Workshop L New to EHS/101 Air Permitting Basics Including Defining - - PDF document

Workshop L

New to EHS/101 … Air Permitting Basics Including Defining an Emissions Unit

Tuesday, March 24, 2020 11:15 a.m. to 12:30 p.m.

Biographical Information

Christopher T. Hage, Global Innovation HS&E Leader The Procter & Gamble Company, Winton Hill Business Center, 6105 Center Hill Avenue, Cincinnati OH 45224 513-634-1566 hage.ct@pg.com Chris started his career with Hampshire Chemical Company, a subsidiary of W.R. Grace, in 1995 as an HS&E Staff Engineer at their Lima, Ohio manufacturing facility, which produced chelates. In 1997, Chris joined Procter & Gamble at the Lima, Ohio plant, where he held numerous positions including liquid laundry and fabric enhancer process engineer, site quality assurance systems manager, and site environmental leader. In 2003, Chris joined Rohm & Haas as an HS&E Staff Engineer at their Cincinnati, OH manufacturing facility, which produced PVC stabilizers, asphalt additives, and catalysts. In 2008, Chris rejoined Procter & Gamble and for the next 11 years held numerous HS&E roles supporting manufacturing plants globally across the Fabric & Home Care, Chemicals, and Fragrances Business Unit and Baby Care, Feminine Care, and Family Care Business Unit. Chris is currently a Global Innovation HS&E leader who ensures project initiatives are delivered to manufacturing facilities in a manner that ensures HS&E compliance and leads the North American Environmental Core Team which is responsible for environmental capability at our manufacturing facilities. Chris is the proud graduate of three different universities. He received a B.A. from Rollins College in Winter Park, Florida in 1991. He received a B.S. in Chemical Engineering from Washington University in St. Louis, Missouri in 1993. He received a M.E. in Environmental Engineering from the University of Florida in Gainesville, Florida in 1995. Demonstrating his strong passion for coaching and teaching, Chris also received his AYA teaching Certificate in Physical Science/Physics & Chemistry from Bluffton University in 2005 and participated as an Adjunct Professor at the University of Northwestern Ohio. Courtney Zimmer, Environmental Health Safety Specialist Ball Metalpack 2850 Charter Street, Columbus, Ohio 43228 614-969-0416 Courtney.Zimmer@ballmetalpack.com Courtney started her career at August Mack Environmental, Inc. as a Compliance Specialist in Lewis Center, Ohio. In this position, she assisted various commercial and industrial facilities with environmental assistance. She worked to ensure facilities- maintained compliance for federal, state, and local requirements and regulations. This included a wide range of projects including, EPCRA Section 312 and 313 reporting, NPDES permitting and compliance, SWPP plans, SPCC, auditing, and air permitting and air reporting. Since then, Courtney is now an Environmental, Health, and Safety Specialist at Ball Metalpack, LLC in Columbus, Ohio. Here she acts as the main environmental contact across all the Ball Metalpack facilities. She works at ensuring environmental compliance and best practices are put in place and being maintained while assisting with environmental reporting. Courtney holds a Bachelor of Arts degree, with a major in Geography of Environment and Society and a minor in Environmental Laws and Policies from The Ohio State University.

Biographical Information

Hope Manning, Senior Project Manager/Multi-Media Leader Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7238 hmanning@eqm.com Hope has over 16 years of technical and compliance management experience in the environmental field in both consulting and industry. She has been involved in a broad range

• f programs including air compliance and permitting, NESHAP Boiler GACT compliance,

NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting, and auditing. Currently Hope leads the Multi-Media group at EQM which is comprised of individuals who have expertise in air, water, SPCC, and EPCRA reporting. She is also the primary environmental auditor for EQM. Prior to her joining EQM in 2015, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for over 50 locations in over 15 states. These activities included assisting in minor and major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University of Cincinnati. Bob Kuklentz, Directing Consultant, All4 Inc. 2393 Kimberton Rd., Kimberton, PA 19442 610.933.5246 x124 rkuklentz@all4inc.com

