Workshop N Practical Tips & Best Practices Navigating the - - PDF document

Workshop N

Practical Tips & Best Practices … Navigating the Complex Maze of Compliance with a New Air Permit

Tuesday, March 24, 2020 2 p.m. to 3:15 p.m.

Biographical Information

Amanda Jennings, Managing Consultant Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43082 614.433.0733 ajennings@trinityconsultants.com

Amanda Jennings is a Managing Consultant in Trinity’s Westerville, Ohio, office and provides air quality support for several industries in Ohio, including but not limited to, petroleum refining/distribution, chemical manufacturing, surface coating, asphalt processing/shingle manufacturing, and fiberglass and foam insulation manufacturing. She graduated from Ohio University with a Bachelor of Science Degree in Chemical Engineering. Amanda has completed numerous projects over her 15 years of consulting experience ranging from minor and major source state construction permit to install (PTI) or permits to install and operate (PTIO) applications, Fee Emissions Reports (FERs), emissions inventories, Toxic Release Inventory Reports (TRIs), Title V operating permit renewal and modification applications, MACT and GACT general consulting/compliance assistance, and regulatory applicability analyses. Also, she routinely teaches Trinity’s Strategic Air Permitting in Ohio training course.

Mark Stammen, Environmental/Safety Engineer Crown Equipment Corporation 40-44 S. Washington St., New Bremen, Ohio 45869 419.629.2311 mark.stammen@crown.com

Mark Stammen is an Environmental/Safety Engineer in Crown’s Corporate Office in New Bremen, Ohio, and provides environmental and safety support for Crowns manufacturing and branch operations across the United States. His range of experience and support includes time as a lead Safety Representative of multiple Crown manufacturing facilities. Mark also has extensive experience in environmental permitting, reporting, remediation, plan writing, surveys, and inspections in the following areas: USTs, Wetlands, Endangered Species Surveys, Wastewater, Air, Asbestos, Hazardous Waste, Toxic Release Inventory (TRI), Tier II, Oil Spill Prevention Controls and Countermeasures (SPCC), and Stormwater. He graduated from Bowling Green State University with a Bachelor of Science Degree in Environmental Science Policy and Analysis. Prior to Crown, Mark spent several years working in the electric power generation industry. He is a certified Asbestos Hazard Evaluation Specialist in the States of Ohio and Indiana.

Tracie Sorvillo, EHS Manager Sofidel 25910 US 23, Circleville, Ohio 43113 740.983.7806 tracie.sorvillo@sofidel.com

Tracie Sorvillo is an EHS Manager at Sofidel Circleville, Ohio, first greenfield site for the Italian based Company and provides Environmental Health and Safety compliance for the facility. She has degrees in Chemical Engineering, Information Technology and obtained her MBA from The Ohio State

• University. Tracie has managed both Title V and non-Title V air permits during her 12 years of

environmental health and safety work. Currently, she has been part of starting up a new tissue facility and managing and creating the tools needed to be in compliance with all the facilities Environmental permitting, health and safety regulations.

MEC Workshop N Navigating the Complex Maze of Compliance with a New Air Permit

Cincinnati, OH – March 24, 2020 Amanda Jennings –Trinity Consultants, Inc. Tracie Sorvillo – Sofidel America Mark Stammen – Crown Equipment Corp.

˃ New installation

 Requirements must be met upon startup

♦Can there be commissioning time (excluded from startup)?

˃ Pros

 Extra time to prepare to comply during

construction of the source

˃ Cons

 All new monitoring and recordkeeping

equipment/ templates/ procedures to implement

 Limited time to work out any kinks during actual

• peration

Permit Purpose & Timing for Compliance

˃ Existing emission unit modification

 Comply with the new permit upon

implementation of the change

˃ Pros

♦Existing monitoring & recordkeeping may be in

place

˃ Cons

♦Potentially less time may be needed for

construction, allowing less compliance prep time

Permit Purpose & Timing for Compliance

˃ Missed initial notifications ˃ Missed/ late reports ˃ Missed test dates ˃ Missing records ˃ Permit expiration ˃ Missed Title V permit updates (?

)

New Permit Pitfalls

Step 1 - Get a Good Permit!

