One of the easiest ways for an EPA or state inspector to find violations is to compare your current operating equipment and emissions with the permitted equipment and emissions. If you do not keep your Air Quality Permit up to date, you run the risk of an inspector finding serious violations – which come with serious monetary fines. This applies to your facility whether your permit is a Title V, Synthetic Minor, or even True Minor operating permit.

If you operate under a Title V Air Quality Permit, you are required to renew your permit every 5 years, and likely have an annual inspection conducted by the EPA or state. With these measures in place, chances are your Air Quality Permit is staying up to date. However, anytime your facility installs new operating equipment or removes/decommissions old operating equipment you should reassess your air emissions. Continue reading “Is My Facility Fully Covered by My Air Quality Permit?”

On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.

Continue reading “EPA Allows Reclassification from A Major Source of Hazardous Air Pollutants (HAP) to An Area Source”

Indoor air quality is important for employee health and comfort. Poor air quality can lead to several negative health effects, including irritation, coughing, and fatigue. More serious health hazards such as occupational asthma, specific organ toxicity, or cancer can also occur, depending on the chemicals being handled on site. Because of this, the Occupational Safety and Health Administration (OSHA) has developed permissible exposure limits (PELs) for several dusts, fumes, and vapors from various chemicals. These PELs, found in 29 CFR 1910.1000 Table Z-1, identify the maximum concentrations of different chemicals and materials an employee can be exposed over the course of an 8-hour work shift. Employees exposed to airborne concentrations of a material above a PEL may be at risk for serious health hazards. Continue reading “When Should You Retest Your Indoor Air Quality?”

Every year, the Georgia Environmental Protection Division (EPD) requires that certain Title V major source facilities submit their air emission data to the state. EPD submits this emission data to the U.S. Environmental Protection Agency (EPA) as part of the National Emissions Inventory (NEI) released every three years. The NEI is a comprehensive and detailed estimate of air emissions comprising of data from State, Local, and Tribal air agencies across the country. This data is used by the agencies for rule development, attainment/nonattainment designations, and State Implementation Plans (SIPs) for attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). Continue reading “2019 Air Emission Inventory Reporting – Georgia”

On September 6, 2019, the EPA published a proposed amendment to what is commonly referred to as the Plywood or Kiln MACT. This proposed amendment does not address lumber kiln emission standards. EPA has stated that the lumber kiln emission and work practice standards will be addressed in a later proposed amendment.

This proposed amendment to 40 CFR 63, Subpart DDDD: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plywood and Composite Wood Products (PCWP) is based on the completion of the residual risk and technology review. The review has found that no revisions are necessary to the current controls in the original rule. The rule does propose removal of the startup, shutdown, and malfunctions plans as EPA has deemed this to be sufficiently addressed in the work practice standards of the regulation, as well as by the Clean Air Act (CAA).

The proposed rule is open to comments until October 21, 2019. All submissions must include Docket ID No. EPA-HQ-OAR-2016-0243-0034. The EPA encourages that comments be submitted through the Federal eRulemaking Portal located at https://www.regulations.gov/.

If you need help identifying how this proposed rule change will affect your facility or need assistance with providing comments to the EPA, please contact us at (770) 263-6330 or cti@conversiontechnology.com.

The Emission Inventory for Georgia facilities is due to the Georgia Environmental Protection Division (GAEPD) by June 30, 2019. This is for the mandatory reporting of facility emissions that occurred in calendar year 2018. This is part of the US Environmental Protection Agency’s (USEPA) National Emissions Inventory (NEI). The NEI is developed during three-year cycle reporting periods, where all Title V (or Part 70) permitted sources will be required to report at least every third year. The other two years only comprise larger sources with greater emission potentials. The 2017 emission inventory required all Title V sources to report. The 2018 inventory due this year, and the 2019 inventory that will be due in 2020, is for the larger Title V sources only. Continue reading “Air Emission Inventory Due End of June”

Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the Environmental Protection Agency (EPA) or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random and infrequent.

Continue reading “Staying in Compliance with Air Quality Regulations”

Changes to EPA “Once In Always In” Policy for MACT Rules

On January 25th 2018, the EPA released a guidance memo reversing the “Once in Always in” (OIAI) policy regarding the classification of major source facilities subject to MACT (Maximum Achievable Control Technology) standards. A major source is defined as any facility which emits at least 10 tons of any Hazardous Air Pollutant (HAP), or 25 tons of any combination of HAPs. This policy, which has been in place since 1995, stated that any major source that becomes subject to a MACT rule must stay in compliance with that rule permanently, even if the facility finds a way to drop emissions below major source thresholds. Continue reading “Federal, State, and Local Changes to Air Permitting Requirements”

The US EPA mailed the ICR by registered mail to 391 facilities in the PCWP industry that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering National Emission Standards for Hazardous Air Pollutants (NESHAP) applicability.

 Recipients are asked to complete the ICR by February 9, 2018.

Continue reading “The EPA Information Collection Request (ICR) for Plywood and Composite Wood Products (PCWP) Was Mailed by the EPA and is Due February 9, 2018”

The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), for the “Plywood Composite Wood Products National Emission Standards for Hazardous Air Pollutants (NESHAP) Risk  and Technology Review (RTR)” (Kiln MACT) to the office of Management and Budget (OMB) for preview and approval.

This Kiln MACT applies to every sawmill that is a Major Source or Synthetic Minor Source for Hazardous Air Pollutants (HAP).

The ICR will be sent to all known operators of PCWP facilities that are major sources for hazardous air pollutants (HAP) regulated by the PCWP NESHAP and synthetic area sources that may have used technology to avoid major source status triggering NESHAP applicability. The information collection seeks to collect facility-level information (e.g. facility name, location, contact information, and process unit details), emissions information, compliance data, control information, and descriptions of technological innovations.

The EPA will either establish an emission limit or work practices in order to minimize emissions for process units included in the PCWP MACT source category. Capturing, controlling, and the measurements of kiln emissions is not feasible. Installing emissions capture and add-on control equipment for VOC/HAP removal have not been identified. It is therefore predicted that facilities will choose to use work practice requirements in lieu of emission limits.

The purpose of work practices is to minimize HAP emissions. For most kiln schedules, the HAP emissions increase near the end of the drying cycle when the wood reaches its final moisture content. HAP emissions increase as the moisture content decreases.

If you operate a lumber kiln, you will need to develop a plan for minimizing HAP emissions from the lumber kiln(s) by minimizing the annual average variability in dried lumber moisture content. Plans must be required to be submitted to the appropriate regulatory agency with your Notice of Compliance Status and you will need to maintain appropriate records of compliance with the work practices.

Changes in kiln operating temperatures can significantly affect mill operations and drying capacity. Lower kiln temperatures result in longer drying times. This is a production and capacity issue for mills. A mill operating four lumber kilns at full capacity at 225OF would have to add two more lumber kilns to dry the same amount of lumber at 180OF. To overcome the potential Kiln MACT limitation, facilities will need to prepare a compliance work practice plan that minimizes emissions with the least affect to drying production.

Shortly Major Source and Synthetic Minor Source of HAPs will receive an ICR survey. You will have 120 days after ICR mailout to submit it. CTI is experienced in this area in assisting many lumber mills in the permitting process that includes most of the information requested in the survey. CTI also has assisted facilities with ICR for other regulations in the past.

Upon receipt of the ICR, feel free to contact us for a proposal to assist you to prepare it. If you have any questions or need additional information, please contact us.