Title V Operating Permit Program Clean Air Act CAA

Control technology

"Control Technology" is not just limited to technology, but also encompasses the processes, methods, systems, and techniques that are used in facilities to reduce their HAP emissions. Under MACT standards, the technology and work practices in facilities that produce the lowest HAP emissions are used to set the standards for the rest of the industry.

Define Major Source threshold for HAP

A major source is defined as any emission point that emits at least 10 tons of any particular HAP per year, or more than 25 tons of any combination of HAPs per year. Title V Air also applies if your sources emit more than 50 tons per year of VOCs or Nitrogen Oxides.

Major Source of HAPs is defined as

A major source of HAPs is defined as any stationary source (or group of stationary sources) that emits at least 10 tons of any single HAP or 25 tons of multiple HAPs.

Pollution control dust collector technology selection

ACGIH Industrial Ventilation Manual

Title IV

Acid Rain program

Environmental lapse rate (Ambient)

Ambient Temperature change rate in elevation Average -.65 degrees C / 100m

Surface inversion (thermal inversion)

Ambient rate is different from the adiabatic rate, so when the ambient rate is hotter at higher levels, it creates a ceiling where the pollutants can't disperse.

Adverse environment effect could be

An adverse environmental effect could be any significant or widespread impact on human health, natural resources, or wildlife.

BDAT

Best Developed Available Technology refers to what ever technology is out there that is being used and proved to be effective.

NSR

Facilities subject to major New Source Review (NSR)

Method of demonstrating Compliance

Calculating your average emissions with MACT model point value equations (one method of demonstrating compliance) is no small task. A facility can otherwise show compliance by: Using only HAPs complaint materials and being able to prove this change through reports Installing and utilizing control equipment, like filters, in the facility.

Ozone depletion

Caused by chlorinated hydrofluorocarbons, CFC, HCFCs Halon (trade name) Freon (trade name) When they go into the atomosphere - stratospshere Ozone filters UV Light so it protects us against skin cancer

Cyclone

Centrifugal force Particles spin until the heavier drop out and the lighter exhaust out Pressure drop 3-6 in water gage Require large space No temperature restrictions Particle sizes > 10 microns Not very efficient Use prior to baghouse to remove larger particles. Reduces wear on baghouse bags.

CAA

Clean Air Act designed to protect air quality to support public health makes it your responsibility to take the necessary actions to ensure your business isn't have an adverse environmental effect on the local air quality. The United States Clean Air Act legally mandated that the EPA regulate the emission of hazardous air pollutants (HAPs) by industrial sources. To accomplish this mandate, the EPA developed MACT - Maximum Achievable Control Technology - standards. MACT standards use the HAP emissions of the best-performing (thus, "Maximum Achievable") industry sources to set the "MACT floor", the new minimum standard that an industry must at least meet in order to comply.

Greenhouse Effect caused by

Combustion of Carbon = CO2

CEMS acronym? used when?

Continuous Emissions Monitoring Systems Used when They could require you to monitor your air emissions from certain major source every hour or even every minute. In order to do this you'll need to implement some sort of Continuous Emissions Monitoring System (CEMS).

Air Quality permits require these types of monitoring

Continuous emission monitoring system Opacity Measurements Stack Testing - Isokinetic sampling

What do you need to do once you have your permit

Demonstrate compliance with the permit conditions by: reporting your air emissions, including HAPs and VOCs, every year to your regulators. Any deviations in your operations or air emissions will need to be accurately accounted for and reported to your regulators, including the time it occurred, why it occurred, how long it lasted, and what corrective actions you took.

