air quality permitting case studies
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Air Quality Permitting Case Studies. March 15, 2006. Peter J. Moore Yorke Engineering 949-248-8490 x24. Agenda. Overview of Permitting Equipment Information Emission Calculations Forms Rule Evaluation New Source Review Health Risk Assessment RECLAIM Title V - PowerPoint PPT PresentationTRANSCRIPT
Air Quality PermittingCase Studies
Peter J. MooreYorke Engineering949-248-8490 x24
March 15, 2006
Agenda Overview of Permitting Equipment Information Emission Calculations Forms Rule Evaluation New Source Review Health Risk Assessment RECLAIM Title V Once You Receive Your Permit-to-
Construct Resources
Overview What requires a permit?
Anything that emits pollutants Equipment Categories
Boilers >2 MMBTU/hour Internal Combustion Engines >50 bhp
New construction Modification of existing equipment
SCAQMD Rule 201 "A person shall not build, install,
erect, alter or replace any equipment, the use of which may cause the issuance of air contaminants or the use of which may eliminate, reduce or control the issuance of air contaminants without first obtaining written authorization for such construction from the Executive Officer"
Criteria Pollutants
Sulfur Dioxide (SOx) Nitrogen Dioxide (NOx) Ozone Lead Carbon Monoxide (CO) Particulate Matter (PM) Precursors are also regulated
Pollutant Precursors
Pollutant PrecursorsOzone NOx, ROGPM10 NOx, SO2, ROGSOx SO2, SO4, PM
Equipment Information Specific equipment information will be put
into the permit Collect detailed information about the
equipment Equipment rating (as indicated on nameplate) Manufacturer’s spec sheets Photos Exhaust stack parameters Emissions data
Equipment Description Boiler
BOILER, NO. 1, CLEAVER BROOKS, MODEL CB-LE, FIRE-TUBE TYPE, WITH A NATURAL GAS FIRED, LOW NOX BURNER, PROFIRE MODEL NTH, RATED AT 4,200,000 BTU PER HOUR, AND EQUIPPED WITH A FLUE GAS RECIRCULATION SYSTEM
Internal Combustion Engine INTERNAL COMBUSTION ENGINE, CUMMINS, MODEL
GTA8.3-HC-G2, NATURAL GAS FUELED, RICH BURN, FOUR CYCLE, SIX CYLINDERS, TURBOCHARGED, AFTERCOOLED, RATED AT 219 B.H.P., WITH A NON-SELECTIVE CATALYTIC CONVERTER, JOHNSON MATTHEY MODEL BX50-6, AND AN AIR/FUEL RATIO CONTROLLER, NEUTRONICS MARK V, DRIVING AN ELECTRIC GENERATOR
Forms Download forms from:
www.aqmd.gov/permit/forms.html 400-A (1 for each piece of
equipment) 400-E-9a (Boiler) 400-E-13b (I.C. Engine) 400-CEQA (1 for each application) 400-XPP (optional expedited)
Rule Evaluation Rule 212: Standards for Approving Permits Rule 219: Exemptions from Permitting Rule 301: Fees Regulation IV: Prohibitions Regulation XI: Source Specific Standards Regulation XIII: New Source Review (NSR) Rule 1401: NSR of Toxic Air Contaminants
Rule 212:Standards for Approving Permits Public Notice is required if:
New or modified equipment that results in increase in air emissions within 1000 feet of a K-12 school
Cancer risk increase >1 in one million for facilities with more than one permit unit
Unless you can demonstrate facility risk is less than 10 in one million
Cancer risk increase >10 in one million for facilities with one permit unit
Nearest SchoolMontessori Academy, 9062 Firestone Blvd.
Scho
ol
IMA
Pollu
ter
Exhaust Stacks
Distance to
school = 1150
ft.
