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Michigan State University Air Seminar - Lecture 6

Michigan State University Air Seminar - Lecture 6. Air Permitting and Testing April 26, 2005. Jeff Pfost Environmental Partners, Inc. Holland, Michigan. Introduction & Background. Graduate of Western Michigan University Post Graduate Studies MSU – Hazardous Material Training

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Michigan State University Air Seminar - Lecture 6

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  1. Michigan State UniversityAir Seminar - Lecture 6 Air Permitting and Testing April 26, 2005 Jeff Pfost Environmental Partners, Inc. Holland, Michigan

  2. Introduction & Background • Graduate of Western Michigan University • Post Graduate Studies • MSU – Hazardous Material Training • UW-Madison – Industrial Ventilation • UW-Madison – Certified Hazardous Waste Operations and Emergency Response Trainer • MIT – Environmental Negotiations • Certified Storm Water Operations - Industrial

  3. Introduction & Background • Internship – Surveying / Engineering/ Consulting Firm • National Council for Air & Stream Improvement (NCASI) – Pulp & Paper Ind. • Partner & Co-owner Dell Engineering, Holland, Michigan • Equity Partner – Environmental Resources Management • Partner & Co-owner- Environmental Partners, Inc. Holland, Michigan

  4. Introduction & Background • Air Compliance Consulting • Litigation Support and Expert Witness • General Environmental Compliance Assistance • Active Trade Association Member • Michigan Manufacturers Association • Air & Waste Management Association • Various West Michigan Chambers of Commerce

  5. Lecture 6 • Attainment versus Non-Attainment • Air Permitting • Construction / Installation • Operating Air Permits • State • Federal • Atmospheric & Emission Source Testing • Ambient • Stationary • Mobile

  6. Discussion Topic #1The National Ambient Air Quality Standard (NAAQS) Attainment versus Non-Attainment

  7. NAAQS • The Clean Air Act • Requirement for U.S.EPA to establish air quality criterion (Values) – Standards • Requirement for U.S.EPA to perform AMBIENT AIR MONITORING - Evaluation • Requirement for U.S.EPA to promulgate rules to ACHIEVE & MAINTAIN

  8. Section 108 • Identify Pollutants that May Endanger Health & Welfare • Issue Criterion that Reflect the Latest Scientific Knowledge Regarding Effects

  9. Section 109 • Establish the National Ambient Air Quality Standard (NAAQS) • “The Attainment and Maintenance are requisite to protect public health” with • “An adequate margin of safety”

  10. 6 Criteria Pollutants • Carbon Monoxide (CO) • Lead (Pb) • Oxides of Nitrogen (NOx) • Ozone (O3) • Oxides of Sulfur (SOx) • Particulate Matter (PM) • Total Suspended Particulate (TSP) • PM10 • PM2.5

  11. Establishment of the Standard • Primary • Established to protect Public Health • Most Restrictive • Hardest to Achieve • Secondary • Established to protect Welfare • More Liberal • Easier to Achieve

  12. GRAY

  13. Protection of Public Health Absolutes = Gray 120 Units

  14. NAAQS Values • CO • Primary Standard • 8 – Hour = 9 ppm • 1 – Hour = 35 ppm • Secondary – None • Pb • Primary Standard = 1.5 µg/m3 • Secondary – same as Primary

  15. NAAQS Values • NOx • Primary Standard – 0.053 ppm • Secondary – same as Primary • Ozone • Primary • 1 Hr – 0.12 ppm • 8 Hr – 0.08 ppm - NEW! • Secondary – same as Primary

  16. NAAQS Values • PM10 • Primary Standard • Annual – 50 µg / m3 • 24 Hour – 150 µg / m3 • Secondary – same as Primary • PM2.5 – NEW! • Primary Standard • Annual – 15 µg / m3 • 24 Hour - 65 µg / m3 • Secondary – same as Primary

  17. NAAQS Values • SOx • Primary Standard • Annual – 0.03 ppm • 24 Hour – 0.14 ppm • Secondary Standard • 3 hour – 0.5 ppm

  18. Particulate Matter 2.5

  19. Discussion Topic #2Air Permitting Stationary Source Construction and Operation Federal and State

  20. New Source Review Permits • Provides Permission & Conditions Acceptable for Building a Source of Air Pollution • Also Known As • Construction Permits • Permits to Install (PTI) • NSR Permits • Installation Permits • Permit Issued Before Building or Installing Source • Air Pollution Control Equipment - Likely Required

  21. New Source Review Permits • Typically submitted to a State Agency, Depending on the State’s Choice to Assume Responsibility for the Permitting Program, and EPA’s Approval of the Program (Implementation Planning) • Usually the Permit is State Issued • Typically a High Level of Technical Effort • Very Process & Equipment Dependent

