AIR CONSTRUCTION PERMITS: CLEVER FUNDAMENTALS March 26, 2020 - - PowerPoint PPT Presentation

AIR CONSTRUCTION PERMITS: CLEVER FUNDAMENTALS

March 26, 2020

W&M Environmental – A Division of Braun Intertec Corporation 972-516-0300 Wh-m.com

Vanessa Coleman, Sally Perry

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VANESSA COLEMAN

• Senior Engineer, Compliance & Permitting,

South Region

• B.E., Civil and Environmental Engineering;

University of Detroit, Mercy

• Over 12 years experience in environmental

compliance for the industrial sector.

• Her experience includes program

development, implementation and management as well as multimedia permitting and compliance.

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SALLY PERRY

• Senior Scientist, Compliance & Permitting,

South Region

• B.S., Earth Systems; Stanford University
• Over 10 years of experience in

environmental permitting and compliance for the industrial sector.

• Her experience includes multimedia

permitting and compliance in multimedia such as air, water, waste, spill prevention, and chemical reporting.

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▪ The Essential

▪ What we are not covering

▪ Construction Triggers ▪ Permitting Action Considerations ▪ Example Scenarios

Agenda

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The Essentials

• Why do we do this? Who and what are we protecting?
• Smog, acid rain, health hazards – human health and the environment outside of

the operation

• NAAQS – EPA CAA
• Criteria pollutants – NOX, CO, PM, SO2, Ozone, Lead
• Air pollutants
• Sources emit these pollutants
• Identify and quantify
• A source of a different color
• What is a source/facility/unit/process? Always look at the definitions specific to

your region!

• Does it emit air contaminants?
• Examples: metal treating, piping components, surface coating
• Air authorizations, permits, registrations, and like are put in place to

comply with to ensure your sources meet the NAAQS

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NSR vs Title V: 3000-foot view

New Source Review Title V Purpose Maintain air quality in attainment areas and bring non-attainment areas into attainment Consolidate all air permitting requirements for a major source into a single federally enforceable permit Authorizes Construction & Emissions Operations Timing Completed first & before construction begins Initial application - prior to operations Subsequent – operations may begin prior to issuance

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NSR vs Title V

Many states have a combined construction/operating permit program, others have a 2-permit system

Combined Construction and Operations 2-Permit System TX

✓

PA

✓

MI

✓

FL

✓

AR

✓

MN

✓

LA

✓

OK

✓

IN

✓

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• New construction of facility
• Facility - a discrete or identifiable structure, device, item, equipment, or

enclosure that constitutes or contains a stationary source, including appurtenances other than emission control equipment.

• Modify existing facility
• any physical change;
• change in the method of operation of a facility that:
• increases the amount of any air contaminant emitted;
• results in the emission of any air contaminant not previously

emitted.

• changes in method of control;
• changes in character of emissions; and
• increases in actual emissions or emission allowed to be emitted by the

permit (allowable).

Triggers, Timing, Construction Oh my

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• A company replaces a boiler with an identical boiler
• Change chemicals used in a scrubber
• Route an existing oven exhaust not previously controlled to an existing scrubber

because throughput is gong to increase

• Move an existing blast booth to a new location inside the same building and

add new blast equipment

• Depends on how it is currently permitted, but ultimately you are

potentially increasing throughput by adding the blast equipment

• Adhesive is used in an adhesive machine. The company wants to switch to a

stronger adhesive to improve quality.

Triggers, Timing, Construction Oh my

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Side note: 30 TAC §116.116(a) (Permit Amendments)(other states have similar language):

"All representations with regard to construction plans and operation procedures in an application for a permit, ... as well as any general and special provisions attached to the permit itself, become

conditions upon which the subsequent permit ... are issued. It

shall be unlawful for any person to vary from such representation or permit provision if the change will cause a change in the method of control of emissions, the character of the emissions, or will result in an increase in the discharge of the various emissions, unless application is … to amend the permit ... and such amendment is approved ..."

