Michigan State University Air Seminar - Lecture 6

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Michigan State UniversityAir Seminar - Lecture 6

• Air Permitting and Testing
• April 26, 2005

Jeff Pfost Environmental Partners, Inc. Holland,
Michigan
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Introduction Background

• Graduate of Western Michigan University
• Post Graduate Studies
• MSU Hazardous Material Training
• UW-Madison Industrial Ventilation
• UW-Madison Certified Hazardous Waste Operations
  and Emergency Response Trainer
• MIT Environmental Negotiations
• Certified Storm Water Operations - Industrial

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Introduction Background

• Internship Surveying / Engineering/ Consulting
  Firm
• National Council for Air Stream Improvement
  (NCASI) Pulp Paper Ind.
• Partner Co-owner Dell Engineering, Holland,
  Michigan
• Equity Partner Environmental Resources
  Management
• Partner Co-owner- Environmental Partners, Inc.
  Holland, Michigan

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Introduction Background

• Air Compliance Consulting
• Litigation Support and Expert Witness
• General Environmental Compliance Assistance
• Active Trade Association Member
• Michigan Manufacturers Association
• Air Waste Management Association
• Various West Michigan Chambers of Commerce

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Lecture 6

• Attainment versus Non-Attainment
• Air Permitting
• Construction / Installation
• Operating Air Permits
• State
• Federal
• Atmospheric Emission Source Testing
• Ambient
• Stationary
• Mobile

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Discussion Topic 1The National Ambient Air
Quality Standard (NAAQS)

• Attainment versus Non-Attainment

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NAAQS

• The Clean Air Act
• Requirement for U.S.EPA to establish air quality
  criterion (Values) Standards
• Requirement for U.S.EPA to perform AMBIENT AIR
  MONITORING - Evaluation
• Requirement for U.S.EPA to promulgate rules to
  ACHIEVE MAINTAIN

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Section 108

• Identify Pollutants that May Endanger Health
  Welfare
• Issue Criterion that Reflect the Latest
  Scientific Knowledge Regarding Effects

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Section 109

• Establish the National Ambient Air Quality
  Standard (NAAQS)
• The Attainment and Maintenance are requisite to
  protect public health with
• An adequate margin of safety

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6 Criteria Pollutants

• Carbon Monoxide (CO)
• Lead (Pb)
• Oxides of Nitrogen (NOx)
• Ozone (O3)
• Oxides of Sulfur (SOx)
• Particulate Matter (PM)
• Total Suspended Particulate (TSP)
• PM10
• PM2.5

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Establishment of the Standard

• Primary
• Established to protect Public Health
• Most Restrictive
• Hardest to Achieve
• Secondary
• Established to protect Welfare
• More Liberal
• Easier to Achieve

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GRAY
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Protection of Public Health
Absolutes Gray
120 Units
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NAAQS Values

• CO
• Primary Standard
• 8 Hour 9 ppm
• 1 Hour 35 ppm
• Secondary None
• Pb
• Primary Standard 1.5 µg/m3
• Secondary same as Primary

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NAAQS Values

• NOx
• Primary Standard 0.053 ppm
• Secondary same as Primary
• Ozone
• Primary
• 1 Hr 0.12 ppm
• 8 Hr 0.08 ppm - NEW!
• Secondary same as Primary

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NAAQS Values

• PM10
• Primary Standard
• Annual 50 µg / m3
• 24 Hour 150 µg / m3
• Secondary same as Primary
• PM2.5 NEW!
• Primary Standard
• Annual 15 µg / m3
• 24 Hour - 65 µg / m3
• Secondary same as Primary

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NAAQS Values

• SOx
• Primary Standard
• Annual 0.03 ppm
• 24 Hour 0.14 ppm
• Secondary Standard
• 3 hour 0.5 ppm

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Particulate Matter 2.5
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Discussion Topic 2Air Permitting

• Stationary Source
• Construction and Operation
• Federal and State

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New Source Review Permits

• Provides Permission Conditions Acceptable for
  Building a Source of Air Pollution
• Also Known As
• Construction Permits
• Permits to Install (PTI)
• NSR Permits
• Installation Permits
• Permit Issued Before Building or Installing
  Source
• Air Pollution Control Equipment - Likely Required

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New Source Review Permits

• Typically submitted to a State Agency, Depending
  on the States Choice to Assume Responsibility
  for the Permitting Program, and EPAs Approval of
  the Program (Implementation Planning)
• Usually the Permit is State Issued
• Typically a High Level of Technical Effort
• Very Process Equipment Dependent

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New Source Review Permits

• Must Demonstrate Compliance
• With Existing Rules and Requirements
• Can not Adversely Impact NAAQS
• Can not Cause Harm from Proposed Emission Types
  or Emission Rates Proposed
• Evaluate Control Options and Feasibility
• Evaluate Alternate Materials and Lower Emitting
  Technologies
• May Require Public Notice

