Air Quality 102

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Air Quality 102

• Sponsored by
• Kansas Small Business
• Environmental Assistance Program
• 1-800-578-8898

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Agenda

• Welcome and introductions (questions)
• Air regulation overview
• Potential to emit (PTE)
• Limiting PTE
• Networking lunch
• Calculate your PTE

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K-States Pollution Prevention Institute (PPI)

• PPI staff operate SBEAP in partnership with KDHE.
• PPI services are
• Multimedia (air, waste, water)
• Free to small- and medium- sized businesses
• Confidential
• Non-regulatory
• PPI special projects enhance SBEAP services.

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Small Business Environmental Assistance Program

• Provides air-focused technical assistance to
  Kansas small- and medium-sized businesses
• Environmental regulatory compliance
• Emissions reduction and pollution prevention
• Permitting and reporting requirements
• All states have a similar program.

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Small Business Environmental Assistance Program

• SBEAP services are provided via
• Environmental hotline [phone])
• On-site visits
• Targeted regulatory or industry-specific
  workshops
• Publications (hard copy or electronic)
• Newsletters AIRlines, EnviroLines
• Fact sheets, manuals
• E-tips
• Web-based resources and training
• www.sbeap.org

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Questions or comments?

• Environmental Hotline
• 800-578-8898
• www.sbeap.org

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Clean Air History

• 1273 King Edward I bans sea coal in London
• 1881 Chicagos first smoke-control law
• 1945 Pittsburgh smoke-control program
• 1947 Los Angeles Air Pollution Control
  District establishes smoke and SO2 regulations
• 1948-1954 several smog-related deaths
• 1955 - Congress passes the Air Pollution Control
  Act (first commitment of federal funds - 5M)
• 1963 Clean Air Act
• 1970 Clean Air Act Amendments (EPA formed)
• 1990 Clean Air Act Amendments of 1990

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London fog incident of 1952
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CAA 1970

• Risk-based standards
• SOx
• NOx
• CO
• PM10
• Lead
• Ozone
• Technology-based standards for point sources

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CAAA 1990

• Contains 11 titles, including
• Title I Ambient air quality standards
• Title III Hazardous air pollutants (HAPs)
• Title V Operating permits

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Kansas Air Quality RegulationsKAR 28-19-1 -- 801

• The Kansas Air Quality Act (KAQA) implements
  elements of the 1990 Clean Air Act Amendments.
• It is administered by the Kansas Department of
  Health and Environment (KDHE) Bureau of Air and
  Radiation (BAR).

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What must you evaluate?

• KAQA applicability and compliance
• Existing sources that are not permitted
• Proposed sources
• Existing sources that are permitted, when
  modifying or adding new equipment

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Kansas air operating permits

• Construction permits or approvals (registrations)
• Class I operating permits (true major sources)
• Class II operating permits (potential major,
  actual area sources limits PTE)
• Class III or registrations no longer in effect

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Major source

• Stationary source with potential emissions
• of
• 100 tons/yr or more of regulated pollutant (e.g.,
  NOx, SOx, PM10, VOC, CO)
• 10 tons/yr of any single HAP
• 25 tons/yr of any combination of HAPs

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Potential to emit (PTE)

• This is the maximum design capacity of a
  stationary source to emit a pollutant under its
  physical and operational design.
• Any physical or operational limitation shall be
  treated as part of the design
• Control equipment
• Hours of operation
• Amount of material
• Stored
• Combusted
• Processed

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PTE assumptions

• 24-hour operation, 365 days per year
• Operate at maximum capacity
• No pollution control devices or practices
• Bottlenecks can limit the PTE

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Quiz Question

• If your facility only operates one shift, why
  calculate emissions as though you operate 24/7?

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Quiz Answer

• Facilities are regulated based on their design
  not their actual hours of operation. Production
  levels could change, and emissions would increase
  within existing facility.

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• Emission source any machine, equipment, device,
  or other article or operation that directly or
  indirectly releases contaminants into the outdoor
  atmosphere.
• Emission unit any part or activity of a
  stationary source that emits or would have the
  potential to emit any regulated pollutant or any
  pollutant listed under 42 U.S.C. 7412(b) of the
  federal Clean Air Act.

