Working with Agencies

1. Working with Agencies March 26, 2019 Kale Walch

2. Hexcel background • Manufacturing of honeycomb blocks • On site since 1966 • Dip Room • RTOs for control of VOCs • CAA permits • PSD permit with BACT controls • Title V operating permit • RCRA • Large Quantity Generator • ISO 14001

3. Permits • Permit applications • Pre-meeting with agency • Explain the process • Revisions • Work with the agency before submitting • Send comments on draft permits • Call or email for interpretations • Use the agency’s knowledge • Understand your permit • Use the citations to look up the rules

4. Permit Revisions • Predictions are not always accurate • Design changes • Market changes • Construction permit must be accurate • Working with operations • Permitting non-process or tangential items • Leave enough time to obtain permit • PCAQCD needs time to write the permit • Public Comment period – 30 days • EPA review period – 45 days

5. Stack Testing • Protocol approval • Opportunity to save time and money • Might have to do it again • Turn in timely • Discussions between the agency and the source • Miscommunication can be expensive • Requests for variances • Design impacts • Some facility components were not built with stack testing in mind • Weather impacts • Safety, malfunctions

6. Stack Design

7. Weather impacts

8. Miscommunications

9. Inspection Entry Rights • Utilized by City, County and State agencies • Take the time to read • Accompany inspector • Take samples or read opacity with inspector • Opacity readings versus screens • Provisions designed to provide benefits for industry

10. Contractors • Dust Permits • Who obtains the permit • Who is responsible for dust control • Asbestos surveys • Stop and resolve problems • Refrigeration servicing • New rules • Recycling, recharging, large units

11. Reporting and Recordkeeping • Ask for interpretations • Try not to procrastinate • Use technology to your advantage • Recent reductions in required reporting • Facility Annual Report (FAR) • MyDEQ defining who needs to submit Discharge Monitoring Reports (DMR) • Pollution Prevention Plans (P2) going paperless

12. Wastewater Operations • Work with the City • Communication • Reporting excursions • Use their knowledge • Total Suspended Solids monitoring

13. Enforcement Process • Deviations • Notice of Opportunity to Correct • Notice of Violation • Order of Abatement by Consent • Many off ramps are built into the system • The response is often more important than the original act • Procrastination limits options typically increases costs

14. ISO 14001 • Communication Log • Calendar of events • Outreach events • Emergency Response Plan coordination • Participation in voluntary programs • Stakeholder participation • ADEQ • PCAQCD • City • Others

15. Government Apps and Technology • PCAQCD forecast • AirNow(https://airnow.gov/) • Twitter • MyDEQ (www.azdeq.gov) • Pipeline and Hazardous Materials Safety Administration (https://www.phmsa.dot.gov/) • ERG 2016 free app (National Library of Medicine) • Chemical Safety Board (https://www.csb.gov/) • Training Videos

16. Contact information Kale Walch Hexcel Kale.walch@hexcel.com 520-413-6407 (office) 520-840-2511 (cell)