∴ permitted facility should be constructed and operated as represented

in the application – high likelihood most deviations from what was represented in the permit would require a modification

∴ ∴permit applications just as important as permit itself

Triggers, Timing, Construction Oh my

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An NSR permit is required before construction or modification of a facility begins Yes, but DEFINE “construction”

• anything other than site clearance or site preparation
• Land clearing, soil load bearing tests, leveling of the area, sewer and

utility lines, road building, power line installation, fencing, construction shack building, etc.

• HOWEVER, once soil and site are ready for foundations, the first

excavation into the readied soil = construction

• Equipment can be at the site and stored
• No attempt is made to assemble the equipment or to connect the

equipment into any electrical, plumbing, or other utility system.

• Excavation, form erection, or steel laying pertaining to

foundations upon which permit units will rest = construction.

• Concrete foundation not required no problem! Earthen dams,

placement of piling, soil stabilization, storage tank fills, or retaining structures = construction.

Triggers, Timing, Construction Oh my

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Other considerations: ❑ Timing ❑ Location:

• Attainment status

❑ Emissions:

• Usage rate
• AP-42
• Material balance

❑ Other applicable rules:

• State
• BACT
• Measurements of

significant air contaminants

• Mass cap and trade

allowances

• Achieve performance

Permitting Action Considerations

This Photo by Unknown Author is licensed under CC BY

I need air authorization!

• Sensitive receptors
• Stack testing
• Engineering calculations
• Federal
• PSD/non-attainment

review status

• Impact on TV
• NSPS
• MACT
• NESHAPs
• HAPs

You have determined you need authorization for a new/modified source

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Various Permitting Mechanisms

Case-by-case Standard Permits (SPs) 20 SPs Specific, characterized class of facilities Permit-by-Rule (PBR) 21 industry-type categories; 108 individual PBRs De Minimis Listed sources: 4 categories; 74 individual exemptions De Minimis Rule: Material usage; Effects Screening Levels

Emissions increase

Negligible sources Must meet all conditions Typically no paperwork Must keep records to demonstrate de minimis Meet all conditions Register or claim Cannot partially permit a process Cannot be used to circumvent permitting

Emission limits Registering – enforceable Operating hours Boilerplate conditions Does not expire Operate as reflected in registration (if applicable); amend when there are changes – registration no longer reflects what is represented in application

More prescriptive

Register Written approval prior to

• perations

Expires May require: Initial compliance testing Continuous demonstrations of compliance Public notice

Full application Subject to Best Available Control Technology (BACT) Agency administrative and technical review Two public notices Postings at site Newspaper Available to view in public place Public comment period Modeling Draft conditions Correspond, correspond, correspond 6 to 9 month approval process Expires every 10 years

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When deciding which authorization mechanism is needed, take goals and

• bjectives into account:
• Operational flexibility
• Start construction and operations ASAP
• Want to avoid larger permit
• Minimal compliance requirements

Client Goals and Objectives

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• Process flow diagram
• Overall
• Identify potential downstream and upstream bottlenecks
• Affected source
• Type – equipment, process
• Inputs materials and rates
• SDSs, EDSs
• Processing rates
• Outputs – pollutants, control devices
• Process description
• SOPs
• Equipment O&M manuals
• Emission calculations
• Site figure
• Sources identified
• Property boundaries

Determine Baseline: Facts and Figures

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Scenario #1: A small metal parts manufacture located in an attainment area currently outsources coating operations. They are looking to grow the business by offering repair services to a select few original parts customers. After the repairs are completed, some coating touch up will be needed. Approximately ½ pint of paint is used per repaired

• part. Currently, the select customers are looking to contract a combined 20 parts per
• week. Minimal solvents will be used and is not expected to exceed 50 gallons of use

per year.

Facts and Figures Meet Goals and Objectives

Does the small metal parts manufacturer require air authorization? Yes. Where do we begin?

