 Floating roof or vapor recovery system > 1.5 psia and < 11.1 psia = internal or external floating roof or vapor recovery system > 11.1. psia = vapor recovery system

Monitoring Product stored, period of storage, and maximum true vapor pressure New Source Performance Standards [40 CFR 60] Tanks 40 CFR 60 Subpart Kb Applies to tanks that store volatile organic liquids > 75 cubic meters after 7-23-84 Exemptions apply Floating roof or vapor recovery system > 27.6 kPa and < 76.6 kPa = internal or external floating roof or closed vent system w/ control device > 76.6 kPa = closed vent system w/ control device

Monitoring Product stored, period of storage, and maximum true vapor pressure Other conditions apply New Source Performance Standards [40 CFR 60] Sugar Mill Example 80 MMBTU/hr Bagasse/Natural Gas Boiler Constructed in 1990 Subject to 40 CFR 60 Subpart Dc Constructed after June 9, 1989 Greater than 10 and less than 100 MMBTU/hr SO2 No coal = no applicable emissions standards

PM No coal & no wood = no applicable emissions standards Subject to recordkeeping under 40 CFR 60.48c(a), (g), and (i) National Emissions Standards for Hazardous Air Pollutants [40 CFR 61 and 40 CFR 63] Applies to sources that emit Hazardous Air Pollutants (HAP) Incorporates Maximum Achievable Control Technology (MACT) Typically applies to major sources of HAP Two varieties: Pollutant Specific NESHAP (40 CFR 61) Source Category NESHAP (40 CFR 63)

National Emissions Standards for Hazardous Air Pollutants [40 CFR 61 and 40 CFR 63] Examples: Shipyard that paints vessels must: Comply with VOHAP limits (in grams/liter) for each painting application Required by 40 CFR 63 Subpart II Incinerator that processes berylliumcontaining waste must: Not emit more than 10 grams/24 hr. period of Beryllium Required by 40 CFR 61 Subpart C National Ambient Air Quality Standards (NAAQS)

LDEQ can never permit any activity that violates NAAQS Primary Standards set to protect public health Secondary Standards set to protect public welfare National Ambient Air Quality Standards (NAAQS) Screen Model

Stack Diameter or Discharge Area Stack Height Stack Gas Exit Velocity Stack Gas Flow Rate Stack gas Exit Temperature 12.62 15 .62 15.6 2 21.63

15.6 2 18 .6 3 18 .6 3 24.64 18

.63 24. 64 15 .6 2 9.6 1 15.62 .63 18

.63 18 413500 2 15.6 12.62 9.61 .62 12 413000

3 .6 18 12.62 15.62 21 .6 3 .62 15

412500 18.63 .62 12 15 .62 .63 21 PLBN1

3 .6 21 414000 414500 PLOT FILE OF HIGH 1ST HIGH 8-HR VALUES FOR SOURCE GROUP: ALL 21 .6 3 18

.63 24 .6 4 3610000 3609500 3609000 2 12.6 .62 12

3608500 18.63 .63 18 3 .6 18 18.63 3608000

2 15.6 4 .6 24 3 .6 21 412000 EQT29 RLP11

EQT56 62 15. 62 12. 2 15.6 21.63 RLP22 3 .6

18 30.653 .62 15 18.63 5 27.6 24.64 33.660

21 .63 .63 18 .64 24 2 15.6 4 .6 24

18 .63 2 .6 12 62 12. 15.62 27.65 21.63

18.63 .63 21 18.63 3 .6 18 12.62 .63

18 63 18. .63 18 21 .63 15.62 18.63

.63 21 2 .6 15 18 .63 ug/m^3 National Ambient Air Quality Standards (NAAQS)

27.647 24.641 21.635 18.628 15.622 12.616 9.609 6.603

Compliance Assurance Monitoring [40 CFR 64] Part 70 (Title V) sources that: Subject to emissions standard (such as lb/hr or TPY emission limits); and Use a control device to comply with the standard; and Pre-control emissions major source threshold [100 TPY attainment, 50 TPY non-attainment (VOC and NOx only), 10 TPY single HAP/25 TPY all HAPs]. Some exemptions apply. Compliance Assurance Monitoring [40 CFR 64] Incorporates Monitoring, Recordkeeping,

Reporting (MRR) Customizable requirements Requires facility design and LDEQ approval of MRR approach General criteria apply to MRR approach Compliance Assurance Monitoring [40 CFR 64] General Guidelines Applicant must propose CAM Must monitor indicators of control device performance Must prove that indicator can assure compliance Source-specific performance tests Manufacturer guarantee (within reason)