• Mr. Bob Kuklentz has 30 years of professional experience in multiple disciplines of

environmental management in industry including 17 years in printing and packaging and 3 years in chemical specialties manufacturing. This includes all phases of industrial environmental management. He has worked in numerous states and Ontario, Canada. In his role in the printing and packaging industry, Mr. Kuklentz was instrumental in the significant reduction of VOCs corporate-wide through the conversion to water-based printing inks, reduction or elimination of VOC containing cleaning solvents, improved management processes and procedures, and partnerships with key suppliers. In his consulting role at ALL4, Mr. Kuklentz has managed multiple large and complex new source review (NSR) air permitting strategy and application projects in several states. Several examples include the permitting of multiple combustion turbines in an ozone non-attainment area, permitting of numerous boilers and industrial processes, permitting of facility-wide modifications at petroleum refineries, and numerous projects in the printing industry. Mr. Kuklentz also has extensive rule compliance and applicability experience including NESHAP’s and NSPS. This experience spans a wide range of industries including pharmaceutical, refining and consumer products manufacturing. Mr Kuklentz also serves as the assistant chief of the Chester County, PA Hazardous Materials Response Team and has over 25 years of emergency response experience.

Workshop L - March 24, 2020 1

• Chris Hage, Global Innovation Leader, Procter & Gamble
• Bob Kuklentz, Directing Consultant, All4
• Hope Manning, E&C Director, EQM
• Courtney Zimmer, Environmental Health & S

afety S pecialist, Ball Metalpack

Air Permitting Basics Including Defining an Emissions Unit

Workshop L - March 24, 2020 2

Air Permitting

Workshop L - March 24, 2020 3

Federal Rules for Air Permitting



40 CFR Part 60 – New S

• urce

Performance S tandards



40 CFR Parts 61/ 63 – National Emissions S tandards for Hazardous Air Pollutants



40 CFR Parts 51/ 52 – New S

• urce Review



40 CFR Parts 72-78 –Acid Rain Program



40 CFR Parts 70/ 71 –Title V Permitting Program

Workshop L - March 24, 2020 4

S tates Authority



States have primacy

 Have permitting authority  S

tate Implementation Plans (S IP)

 S

• urce of most of permitting requirements.

Workshop L - March 24, 2020 5

Putting it All Together

Facility Permit

State Requirements (S IP) Federal Requirements (NS PS , NES HAP/ MACT , Acid Rain) Federal Programs (S tratospheric Ozone Protection, RMP)

Workshop L - March 24, 2020 6

What Requires a Permit

New Construction New Construction Modification of existing equipment Modification of existing equipment Increase in production Increase in production Change in formulation Change in formulation

Workshop L - March 24, 2020 7

What type of permit do I need?



New S

• urce Review Construction Permits – LARGES

T

 PS

D Maj or S

• urce/ Maj or Modification Thresholds

 100 tpy for any listed source category  250 tpy for any other source category  Pollutant-specific thresholds for modifications  NNS

R Maj or S

• urce/ Maj or Modification Thresholds

 100 tpy  Pollutant-specific thresholds for modifications 

Title V Operating Permit – LARGE

 Maj or source thresholds  100 tpy for any air regulated pollutant (lower for non-

attainment areas)

 10 tpy for a single HAP or 25 tpy for any combination of HAPs  Other triggers = NS

R Permit, Acid Rain Program, NS PS standards, most NES HAP/ MACT standards

Workshop L - March 24, 2020 8

What type of permit do I need?