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Facts and Figures Meet Goals and Objectives

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Facts and Figures Meet Goals and Objectives

.5 𝑞𝑗𝑜𝑢 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑠𝑓𝑞𝑏𝑗𝑠𝑓𝑒 𝑞𝑏𝑠𝑢 𝑌 20 𝑞𝑏𝑠𝑢𝑡 𝑥𝑓𝑓𝑙 X 52 𝑥𝑓𝑓𝑙𝑡 𝑧𝑓𝑏𝑠 X 1 𝑕𝑏𝑚𝑚𝑝𝑜 8 𝑞𝑗𝑜𝑢𝑡 = 65 gallons

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Facts and Figures Meet Goals and Objectives

Scenario #2: Fast forward a year, same small metal parts manufacturer is looking to build efficiencies and increase turnaround times. In effort to meet those goals, they are considering greatly reducing, ideally eliminating, any production outsourcing, includes coating. Management wants to accomplish this sooner than later, yesterday as they like to say. The production goal is 100 parts per week with every part needing to be coated. Based on third-party vendor information, a maximum of 5 gallons of coating is used to coat the part. They will continue to use the same coating the supplier has used. Coating does not require thinning and spray guns will be used for

• application. Cleaning solvent will be used to clean the guns and paint lines.

Is this quite a deviation form the de minimis operations they are currently conducting? Yes, but how much so? 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 100 𝑞𝑏𝑠𝑢𝑡 𝑥𝑓𝑓𝑙 X 52 𝑥𝑓𝑓𝑙𝑡 𝑧𝑓𝑏𝑠 = 26,000 gallons

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Facts and Figures Meet Goals and Objectives

Scenario #2: Fast forward a year, same small metal parts manufacturer is looking to build efficiencies and increase turnaround times. In effort to meet those goals, they are considering greatly reducing, ideally eliminating, any production outsourcing, includes coating. Management wants to accomplish this sooner than later, yesterday as they like to say. The production goal is 100 parts per week with every part needing to be coated. Based on third-party vendor information, a maximum of 5 gallons of coating is used to coat the part. They will continue to use the same coating the supplier has used. Coating does not require thinning and spray guns will be used for

• application. Cleaning solvent will be used to clean the guns and paint lines.

Is this quite a deviation form the de minimis operations they are currently conducting? Yes, but how much so? 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 100 𝑞𝑏𝑠𝑢𝑡 𝑥𝑓𝑓𝑙 X 52 𝑥𝑓𝑓𝑙𝑡 𝑧𝑓𝑏𝑠 = 26,000 gallons

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Facts and Figures Meet Goals and Objectives

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Facts and Figures Meet Goals and Objectives

Coating: 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 1.16 𝑚𝑐 𝑊𝑃𝐷 𝑕𝑏𝑚 𝑌 1 𝑞𝑏𝑠𝑢 0.5 ℎ𝑠 𝑑𝑝𝑏𝑢 X 8760 ℎ𝑠𝑡 𝑧𝑓𝑏𝑠 X 2,000 lbs ton = 50.8 tpy VOC

1 𝑕𝑏𝑚 𝑡𝑝𝑚𝑤𝑓𝑜𝑢 𝑣𝑡𝑓𝑒 𝑑𝑚𝑓𝑏𝑜

• .75 𝑕𝑏𝑚 𝑡𝑝𝑚𝑤𝑓𝑜𝑢 𝑠𝑓𝑑𝑝𝑤𝑓𝑠𝑓𝑒

𝑑𝑚𝑓𝑏𝑜

𝑌 6.68 𝑚𝑐 𝑊𝑃𝐷

𝑕𝑏𝑚

𝑌 𝑒𝑏𝑗𝑚𝑧 𝑑𝑚𝑓𝑏𝑜 𝑏𝑜𝑒 𝑔𝑚𝑣𝑡ℎ

1 ℎ𝑠

𝑌 1 𝑑𝑚𝑓𝑏𝑜 𝑏𝑜𝑒 𝑔𝑚𝑣𝑡ℎ

𝑒𝑏𝑧

X 365 𝑒𝑏𝑧𝑡

𝑧𝑓𝑏𝑠

X 2,000 lbs

ton

= 0.3 tpy VOC

50.85 𝑢𝑞𝑧 𝑊𝑃𝐷 𝑔𝑠𝑝𝑛 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 + 0.3 tpy VOC from solvent = 51.1 tpy total VOC < 100 tpy VOc