˃ Prepare a good application that allows for

maximum operational flexibility

 Conservative emission rates or PTE-based

limits potentially reduce monitoring and record keeping burden

˃ Carefully review any draft versions of the

permit for accuracy, flexibility, and “ zinger” permit conditions

 Draft permit is not set in stone – comment

and negotiate!

˃ Working draft permit (?

)

˃ Draft permit (?

)

˃ Final permit ˃ Compliance demonstration ˃ Changes to permit

Stages of Living with a Permit

˃ Must review permit at this stage – best

• pportunity to get a permit that you can live with

˃ Permits that go “ direct final”

 There is no official draft stage  Will the agency allow you to review a working draft

version of the permit?

˃ Permits that go “ draft” & then “ final”

 Will the agency also allow you to review a working

draft version of the permit?

 Additional, 30-day public comment period

Draft or Working Draft Permit Stage

˃ Correct applicable requirements

 Does it match application?  Exemptions properly documented?

˃ Duplicative or overlapping requirements

 lb/ MMBtu & lb/ hr limits for same pollutant  One limit more stringent than another?

˃ Incorrect internal references ˃ Compliance demonstration methods

 Are they accurate (e.g., units)?  Correct test methods  Feasibility?

What to Look for in a Draft Permit?

˃ Review to make sure comments

incorporated

˃ Identify all changes vs. previous version

• f permit

Do not j ust file that permit away! It’s time to live with your permit each & every day.

Final Permit Stage

˃ Ohio Title V source - example ˃ Don’ t forget that newly issued permits to install

(PTIs) must be incorporated into your Title V permit!



Off-permit change (e.g., new install)



Minor permit modification



S ignificant permit modification

˃ Beware: There are some instances where operation

• f a new/ modified source can be prohibited until a

revised Title V permit is issued final!



For example, maj or NS R / PS D proj ects

Title V Operating Permit Updates

Step 2 - Read Your New Permit!

˃ Read and understand your permit (it is a

contract & a living document!)

˃ Highlight “ action items” (as opposed to

factual statements)

˃ Put reporting/ recordkeeping due dates

• n your calendar

˃ S

tandard or General Terms and Conditions



Permit expiration



General deviation reporting requirements



Malfunction reporting requirements



General recordkeeping (e.g., 5 years)

˃ Facility-Wide Terms and Conditions



S ynthetic minor limits

˃ Emission Unit-S

pecific Terms and Conditions



Description



Limits – emission limits, control requirements, &

• perational restrictions



Testing requirements



Monitoring\Record keeping\Reporting requirements

Permit Structure

˃ Understand the units (lb/ hr, lb/ MMBtu, tpy, gr/ dscf,

ppm, lbs/ gal, %

• pacity, %

control, etc.)?

˃ What is the averaging period?



S hort-term or long-term (instantaneous, 6-minute, hourly, monthly, annual, etc.)



Rolling or block average

˃ Are there allowable exceptions?



May be hidden in the rule language



e.g., startup, shutdown malfunction

The answers to these questions are key to developing an effective compliance demonstration plan!

Emission Limits, Control Requirements, & Operational Restrictions – Considerations

Don’t Forget Initial Notifications!

˃

General permit condition often requires initial notifications to the S tate, such as:



Construction starts



Construction complete



Equipment placed in operation



Equipment reaches target production rate

Initial Notifications

˃

May be hard to see!

˃

S tandard/ general terms

˃

Incorporation by reference

Compliance Assurance Requirements

˃ Testing

 Implies direct measurement of emissions using

a defined reference method

 If required/ as required

˃ Monitoring

 Implies reading an instrument or gauge

(including a CEMS / COMS )

˃ Record keeping

 All other paperwork associated with permit

Testing Pitfalls

˃

Not being prepared



Ports not in correct position



Operating schedule coordination poor (100% load vs. partial load)



No recording of production variables during test

˃

Errors



Math errors



S loppy field work, hand-written records

˃

Inappropriate test methodology



VOCs – are all accounted for?



Condensable/ Filterable particulates

˃

Results are questionable



Make no sense (variability run-to-run)



No correlation to other test results

Monitoring Considerations

˃ What does the regulation specify?



