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

Peter MooreYorke Engineering, LLC

(949) 248-8490 x24PMoore@YorkeEngr.com

www.YorkEngr.com