Cleaning Solvent: Quick PTE Check:

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Facts and Figures Meet Goals and Objectives

Coating: 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 1.16 𝑚𝑐 𝑊𝑃𝐷 𝑕𝑏𝑚 𝑌 100 𝑞𝑏𝑠𝑢𝑡 𝑥𝑓𝑓𝑙 X 52 𝑥𝑓𝑓𝑙𝑡 𝑧𝑓𝑏𝑠 X 2,000 lbs ton = 15.08 tpy VOC

1 𝑕𝑏𝑚 𝑡𝑝𝑚𝑤𝑓𝑜𝑢 𝑣𝑡𝑓𝑒 𝑑𝑚𝑓𝑏𝑜

• .75 𝑕𝑏𝑚 𝑡𝑝𝑚𝑤𝑓𝑜𝑢 𝑠𝑓𝑑𝑝𝑤𝑓𝑠𝑓𝑒

𝑑𝑚𝑓𝑏𝑜

𝑌 6.68 𝑚𝑐 𝑊𝑃𝐷

𝑕𝑏𝑚

𝑌 𝑒𝑏𝑗𝑚𝑧 𝑑𝑚𝑓𝑏𝑜 𝑏𝑜𝑒 𝑔𝑚𝑣𝑡ℎ

1 ℎ𝑠

𝑌 1 𝑑𝑚𝑓𝑏𝑜 𝑏𝑜𝑒 𝑔𝑚𝑣𝑡ℎ

𝑒𝑏𝑧

X 365 𝑒𝑏𝑧𝑡

𝑧𝑓𝑏𝑠

X 2,000 lbs

ton

= 0.3 tpy VOC

15.08 𝑢𝑞𝑧 𝑊𝑃𝐷 𝑔𝑠𝑝𝑛 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 + 0.3 tpy VOC from solvent = 15.38 tpy total VOC < 25 tpy VOc

Cleaning Solvent: PBRs based on actuals: Other conditions to consider:

• Hourly emissions
• Stack height
• Distance to off-site receptors
• Booth velocity
• etc

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Facts and Figures Meet Goals and Objectives

Scenario #3: Fast forward another year, same small metal parts manufacturer is really

• booming. All coating as been moved in house. Potentially adding another

paint line and booth (2 paint lines per booth). Increase production throughput to 250 parts per week. Additionally, one customer has requested a specialty paint that has a higher VOC content, 3.4 lbs VOC/gal. Management wants to start yesterday and does not want the burden of a bigger permit.

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Facts and Figures Meet Goals and Objectives

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Facts and Figures Meet Goals and Objectives

Coating max hours: 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 3.4 𝑚𝑐 𝑊𝑃𝐷 𝑕𝑏𝑚 𝑌 1 𝑞𝑏𝑠𝑢 0.5 ℎ𝑠 𝑑𝑝𝑏𝑢 X 8760 ℎ𝑠𝑡 𝑧𝑓𝑏𝑠 X 2,000 lbs ton = 148.92 tpy VOC Quick PTE Check: 5 𝑕𝑏𝑚 𝑑𝑝𝑏𝑢𝑗𝑜𝑕 𝑞𝑏𝑠𝑢 𝑌 3.4 𝑚𝑐 𝑊𝑃𝐷 𝑕𝑏𝑚 𝑌 250 𝑞𝑏𝑠𝑢𝑡 𝑥𝑓𝑓𝑙 X 52 𝑥𝑓𝑓𝑙𝑡 𝑧𝑓𝑏𝑠 X 2,000 lbs ton = 110.5 tpy VOC Coating production based:

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Production goal is not feasible without concessions and need to have a come to goodness discussion with management. Maybe:

• Operational restriction on the number of parts coated

with higher VOC coating

• Install pollution control device
• Obtain a bigger permit

Revisit Goals and Objectives

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Questions?

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Sally Perry Vanessa Coleman

Group Manager, Senior Scientist Senior Engineer 713.987.4509 210.591.0363 SPerry@BraunIntertec.com VColeman@BraunIntertec.com

CONTACT INFORMATION

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