Must use appropriate monitoring frequency Daily, if minor source post-control Four evenly spaced times per hour if major source post-control Must detail response to excursion or exceedance Compliance Assurance Monitoring [40 CFR 64] Examples Baghouse Could potentially monitor opacity and/or differential pressure across baghouse Wet scrubber Could potentially monitor scrubber supply pressure and/or

scrubbing medium flow rate PERMIT TYPES Permit Types LDEQ Divides Permits into two basic types: 1) Minor Source Permits 2) Part 70 (Title V) Permits What is a Minor Source? Criteria Pollutants (CO, NOX, SO2, VOC, PM10) 1) Attainment Parish < 100 tpy 2) Non-Attainment Parish < 50 tpy

HAP (Federal) and TAP (State) 1) All Parishes < 10 tpy for any single HAP or TAP 2) All Parishes < 25 tpy for aggregated emissions of HAP or TAP Federally enforceable Specific condition limiting PTE below one or more of the above listed thresholds. What is a Title V Source? For Title V, if a stationary source*: - Emits or has PTE 100 tpy** of PM10, SO2, CO, NOx, or VOC - Emits or has PTE 10 tpy** of any single HAP, or 25 tpy of all HAPs - Any major stationary source as defined in Part D (Nonattainment) of Title I of the CAA, including those defined as major under LAC 33:III.504.K (NNSR)

* Contiguous stationary sources must aggregate emissions ** Fugitive emissions are not included unless sources are listed in Table A or are being regulated under Section 111 (NSPS) or 112 (HAP) of the CAA as of 08/07/1980. [LAC 33:III.502.A] What is a Title V Source? For NSR, if a stationary source, which is located in an attainment parish (PSD source): - Emits or has PTE any regulated NSR pollutant (e.g., PM10, SO2, CO, NOx, or VOC) 250 tpy*, or - Is listed in Table A found in LAC 33:III.509.B and emits or has PTE 100 tpy* of any regulated NSR pollutant * Fugitive emissions are included if sources are listed in Table A or are being regulated, as of 08/07/1980, under Section 111 or 112 of the CAA.

[LAC 33:III.509.B] What is a Title V Source? For NSR, if a source*, which is located in a nonattainment parish stationary (NNSR source): - Emits or has PTE 50 tpy** NOx or VOC - PM/PM10, SO2, and CO treated the same as PSD * Contiguous stationary sources must aggregate emissions. ** Fugitive emissions are not included unless sources are listed in Table A or are being regulated under Section 111 or 112 of the CAA as of 08/07/1980. [LAC 33:III.504.K] Prevention of Significant Deterioration [40 CFR 52]

Incorporates Best Available Control Technology (BACT) on a pollutant-by-pollutant basis Requires sources to control operations at least as well as the best performing similar source, within reason Source is compared to other similar sources RACT/BACT/LAER Clearinghouse (RBLC): http://cfpub.epa.gov/rblc/cfm/basicsearch.cfm Researching other permits Prevention of Significant Deterioration [40 CFR 52] Source is allowed to take credit for certain decreases in emissions Must occur over contemporaneous period

Must be practically enforceable Can not have been used in previous PSD determination Suggest alternate BACT Economic justification Environmental justification Technical justification PSD vs. NNSR PSD Triggers Source located in attainment parish Must be an new major stationary source or involve a major modification at an existing major stationary source as defined in LAC

33:III.509.B Major mods typically involve significant net increases of criteria pollutants: CO - 100 tpy NOx , VOC, SO2 - 40 tpy PM/PM10 - 25/15 tpy PSD vs. NNSR NNSR Triggers Source located in nonattainment parish Currently in nonattainment for 8-hr Ozone (NOx/VOC) std Ambient concentrations of PM, SO2, and CO in compliance respective NAAQS; therefore, are evaluated per PSD regulations Must be an new major stationary source or involve a

major modification at an existing major stationary source, as defined in LAC 33:III.504.K, for the same regulated pollutant for which the area is designated nonattainment Major mods typically involve significant net increases of criteria pollutants: NOx , VOC - 25 tpy Highly reactive VOC - 10 tpy PSD vs. NNSR PSD affected sources subject to: Best Available Control Technology (BACT) regulation Air Quality Modeling NNSR affected sources subject to: Lowest Achievable Emission Rate (LAER) regulation Emission Reduction Credit/ ERC Banking

Current or previous reductions of NOx or VOC may be approved as offsets to NOx or VOC increases from NNSR affected sources. Air Quality Modeling not required PERMIT COMPONENTS Permit Components What is in a Permit? Cover Letter Air Permit Briefing Sheet General Information Inventories Emission Rates for Criteria Pollutants Emission Rates for TAP/HAP & Other Pollutants

Specific Requirements Permit Components Cover Letter PER Number (Activity No.) Agency Interest Number Effective Date Permit Number Assistant Secretarys Signature

Permit Components Briefing Sheet Background Origin Description Type of Review Public Notice Effects on Ambient Air General Condition XII Activities Insignificant Activities Permit Components Briefing Sheet Background