  22. New Source Review Permits • Must Demonstrate Compliance • With Existing Rules and Requirements • Can not Adversely Impact NAAQS • Can not Cause Harm from Proposed Emission Types or Emission Rates Proposed • Evaluate Control Options and Feasibility • Evaluate Alternate Materials and Lower Emitting Technologies • May Require Public Notice

  23. New Source Review Permits • Generally regulated at the Federal Level in 40 CFR Part 60 – New Source Performance Standards (NSPS) • May Also be Regulated under the Toxic Emissions Standards found in 40 CFR Part 63 - National Emission Standards for Hazardous Air Pollutants (NESHAP) • State by State Requirements – Vary widely

  24. Operating Permits • After Construction – Provides Permission to Operate the Source of Air Pollution • State Typically Issues Operating Permits • Could be a Combination of a State and Federal Permit • Tend to be More Regulatory Intensive In Place of Technically/Process Oriented

  25. Operating Permits • Clean Air Act Amendments of 1990 & the Title V Program • Attempt to Simplify Air Permits • Combine a Source (site) Requirements into a Single Air Permit – The 1 Permit Approach – Applicable Requirements • Concise Monitoring Terms • Self Reporting Provisions – Compliance Certification

  26. Discussion Topic #3Air Monitoring & Testing Ambient Air Monitoring Mobile Source Testing Stationary Source Testing

  27. Air Monitoring & Testing • Ambient Air Monitoring – NAAQS • Mobile Source Testing – Cars & Trucks • Stationary Source Testing – Power Plants

  28. Monitoring for NAAQS • Monitoring is Conducted at Stationary Sampling Sites Called a Monitoring Network • Not all Stations Monitor All Criteria Pollutants • Data is Collected and Quality Assured • Compliance is Determined by Comparing the QA Data to the NAAQS - Annually

  29. Ambient Air Monitoring“Permanent” Site Monitoring • Performed to Determine/Confirm the Localized Ambient Air Conditions • Typically Monitored for NAAQS Parameters • Can/Will Monitor for Various Parameters at Various Locations • Generally Combined with a Weather Monitoring Station (Meteorological Station) • Michigan has 41 Dedicated Monitoring Sites in their Monitoring Network

  30. Ambient Air Monitoring“Temporary” Site Monitoring • Agency Sited Monitoring Stations – to address localized activities and source impacts • Site (private) Located Stations – to address regulated activities, such as PSD permitting • Agency Deployed Mobile Stations – to address atmospheric events and specialized studies undertaken by the agency (atmospheric research related to regulatory response issues)

  31. Mobile Source Testing • Testing Methodology • Tailpipe and Remote Testing • Dynamometer Testing • Performance of the Engine and Control Equipment • Level of Tune – Air to Fuel, Ignition System, Etc. • Engine Wear – Oil Consumption • Tune or Repair as Necessary • On-Board Diagnostics • Roughly 1998 and Newer Vehicles • “Tested” at the Dealership – Readings Collected • Tune or Repair as Necessary

  32. Stationary Source Testing • Typically Conducted to Determine a Sources Emissions to the Environment/Atmosphere • May Include the a Determination of the Performance of a Pollution Control Device • Most Commonly Conducted by Specialty Testing Firm, at the Expense of the Source • Can be Either Voluntary or Mandatory • Event Based (Stack Test) or Dedicated/Continuous Monitor (CEMs)

  33. Stationary Source Testing • Most Often the Testing has Regulatory Implications • Permit Limits • Rule Restrictions • Applicability to a Specific Section of the CAA • Most Often use Techniques Published and Promulgated by U.S.EPA • Most Frequently Used Methods • 40 CFR Part 60, Appendix A & Appendix B

  34. Stationary Source Testing • Examples of U.S.EPA Methods • Method 1 – Sample and Velocity Traverses • Method 2 –Stack Gas Velocity and Flow Rate • Method 3 – Stack Gas Dry Molecular Weight • Method 4 – Stack Gas Moisture • Method 5 – Stack Particulate Concentration • Method 18 – Gaseous Organic Emissions (GC) • Method 25A- Total Organic Emissions (FID) • Method 26- Hydrogen Halide & Halogens

  35. Source Testing • Should be Preceded by an Approvable Test Plan • Single or Multiple Events (Average of 3 Runs) • Ideally Linked to: • Allowed Emission Rate • Production Rate • Production Event or Activity • Should be Followed by an Approvable Test Report

  36. Source Testing • Methods: • Collection of Stack Data • Collect Emission Parameters • Quantify in Field, and/or • Quantify in Field Laboratory, and/or • Collect and Transport to a Laboratory • Example/Photos

  37. Conclusion and Wrap-up • Air Practice is Wide Open • Can be: • Very Technical • Heavily Regulatory Based • Very Litigious • Rewarding • Overwhelming

  38. Questions? Jeff Pfost Environmental Partners, Inc. 616-928-9129 direct jeff.pfost@enviro-partners.com

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