Optimizing Compliance Strategy for Title V Permit Issuance: A Case Study

1. Using a Flexible Compliance Strategy to Issue a Title V Operation Permit Steven Klafka, PE, DEE Wingra Engineering, S.C. A&WMA Conference 2002 Wingra Engineering, S.C.

2. Case Study • Title V experience of a WI iron foundry. • Some processes grandfathered and subject to lenient limitations. (i.e. Allowable PM = 17.31P0.16) • Use of roof vents and short stacks. • Compliance with air quality standards via dispersion modeling never evaluated. Wingra Engineering, S.C.

3. Challenge • Application initially submitted in 1994. • Agency modeling evaluation in 1999 predicted air quality standard violations. • Initial emission estimates showed potential emission limit exceedences. • Title V permit could not be issued. • Compliance strategy needed. Wingra Engineering, S.C.

4. Initial Agency Modeling Results Wingra Engineering, S.C.

5. Development of Compliance Strategy • Update 1994 inventory of stacks, vents, control equipment and processes. • Improve emission estimates from published data or stack tests. • Assure compliance with emission limitations. • Assure compliance with air quality standards by internal dispersion modeling analysis. Wingra Engineering, S.C.

6. Review Facility Inventory • Facility expanded since 1994. • Updated process and stack inventoryto reflect current configuration --- • 112 roof vents or stacks • 32 processes • 83 buildings or structures Wingra Engineering, S.C.

7. Existing Foundry Layout Wingra Engineering, S.C.

8. Review Emission Estimates • Verify raw materials & production capacities. • Update emission estimates using test results. • Iron pouring operations exceeded PM limits. • Uncontrolled emissions exhausted thru roof vents. • Flagged for either testing or add-on controls. Wingra Engineering, S.C.

9. Review Air Quality Standards Analysis • Dispersion modeling analysis using ISC3 • National Ambient Air Quality Standards • Acceptable Air Concentrations for air toxics • Verify modeling by state agency. • Update stack and emission inventory. • Begin new internal modeling analysis. Wingra Engineering, S.C.

10. New PM Modeling Evaluation • Evaluate PM first, then other pollutants. • Agency PM results = 600 > 150 ug/m3 • New PM results = 2,519 > 150 ug/m3 • Identify culpable vents and stacks. • Improve largest contributors to high PM concentrations. Wingra Engineering, S.C.

11. PM Compliance Improvements • Incorporate new baghouse controls as needed to comply with state or anticipated MACT emission limitations for PM at 0.005 gr/acf. • Consolidate roof vents into stacks. • Raise stacks heights incrementally. • Repeat until facility complies with NAAQS. Wingra Engineering, S.C.

12. Incremental Improvements via ISC3 Analysis Wingra Engineering, S.C.

13. Other Air Pollutants • After PM compliance strategy finalized, other air pollutants evaluated for compliance with NAAQS and AAC. • No additional changes necessary for other air pollutants to comply. Wingra Engineering, S.C.

14. Title V Application Amendment • Original 1994 application amended with updated inventory, modeling analysis, and compliance strategy. • Compliance strategy includes vent consolidation into stacks, stack height increases, baghouse installation, and imposition of emission limitations. • Strategy referred to as Scenario #1. Wingra Engineering, S.C.

15. Issuance of a Flexible Permit • Scenario #1 not specified in Title V permit • Demonstrates one feasible compliance alternative. • “X” lbs/hr PM emission limits for 22 processes. • Serve as placeholders for final compliance plan. • Compliance schedule included in Title V permit. • Ten month deadline for compliance plan with final improvements and limitations. • Deadlines for 50% and 100% completion. • Deadline for compliance testing. Wingra Engineering, S.C.

16. Compliance Plan Development • Title V permit issued in 2000. • Initiate development of new compliance strategy. • Identify processes requiring controls to comply with state and MACT limitations for PM. • Initiate new round of air quality modeling. • More time taken to evaluate compliance options. • New strategy required fewer changes than Scenario #1. • Submit compliance plan in 2001. Wingra Engineering, S.C.

17. Final Compliance Plan • Vents & stacks reduced from 112 to 51. • 5 new baghouses proposed with total capacity of 400,000 acfm. • 22 new PM limitations established to replace “X” lbs/hr limits. • Total capital investment $7.2 million over three years. Wingra Engineering, S.C.

18. Final Facility Layout Wingra Engineering, S.C.

19. Operation Permit Revision • Agency will incorporate final compliance strategy as significant revision to permit. • All revisions incorporated during renewal every five years. • If necessary, additional facility changes will be incorporated during permit renewal. Wingra Engineering, S.C.

20. Summary • Original Title V permit application could not be issued due to potential emission limitation and air quality standard violations. • Viable compliance strategy developed to allow issuance of initial Title V permit. • Title V permit included placeholder “X lbs/hr” limitations and compliance plan schedule. • Flexible approach allowed issuance of Title V permit and time for development of a cost-effective compliance strategy. Wingra Engineering, S.C.