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What to Report How to Comply

What to Report How to Comply

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What to Report How to Comply

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  1. What to ReportHow to Comply Barbara Johnson, PE K-State Pollution Prevention Institute Small Business Environmental Assistance Program

  2. Overview • What to report • Tips for proper reporting • Future additions or modifications • General compliance tips

  3. What to Report? • 40 CFR Parts 60 NSPS • 40 CFR Parts 61 and 63 – NESHAP and MACT Standards • Semi-Annual Reports for Title V Permits • Annual Certifications for Title V Permits • Emissions Inventory (both Class I and Class II permits) • Performance Testing (Protocols, Reports)

  4. And to Whom?

  5. Notifications to Whom? *available at www.kdheks.gov/air-permit/download.html

  6. What to Report? READ YOUR PERMIT! (and understand what it says)

  7. What to Report – NSPS • 40 CFR Parts 60 NSPS (New Source Performance Standards). Applies to: • Categories of sources causing significant air pollution of criteria pollutants • New stationary sources of emissions (construction or modification after date standard is proposed) • Control emissions to level achievable by best system of continuous emission reduction

  8. NSPS Components • Emission limits • Standards for visible emissions • Modification provisions • Monitoring requirements • Performance test methods & compliance procedures • Reporting & recordkeeping requirements

  9. Example – Small Boiler NSPS 40 CFR 60.42 subpart Dc • Installed or modified after June 9, 1989 • Heat input capacity is between 10 and 100 MMBTU/hr

  10. Subject to NSPS?(for boilers <100 MMBtu/hr) The boiler was constructed, modified, or reconstructed after June 9, 1989 The heat input capacity of the boiler is between 10 and 100 MMBtu/hr Complete the expedited KDHE boiler form Yes Yes No No The boiler is not subject to NSPS requirements

  11. Evaluating Permit Needs • Identify for all boilers: • Date of installation or modification • Heat input capacity (typically in MMBTU/hour) • Type of fuel (natural gas, fuel oil, etc) • Back-up fuel: evaluate using fuel with greater PTE • Low NOX burner (for natural gas-fired boilers)

  12. KDHE Boiler “Sheltered” Initiative • KDHE is assisting boiler owners w/coming into compliance without incurring a penalty • Applies to companies or institutions that have boiler(s) with heat input capacity between 10 and 100 MMBtu/hr and installed after June 9, 1989 (i.e., those subject to NSPS reporting)

  13. KDHE Boiler “Sheltered” Initiative • Company/institution must evaluate need for air permit/approval • Complete applicable permit applications • Expedited approval or permit • NSPS boiler form • Must be in compliance by September 30, 2008

  14. Tips for NSPS Reporting • Air quality performance test guidelines • www.kdheks.gov/air-permit/forms/ Performance_Test_Guidelines.pdf • KDHE visible emission observation form • www.kdheks.gov/air-permit/forms/KDHE_VE_form.pdf • Performance test companies • www.kdheks.gov/air-permit/forms/stack_testers.pdf • KDHE NSPS notification form • www.kdheks.gov/air-permit/forms/NSPS%20Notification.pdf

  15. NSPS notification form: www.kdheks.gov/air-permit/forms/NSPS%20Notification.pdf

  16. What to Report - MACT • 40 CFR Parts 61 and 63 – NESHAP (Nat’l Emission St’ds for Hazardous Air Pollutants) and MACT (Maximum Achievable Control Technology) Standards. Applies to: • Sources of HAP emissions within certain source categories • Mostly major sources, some area sources

  17. MACT Components • Compliance standards • Compliance dates – often 3 years after rule promulgated • Operation and maintenance requirements • Compliance with emission standards • Notification & conduct opacity or visible emission observations • Availability of records • Performance testing requirements • Monitoring requirements • Initial notification requirements – due 120 days after rule promulgated • Initial Compliance Status Report – due anywhere between 30 days to one year after the rule compliance date • Recordkeeping and reporting requirements • Control device requirements

  18. Tips for MACT Reporting • Initial notification form – send to KDHE & EPA • KDHE spreadsheet template (styrene) • SBEAP compliance calendar (dry cleaners) • EPA Web resources: www.epa.gov/ttn/atw/mactfnlalph.html

  19. www.epa.gov/ttn/atw/mactfnlalph.html

  20. Initial Notification Form

  21. What to Report – Class I Permit • Class I operating permit overview • Semi-Annual Reports for Title V (Class I) Permits • Class I annual certification – CR-02 • Emissions Inventory • Performance testing

  22. Class I Operating Permit Overview for Compliance • Permit Intent – identifies the pollutants that are over the major source threshold to require the operating permit • Facility Description – process units evaluated and description of the facility process

  23. Class I Operating Permit Overview for Compliance con’t • Emission Source Information – detailed emission units description, stack/vent ID, control equipment, and applicable regulations • Applicable Regulations – • Emission Source • Limit or Standard • Monitoring • Recordkeeping and Reporting

  24. Class I Operating Permit Overview for Compliance con’t • Opacity Summary – summarizes opacity requirements from the applicable requirements section • Facility-Wide Applicable Requirements – facility is subject to comply with, if applicable (e.g. Annual Fees, Emission Inventory, Emergency Episode Plans, Chemical Accident Prevention)

  25. Class I Operating Permit Overview for Compliance con’t • Opacity Monitoring – methodology used to perform qualitative assessments and/or Method 9’s, when required • Requirements which will become effective during the term – any new regulation(s) that weren’t applicable at the time of the issuance but will become effective during the 5 year permit term