Collection Efficiency

Efficiency = Mass removal / mass entered x 100

ESP

Electrostatic Precipitator Charges wires or plates in the system with negative charges. Then the particles come in as a positive charge they get drawn to the plate or wire and collected. Then it is shaken off. Electrostatic attraction • Pressure drop 0.5 in. water gauge (very little making it more efficient than baghouses) • Generally require large space • Temperature restrictions - none • Particle Sizes > 0.25 microns • Used by power plants

What else goes into Title V Permits

Emission Limits, Operational Restrictions, Work Practice Standards Monitoring and Testing Recordkeeping and Reporting Any Compliance Schedules

What is Title V Operating Permit Program

Established by the Clean Air Act Amendments of 1990 One source - One Title V Permit Permit expires after 5 years Title V pays for itself - Permit fees

How often do you need to renew your permit

Every 5 years

Baghouses

Filtration - Most common form of pollution control Captures particle sizes >0.25 microns Cleaning Shaking Pulsing (Reverse blowing) (noisy) Limitations • Pressure drop 3 - 6 in. water gauge (increase energy requirements) • Generally require large space • Temperature restrictions • Cotton 180ºF • Nylon 225ºF • Nomex 400ºF • Teflon 500ºF • Fiberglass 550ºF

Global Warming from

Greenhouse gasses CO2 from Combustion of Carbon

HAP

Hazardous Air Pollutant

Looping instability

Pollutants effected by environmental instability in the air

PTE

Potential to Emit (thresholds for regulated pollutants)

Secondary Pollutants

Interaction that makes it change from primary Ozone from Hydrocarbons Nitrigon DiOxide combines with Hydrocarbons to create changes in the Ozone - Need to update this Sulfur Dioxide combines with water in clouds to form Sulfuric Acid or Acid Rain

Condenser

Like a parts washer vat... Warm vapor moves through the ductwork bringing it in contact with cooling coils. The coils cool the vapor and then it recondenses and goes back into the system where the air is now clean and can be exhausted

absorber

Liquid causes a chemical reaction (bubbly) • Gases counter to flow of liquid • Similar to scrubber • Gases and vapors absorbed into liquid • Liquid must be good solvent for gases and vapors • Liquid is recycled

MST

Major Source Threshold

Who needs a Title V Permit

Major Sources - any stationary source that exceeds potential-to-emit (PTE) thresholds = for regulated pollutants. Facilities subject to (regardless of size): - New Source Performance Standards (NSPS) - National Emission Standards for Hazardous Air Pollutants (NESHAPs) aka - Maximum Achievable Control Technology (MACT) Standards Facilities subject to major New Source Review (NSR) including Prevention of Significant Deterioration (PSD) Sources subject to the Title IV Acid Rain program. Any solid waste incinerator that is subject to Section 129(e) of the CAA. These incinerators have the capacity to burn more than 35 Mg per day of residential or commercial waste. Your sources emit more than 100,000 Carbon dioxide equivalent tons of greenhouse gases per year.

MACT

Maximum Achievable Control Technology (MACT) standards MACT standards use the HAP emissions of the best-performing (thus, "Maximum Achievable") industry sources to set the "MACT floor", the new minimum standard that an industry must at least meet in order to comply.

Air Pollution

Presence of solids, liquids or gases in outdoor air in amounts that are injurious or detrimental to man, animals, plants, or property, or unreasonably interfere with the comfortable enjoyment of life and property

Pollution control

Prevention Dispersion (dilution) Collection and disposal Chemical Change (combustion)

PSD

Prevention of Significant Deterioration (PSD) Requirement placed on industries to control your pollutant to the extent it doesn't cause deterioration in health or plant life

Who does not need a Title V permit

Minor sources Natural Minors Synthetic Minors Exempted Areas Sources under Section 112 MACT standards (such as dry cleaners) ------ There is some flexibility in the CAA that could mean your business isn't required to have a Title V Air Permit. Check to see if any of these conditions apply: Your facility has a lower potential to emit (PTE) regulated air emissions than the MST or other Title V emission limits. You agree to artificially limit your potential emissions through an enforceable permit condition. This would apply if your PTE is higher than the MST but you agree to operate at a lower production capacity. You have accurately reported actual air emissions of HAPs and VOCs below 50% of applicable Title V air emission thresholds, demonstrating that despite your PTE your real-world operations would not put you at risk for breaking Title V emission thresholds.

