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Air Quality 101

Air Quality 101. Kansas Air Quality Program overview. Kansas Air Quality Program overview. Provide brief history of CAA and Kansas Air Quality Program Explain what it means to your business Calculating your PTE Explain related features NSR (reform) Preconstruction review

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Air Quality 101

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  1. Air Quality 101 Kansas Air Quality Program overview

  2. Kansas Air Quality Program overview • Provide brief history of CAA and Kansas Air Quality Program • Explain what it means to your business • Calculating your PTE • Explain related features • NSR (reform) • Preconstruction review • Operating permits • NSPS • Goal of protecting health and the environment KS SBEAP 800-578-8898 January 2006

  3. History of air regulations • 1273 – England • King Edward banned use of sea coal • 1881 – Chicago • City passes first smoke control law • Adopted by other cities in 1990s • 1945 – Los Angeles • Air pollution control district formed KS SBEAP 800-578-8898 January 2006

  4. 1930 – Belgium 63 deaths Smelters and sulfuric acid 1948 – Pennsylvania 20 deaths Steel mill and sulfuric acid plants 1952 – London 4,000 deaths 1953 – New York 250 deaths 1956 – London 1,000 deaths Catalysts KS SBEAP 800-578-8898 January 2006

  5. The response… • 1955 - Congress passed the Air Pollution Control Act (first commitment of federal funds) • 1963 – Clean Air Act • 1965 – Motor Vehicle Air Pollution Control Act • 1967 - Air Quality Act KS SBEAP 800-578-8898 January 2006

  6. The response… • 1970 - EPA formed • 1970 – Clean Air Act Amendments: • NAAQS, SIPs, NSPS, NESHAPs • 1977 – Clean Air Act Amendments • 1990 – Clean Air Act Amendments • 1990 – Pollution Prevention Act KS SBEAP 800-578-8898 January 2006

  7. NESHAP vs. MACT • 1970 Section 112 provisions • EPA had to identify hazardous air pollutants (HAPs) and identify standards to prevent any adverse human health effects with “ample margin of safety.” • All risk-based • Courts directed EPA to determine safe air pollutant levels without technological or cost concerns (NESHAP). • 1990s • Congress saw setting health-based standards too long and difficult, so initiated new “technology-based standards. Maximum Achievable Control Technology (MACT). *Afternoon session on MACTs KS SBEAP 800-578-8898 January 2006

  8. 1990 Clean Air Act overview • Title 1: Ambient air quality standards • Title 2: Mobile sources • Title 3: Hazardous air pollutants • Title 4: Acid rain • Title 5: Operating permits • Title 6: Ozone protection • Title 7: Enforcement • Title 8: Miscellaneous • Title 9: Clean air research • Title 10: Disadvantaged businesses • Title 11: Employment transition KS SBEAP 800-578-8898 January 2006

  9. Kansas Air Quality RegulationsKAR 28-19 • The Kansas Air Quality Act (KAQA) implements elements of the 1990 Clean Air Act Amendments. • Administered by the Kansas Department of Health and Environment Bureau of Air and Radiation • KAQA includes the following requirements for air pollution sources in Kansas… KS SBEAP 800-578-8898 January 2006

  10. Kansas Air Quality Act • Preconstruction review • Operating permits • Annual air emissions fees • Other air requirements KS SBEAP 800-578-8898 January 2006

  11. What this means to your business • Assess your air emission sources for compliance with the KAQA. • Existing sources not permitted • New businesses or sources • Existing sources permitted, modifying or adding new equipment • Determine KAQA applicability and maintain records on site (not unlike RCRA determinations). KS SBEAP 800-578-8898 January 2006

  12. Steps to making a determination • Identify all emission sources (units or processes) at your facility. • Activity that emits or has the potential to emit • Does not necessarily have to be connected to a stack or vent • Identify the pollutants being emitted. • Use MSDS, contact vendors • NOx, SOx, CO, VOC, PM, HAP KS SBEAP 800-578-8898 January 2006

  13. Steps to making a determination • Calculate your actual emissions and then your PTE or “potential to emit.” • Based on your PTE, do you trigger standards? • Preconstruction • Operating permits • Do you trigger other emission standards based on equipment type or HAP use? KS SBEAP 800-578-8898 January 2006