Federally Enforceable S tate Operating Permit (FES OP) – MEDIUM

 For synthetic minor sources  S

ite has taken a federally enforceable restriction (such as operating restrictions or emission limitations) to maintain potential emissions less than Title V maj or source thresholds



S tate Operating Permit (PTI/ PTO/ PTIO) – S MALL

 For natural minor sources 

Everything Else (Registration, Permit-by-Rule, Exemptions)

Workshop L - March 24, 2020 9

OH

• Construction (PTI)
• PTIO
• FEPTIO
• Title V
• PSD/NNSR

Types of Permits by S tate

KY

• Construction
• Registration
• State Origin
• Title V
• PSD/NNSR

IN

• Construction
• Minor Source
• FESOP
• Title V
• PSD/NNSR

Workshop L - March 24, 2020 10

Permit Process

Application

Agency discussions

Draft

Agency discussions

Review/ Public Comment

Facility review S tate and/ or Federal dependent

• n type of

permitting Agency discussions

Final

Workshop L - March 24, 2020 11

S tate S ites



Ohio https:/ / www.epa.ohio.gov/ dapc/ permits/ permits



Kentucky https:/ / eec.ky.gov/ Environmental-Protection/ Air/ Pages/ Air- Permitting.aspx



Indiana https:/ / www.in.gov/ idem/ airquality/ 2495.htm

Workshop L - March 24, 2020 12

Permitting Application Needs

 What do you need

 Change information

 Define the proj ect including emission units

 Facility-wide information

 How does that proj ect affect the facility

Workshop L - March 24, 2020 13

Define an Emissions Unit



What is an emissions unit

 Regulatory definition  Guidance



Pros and Cons: Individual emissions units vs. Grouping emissions units

Workshop L - March 24, 2020 14

What is an Emissions Unit?



Emissions unit

 Any part of

a stationary source that emits or would have the potential to emit any regulated New S

• urce Review

(NS R) pollutant



NS R pollutants:

• Particulate Matter
• Carbon Monoxide
• Particulate Matter <

10 microns

• Lead
• Particulate Matter <

2.5 microns

• Fluorides
• Sulfur Dioxide (SO2)
• Total Reduces Sulfur

Compounds

• Ozone (VOC)
• Sulfuric Acid Mist
• Nitrogen Oxides

(NOX)

Workshop L - March 24, 2020 15

What is an Emissions Unit?



New emissions unit – any emissions unit that is (or will be) newly constructed and that has existed for less than 2 years from the date such emissions unit first operated



Existing emissions unit – any emissions unit that is not new



Affected emissions unit – unit whose emissions could be affected by the proj ect

 Example: I need more steam from my existing boiler to

support my new proj ect

Workshop L - March 24, 2020 16

Individual Emissions Units vs. Grouping Emissions Units



Example of Individual vs. Grouped units



Individual Emissions Unit

 Only need to consider the modified/ affected unit   Each machine will have it’s own limits (e.g., emissions,

throughput, etc.) ☹



Grouping Units

 Group limits   Modify one unit, modify them all ☹

Workshop L - March 24, 2020 17

Defining a Project

Understand the Emissions Units within Y

• ur Proj ect

Consideration of Potential Proj ect Related Emissions Emissions Proj ect Aggregation

Workshop L - March 24, 2020 18

Project Emissions Considerations (General Summary)



New emissions units



Physical changes to existing emissions units



Change in the method of operation of existing emissions units (e.g., debottlenecking)



Removal of previous capacity restrictions



Use of fuels or raw materials that the unit could not previously use



Current emissions limits may become irrelevant

Workshop L - March 24, 2020 19

Example of Limit Being Irrelevant



Existing 100 tpy NOX limit on your boiler



Highest historical emissions were 50 tpy



Y

• u need to modify the

boiler



After modification your actual NOX emissions will be 70 tpy



Y

• ur current 100 tpy

becomes irrelevant



Y

• u have a 20 tpy increase

Workshop L - March 24, 2020 20

Defining a Proj ect



Think of the emissions unit as a race car.

 If all you have to do is press the accelerator down to make

your race car run faster, without making any changes to your car, you are allowed to make it go faster without a permit modification (as long as the emission unit was

• riginally permitted to run at top speed).