Origin Description Type of Review Public Notice Effects on Ambient Air General Condition XII Activities Insignificant Activities Permit Components General Conditions Part 70 General Conditions LAC 33:III.535. Applies to all Part 70 (Title V) Sources. Louisiana Air Permit General Conditions

LAC 33:III.537. Applies to all permitted sources. No longer appear in permits Permit Components General Information Permit Components Inventories Permit Components Criteria Pollutants Permit Components TAP/HAP Pollutants

Permit Components Specific Requirements What are the Components of Major Source Permits Major Source Permit Components Title V Cover Letter* Air Permit Briefing Sheet* General Information Inventories Emission Rates for Criteria Pollutants Emission Rates for TAP/HAP & Other Pollutants

Specific Requirements Major Source Permit Components: Title V Cover Letter PER Number (Activity No.) Agency Interest Number Expiration Date Effective Date Permit Number Assistant Secretarys Signature

Major Source Permit Components: Title V Briefing Sheet Background Origin Description Type of Review Credible Evidence Public Notice Effects on Ambient Air General Condition XII Activities Insignificant Activities Applicability/Exemption Tables

Major Source Permit Components: Title V Major Source Permit Components: Title V Major Source Permit Components: Title V Major Source Permit Components PSD Cover Sheet Authorization Page Briefing Sheet

Preliminary Determination Summary Specific Conditions BACT Cost Summary Air Quality Analysis Summary Major Source Permit Components: PSD Cover Letter

Activity No. AI No. Date of Signature Permit Number Assistant Secretarys Signature Major Source Permit Components: PSD Authorization Page Company Name Project Location Deadline for Construction Effective Date Assistant Secretarys Signature

Major Source Permit Components: PSD Briefing Sheet Purpose Recommendation Reviewing Agency Project Description Major Source Permit Components: PSD Briefing Sheet (cont) Type of Review BACT Air Quality Impact Analysis

Major Source Permit Components: PSD Briefing Sheet (cont) Additional Impacts Processing Time Public Notice Major Source Permit Components: PSD Preliminary Determination Summary Applicant Location Project Description Major Source Permit Components:

PSD Preliminary Determination Summary Source Impact Analysis Major Source Permit Components: PSD Preliminary Determination Summary Source Impact Analysis - BACT Major Source Permit Components: PSD Preliminary Determination Summary Source Impact Analysis - Existing Air Quality

- NAAQS - PSD Increment - Source Related Growth Impacts Major Source Permit Components: PSD Preliminary Determination Summary Source Impact Analysis - Soil, Veg, Visiblity - Class I Area - Toxic Emission Conclusion Major Source Permit Components: PSD

Specific Conditions Mass Limits Concentration Limits Operating Time Limits Operating Rate Limits Major Source Permit Components: PSD BACT Cost Summary Shows what form of BACT were chosen and what form(s) of BACT were not Products R Us Facility

Agency Interest No.: 11111 Consumer Product Production Ruston, Lincoln Parish, Louisiana PSD-LA-999 Major Source Permit Components: PSD Air Quality Analysis Summary Breakdown of Air Quality Analysis and Modeling results Major Source Permit Components NNSR No separate permit documents

issued Conditions incorporated into Title V Permit Modifications Two Types Permit Application Fees (LAC 33:III.211.B.13.b & c) Permits For Permits Significant (Public Notice Required) Minor (No Public Notice Required) Substantial (Public Notice Required)

Minor Modifications LAC 33:III.525 Minor sources Part 70 Sources that: Would not constitute a Title I mod Would not establish case-by-case MACT Would not add condition(s) in order to avoid federally applicable requirement Would not establish an emissions cap Not otherwise determined by LDEQ to be a significant mod Significant Modifications LAC 33:III.527 Modifications that:

Would constitute a Title I mod Would require significant change(s) in existing monitoring terms and conditions Would relax reporting or recordkeeping terms and conditions Otherwise requires Public Notice (LAC 33:III.5109, for example) Substantial Modifications PSD/NNSR permits Follows Significant Modification procedures INTERNAL PERMIT PROCESS

Permit Process Permit Processing Public Notice (minimum 30 days) Technical Review & Drafting Internal Review of Revised Draft Internal Review of Draft Permit

Final Decision w/ Basis for Decision and Response to Comments, if applicable Permit Process Application is received and reviewed for technical deficiencies Permit Writer obtains any necessary additional information from applicant Give and take to draft permit Applicant is more likely to alter original request than to let LDEQ deny permit

PUBLIC NOTICE PROCESS Public Notice Process Notice is Published Local Paper Official State Journal (The Advocate) Comment period Public minimum of 30 days For Part 70, EPA 45 days Comment periods run concurrently Public Notice Process Public Hearing