  14. What is potential to emit? • The maximum amount of air pollution your facility can emit if • Each process is operated at 100% of its physical and operational capacity. • All equipment is operating 24 hours per day, 365 days per year (8,760 hours per year). • Materials that emit the most air pollution are processed 100% of the time. • No pollution control equipment is used. * See SBEAP fact sheet KS SBEAP 800-578-8898 January 2006

  15. Potential to emit • Calculation methods • Emission factors • Material balances • Other approved methods • Computer programs • Industry-specific emission factors • Approved by KDHE on an individual basis • Represent the source’s maximum capacity or worst case scenario emissions KS SBEAP 800-578-8898 January 2006

  16. Potential to emit • Emission factors • Manufactures emission factors are best • Ap-42 is a compilation of factors for specific processes accepted by EPA • http://www.epa.gov/ttn/chief/ap42/index.html • Emission factor software and tools • http://www.epa.gov/ttn/chief/efpac/efsoftware.html KS SBEAP 800-578-8898 January 2006

  17. Potential to emit • Material balance: • Product in = product out (assumes constant inventory) • Product in can be the purchased material. • Product out can be the emissions. • Material balance can be applied to individual units or the whole process. KS SBEAP 800-578-8898 January 2006

  18. Potential to emit • SBEAP fact sheet • Here’s how to calculate your potential to emit (Tab 5) • Material balance example – most common method for solvent emissions (painting, coating, printing) • Emission factor example – most common for non-solvent emissions (oil-fired boiler) KS SBEAP 800-578-8898 January 2006

  19. Does the PTE trigger standards? • Total all PTE emissions at your facility • Compare against KAQA standards • Preconstruction standards • Operating permits • Other requirement KS SBEAP 800-578-8898 January 2006

  20. Existing Program Preconstruction categories 28-19-300 Approvals Permits Operating permits Class I Class II Class III General permits New Program Preconstruction categories (new fact sheet) Registration Approval Operating permits Class I Class II (Class III) (General) KAQA standards KS SBEAP 800-578-8898 January 2006

  21. Class I • If your PTE exceeds these thresholds, then you’ll need a Class I operating permit: • 100 tons per year NOx, SOx, PM10, VOC, CO • 10 tons per year of any single hazardous air pollutant (HAP) • 25 tons per year of combined HAPs KS SBEAP 800-578-8898 January 2006

  22. Class II • If your actual emissions are below the Class I thresholds but your PTE is above – then you can limit your PTE and apply for a Class II operating permit. • A Class II permit requires minimal record keeping and is simpler (and cheaper) than maintaining a Class I permit. • Class II permit-by-rule (KAR 28-19-561 - 564) KS SBEAP 800-578-8898 January 2006

  23. Solvent evaporative sources Class II permit-by-rule for solvent users (9 ton rule) KAR 28-19-562 • Purchase or use less than 9 tons of VOC’s or HAPs or both in a 12-month period • Don’t have to calculate PTE, just need to maintain records to show below 9 tons • If exceed 9 tons in 12-months have 60 days to notify and apply for a Class II operating permit KS SBEAP 800-578-8898 January 2006

  24. Limit your PTE by • Implementing pollution prevention • Change the material • Change the process • Change the technology • Limiting your process rate • Limiting hours of operation • Limiting amount of material processes • Installation of a pollution control device Must be federally enforceable KS SBEAP 800-578-8898 January 2006

  25. Other air requirements • New Source Performance Standard (NSPS) • Trigger a NESHAP or MACT standard • Located in Johnson and Wyandotte Counties subject to RACT rules • Have an incinerator • New Source Review (NSR) Reform KS SBEAP 800-578-8898 January 2006

  26. New Source Performance Standard • Applies to newly constructed, reconstructed, or modified sources • Based on date of construction, reconstruction, or modification • KAR 28-19-720 40 CFR Part 60 KS SBEAP 800-578-8898 January 2006

  27. Questions? • Our goal is protection of human health and the environment. • Our mission is to help small businesses comply with environmental regulations and identify pollution prevention opportunities. • www.sbeap.org KS SBEAP 800-578-8898 January 2006

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