ems_l5 [air permits]

8/3/2019 EMS_L5 [Air Permits]

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Environmental Management Systems


LECTURE - 5


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Permit Procedures Introduction


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Permit Procedures Amendment in Clean Air Act and Clean Water act in US

brought significant changes in the acts

The change include permit programs

for larger sources of air emissions

discharge of pollutants from any point source into waters

Permits are issued by the states

or when the state fails to carry out the responsibility satisfactory,

by the EPA


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Permit Procedures The permits includes

information on which pollutants are being released

how much may be released what kind of steps the sources operator is taking to reduce

pollution, including plans to monitor the pollution

The permit system unifies many of the legalresponsibilities of the business


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Air Permit the first requirement in determining the applicable air

regulations and permit requirements for an industrial

facility

For facilities that are major sources of emissions

the inventory is used to determine fee requirements for airoperating permits

In the case of permitting, the inventory is used to

establish an air emissions baseline for evaluating futurechanges


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Emission Inventory and Analysis EPA's Emission Inventory and Analysis Group

(EPA/OAR/OAQPS/AQAD/EIAG)

prepares a national database of air emissions information withinput from numerous State and local air agencies, from tribes,and from industry

This database contains information on

stationary and mobile sources that emit criteria air pollutants their precursors

as well as hazardous air pollutants (HAPs)

The database includes estimates of annual emissions,by source, of air pollutants in each area of the country,on an annual basis

Air pollutants are emitted either from stationary sources

through stacks, chimneys, vent, or as fugitive emissions


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Emission Inventory and Analysis Fugitive emissions are typically defined as any air

emissions that cannot reasonably pass through a stack,

chimney, vent or other functionally equivalent opening Examples: the emissions associated with the loading and

unloading of ore in a mine pit

Regulatory and air modeling requirements for source

emissions and fugitive emissions differ requiring that the inventory list be divide by type of source

Most existing industrial facilities will have completed anupdate of the source inventory

However, new facilities and proposed modifications toexisting facilities also require the preparation of a sourceinventory


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Emission Inventory and Analysis In these cases because the source has not yet been

constructed, there is no existing emission information to

review The emission inventory and point of emissions will be

based on information obtained from resources such as

industrial associations

process flow diagram

scale models

and/or visit to similar facilities

During preparing an inventory for a new or modifiedfacility

maintain good communication with the engineering design team


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Emission Inventory and Analysis Environmental manager plays a role in between both

teams

Final emission estimates will have to be included inpermit applications

Factual misunderstanding between the project team andpermit team are among the primary causes

of delay in obtaining the necessary regulatory approvals

If air modeling is part of the permitting process

the coordinates and elevation of the emission sources

the heights and coordinates of surrounding buildingsshould be added to the source list


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Emission Inventory and Analysis Air modeling is required to demonstrate compliance with

ambient air quality standards or determine levels of

hazardous air pollutants at the property line


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Actual versus Potential Emissions Generally, potential emissions are the maximum

emissions

that would result from operating the facility at full capacity 24hours a day

Actual emissions are emissions produced by a facility,based on actual operating times and actual operating

conditions In permitting a facility, try to avoid permit provisions that

limit the hours of plant operations

If a production rate has been included as an enforceablepermit limitation

the limit cannot exceeded until a permit modification is approvedby the regulatory agency


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Estimating Emissions

In order to make improvements in the air quality, theamount of pollutants in the air must be measured

The Emissions Measurement Center develops standardsand evaluates testing methods

so that regulations can be developed and enforced

An emission inventory should include know HAPemission as well as criteria pollutants

The list of regulated pollutants should be analyzed to seewhich pollutants are emitted from which source

For example, emission once considered as a group ofVOCs emission may, in fact, contain specific HAPs


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Estimating Emissions

With all of the information that has been gathered

there is a need to evaluate the input, recommend changes toregulators, and provide technical assistance

A conversation with equipment supplier can provideverification of the pollutants emitted and estimatedquantities of emission

Always verify the intended operating parameters with theoperation manager

or, in the case of new equipment, the design team for theparticular production unit

An emission inventory is created with the use of a list ofsources, emission data and production data


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Purpose of Permit

The purpose of permits is to ensure compliance with allstate and state air pollution control rules

Permits require sources to comply with all health- andtechnology-based standards established by the EPA

The permit and accompanying technical analysis include

detailed information on the types of pollutants released

how much may be released

how the facility will comply with the air pollution control rules how the pollutants will be monitored


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Types of Permits

Title V Air Operating Permit Operating permits are legally enforceable documents

permitting authorities issue to air pollution sources after thesource has begun to operate

The operating permit

describes the emission limits and operating conditions

A facility must satisfy and specifies the reporting requirements

A Tier I operating permit (also known as a Title Voperating permit) is required by the federal Clean Air Actfor major sources