Respond to Comments Basis for Decision (if required) Title V Deviation Reports and Certifications Do I Need To Report? If you have a permit, you must report If you have deviations, you must report If you have no deviations, you must report Use form:

http://www.deq.louisiana.gov/portal/Default.aspx?t abid=2273 Title V Deviation Reports and Certifications When Do I Need To Report? Title V Semiannual - March 31st and Sept. 30th (Gen. Cond. K) Annual March 31st (Gen. Cond. M) Minor Source According to permit RESOURCES, DEFINITIONS,

AND ACRONYMS Resources Louisiana Environmental Regulatory Code (LAC) Title 33 :Part III.Air Part I. Office of the Secretary http://www.deq.louisiana.gov/portal/tabid/96/Default.aspx The Code of Federal Regulation (CFR) NSPS (40 CFR 60) NESHAP (40 CFR 61) http://www.gpoaccess.gov/cfr/retrieve.html The Clean Air Act (CAA) The Clean Air Act Amendments (CAAA)

http://www.epa.gov/air/caa/peg/ Resources DEQ Website http://www.deq.louisiana.gov/portal/tabid/36/Default.aspx A weekly list of permit applications received http://www.deq.louisiana.gov/portal/tabid/2824/Default.aspx A list of permits on public notice http://www.deq.louisiana.gov/apps/pubNotice/default.asp EDMS Can be accessed on-line http://www.deq.louisiana.gov/portal/tabid/2604/Default.aspx

Public Participation Group http://www.deq.louisiana.gov/portal/tabid/2198/Default.aspx Definitions and Acronyms APD Air Permits Division BACT Best Achievable Control Technology BART Best Available Retrofit Technology

BMP Best Management Practices (Plan) CAA Clean Air Act CAAA Clean Air Act Amendments CEMS

Continuous Emission Monitoring System CFR Code of Federal Regulations CMS Continuous Monitoring System CO Carbon monoxide Criteria Pollutants

These are nitrogen oxide (NOx), sulfur dioxide (SO2), Particulate Matter (PM), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Lead (Pb). DEQ Department of Environmental Quality EPA Environmental Protection Agency EDMS Electronic Documents Management System : The repository for all official records created or received by the Department Definitions and Acronyms HAP

Hazardous Air Pollutant HON Hazardous Organic NESHAPS LAC Louisiana Administrative Code LAER Lowest Achievable Emission Rate Major Source

Facilities with emissions of criteria emissions that equal or exceed 100 tons per year (TPY) or emissions of any one federally-regulated HAP that equals or exceeds 10 TPY or if total HAP emissions for the facility equal or exceed 25 TPY. Lower emission thresholds for a criteria pollutant may apply in nonattainment areas. A facility which has emissions of one or more criteria pollutants above 100 tpy. MACT Maximum Achievable Control Technology MER

Minimum Emission Rate Minor Source Facilities with emissions of criteria emissions that are less than 100 tons per year (TPY) or emissions of any one federally-regulated HAP is less than 10 TPY or if total HAP emissions for the facility are less than 25 TPY. MM Million MMBTU Millions of British thermal units

Definitions and Acronyms NAA Nonattainment area NAAQS National Ambient Air Quality Standards PM2.5 Particulate Matter of 2.5 microns or less aerodynamic diameter PM-10

Particulate matter, 10 microns or less in size NESHAP National Emission Standards for Hazardous Air Pollutants NSPS New Source Performance Standards NSR New Source Review

NNSR Non-attainment New Source Review Pb Lead PPB Parts per Billion PPM Parts Per Million

PSD Prevention of Significant Deterioration PTE all year long. SCF Potential To Emit is the emissions from a facility if it is run at maximum SCFH Standard Cubic Feet per Hour

SCFM Standard Cubic Feet per Minute Standard Cubic Foot Definitions and Acronyms SCM Standard Cubic Meter SIC Standard Industrial Classification

SIP State Implementation Plan SO2 Sulfur dioxide SOCMI Synthetic Organic Chemical Manufacturing Industry SOP Standard Operating Procedures

Synthetic minor source A facility that would be major source except that the emissions are being controlled below the major source emission level. The facility is permitted as a minor source. Title V Operating Permit Program authorized by Title V of the Clean Air Act TPY Tons per year VOC Volatile Organic Compound TEMPO

Tools for Environmental Management and Protection Organizations.: The Departments official database into which all data for every facility is entered. Office & Division Contact Information Air Permits Division 602 N. Fifth Street Baton Rouge, LA 70802 225.219.3181 Customer Service Center 225-219-LDEQ (5337) Toll Free 1-866-896-LDEQ (5337) Hours 8-4:30 M-F

Contact Information Dustin Duhon Environmental Scientist Supervisor 225.219.3496 [email protected] Lance Green Environmental Scientist Supervisor 225.219.3063 [email protected]

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