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Air Permitting Biomass Combustion Units
1. Air Permitting Biomass Combustion Units Penn State University Biomass Combustion Conference Short Course Series 2010 April 20, 2010 John Slade, ALL4INC [email_address] 717-822-0009
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18. Major Source Emission Increase Pollutants Precursors Attainment Classification Major Source Threshold (tons per year) Significant Emission Increase (tons per year) NOx, SO 2 , Lead NA PSD General 100/250 As applicable Ozone VOC/NOX NNSR outside of Philadelphia 5-County Area 50/100 40 Ozone VOC/NOX NNSR Severe-Philadelphia 25 25 PM 2.5 NA PSD/NNSR 100 10 PM 2.5 NO X PSD/NNSR 100 40 PM 2.5 SO X PSD/NNSR 100 40 PM 10 NA PSD/NNSR 100 15
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Notas del editor
Use Glatfelter example – steam turbine.
Here are some examples of common air emission sources:
JFS please edit this
Here are few common misconceptions that we run across all the time at ALL4 when facilities get into trouble for not having the proper air permits. Size does not matter: It doesn’t matter how many employees you have or how often you actually run an operations, you need to pay attention to the local air rules and your process’ potential to emit regulated pollutants. Vendors want to make a sale and the odds that they are conversant in your state’s air pollution regulations are pretty small. Even the agency person may not be correct – CT example. You may need more than one permit. Depending on when units were installed, it’s common for facilities to have several air permits.
The first step in figuring out if you need an air permit is to understand what types of operations generate and emit air pollution. Here are some simple rules of thumb for determining if equipment at your facility might need an air permit. Does the unit have a stack, vent, or dust collector that vents to the outside? Does your process use paints, solvents, inks, adhesives, or other raw materials that contain organic compounds or VOC? Does your process burn fuel? Does your process generate fumes, dust, smoke, or odors? If you answered yes to any of the above, it’s a good sign that the equipment may need an air permit.
It is also important to understand that you may need more than one type of permit for your facility. Permit to install is typically required before you can install new equipment or modify your existing equipment. Permit to operate is usually required once installation or modification is completed. We’ll talk a little bit more about these permit types later on in the presentation.
What is ACHD???
How do I know if my project will need an air permit? Here are some examples of projects that would require a permit: Method of operation refers to the way in which you operate a process. So, for example, if you have a coating operation that applies coatings that are water-based, and you want to change the coating type to solvent based, even though you may not require any physical changes, you are however changing the way you are operating and it may require permitting.
The first step in understanding whether or not a planned project will trigger permitting is to as yourself these questions:
Debottlenecking?
The next thing you should do is pick up the air permitting regulations for your State and find the exempt activity list. This is a codified list of activities that the state has determined do not need an air permit.
When you begin looking for federal rules, a great place to start are the new source performance standards or NSPS. These rules regulate specific operations installed or modified after a certain date, and meeting specific size requirements. There is a size requirement and an age requirement. Two that come to mind that might apply to some of your facilities….
The next thing you want to look at are MACT standards. Remember, these only apply to major sources of HAP which would be any facility with the PTE > 10tpy single HAP or >25 tpy all HAP combined. Again, two examples of MACT standards that may apply to your facilities would be the boiler MACT and the Brick MACT.
Level of detail required for one of these control analyses can vary from state-to-state, and can even vary between the local district offices in your state. The worst case type of analysis would be a so-called “top-down” analysis. This type of analysis requires you to determine all control technologies available, determine which ones are technically feasible, rank all of the feasible technologies according to the effectiveness, and then evaluate each one based on costs on a dollars per ton of pollutant removed basis. Of course, if you select the most stringent control technology, there is no need to perform any cost analyses.
After you’ve taken a look at the regulations that might apply to your project, you need to determine the potential to emit rates for all regulated pollutants that could potentially be emitted from your operation.
Calculating the PTE rates is also important because you need to determine if there are any pollutants not previously emitted by the operations that will be emitted after the changes to your facility. Also need to look for any increases or decreases in emissions of pollutants already emitted
So what are some ways to calculate the Potential to emit?
Something else you need to be aware of when preparing an application is that some states are now requiring dispersion modeling for air toxics compounds. There are two types of modeling; they are screen modeling and refined modeling.
Also need to be aware that delays in issuing your permit can occur.
Everyone wants to know…what activities can I begin prior to receiving my permit?
After construction and startup are completed, you are going to have to obtain an operating permit.
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