  26. Class I Operating Permit Overview for Compliance con’t • Permit Shield – conditions that are deemed in compliance with applicable requirements of the Kansas Air Quality Program as of the date of permit issuance • Test, Monitoring, Recordkeeping, and Reporting – guideline(s) to assure compliance with the terms and conditions of the permit

  27. Class I Operating Permit Overview for Compliance con’t • Temporary Replacement of Internal Combustion Engines – guideline(s) and provision(s) for when an internal combustion engine is authorized to operate pursuant to the terms of this permit is out-of-service because of repair or maintenance • Reporting of Deviations from the Permit Terms – unless a different period is specified in this permit, guideline(s) for reporting deviations from the requirements of this permit

  28. Class I Operating Permit Overview for Compliance con’t • General Provisions • K.A.R 28-19-11 • K.A.R 28-19-752a • K.A.R 28-19-753 • Permit Term and Renewal • Compliance • Compliance Certification • Emergency • Inspection and Entry • Permit Amendment, Modification, Reopening, and Changes not requiring a permit • Duty to provide information • Duty to supplement • Other Permit and Approvals; Applicability • Submissions

  29. Tips for Semi-annual Report • Copy permit conditions • Indicate whether or not in compliance • Review permit for new qualitative assessment language (see next slide) • Report deviations • KDHE technical guidance documents – BAR 2005-01 www.kdheks.gov/air-permit/forms/2005- 01_KAR_28-19-11.pdf • KDHE technical guidance documents – BAR 2006-01 www.kdheks.gov/air-permit/forms/2006- 01_Reporting_Deviations.pdf • KDHE example semi-annual report www.kdheks.gov/air-permit/forms/Example_SemiAnnual_Report.pdf

  30. Qualitative Assessments • Initial Permits • All sources listed • Required 2 Method 9’s per year and qualitative assessments • Opacity monitoring requirements detailed in the applicable requirements • Procedures provided in Facility-Wide Applicable Requirements section

  31. Qualitative Assessments (con’t) • Renewal and New Permits (as of mid 2005) • No source list (except sources subject to 40% opacity requirement) • Facility must determine which sources require assessments • Monthly qualitative assessments by a knowledgeable observer • Procedures provided in Facility-Wide Applicable Requirements section

  32. Example semi-annual reportwww.kdheks.gov/air-permit/forms/Example_SemiAnnual_Report.pdf

  33. What to Report – Class I Permit • Annual Certifications for Title V (Class I) Permits • KDHE CR-02 form • Provides certification of facility compliance status of each condition of the permit • If non-compliance – summarize nature, duration, and frequency • Submit to KDHE and EPA Region VII

  34. Annual Certificationwww.kdheks.gov/air-permit/forms/CR-02_Annual_Certification.pdf

  35. What to Report – Emission Inventory Annual Emissions Inventory • Class I Permit or applied for Class I • Due June 1 • Can submit electronically – need password • Forms for mailing available on Web • Class II Permit • Due April 1 • Forms available on Web, specific to industry • Class II Permit-by-rule, 50% actual emissions • Due February 15 • Reminder letter sent in December – no forms sent

  36. Tips for Air Emissions Inventory Reporting www.kdheks.gov/emission/EmInfaq.html

  37. What to Report – Performance Tests Performance testing: • Required by NSPS, MACT, other (RACT) • Required by Acid Rain regulations • Required by other Kansas regulations • Required by State Approvals/Permits and/or an enforcement actions • Protocols – due 30 days prior to testing • Reports – due 60 days after testing or specified in the subpart • Read permit conditions

  38. Tips for Performance Testing www.kdheks.gov/air-permit/forms/Performance_Test_Guidelines.pdf

  39. Performance Test Report Requirements

  40. Future Additions or Modifications • Evaluate PTE for new or modified equipment. • If increase in PTE exceeds construction approval or permit thresholds, submit application. • Thresholds: www.sbeap.org/publications/ airqual.pdf • Forms: www.kdheks.gov/air-permit/download.html

  41. When to Notify • Air construction approval/permit • New emission source • Increased emissions due to expansion or process change • Prior to start of construction or modification

  42. Tips for Construction Permits www.kdheks.gov/air-permit/forms/Informational_Sheet.pdf

  43. Tips for Construction Permits www.kdheks.gov/air-permit/forms/Pre_Construction.pdf

  44. When to Notify • Operating permit • New emission source • Increased emissions due to expansion or process change • Notify KDHE • New – one year after initial start up • Existing • Class I – one year after initial start up • Class II – six months after initial start up

  45. Other Reporting Emergency Generators • Emergency generator definition • Used only for back-up power (not to offset peak energy usage) • For PTE calculations, assume 500 hours/year • All emergency generators should be registered with KDHE • Expedited form available

  46. Expedited Form www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

  47. Other ReportingChange of Ownership/Operator/Name Notification

  48. KDHE/SBEAP Compliance Assistance • Encourage emission sources to: • Notify KDHE, if subject to any applicable regulations • Understand and comply with applicable regulations • Reduce air pollutant emissions beyond minimum requirements • How? • Conference/workshop presentations • Webcasts • Mass mailings • Telephone consultations • Site visits

  49. Who performs inspections? • BEFS – KDHE district office personnel through a Memorandum of Understanding with BAR • Major and synthetic minor sources • Local partners • Johnson County • Sedgwick County • Shawnee County • Wyandotte County • US EPA Region VII (Limited)