What to monitor



Frequency



Parametric or emissions



Prescribed method or device



Accuracy and/ or reliability requirements



Calibration requirements

˃ Explore alternatives & customize ˃ Plan to automate associated record keeping? ˃ Test drive prior to compliance date

Basic Monitoring Options

˃ Four basic monitoring approaches

 Mass Balance – requires accurate formulation data,

best for coating/ solvent usage activities

 CEMs – must meet NS

PS Performance S pecification Requirements (40 CFR Part 60, Appendix B)

 Continuous parameter monitoring system (CPMS) or

predictive emissions monitoring system (PEMS) – establish correlation between monitored parameter(s) and emission rate, [e.g., pressure drop (scrubber),

• xygen monitoring (boiler), temperature monitoring

(afterburner)]

 Emission factors - site specific testing establishes site

specific emission factor, operate unit within designated range of operation of the emission factor

Control Device Monitoring Examples

Control Device Parameter(s) Measurement Options Baghouse/Dust Collector Pressure drop Opacity Visible emissions (VE) Gauge COMS or test Manual VE checks Incinerator/Thermal Oxidizer Firebox temperature Thermocouple Wet Scrubber pH Liquid flow Pressure drop Sensor Flow meter Gauge Flare Pilot Thermocouple, UV or IR detector Any Pollutant concentration and/or emission rate CEMS Flow meter

Process Related Monitoring Examples

˃ Ensure methods are in place to maintain and

gather production-related records

˃ Examples

 Material usage (paint, reactants, solvents)  Production rates (e.g., tons widgets)  Fuel fired  Operating hours  Fuel properties (e.g., sulfur content)

˃ Confirm frequency (monthly, daily, annual) ˃ Permit may not require it, but records still may be

necessary for annual emissions reporting!

Record Keeping

˃ Inspectors look first for complete and

• rderly records!

˃ Update records on time (daily, weekly, or

monthly)

 S

et an internal deadline to have records updated (e.g., monthly records complete within 15 days following the end of the month)

˃ Keep records together and in central

location

Record Keeping Decisions

˃ File retention

 On-site vs. off-site

˃ What format?

 Hard copy vs. electronic

˃ What data?

 Notifications & reports  Testing & monitoring data  Maintenance data  Corrective action data

5 years of records is a lot of paper!

Manual Record Keeping Considerations

˃ Identify who should complete ˃ S

implify

 Terminology & forms

˃ Training ˃ Test drive prior to compliance date ˃ Pros - simplicity, forces periodic

inspection of regulated processes/ shops, & eliminates issues related to sustaining automated system

˃ Cons - unreliability & the drain on

resources

Automated Record Keeping Considerations

˃ Identify who will provide technical

support

˃ Necessitates

 S

elf-diagnostic capabilities

 Contingency plan

˃ Pros - reliability, reduces record keeping

violations, reduces chance for excess emissions, & reduces drain on resources

˃ Cons - complexity, collection frequency may

exceed regulatory requirements, & eliminates interaction with the shop floor

Reporting

˃ S

et up report templates to ensure all required information is included

˃ S

ubmit reports on time!

˃ Types of Reports

 Malfunction reports – as they occur  Emissions reports – annually (usually)  Deviation reports ♦Can be rule-based or permit-based ♦Can be of varying frequency (quarterly, semi-

annually, annually, etc.)

♦Can be based on varying reporting schedules  Title V compliance certification reports – annually

Deviation Reporting

˃ Typically need to include:

 Deviation description  Probable cause  Estimated magnitude and duration, and  Any corrective actions or preventive measures taken

˃ May vary depending on state requirements ˃ Do you have to submit a report if no deviations

• ccurred?

˃ S

hould malfunctions be included?

Compliance Management Tools Can Help

˃ Create a calendar to show what is needed each

day, week, etc.

˃ Tools (e.g., spreadsheets, databases, off-the-

shelf software) can streamline compliance demonstration efforts to free up environmental staff for other tasks

˃ Customize to each facility’s permit requirements ˃ Let technology work for you (electronic data

gathering and storage)

Questions to Ask DAILY

˃ Do you know if you are doing

everything you are supposed to be doing?

˃ Can you prove you are doing

everything you are supposed to be doing?

˃ Is all of your compliance

documentation easily accessible?

THE FUTURE, NOW

SUSTAINABILITY IN THE SOFIDEL WAY

Our Commitment

«LESS IS MORE» This leading principle is the best example of the commitment of Sofidel Group to give more in terms of products, services and sustainability, reducing consumption

• f

resources, emission in the environment and generation of waste, in line with the aim at improving people's lives.