Major sources are sources that emit, or may emit, 100

or more tons of any regulated air pollutant per year


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Air Operating Permit (Qualifying Facilities)

Under the applicable regulations

new or existing industrial facilities are required to obtain an AOP

Some state rules will require sources subject to newsource performance standards to obtain an AOP

even if the total facility emissions are below the qualifying

thresholds


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It can allow a facility to avoid the costly annual permitfees and environmental management costs relating to

the AOP program

If you have determined that your existing facility or newsource qualifies for the AOP program

the next step in the process is to prepare an application


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Application Elements

Facility Information name, address, phone, contacts

Process description narrative and process flow diagram of thenormal mode of operation and production

Alternative Operating Scenario Similar information foralternative production that would change emissions

Emission source identification Emission inventory For each operating scenario

Applicable air regulations

Proposed de minims or other exemptions

Controls: Air pollution equipment, Current limit, compliancetesting and monitoring methods

Compliance status summary including proposed complianceplan and schedule for areas not in compliance

Compliance certification by responsible official


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Air Operating Permit (Implementation)

At this point, experience with implementing AOPs islimited

Without good documentation

the environmental manager may find these incidents classifiedby the agency as permit violations

Perhaps the most significant change associated with theTitle V permits is

the need for periodic certification of compliance by the facilitymanager


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Air Operating Permit (Implementation)

The key elements of a successful AOP managementprogram are

Detailed analysis of the permit requirements

Establishment of an expanded monitoring and record keepingsystem

Training for environmental and operating personnel Periodic reviews for compliance certification


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AOP (Compliance Assurance Monitoring)

Pursuant to requirements concerning enhancedmonitoring and compliance certification under the Clean

Air Act EPA has promulgated new regulations and revised some

existing regulations to implement compliance assurancemonitoring (CAM) for major stationary sources

that are required to obtain operating permits under Title V of theact

The new regulations require owners or operators of suchsources to conduct monitoring

that satisfies particular criteria established in the rule to provide areasonable assurance of compliance with applicablerequirements under the act


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Monitoring focuses on emissions units that rely onpollution control device equipment to achieve

compliance with applicable standards The effective date of this rule is November 21, 1997

CAM applicability

The CAM rule applies to each Pollutant Specific Emissions Unit

(PSEU)

when it is located at major source that is required to obtain TitleV, Part 70 or 71 permit and it meets all of the following criteria

The PSEU must

be subject to an emission limitation or standard

use a control device to achieve compliance

have potential pre-control emissions that exceed or areequivalent to the major source threshold


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The rule allows owners and operators to design CAMplans around current requirements and operating

practices to select representative parameters upon which compliancecan be assured

to establish indicator ranges or procedures for setting theindicator ranges for the parameters

to use performance testing and other information to verifythe parameters and ranges

to correct control device performance problems asexpeditiously as practicable


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Elements of CAM Plan

Describe the indicators to be monitored and how they are to bemeasured

Describe the indicator ranges or the process by which indicatorsare to be established

Describe the performance criteria for the monitoring approach,including

specifications for obtaining representative data

quality assurance and control procedures

monitoring frequency

data collection procedure

data averaging period


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Provide a justification for the proposed elements of themonitoring

Provide historical monitoring data, emissions test data and

control device operating data recorded during performancetest, if necessary

Provide an implementation plan, if monitoring requiresinstallation, testing, or other activities prior to implementation.


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Permit to Construct

An air quality permit to construct (PTC) is required priorto construction or modification of

Buildings Structures

Installations that emit, or may emit, pollutants into the air

PTCs are required for certain portable equipment as

well, such as generators

crushing equipment

asphalt plants

concrete batch plants


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Permits to Construct

PTC applicants are required to submit the following information:

A complete description of the

proposed process from raw material feed to final productoutput, including operating design capacity, hours of

operation, and feed material characteristics.

Manufacturers' guarantees for stated control efficiencies of allcontrol equipment.

Emission estimates for all regulated air pollutants with

supporting calculations, assumptions, or manufacturer

guarantees for emission control devices.


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PTC (Specific Application Requirements)

A PTC application requires the applicant to supply detailed

information on the proposed new source, modification of an

existing source, or process change.

Process Description

Site Plans

Equipment List

Air Emission Inventory


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Other Potential PTC Application Requirements

Some state rules require that a PTC be accompanied by a

simplified Environmental Impact Statement (EIS) or site review

application

Some states also require the applicant to submit an air dispersion

model analysis to demonstrate that air quality will not be

significantly impacted by the proposed work

One state requires PTC applicants to complete Best Available

Control Technology (BACT) review for criteria pollutants for

any project that increases air emission more than over 1 ton/year


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Permitting Major Sources PSD and NSR

NSR is a preconstruction permitting program that serves two

important purposes

First, it ensures that air quality is not significantly degraded from

the addition of new and modified factories, industrial boilers andpower plants.