Rule 219: Equipment Not Requiring a Written Permit
Lists equipment that is exempt from permitting
Always review to see if there is an exemption for your equipment
Boilers <2 MMBTU/hour Internal Combustion Engines <50
bhp
Rule 301: Permit Fees Look up equipment category in Tables
IA (Control Equipment) and IB (Basic Equipment)
Look up fees on table of Summary Permit Fee Rates
Expedited processing: para. 301(y) 50% additional fees
Small Business: para. (c)(1)(E) 50% discount on fees
Identical Equipment: para. (c)(1)(F) Fee for second unit is 50% of first
Regulation IV: Prohibitions Rule 401: Visible Emissions Rule 402: Nuisance Rule 404: Particulate Matter-
Concentration Rule 405: Solid Particulate Matter-
Weight Rule 431.1: Sulfur Content of Gaseous
Fuels
Regulation XI:Source Specific Standards
Rule 1110.2: Emissions from Gaseous- and Liquid-Fueled Stationary Internal Combustion Engines
Rule 1146 (Large boilers) Rule 1146.1: Emissions of Oxides of
Nitrogen from Small Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters
Rule 1146.2 (Water heaters, small boilers)
New Source Review
Regulation XIII:New Source Review (NSR)
Rule 1303: Requirements Rule 1304: Exemptions Rule 1306: Emission Calculations Major concepts:
BACT Offsets Modeling
NSR:Best Available Control Technology Required for all new equipment and any
modification that increases emissions BACT is determined on a case-by-case
basis Use BACT listings to find comparable
equipment The SCAQMD publishes a separate
document for “Non-major polluting facilities” (minor source BACT)
NSR: Offsets Adding new pollutants to the air may
need to be “offset” by purchasing Emission Reduction Credits (ERC)
Calculate the facility Potential-to-Emit Maximum operating schedule for all
permitted equipment for one year If PTE exceeds thresholds, offsets are
required [Rule 1304 para. (d)]
NSR: Modeling Modeling determines whether the
emissions from the new equipment will cause a violation of the clean air standards
Requires use of an air quality simulation model
For small equipment, modeling is satisfied by exemption: 1303, Appendix A, Table A-1
Health Risk Assessment
Rule 1401:NSR of Toxic Air Contaminants Required to perform health risk
assessment for any increase in toxic air contaminants
Calculate health risk indices: Maximum Individual Cancer Risk
(MICR) Cancer Burden Acute Health Risk Index (HIA) Chronic Health Risk Index (HIC)
Toxic Air Contaminants (TAC) There are a large number of toxics
to be considered, for example: Benzene Formaldehyde Acetaldehyde Acrolein Polycyclic Aromatic Hydrocarbons
(PAHs) TAC’s cause health risk impacts
Health Risk Assessment Guidelines
Determine TAC emission rates Determine distances to nearest
receptors Calculate health risk indices per
SCAQMD guidelines
Aerial Photo
Exhaust Stacks
IMA Polluter
Facility Boundary
Nearest Offsite Worker
Exhaust Stacks
Distance to offsite
worker = 50 meters
Offsite worker
Nearest Residence
Exhaust Stacks
Distance to residence = 250
meters
Residences
Health Risk Index - MICR
Maximum Individual Cancer Risk (MICR) Long term impact Probability that an individual will
contract cancer over 70 years (resident receptor) or 40 years (commercial receptor)
Must be < 1 x 10-5 (10 in one million) for new equipment <1 x 10-6 to avoid public notice
Health Risk Index - Chronic
Chronic Hazard Index (HIC) Long term, non-cancer health
effects Must be < 1.0 for all target organs
Health Risk Index - Acute
Acute Hazard Index (HIA) Short term (1-hour average) health
effects Must be < 1.0 for all target organs
What Are Target Organs? Specific systems in the human body that are affected by TACs
Symbol Description Chronic Acute
AL Alimentary system (liver) X X
BN Bones and teeth X
CV Cardiovascular system X X
DEV Developmental X X
END Endocrine system X
EYE Eye X X
HEM Hematopoietic system (blood) X X
IMM Immune system X X
KID Kidney X
NS Nervous system X X
REP Reproductive system X X
RESP Respiratory system X X
SKIN Skin X X
Tier I Screening Evaluation
Max Annual Controlled Emissions (tons/year)
Max Hourly Controlled (lbs/hr) Look up tables in: “Risk Assessment
Procedures for Rules 1401 and 212” Check for most recent version!