NESHAP aka

NESHAP aka MACT

NESHAP

National Emission Standards for Hazardous Air Pollutants Industry-specific NESHAPs outline how each industry must comply with EPA regulations Since every industry uses different technology and produces different HAPs, there are additional industry-specific standards, known as National Emission Standards for Hazardous Air Pollutants, or NESHAPs. These specific NESHAPs apply to all major air emission sources in every industry, though every industry has a different standard. The NESHAPs are based on the MACT approach of setting regulations, with the goal of reducing these HAP air emissions and protecting public health while still being achievable and encouraging industrial development.

NSPS

New Source Performance Standards

Adsorber

Non particle type pollutants such as gases and vapors. Ex: VOC moledularly connecting to the activated carbon or charcoal media. Clean with heat • Vapors and gases adsorbed on surface of porous medium • Does not work at high temperatures

Effective way to capture particulates

Particulate maters can be caught in a bag house. The socks filter out the particles before coming

Velocity test in a stack requires pitot tube placements:

Pitot tube placement Needs to be placed 7 duct diameters downstream of any obstruction. ex: 1 foot duct diameter would require 7 feet downstream from the elbow or y in the line Needs to be placed 3 duct diameters upstream of any obstruction ex 1 foot duct diameter would require 3 feet upstream from the elbow or y in the line

Regulated Pollutant Thresholds

Regulated Pollutant Thresholds - Criteria Pollutants: >100 tpy PTE - HAPs: >10 tpy (1 HAP) or >25 tpy (HAPs)

SIPs

SIPs are required under Title I of the CAA and must stand complete on their own. Title V permits "house" existing SIP requirements (and all other applicable federal and state requirements). SIP requirements cannot be open-ended with the "details" to be set in the Title V permit.

Acid Rain

Sulfur Dioxide Coal Combustion Sulfur + rain = sulfuric acid Destroys vegetation, water habitat, structures

Primary Pollutants

Sulfur Oxide Particulates VOC

Adiabatic lapse rate

Temp change rate in elevation with no heat exchange for dry air. Sunlight would give you Only relates to changes in pressure. As air temp goes down. Heat change is only caused by the rising and falling of heat changes associated with pressure on the air.

Who is Title V Permitting Authority

The CAA envisioned that State and Local air pollution agencies would issue Title V permits. States become the Title V permitting authority upon final approval by EPA of its Title V Program consisting of regulations to satisfy 40CFR Part 70. Until that happens, EPA is the permitting authority under 40 CFR Part 71.

Scrubber

Scrubber Liquid spray such as water that sprays down through the air flow (perpendicular) it will entrain the particulates that go through a cyclone that through centrifugal force will drop the particles down. Inertial impingement Particles > 5 micron

Isokinetic sampling - Isokinetic mode

Stack testing Flow of the sampler must match the flow of the air in the stack.

Benefit to company?

Though there is an initial investment in complying with these air emissions regulations, becoming more efficient has actually seen some facilities reduce their overall operating costs over a short period of time.

What goes into a Title V Permit?

Title 1 Nonattainment Title III air toxics Title IV Acid Rain Title VII Enforcement State Permit programs Existing SIP requirements Applicable Requirements - SIP Requirements - Major NSR/PSD Permits - Other Federally Enforceable Permits - NSPS and 111(d) Plans - NESHAPs/MACT- 40 CFR Parts 61 and 63 - Acid Rain Permits (Title IV) - Stratospheric Ozone (Title VI) - Other

US Legal requirements combined under one program and now requires public reviews. Review every 5 years

Title V Permits

Preconstruction permits differ

Title V does not establish any new Federal requirements for a facility. Preconstruction permits are required for most new facilities or new/modified units at existing facilities. Title V permits will contain most preconstruction permit conditions.

venturi scrubber

Variation is scrubber has a restriction in the airflow allows for capturing smaller particle sizes Venturi Scrubber • Inertial impingement • Centrifugal force • Particles > 1 μm • High energy costs

Benefits of Title V

uniform and comprehensive permit system that implements the Clean Air Act. Improved compliance due to consolidation of requirements Improved implementation

Settling Chamber

• Oldest method of mechanical collection Airflow velocity is high and enter a larger area the velocity is lowered allowing the particles to drop before the airflow goes into the narrower exit duct. • Good for Low flow • Good for Uniform flow • Low efficiency • Chip type material