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Air Pollution Source Permitting. For Boat Manufacturers The Boat Manufacturing MACT an EPA Workshop February 8, 2002 IBEX conference Ft. Lauderdale Convention Center. Nationwide Permitting…. A Boat Manufacturing facility that is subject to the NESHAP standard 40 CFR 63 Subpart VVVV
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Air Pollution Source Permitting For Boat Manufacturers The Boat Manufacturing MACT an EPA Workshop February 8, 2002 IBEX conference Ft. Lauderdale Convention Center
Nationwide Permitting… A Boat Manufacturing facility that is subject to the NESHAP standard 40 CFR 63 Subpart VVVV • is a major source of hazardous air pollutants (HAPs) • and should already have a Title V (Part 70) Permit. However, at this point in time, unless it is also a major source of volatile organic compounds (VOCs) there may not be much more than recordkeeping requirements in the permit.
Nationwide Permitting (cont’d)… • Reopening of the Title V Permit for Cause when additional requirements become applicable. • Title V permits with expiration dates of August 22, 2004 or later, must be reopened and significantly modified by February 22, 2003 to include the NESHAP requirements.
Nationwide Permitting (cont’d)… • Reopening of the Title V Permit for Cause when additional requirements become applicable (cont’d)… • Proceedings to reopen and reissue a permit • shall follow the same procedures as apply to initial permit issuance, and • shall affect only those parts of the permit for which cause to reopen exists.
Nationwide permitting (cont’d)… • In order to escape complying with the NEHSAP regulations, an existing facility that is currently a major facility has until the compliance date of the NESHAP (August 23, 2004) to become permitted as a non-major (area) source. • If a facility uses the material consumption option described in Sec. 63.5686(b) to demonstrate that it is not a major source, the facility must start keeping records no later than August 23, 2003.
Florida Permitting for Area Source Boat Manufacturers • Permitting Options • Federally Enforceable State Operation Permit (FESOP) • Air Construction / Air Operation Permits • Non-Title V General Permit • Exemption
Florida Permitting for Area Source Boat Manufacturers(cont’d) • Permitting Options (cont’d) • Federally Enforceable State Operation Permit (FESOP) • Good choice for a facility that is currently a major source and wants to become an area source • Good choice for an existing area source that has never had an air construction permit and can not qualify for a General Permit.
Florida Permitting for Area Source Boat Manufacturers(cont’d) • Permitting Options (cont’d) • Air Construction / Air Operation Permits • Good for a new area source facility thatcan not qualify for a General Permit.
Florida Permitting for Area Source Boat Manufacturers(cont’d) • Permitting Options (cont’d) • Non-Title V General Permit (GP) for “Polyester Resin Plastic Products Fabrication” • Good for most area sources. • Gap in material consumption applicability criteria for General Permit and applicability of NESHAP. • GP limit: 38 tons per year (tpy) • NESHAP limit: less than 50 tpy
Florida Permitting for Area Source Boat Manufacturers(cont’d) • Permit Exemption (No Permit Required) • Generic Facility Exemption if the facility emits or has the potential to emit … • Less than 1 tpy of any hazardous air pollutant; • Less than 2.5 tpy of total hazardous air pollutants; • Less than 25 tpy of CO, NOX, and SO2; • Less than 1000 pounds per year of lead; and • Less than 10 tpy of any other regulated pollutant [example: Volatile Organic Compounds (VOCs)] …and there are no unit-specific applicable requirements.
For further information call…
Florida Permitting Authorities District Air ProgramsPhone # West Palm Beach 561-681-6600 Ft. Myers 941-332-6975 Orlando 407-894-7555 Tampa 813-744-6100 Jacksonville 904-807-3300 Pensacola 850-595-8300
Florida Permitting Authorities(cont’d) Local Air ProgramsPhone # Broward County 954-519-1220 Dade County 305-372-6925 Palm Beach County 561-355-3070 City of Jacksonville 904-630-4900 Orange County 407-836-1447 Hillsborough County 813-272-5530 Sarasota County 941-378-6128