If emissions are lower than screening levels, Rule 1401 is satisfied. If not, proceed to Tier II
Tier II Risk Assessment for MICR
MICR = CP x DI x MP CP: cancer potency factor (mg/kg-day)-1
DI = Dose inhalation (mg/kg-day) DI = Cair x DBR x EVF x 10-6
Cair = concentration in air (µg/m3)
DBR = daily breathing rate (L/kg-day) EVR = Exposure value factor (unitless) 1 x10-6 = convert µg to mg(10-3 mg/µg), liters to cubic meters (10-3 m3/l)
Cair = Qtons x X/Q x AFann x MET Qtons = Emission rate (tons/year) X/Q = Dispersion Factor ((µg/m3)/(ton/yr) AFann = Annual Averaging factor MET = meteorological correction factor (unitless)
MP: multipathway factor (unitless)
MICR = CP x ((Qtons x X/Q x AFann x MET) x DBR x EVF x 10-6) x MP
Chronic Index Equation
HIC Chronic hazard index (calculated for each target organ)
TAC Sum of the contribution for each Toxic Air Contaminant (TAC)
QyrTAC Emission rate of each TAC (tons/year)
X/Q Annual average dispersion factor (g/m3)/(ton/year)
RELTAC Chronic Reference Exposure Level (g/m3) for each TAC
MP Multi-pathway adjustment factor (n.d.)MET Meteorological correction factor (n.d.)
organtarget TAC
yrorgantarget RELChronic
MPMETX/QQ HICTotal TAC
Acute Index Equation
HIA Acute hazard index (calculated for each target organ)
TAC Sum of the contribution for each Toxic Air Contaminant (TAC)
QhrTAC Emission rate of each TAC (lb/hour)
X/Qhr Hourly average dispersion factor (g/m3)/(lb/hour)
RELTAC Acute Reference Exposure Level (g/m3) for each TAC
organtarget TAC
hrhrorgantarget RELAcute
X/QQ HIATotal TAC
Cancer Burden Calculation
Only Needed if MICR >10-6
Estimate Area (km2) with Risk >10-6
Multiply Area by 4,000 - 7,000 persons/ km2
Multiply Total Persons by MICR If Burden >0.5
More detailed calculations or modeling required
RECLAIM REgional CLean Air Incentives
Market NOx and SOx are only pollutants
regulated under RECLAIM Facilities that have reported over 4
tons/year of NOx/SOx are in RECLAIM RECLAIM permits look different
“Facility” permit Regulation XX
Differences in Permitting under RECLAIM NSR for NOx/SOx is found in Regulation
XX (Rule 2005) Existing rules do not apply to NOx/SOx
E.g. NOx requirements in Rule 1110.2 and 1146.1 would not apply
For emission increases, facility must hold sufficient RECLAIM Trading Credits (RTC) for one year ahead
Additional fees in Rule 301(o) and (q)
Title V Title V is a Federal Operating Permit
program under EPA Major sources of pollutants are
subject to Title V e.g. NOx or VOC PTE > 10 tons/year
Title V permits are also “facility” permits
Regulation XXX
Differences in Permitting under Title V
Additional forms Form 500 series
Requires certification of compliance Additional fees in Rule 301(p) and
(q) Permits must be reviewed by EPA
prior to issuance (45 days) Public notice
Once You Receive Your Permit Read it!!! If there are errors or disputed
conditions, write to the permit engineer within 30 days to negotiate corrections
If necessary file appeal to Hearing Board within 30 days
Permit to construct is valid for one year Request an extension if you need one
Source Test Conduct source test
Hire qualified source test company Have them submit a source test
protocol; make sure that all permit conditions are reflected in protocol
Notify SCAQMD of test date Observe deadlines Communicate with permit engineer if
you cannot meet deadlines
Ongoing Compliance When equipment is constructed,
permit to construct functions as temporary permit to operate
Read carefully all monitoring and recordkeeping conditions and do what it says
Resources North American Industrial Classification
System (NAICS) www.census.gov/epcd/www/naics.html
Maps/Aerial Photos www.mapquest.com terraserver.microsoft.com maps.google.com
BACT Guidelines www.aqmd.gov/bact/BACTGuidelines.htm
Resources: Emission Factors EPA AP-42
www.epa.gov/ttn/chief/ap42/index.html Ventura County Emission Factors
(external combustion only) www.aqmd.gov/prdas/pdf/COMBEM2001.pdf
SCAQMD(Annual Emission Report Guidelines) www.ecotek.com/aqmd/2005/
forms_and_instructions_pdf/0405_GuideBook.pdf
Resources Risk Assessment Guidelines
www.aqmd.gov/prdas/Risk%20Assessment/RiskAssessment.html#CurrentRiskAssessment
Gas Company socalgas.com/business/
resource_center/aq_programs.shtml PermitWorks Program
Questions & Answers