PTEPotential to Emit

What is PTE?

K.A.R. 28-19-200 General provisions; definitions.

(yy) ‘‘Potential-to-emit’’ means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Secondary emissions shall not be considered in determining the potential-to-emit of a stationary source.

What is PTE?

• 24-hour operation, 365 days per year

• Operate at maximum capacity

• No pollution control devices or practices

Reasons for evaluating

•It’s required by your permit

•Determine if you need a permit

•Demonstrate your facility is below certain thresholds

•Determine if permit needs have changed

•Determine if adding new equipment will require a construction permit

PTE for what?

• Volatile organic compounds (VOCs)

• Nitrous oxides (NOX)

• Sulfur dioxide (SO2)

• Carbon monoxide (CO)

• Particulate matter (PM)

• Lead (Pb)

• 187 hazardous air pollutants• (e.g., xylene, toluene, chromium, methylene chloride,

manganese, styrene, etc.)

NAAQS

NESHAP

100 tons

25 tons

10 tons

Major sources – above the lineMinor source – below the line

Primary thresholds

Various thresholds

Operating permitClass I (Title V)Class IIPermit by rule

Construction permitApprovalPermit

NESHAPMACTNSPSRACT

Operating permit (Class I)

• Required if your PTE exceeds these thresholds:• 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

• Also referred to as Title V permits (EPA version)

Operating permit (Class II)

• Actual emissions are below Class I thresholds but PTE is above—limit PTE and apply for Class II operating permit

• 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 through 564)

Operating permit (Class II)

• Limit 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 processed

• Installing a pollution control device

Construction permit/approval

• Evaluate PTE for new activities/equipment

• Evaluate PTE for modified activities/ equipment• Change in method of operation

• Modification of existing emission unit

• If PTE exceeds construction approval or permit thresholds, contact KDHE• Thresholds: www.sbeap.org (helpful resource- Five steps to determine whether your

facility needs an air permit)

• Forms: www.kdheks.gov/air-permit/download.html

Construction permit

If your PTE exceeds these thresholds, then you’ll need a construction permit:

Source: Step 3 of SBEAP fact sheet,Five steps to determine whether your facility needs an air permit -www.sbeap.org/

Construction approval

If your PTE exceeds these thresholds, then you’ll need a construction approval:

Source: Step 3 of SBEAP fact sheet,Five steps to determine whether your facility needs an air permit -www.sbeap.org/

How to evaluate

•Based primarily on potential to emit (PTE)•24 hrs/day, 365 days/year•No control equipment

•Depending on regulation, evaluate on a facility-wide or process/equipment-specific basis

SBEAP’s air emissions toolswww.sbeap.org

Potential to emit (PTE) calculators

• Painting and coating

• Boilers and furnaces

• Engines

•Welding

• Grain elevator (being revised)

• Blasting (not yet posted)

• Plasma cutting (not yet posted)

PTE calculator typical contents

• Typical spreadsheet tabs• Instructions

• Product information and usage amounts

• Summary• PTE

• Actual

• Rolling total

• Other tabs• List of HAPs

• Facility information

PTE calculators input needed

PTE calculator Possible info needed for PTE calculation (spreadsheet inputs)

Painting/coating Density, VOC wt%, each HAP wt% (SDS); monthly usage amts; annual hrs operated; spray gun transfer efficiency; JO or WY county?

Boilers/furnace Heat input capacity or HP, fuel burned, JO or WY county?

Engines Fuel burned; HP or power output/fuel heat input; emergency or non-e

Welding Welding process, electrode type, amt. wire/rod consumed

Grain elevator (being revised) Annual throughput, elevator type,

Blasting (not yet posted) Amt. blasting material, wind speed

Plasma cutting (not yet posted) Steel type, steel thickness; cut dry, semidry, or wet; HAP in steel

Calculation methods (most to least preferred)

• CEMS (continuous emission monitoring systems)

• Stack tests

• Material balance (emissions from painting/coating)

• Emission factors (emissions from engines, boilers, metal fabrication processes, grain elevators, and many more sources)

• Engineering judgement

• Other approved method

Material balance calculations – painting/coating emissionshttp://www.sbeap.org/tools/potential-to-emit-calculators

(www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emission-factors)

So you want to build/expand your facility/process

Step 1: Identify emissions

• What are possible emission sources from equipment performed at your facility?

Step 1: Identify emissions

• What are possible emission sources from equipment performed at your facility?• Paint booth

• Curing ovens

• Engines (emergency and non-emergency)

• Boilers

• Compressors

• Heaters

• Grain conveyor, unloading leg

Step 1: Identify emissions

• What are possible emission sources from activities performed at your facility?

Step 1: Identify emissions

• What are possible emission sources from activities performed at your facility?• Spraying paint, gel coat/resin

• Spray gun cleaning

• Paint stripping

• Parts cleaning

• Welding

• Metal blasting

• Plating

• Moving grain

Step 2: Calculate PTE

• Select method(s) to use

• Gather needed information to perform calculations

• Calculate PTE for each criteria pollutant and HAP generated at your facility

• Contact SBEAP or KDHE Permitting Section for assistance

Step 3: Compare PTE results with thresholds

• Refer to SBEAP fact sheet, Five Steps to Determine Whether Your Facility Needs an Air Permit, Step 3, for tables with thresholds

• Determine which permit to apply for• Are you an existing Class II that needs to be a Class I?

• Are you an existing Class I that could be a Class II?

• Have you added a piece of equipment?• Do you need a construction approval?

• Do you need a construction permit?

Step 4: Apply for the appropriate permit

• To be discussed in the next few sessions

Conclusion

• PTE is fundamental to determining your permitting requirements

• If PTEs are below regulatory thresholds and no permit is needed for any other reason—• File calculations should they be requested later by an inspector

• Continue to track emissions, especially if product usage or product type changes

Questions or comments?Contact information

800.578.8898

www.sbeap.org

Barb Goode

785.452.9456

barblj@ksu.edu