 If you need to make a pit stop to make physical changes to

the original design of the race care, you have now modified the race car and are required to evaluate whether a permit modification is required.

Workshop L - March 24, 2020 21

Widget Example



Y

• ur widget machine

was permitted to run 1,000 widgets per hour



Current customer demand is 700 widgets per hour



Customer demand increases to 1,000 widgets per hour



This is not a modification

Workshop L - March 24, 2020 22

Project Aggregation



A Facility cannot break up a proj ect into smaller proj ects to avoid permitting implications



U.S. EP A Guidance – 3/ 30/ 2019 Federal Register

 Projects within the last several years must be reviewed for project

aggregation

 Review your internal documentation of project scope  Keep a project aggregation determination justification on record

Workshop L - March 24, 2020 23

 When you look at these 3 pictures what

do you see, a diaper?

 A diaper is j ust a diaper…

right?

 NO!

Proj ect Aggregation Example

Workshop L - March 24, 2020 24

Air Permitting “Dirty” Words

Debottlenecking: what it means to you vs. regulators Production Increases Increase S peed Reduce downtime Like Kind (New NS R Manual) Turn up the Knob

Workshop L - March 24, 2020 25

Exemptions



Can this proj ect fall under an exemption?

 Combustion unit < 10 mmBtu/ hr  R&D  S

tate S pecific

 De Minimus

 <10 lb/ day of criteria pollutants

 MAKE S

URE YOU DOCUMENT YOUR DECIS ION TREE

Workshop L - March 24, 2020 26

Calculate Emissions



Need emissions of all criteria pollutants and/ or HAPs

 Proj ect/ Emission unit info

 Throughputs  Emission factors

 Facility Wide

 Throughputs  Emission factors

Workshop L - March 24, 2020 27

Where to Get Info



Plant Engineer

 Layout of line  Process flow diagram  Understanding how line will operate / description  What the lines full capacity is  Any bottlenecking?



Planning Coordinator

 Proj ected volume/ throughput rates  Will this be a scale up?

Workshop L - March 24, 2020 28

Where to Get Info



Material & Process Manager

 Materials that may be used  S

DS s of the materials

 Technical Data S

heets (TDS s) for materials

 Throughputs of materials/ Application rates

Workshop L - March 24, 2020 29

Where to Get Info



Emission Factors

 S

ite S pecific

 Industry/ Process S

pecific

 AP-42

 Combustion  Process information (can use similar if not exact)

Workshop L - March 24, 2020 30

Complete Application

• General forms and unit

specific forms Make sure have ALL forms needed Make sure have ALL forms needed

• PTE cals
• Maps
• Process Flow Diagrams
• Technical support

document All supplemental information All supplemental information

Workshop L - March 24, 2020 31

Complete Application

Make sure RO signs application Read submittal instructions

Online (Ohio eBiz) Emailed Hard copy (how many copies) Confidential vs Non-confidential versions

Pay attention to additional requirements for application posting

IN requires it to be posted in local library

Workshop L - March 24, 2020 32

Permitting Timelines



Application review timelines

 Ohio  Kentucky  Indiana

Workshop L - March 24, 2020 33

Example 1

S team demand at a facility has increased. Operations informs you they need to install a new boiler to make up for additional demand. Will this need a permit?

Workshop L - March 24, 2020 34

Example 2

A facility in your company is shutting

• down. Equipment from that facility is

being moved to a 2 sister locations in other states A facility in your company is shutting

• down. Equipment from that facility is

being moved to a 2 sister locations in other states

• Facility 1 has existing lines grouped as one process
• Facility 2 has existing lines permitting individually

Equipment is a metal can forming line which applies a coating to the interior of the can. Equipment is a metal can forming line which applies a coating to the interior of the can. Do you need a permit? Do you need a permit?

Workshop L - March 24, 2020 35

Questions?