SOFIDEL & ENVIRONMENT

INVESTMENTS IN RENEWABLES, CHP, EFFICIENCY

The Circleville (OH) paper mill has been equipped with the most advanced tissue technology, allowing premium quality with reduced energy consumptions.

INVESTMENTS IN RENEWABLES, CHP, EFFICIENCY

Paper machine exhaust (air emission) Yankee cylinder 8 MW electric power for each gas turbine (2 turbines) Yankee hoods burners

In Circleville (OH) Sofidel invested in the newest gas turbine CHP technology, integrated with the drying

• system. This configuration

allows important costs savings and the reduction of 25.000 t of CO2 emission every year, if compared with the solution without cogeneration. The plant provides around 80 % of power needed by the paper mill.

Circleville CHP

CHP Feed and Returns to the Paper machine

Circleville CHP Wet end Dry end

Circleville CHP

G as Turbine

Circleville CHP

Boilers

Circleville Plant Aerial – record keeping areas required by our non‐title V Air Permit

Plant Key Numbers

350

NEW JOBS – phase 1

283 ACRES

ACQUIRED LAND

1,8 MLN SQF

FACILITY

140,000 TONS

ANNUAL PRODUCTION CAPACITY

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Converting

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Implementing a new air permit a successful approach:

• Where should you start when making sure your new permit will

be in compliance with what can appear to be an overwhelming process

• How to set up initial Air Stack Testing

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Air Permit Compliance – where do you start?

Step 1 : Determine if you need outside consultant help and to what extent you need their

• help. If you do need help, start working on finding one that meets your needs.
• Be honest with yourself about 2 things:
• 1. Your experience level in the subject matter
• 2. How it fits into your overall job tasks.
• Those tasks that are needed for you to be

successful in the role your are getting paid to do

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Air Permit Compliance – where do you start?

Step 2 : Read the permit and start a tracking tool that you can categorize the requirements into manageable pieces

• Plan to give yourself amble time to work through it
• Be kind and reasonable to yourself ‐ set your expectations right
• set small goals, that will allow you to feel progress
• This will also help you get to know your permit better; one emission unit at a time
• It will also help you begin your journey of Zen and not anxiety when it comes to keeping your

emission units compliant with the law

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Step 2:

Tracking Tool that can categorize the requirements in manageable pieces.

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Air Permit Compliance – where do you start?

Step 3 : Now prioritize. Determine what needs attention first and then move into the best practices

• What permitted EU’s have the biggest risk to damage the environment?
• What reports, if missed will cause an NOV?
• What record keeping requirements signal an out of compliance?
• What record keeping is needed but doesn’t contribute to a large release?
• Pull out all the mandatory due dates of reports and notifications and make sure you

have a way to manage that they are submitted on time and you have a quick way to report them to your boss, corporate and leadership team.

• For example, the new site permit I work with had some one‐time due dates

and reoccurring annual due dates.

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Air Permit Compliance – where do you start?

Step 3 : Prioritize and manage One Time Notifications: Recurring Report Due dates:

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Air Permit Compliance – where do you start?

Step 4 : Investigate how will you retrieve the required information? Who will do the ground checks? Who or what will capture the daily checks?

• Capture this on one of your tracking forms – do this as intuitively as possible so

someone else can view it and follow it pretty easily Step 5: Map out your time line and begin the work. Final Step!

• Set the small goals that show completion
• Track your work

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Initial Air Stack Testing

Selecting the independent testing vendor

• Now that you know when your first required air stack testing is due – start

shopping around for a certified vendor in your area that will do the testing for you

• From the Ohio EPA site they provide this link which lists testing firms:
• http://www.activeset.org/states/central/ohio.htm
• Internet searches of companies that service you areas; social media;

professional network

• If you already have independent lab testing vendor you use for waste water –

see if they do air stack testing also

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Initial Air Stack Testing

Selecting the independent testing vendor

• Set goals on when you will require all bids to be submitted. Make sure it allows you

enough time to make the decision and meets the scheduling norms of the testing firm selected.

• Know what your decision making process is in your organization – do you need corporate

approval? Are you the first site that needs air permit testing in your company? If so, will you need to explain to corp why it is needed and what is needed? Is the budget available and who is the decision maker to spend that budget?

