Air Quality Permitting and Compliance

1. Air Quality Permitting and Compliance

2. Contact Information Tim Plander Phone #: 402-458-5919 E-mail: tplander@oaconsulting.com Bill Imig Phone #: 402-458-5903 E-mail: bimig@oaconsulting.com

3. Air Quality Construction Permits • What are they? • How do they affect my facility? • Required before “construction”

4. “Construction” • Physical on site construction or installation, • Contract to purchase or install equipment and/or • Purchase of equipment

5. Major vs. Minor Construction Permits • Major = Prevention of Significant Deterioration (PSD) regulations • Minor = Potential emissions less than PSD thresholds • Valmont goal: to remain minor source status

6. Potential to Emit • PTE = Potential to emit • PTE is calculated based on 8760 hours of operation per year (full operation) • PTE > thresholds trigger construction permit requirement

7. Particulate Matter (PM10) • PM10 = particulate matter ten micrometers in diameter or less • Most prevalent activities that emit particulate emissions at Valmont facilities: • Drilling, cutting and welding • Combustion (i.e., ovens and engines)

8. Construction Permit Triggers • PTE emissions exceed thresholds • PTE thresholds vary by state (i.e., 15 tons/yr PM10) • National Emission Standards for Hazardous Air Pollutants (NESHAP) – i.e., Kansas

9. Construction Permit Application Paperwork involving: • Facility description • Historic permitting activity • Process flow diagrams • Air emission estimates • Forms, forms and more forms • Application fee

10. Construction Permit Timeline • Plan Ahead • Typical application takes 30 days to develop • Regulatory agency requires a 30 day period to publicize draft permit • Regulatory agency issues permit 60 to 90 days after application submittal

11. Construction Permit Content • Could contain operating limitations on new equipment (i.e., pole production restricted) • Record-keeping, monitoring, and reporting requirements Monitor: • Air emissions and/or • Operating parameters

12. Air Quality Operating Permits • Includes requirements for entire facility • Renewed every five (5) years

13. Types of Operating Permits • Major source permit – Title V permit • Minor source permit – Synthetic minor* • Minor source permit – Natural minor* • Permit-by-Rule • Low Emitter* *Nebraska terminology

14. Title V Permit • Title V permit required due to: • Potential and actual emissions exceed major source thresholds • Source category

15. Minor Source Operating Permit • Air emissions less than major source levels • Permit contains record-keeping, monitoring and reporting requirements • Permit contains air emission limitations • Synthetic = restricted PTE • Natural = unrestricted PTE

16. Minor Source Operating Permit • Incorporates construction permit requirements and • Adds new requirements on previously unpermitted equipment

17. Permit-by-Rule Option • Typically covers smaller facilities that are numerous (i.e., paint booths or small engines) • State of Kansas: 50% of major source threshold Permit-by-Rule • Typically no paper permit, comply with regulation • Quicker process

18. Low Emitter Option • Nebraska option to avoid operating permit • Potential emission above major source levels but actual emissions less than 50% of major source levels

19. Operating Permit Timeline • Typical application developed in 30 days • Initial operating permit application due in accordance with construction permit requirement or state requirement • To reapply for an existing operating permit, submit application to regulatory agency no less than 180 days before operating permit expiration date

20. Questions

21. NESHAP • NESHAP – National Emission Standards for Hazardous Air Pollutants • Federal emission standards applicable to specific manufacturing facilities or equipment • Record-keeping, monitoring and reporting requirements

22. Valmont Survey • 2009 Completed Survey of all Valmont Sites • Results of Survey • Majority of Facilities are subject to NESHAP 6X (Metal Fabrication Source Category) • Three Facilities are subject to NESHAP 6C (Gasoline Dispensing) • Three are subject to NESHAP 4Z (Reciprocating Internal Combustion Engine (RICE)

23. NESHAP Subpart 6X • Applies to Fabrication and Finishing Facilities that emit Cd, Cr, Pb, Mn and/or Ni • SIC code specific Activities regulated include: • Welding, • Dry Abrasive Blasting, • Dry Grinding, • Spray Painting, • Cutting and Drilling

24. NESHAP Subpart 6X General Requirements: • Minimize dust, • Operate equipment according to specs,

25. NESHAP Subpart 6X Requirements for Welding Operations: • Minimize Emissions (welding process, process materials, optimize welding processes, fume capture/control systems) • Visual observation of emissions at the Primary Exhaust Point of the building

26. NESHAP Subpart 6X Requirements for Painting Operations: • Comply with paint booth design specifications, • Control paint emissions by 98%+, • Must use paint application equipment and cleaning techniques as specified in the rule, • Certified Painters, and • Recordkeeping

27. NESHAP Subpart 6C Standards for Gasoline Dispensing Facilities • At all facilities, check for leaks and use good housekeeping procedures to prevent evaporation of gasoline and • At facilities with monthly gasoline throughputs of 10,000 gallons or more, use submerged fill pipe when loading storage tanks • Must be in compliance by January 10, 2011

28. Emission Standards for Engines • Two Regulatory Programs for Engines • NSPS= New Source Performance Standards • NESHAP=National Emission Standards for Hazardous Air Pollutants • Applicable to Stationary Engines Only

29. NSPS 4I Standards for New diesel engines • Certified engines have minimal requirements • Requirements for certified engines: • Emergency engines are restricted to 100 hours of operation per year for maintenance checks • Routine oil filter changes

30. NSPS 4J • NSPS JJJJ – Standards for New spark ignition engines (i.e., gasoline, natural gas, propane) • Requirements separated by size and age • Similar requirements as NSPS IIII

31. NESHAP 4Z • New engines subject to and in compliance with NSPS are in compliance with NESHAP ZZZZ • Existing certified engines have minimal requirements • Routine oil filter changes • Emergency engines limited to 100 hours of operation per year for maintenance checks

32. Compliance Strategy • Compliance Notebook • Completed Survey Results of your Facility • Notification documents • Compliance demonstration documents • Awareness • Stay in the loop for notice of manufacturing changes involving regulated equipment or processes, • Look for new equipment or changes to manufacturing processes at the facility. • Use your Resources • Coordination with your Corporate Environmental Specialist

33. Questions