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What are emissions?

• Stack emissions
• Fugitive emissions (if a federally designated
  fugitive emission source)
• Other emissions

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Identify each emissions unit

• A unit is an activity that emits or has the
  potential to emit.
• Emission units do not have to be connected to a
  stack or vent.
• The entire facility can be viewed as an emissions
  unit.

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Frequently overlooked emission sources

• Bleed valves
• Compressors
• Degassing (line, pump, vessel)
• Steam traps
• Process vents
• Pressure-relief

• Cooling towers
• Loading operations
• Solid wastes
• Storm water runoff
• Wastewater collection and treatment
• Transfer operations

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Emissions from activities

• Conveyors
• Tank truck loading and unloading
• Valves and vents
• Wastewater treatment plant emissions
• Material storage and transfer
• Evaporation
• Wind erosion
• Haul roads

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Other emissions to consider

• Degreasing tanks
• Welding activities
• Pumps
• Painting
• Cleanup

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What to leave outCategories of Exempt Activities

• Fuel use
• Upkeep and maintenance
• Production operations
• Finishing operations
• Storage tanks
• Wastewater collection and treatment
• Cleaning operations
• Residential activities
• Recreational activities
• Health-care activities
• Miscellaneous

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Quiz Question

• Do you calculate emissions from welding
  operations?

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Quiz Answer

• Only if HAPs are emitted as a result of the
  welding.

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PTE calculation methods

• Material balance
• Emission factor
• Stack tests
• Other approved method

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Steps for calculating PTE

• Identify each emission unit
• List all possible pollutants
• Quantify emissions (tons/year)
• Material balance
• Emission factors

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List all possible pollutants

• Nitrogen oxides (NOx)
• Sulfur oxides (SOx)
• Carbon monoxide (CO)
• Volatile organic compounds (VOCs)
• Particulate matter 10 microns or less (PM10)
• Hazardous air pollutants (HAPs)

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Quantify emissions

• Material balance
• Emission factors
• EPAs AP42 factors
• Trade organization studies
• Performance tests

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Fuel consumption

• Emissions from combustion can be calculated based
  on the fuel and equipment used.
• Rated heat capacity can be used.
• Maximum rated fuel consumption can be used.

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Material balance

• Product in product out
• (assumes constant inventory)
• Example solvent cleaning
• Solvent purchased emissions
• Material balance can be applied to individual
  unit, activity, or entire source process.

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Air construction permits(Preconstruction
approvals)

• Prevention of Significant Deterioration (PSD)
  permits
• Significance levels
• 100 ton/yr PTE for listed sources
• 250 ton/yr PTE for all other sources
• Construction permits KAR 28-19-300(a)
• Construction approvals KAR 28-19-300(b)

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Construction permits when?

• If PTE threshold is met because of
• New construction
• Modification of existing emission unit
• Change in method of operation
• Emissions unit is major HAP source or incinerator

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What ISNT a modification?

• Routine maintenance, repair, or replacement
• Switching fuel specific cases
• Increase in production rate or hours as long as
  not prohibited by permit
• Change in ownership

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Construction approvals (registrations) when?

• Emissions exceed thresholds
• Emissions unit is subject to
• NSPS
• NESHAP/MACT

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Class I permits

• Combines all air quality requirements into single
  permit (corrects and modifies previous permits
  and approvals)
• Requires sources to review and correct air
  quality requirements
• Requires annual air emission inventory submissions

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Class I permits (cont.)

• Establishes recordkeeping, monitoring, and
  testing requirements
• Establishes semi-annual reporting and annual
  compliance certification
• Federally enforceable

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Class I permit who needs it?

• Major source
• Affected source
• Subject to New Source Performance Standard (NSPS)
• Subject to 112(r), prevention of accidental
  releases
• Designated by the secretary

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Quiz Question

• I think our facility needs a permit and I dont
  think we have one but Im not sure.
• What do I do?

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Quiz Answer

• Work with us and KDHE.
• KDHE will work with you but if legally required
  to impose a fine, they will have to do it.
  Still, better to get it resolved right away.