• Stack testing companies schedule 6 months out. Make sure you are within this time frame
• If you have enough time, I would suggest having the vendors come out to the site so they may

see the stack and their testing port access to give you the most accurate quote

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Initial Air Stack Testing

Selecting the independent testing vendor

• After the testing firms have come back with their proposals – how do you know which
• ne to select?
• Compare all quotes, apples to apples. They won’t be written that way so you will have to

gather your questions to ask each vendor.

• Have them resubmit a quote if needed so they are all comparable
• I suggest Creating a vendor matrix to be helpful – based on ranking or price system
• These testing firms cost range can be large for the same service – so ask, ask, ask
• $14,500‐$31,100 – approx. 50%
• Make sure the vendor you choose has at least one QSTI (Qualified Sourcing Test Individual)

who will be involved in the supervision of the project

• Make sure their quote run times reflect your permit correctly
• That they aren’t over running or under running
• Confirm they will deliver all the required reporting in a time frame you are able to submit the

reports on time per your permit requirements

A peculiarity of Circleville Plant is the high automation level

• f

internal logistic management, including a fully automated warehouse, by implementing the most advanced automated control system.

Initial Air Stack Testing

Confirm Emission Units are Running as required

• MAKE SURE ALL EMMISSIONS UNITS THAT WILL BE STACK TESTED ARE ABLE TO RUN AT

THE PEAK LOAD +/‐ 25%.

• EPA wants 90%
• If the EU is not up to running at this rate, you will not be able to run past the load you

tested until you have re‐stack tested at the new load

• This load was submitted in the designs that the permit was granted under
• If you are not able to reach this load, work with your local EPA rep and air permit writer and

request an extension if needed

• You want the testing to be at the closest test scenario possible and also you do not want to be

limited by premature stack testing values.

THANK YOU !

Innovating Air Permit Recordkeeping Requirements

Mark Stammen – Corporate Environmental/Safety Engineer

March 24, 2020

Who is Crown?

• Corporate

Headquarters, New Bremen, Ohio

• Private, Family-Owned

Company for 75 Years

• 19 Manufacturing

Locations Across the Globe

• Over 16,000

Employees Worldwide

Crown Lift Trucks

Who is Crown?

• Vertically Integrated
• Global Leader in the

narrow-aisle lift truck market

• Lift loads of 1000-8000
• lbs. from 5 inches to 45

feet

Crown Lift Trucks

Agenda

• Crown Permitting and Emissions Sources
• Recordkeeping Risk Points
• Selection Process
• Solution
• Issues
• Benefits

Air Permit

Non-Title V Minor Source

• Multiple Sources

Paint Booths Shot Blasters Chrome Plating Heat Cleaning Oven (Burn-Off)

• Multiple Types of Recordkeeping requirements

Recordkeeping Risk Points

Paint Booth Usage Logs Paper/Hard Copy Records

• Human Error
• Lost Records

Product Transfers between Locations Duplication of Data Entry Lagging Reporting Staff Transfers

• New Supervisors

Selection Process

Reviewed Eight Vendors

• Gear Meters
• Coriolis Meters
• Ultrasonic Meters
• Mixing Cabinets

Trialed Two Types of Meters for 8 months Electronic Integration/Recordkeeping was preferred

Solution

AW-Lake Company

Tricor Coriolis Meters

• Accurate within 0.5 % or

better

• Proven Experience
• Minimal to No

Maintenance

• Solid Design – No Moving

Parts

Tricor Coriolis Meters Integrated with Opto22 Groov Software

Solution

Coritech Services , Inc.

• Panel Design and

Fabrication

• Software Integration
• Data Management and

Automated Reporting

Tricor Coriolis Meters Integrated with Groov Software

Crown Paint Metering Network Diagram

Solution

Paint Metering System

Solution

Paint Metering System

Solution

Paint Metering System

Paint Metering System Troubleshooting

Learning Experiences

• Power Surges
• Paint Issues
• Network

Expansion/Reconfiguration

Paint Metering System Benefits & Improvements

Offers Better Data Reliability

• Improves Toxic Release Inventory Reporting Accuracy

Forecasts Air Permit Level Status as Processes Change Less Training and Data Logging Hours Simplifies Annual Permit Evaluation Reporting Decreases the Possibility of Noncompliance

• Leading vs. Lagging Indicators

Realtime Information for Operator Performance Improvement

• Opportunity to include additional sources outside of paint