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New Source Review Permits

• Generally regulated at the Federal Level in 40
  CFR Part 60 New Source Performance Standards
  (NSPS)
• May Also be Regulated under the Toxic Emissions
  Standards found in 40 CFR Part 63 - National
  Emission Standards for Hazardous Air Pollutants
  (NESHAP)
• State by State Requirements Vary widely

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Operating Permits

• After Construction Provides Permission to
  Operate the Source of Air Pollution
• State Typically Issues Operating Permits
• Could be a Combination of a State and Federal
  Permit
• Tend to be More Regulatory Intensive In Place of
  Technically/Process Oriented

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Operating Permits

• Clean Air Act Amendments of 1990 the Title V
  Program
• Attempt to Simplify Air Permits
• Combine a Source (site) Requirements into a
  Single Air Permit The 1 Permit Approach
  Applicable Requirements
• Concise Monitoring Terms
• Self Reporting Provisions Compliance
  Certification

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Discussion Topic 3Air Monitoring Testing

• Ambient Air Monitoring
• Mobile Source Testing
• Stationary Source Testing

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Air Monitoring Testing

• Ambient Air Monitoring NAAQS
• Mobile Source Testing Cars Trucks
• Stationary Source Testing Power Plants

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Monitoring for NAAQS

• Monitoring is Conducted at Stationary Sampling
  Sites Called a Monitoring Network
• Not all Stations Monitor All Criteria Pollutants
• Data is Collected and Quality Assured
• Compliance is Determined by Comparing the QA Data
  to the NAAQS - Annually

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Ambient Air MonitoringPermanent Site
Monitoring

• Performed to Determine/Confirm the Localized
  Ambient Air Conditions
• Typically Monitored for NAAQS Parameters
• Can/Will Monitor for Various Parameters at
  Various Locations
• Generally Combined with a Weather Monitoring
  Station (Meteorological Station)
• Michigan has 41 Dedicated Monitoring Sites in
  their Monitoring Network

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Ambient Air MonitoringTemporary Site Monitoring

• Agency Sited Monitoring Stations to address
  localized activities and source impacts
• Site (private) Located Stations to address
  regulated activities, such as PSD permitting
• Agency Deployed Mobile Stations to address
  atmospheric events and specialized studies
  undertaken by the agency (atmospheric research
  related to regulatory response issues)

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Mobile Source Testing

• Testing Methodology
• Tailpipe and Remote Testing
• Dynamometer Testing
• Performance of the Engine and Control Equipment
• Level of Tune Air to Fuel, Ignition System,
  Etc.
• Engine Wear Oil Consumption
• Tune or Repair as Necessary
• On-Board Diagnostics
• Roughly 1998 and Newer Vehicles
• Tested at the Dealership Readings Collected
• Tune or Repair as Necessary

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Stationary Source Testing

• Typically Conducted to Determine a Sources
  Emissions to the Environment/Atmosphere
• May Include the a Determination of the
  Performance of a Pollution Control Device
• Most Commonly Conducted by Specialty Testing
  Firm, at the Expense of the Source
• Can be Either Voluntary or Mandatory
• Event Based (Stack Test) or Dedicated/Continuous
  Monitor (CEMs)

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Stationary Source Testing

• Most Often the Testing has Regulatory
  Implications
• Permit Limits
• Rule Restrictions
• Applicability to a Specific Section of the CAA
• Most Often use Techniques Published and
  Promulgated by U.S.EPA
• Most Frequently Used Methods
• 40 CFR Part 60, Appendix A Appendix B

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Stationary Source Testing

• Examples of U.S.EPA Methods
• Method 1 Sample and Velocity Traverses
• Method 2 Stack Gas Velocity and Flow Rate
• Method 3 Stack Gas Dry Molecular Weight
• Method 4 Stack Gas Moisture
• Method 5 Stack Particulate Concentration
• Method 18 Gaseous Organic Emissions (GC)
• Method 25A- Total Organic Emissions (FID)
• Method 26- Hydrogen Halide Halogens

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Source Testing

• Should be Preceded by an Approvable Test Plan
• Single or Multiple Events (Average of 3 Runs)
• Ideally Linked to
• Allowed Emission Rate
• Production Rate
• Production Event or Activity
• Should be Followed by an Approvable Test Report

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Source Testing

• Methods
• Collection of Stack Data
• Collect Emission Parameters
• Quantify in Field, and/or
• Quantify in Field Laboratory, and/or
• Collect and Transport to a Laboratory
• Example/Photos

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Conclusion and Wrap-up

• Air Practice is Wide Open
• Can be
• Very Technical
• Heavily Regulatory Based
• Very Litigious
• Rewarding
• Overwhelming

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Questions?

• Jeff Pfost
• Environmental Partners, Inc.
• 616-928-9129 direct
• jeff.pfost_at_enviro-partners.com