In areas with unhealthy air, NSR assures that new emissions do

not slow progress toward cleaner air.

In areas with clean air, especially pristine areas like nationalparks, NSR assures that new emissions do not significantly

worsen air quality

Second, the NSR program assures people that any large new or

modified industrial source in their neighborhoods will be as

clean as possible, and that advances in pollution control occur

concurrently with industrial expansion


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New Source Review

NSR or Prevention of Significant Deterioration (PSD)was established as part of the 1977 Clean Air ActAmendments

The construction or modification of a major stationarysource that results in significant increase in air

emissions is subject to the NSR program

The permit specifies

what construction is allowed what emission limits must be met

often how the emissions source must be operated

E i l M S


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Attainment and Non Attainment Areas

The air quality of designation of an area for each pollutant can

be obtained from the local air authority.

If the air quality of an area for a particular pollutant isattainment, the proposed facility will be subject to the

requirements of the Prevention of Significant Deterioration

(PSD) program

Under the rules of PSD permitting, you must proceed with air

modeling to determine whether you will increase the

concentration of the pollutant beyond acceptable levels

Each pollutant in a given attainment area has a maximum

allowable ambient concentration

E i t l M t S t


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The project team must be fully aware of the dynamic nature of

the PSD process

First, you will have to determine what control technology orprocess design specifications are required to meet the ambient

air quality standards

Secondly, a facility subject to PSD program must install BestAvailable Control Technology (BACT)



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When the air quality designation of an area for the pollutant you

are increasing is classified as non attainment, the permit

application will be subject to a much more stringent review

under the New Source Review (NSR) rules

Instead of BACT, the facility will be required to meet the

lowest achievable emission rates (LAER)

It will also be necessary to establish emission offsets for the

proposed project that demonstrate that a net improvement in air

quality will result from the construction of the project



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Permitting Major Sources PSD and NSR

Both PSD and NSR permitting involve a significant amount of

documentation, air dispersion modeling, and regulatory agency

review

When permitting a major source, the facility permitting team

should include in its schedule a significant amount of time for

environmental agency review and response to comment



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New or Modified Source Determinations

To determine whether a proposed project is subject to PSD or

NSR review requirements, the initial step is to establish an

emission inventory

Once an emission inventory is complete, data on the specific

annual emission of each pollutant will be available



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Pre Application Monitoring

These requirements are triggered by lack of specific ambient air

quality data for the pollutant you are proposing to increase

Although monitoring may not be technically difficult, theamount of time required to collect the data is often a surprise to

the project team

A full year of air quality monitoring may be necessary to satisfythe environmental agency



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Determining BACT

The EPA requires that the BACT analysis be done using the top-

down approach

This means that the most effective method of controlling apollutant is analyzed first; then less effective controls are

evaluated in descending order

For each potential technology, you will need the followinginformation:

Description of the technology or process

Capital cost of installation

Quantity of pollutant removed (annually), and

Cost-effectiveness calculation

Once the cost effective calculation is made, the various pollutioncontrol technolo ies are com ared



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Determining LAER

LAER may be established through the EPA Clearinghouse or

through discussions with manufactures or design firms familiar

with your manufacturing process.


PSD d NSR A li i P


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PSD and NSR Application Process

The application for a PSD or NSR permit is a voluminous

document, which includes the following items:

project application form and fee project description List of Sources Emission Inventory

Applicability analysis Air modeling information Visibility analysis (if required) BACT/LAER Determinations

Support appendixes Drawing and site map


PSD d NSR A li ti P


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A key to managing the permit review process is to meet

frequently with the permitting agency and to begin these

meetings well before the permit application is submitted

Items that should be preliminary reviewed with the agency

include the following:

An overview of the project

Potential public concerns Air emission inventory PSD pollutant analysis Air modeling requirements

Previous BACT/LAER determinations

After the permitting agency has reviewed and accepted the

permit application as complete, you must still respond touestions osed b the a enc and rovide the a enc with an


PSD d NSR A li ti P


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After the permitting agency has reviewed and accepted the

permit application as complete, you must still respond to

questions posed by the agency and provide the agency with anyadditional information it requests


Implementing Permit Requirements


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Implementing Permit Requirements

It is necessary to obtain the permit before beginning the

construction and to comply with the terms of the permit once it

is issued

EPA can issue significant penalties to companies that commence

construction of a new source or modification of an existing

source prior to receiving final PSD or NSR permit

Permit compliance will likely require new operator training

manuals, new monitoring or testing equipments, and revisions to

the reporting and data systems

These requirements should be identified and implemented well

in advance of the actual start of a new facility or modification

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