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Class I renewals

• KDHE has a special form for Class I renewal
  applications.
• New forms may be required if operations have
  significant changes.
• Submit application six to18 months prior to
  expiration of current permit.
• Contact KDHE for more information.

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Limiting PTE

• Any physical or operational limitation on the
  capacity of the source to emit a pollutant,
  including air pollution control equipment and
  restrictions on hours of operation or on the type
  or amount of material combusted, stored, or
  processed, shall be treated as part of the design
  if the limitation or effect it would have on
  emissions is federally enforceable.

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Common methods of reducing PTE

• Pollution prevention
• Limit process rates
• Limit hours of operation
• Limit amount of material processed or combusted
• Add pollution control equipment
• Emission limit required by a regulation
• Combination of these

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Regulatory limits

• Regulations that are part of the state
  implementation plan (SIP) Class II permits
• New Source Performance Standards (NSPS)
• National Emission Standards for Hazardous Air
  Pollutants (NESHAP/MACT)
• Other federal regulations

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Class II (synthetic minor) permits

• General Class II permits
• General rock crushers
• Permit-by-rule
• Reciprocating engines
• Organic solvent evaporative sources
• Hot-mix asphalt
• 50 actual

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Class II permit emission levelsActual emissions
(blue), potential emissions (red)
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Federally enforceable permit conditions

• The condition must be permanent, quantifiable,
  and otherwise enforceable.
• The source must be able to meet its business
  needs while operating under the permit conditions.

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Class II general permits

• Source proposes restrictions used to limit
  emissions
• Material purchased, used, or processed
• Hours of operation
• Control equipment
• Other restriction
• KDHE has specific forms for several processes and
  equipment.
• Recordkeeping

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Class II Permit Application

• Process/Equipment
• Description Form

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Class II rock crushers (PM10)

• Special case of Class II permits
• Applies to portable or stationary facilities
• Select dry or controlled operation

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Class II permit-by-rule for reciprocating
engines withcapacity less than

• 730 HP, or
• 550 kW, or
• 5.1 million Btu/hr input
• Or, limit hours or fuel input and maintain records

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Class II permit-by-rule for organic solvent
evaporative sources that purchase or use less
than (in any consecutive 12-month period)

• 9 tons of VOCs or HAPs
• 90 tons of VOCs, or 22.5 tons of combination of
  HAPs, or 9 ton of a single HAP, and maintain
  records

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Class II organic solvent evaporative sources

• Facility must
• Maintain on-site records, updated monthly
• Submit annual report of usage
• Report to KDHE if exceeds 85 of any restriction
  in a quarter
• Submit compliance plan if fails to meet any
  requirement

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Example Calculations

• Solvent evaporative source

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Recordkeeping varies look at your permit

• Rolling 12-month totals
• Total is calculated every month
• Not based on calendar year, based on last 12
  months
• Example total as of March 31, 2007 would be sum
  of emissions from April 1, 2006 through March 31,
  2007
• Quarterly totals these are based on calendar
  quarters, which end in March, June, September,
  and December

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Class II permit-by-rule for hot-mix asphalt

• Control particulate emissions
• Limit production to lt250,000 ton (12-month
  rolling total)
• Maintain records

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Permit-by-rule, 50 rule

• For facilities with actual emissions less than
  50 of major source thresholds
• For facilities with actual emissions between 25
  and 50 of major source thresholds

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NESHAP/MACT

• 1970 Section 112 provisionsnational emission
  standards for hazardous air pollutants (NESHAP)
• EPA had to identify hazardous air pollutants
  (HAPs) and identify standards to prevent any
  adverse human health effects with ample margin
  of safety.
• All were risk-based.
• Courts directed EPA to determine safe air
  pollutant levels without technological or cost
  concerns.
• 1990smaximum achievable control technology
  (MACT)
• Congress saw setting health-based standards as
  too long and difficult, so initiated new
  technology-based standards.

