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Air Quality To Permit or Not to Permit?. Vickie Walsh Montana Department of Environmental Quality Biomass Workgroup March 23, 2010. Today’s Questions. Do wood grinders need air quality permits? What is the Department talking about? Are these new regulations on this source type?
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Air QualityTo Permit or Not to Permit? Vickie Walsh Montana Department of Environmental Quality Biomass Workgroup March 23, 2010
Today’s Questions • Do wood grinders need air quality permits? • What is the Department talking about? • Are these new regulations on this source type? • Do we need a new permit every time we move or even every year? • What fees associated with permitting actions?
Air Quality Information • Overview of Air Quality Requirements • Overview of Air Quality Permitting • Who Needs an Air Quality Permit? • Path Forward
Overview of Regulation • Statutory Authority • Montana Clean Air Act • Montana Code Annotated (Title 75, Chapter 2) • Federal Clean Air Act • Rules • Administrative Rules of Montana (ARM) • Code of Federal Regulations (CFR)
Air Pollutants • Particulate Matter (PM) (<10µg/m3, <2.5µg/m3 ) • Carbon Monoxide (CO) • Sulfur Dioxide (SO2) • Oxides of Nitrogen (NOx) • Volatile Organic Compounds (VOCs) • Lead (Pb) • Miscellaneous (Mercury (Hg), Hazardous Air Pollutants (HAPs))
Montana Air Quality Permitting Programs Minor Source Permit Program Major Source Permit Program Title V Operating Permit Program Open Burning Permit Program Air Quality Permitting
Air Quality Permit Process • Submit an application and application fee • Montana Air Quality Permits are issued with NO expiration date • Public Notice requirements • At the time of application • Based on location
Air Quality Permit Timelines • Air Quality Permit Time Frames • Application Completeness Review (day 30) • Preliminary Determination (day 40) • Department Decision (day 60) • Final Permit Issued (day 75)
Who Needs a MAQP? • Minor Source • Potential To Emit > 25 tons per year (tpy) of any one regulated pollutant • NSR/Prevention of Significant Deterioration (PSD) • PTE > 250/100 tpy regulated pollutant • NSR/Non-Attainment Area (NAA) • Major sources - 100 tpy
Requirements of Air Quality Permits • Conditions • Established to Protect National and Montana Ambient Air Quality Standards • Established by Rule • Established to protect analysis in the application • Established from Best Available Control Technology (BACT) Analysis and air quality model
MEPA • Montana Environmental Policy Act (MEPA) • Environmental Assessments (EA) and/or Environmental Impact Statements (EIS) are prepared • Departmental actions require compliance with MEPA
Industry Types • Oil and Gas • Pulp and Paper • Sand and Gravel • Manufacturing • Wood Products • Mining • Crematoriums
Wood Grinders • Emissions – PM from the grinding and NOx and CO from combustion source • Credit for new technology • Determine need for a permit (potential to emit)
Path Forward • Education on the Department’s part to learn more about industry operations. • Sub-group creation and discussions • Provide options and guidance to the industry • Develop path forward • Implement any action Items
Thank You • Vickie Walsh • Montana Department of Environmental Quality • Air Resources Management Bureau • Air Permitting Supervisor • 406-444-9741 • 406-431-1192 (cell) • Fax 406-444-1499 Additional web links Department of Environmental Quality Air Quality Information/Air Resources Management Bureau Air Quality Rules (Administrative Rule of Montana) Air Quality Statutes (Montana Code Annotated)