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NESHAP/MACT sources

• Generally major HAP sources, with a few
  exceptions
• New sources must install Best Available Control
  Technology comply upon startup
• Existing sources must meet emission limits of top
  12 of controlled units comply within three
  years of promulgation

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General MACT requirements

• Initial notification
• Recordkeeping and reporting
• Malfunctions plus periodic startup and shutdowns
  must be reported.
• KDHE has adopted all MACT standards through July
  1, 2003 (K.A.R. 28-19-750) submit reports for
  these to KDHE, copying EPA.
• List of MACTs http//www.epa.gov/ttn/atw/mactfnlal
  ph.html

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Area SourceMACTs coming soon

• Autobody refinishing
• Fabricated metal products
• Paint stripping operations
• Plating and Polishing

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Kansas Air Operating Permits Construction Permits
or Approvals
KDHE Construction Approval
DRAFT
IF NEEDED File for Operating permit 180
days before beginning operations
Construction, Modification, or Operations change
Exceed Permit PTE Thresholds? Tons/year PM 25 PM10
15 PM (ag) 100 SOx 40 CO 100 NOx 40 Lead 0.6 VOC
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yes
Already a major HAP source or incinerator?
Subject to NSPS or NESHAP/MACT?
no
no
yes
no
Subject to PSD?
no
yes
no
yes
exceed Approval PTE Thresholds? PM 5
lb/hr PM10 2 lb/hr PM 2.5 (ag) 5 lb/hr SOx 2
lb/hr CO 50 lb/24hr NOx 50 lb/24hr Lead 0.1
lb/hr VOC (JO, WY) 15 lb/24hr VOC (JO, WY) 3
lb/hr VOC (others) 50 lb/24hr
Much review is required
yes
yes
KDHE Construction Permit
No approval or permit needed
File for Operating permit within one year of
commencing Operations IF NEEDED
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Kansas Air Operating Permits Class I Permits
DRAFT
Major Source Actual? 100 tpy criteria
pollutant 25 tpy combination of HAP 10 tpy single
HAP
Major source PTE?
Check Class II applicability
yes
no
no
Affected Source? (acid rain)
yes
no
yes
Class I Operating Permit
Subject to NSPS? (which requires Title V permit?)
yes
Establishes Recordkeeping Monitoring Testing Semi
annual reporting Annual compliance
certification Federally enforceable
no
yes
Subject to NESHAP that requires Title V?
yes
no
Designated by Secretary?
RMP and other requirements may apply
Subject to 112(r) only?
yes
no
No Permit Required
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Go back to Class I
PTE Major Source? (100 tpy criteria pollutant 25
tpy combo of HAP 10 tpy single HAP) BUT Actual
emissions are less?
Kansas Air Operating Permits Class II Permits
no
no
Can reduce PTE by physical or operational capacit
y?
yes
yes
Solvent Evap. Permit-by-rule
Solvent evaporative emissions? (lt 90 tpy VOC,
22.5 tpy HAPs 9 tpy HAP)
yes
no
Recip. Eng. Permit-by-rule
DRAFT
Emissions from reciprocating engines? (lt730 HP,
5.1 MMBtu, or 550 kW)
yes
H.M. Asphalt Permit-by-rule
no
yes
Hot-mix asphalt facility? (lt250K ton, control
PM)
Rock Crusher General permit
no
yes
Rock crushing? (size limits, wet or dry)
Class II Permit (set indiv. facility
restrict. Can include control equip.)
no
50 Permit-by-rule
no
Total actual emissions less than 50 of major
thresholds? (lt50 tpy criteria, 12.5 tpy HAPs 5
tpy HAP)
yes
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Kansas City Requirements

• Reasonably Available Control Technology (RACT)
  Johnson and Wyandotte counties
• Issued when counties exceed federal ozone
  standard restrictions remain in place
• Auto and light-duty truck surface coating
• Bulk gasoline terminals
• Petroleum refineries
• Printers
• Misc. metal parts coating

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Jo Wy County Requirements

• Cleaning/degreasing solvents
• Commercial bakeries
• Gasoline volatility

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Kansas City Landmarks
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Kansas City Good Ozone Day
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Kansas City Bad Ozone Day
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Possible Controls

• Phased reduction in NOx emissions
• Sources with actual emissions gt1,000 tpy
• Sources with actual emissions gt100 tpy

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Summary

• Calculate PTE
• Identify emission sources
• Decide how to limit emissions
• Apply for a permit if needed
• NESHAP/MACT
• Kansas City requirements