PERMITTING INNOVATIONS

Transcription

1 PERMITTING INNOVATIONS TECHNICAL SUPPORT DOCUMENT FLEXIBLE AIR PERMITTING RULEMAKING MONITORING KNOWLEDGE BASE Flexible Packaging Association 2006 Environmental Summit and Safety Conference January 17-20, 2006

2 TECHNICAL SUPPORT DOCUMENT ISSUANCE 2

3 PURPOSE Summarize Final TSD Content Discuss Any Remaining Issues 3

4 BACKGROUND 1998: CSI Spin-off 2002: TSD Development : 80-Day Public Comment 2005: Final TSD 4

5 CHAPTER 1 OVERVIEW TSD CONTENTS CHAPTER 2 - TITLE V PERMITTING REQUIREMENTS CHAPTER 3 - MACT STANDARDS PERMITTING CHAPTER 4 - MONITORING AND PRACTICAL ENFORCEABILITY CHAPTER 5 - TESTING REQUIREMENTS CHAPTER 6 - ADDITIONAL PERMITTING APPROACHES APPENDICES 5

6 CHAPTER 1 OVERVIEW 1.1 WHAT IS THE PURPOSE OF THIS DOCUMENT? 1.2 HOW IS THIS DOCUMENT TO BE USED? 1.3 WHAT ARE THE TITLE V ISSUES RELATED TO THE PRINTING INDUSTRY? 1.4 HOW IS THIS REPORT ORGANIZED? 6

7 Table 1-1. Summary of Approaches For Addressing Title V and Other Permitting Issues for Printers CATEGORY/ISSUES APPROACH SECTION Title V Applicability How can owners or operators of major printing facilities determine potential-to-emit (PTE)? What are examples of monitoring, recordkeeping, reporting, and testing (MRRT) requirements that could be used for facilities interested in keeping minor source status? How can printing equipment be described in a title V permit? How can insignificant units and activities be treated? Our May 2002 guidance, Preferred and Alternative Methods for Estimating Air Emissions from the Printing, Packaging, and Graphic Arts Industry (EPA, 2002a), establishes one way to calculate volatile organic compound/hazardous air pollutant (VOC/HAP) emissions. Having the PTE calculation reflect the maximum hourly usage rate, the materials with the highest VOC/HAP content, and the maximum feasible hours of operation may establish an appropriate annual limit. Note that the PTE would be reduced after consideration of any enforceable limits on emissions, hours of operation, and/or material throughput. For sources below the major source threshold, one way to ensure minor source status is to limit the PTE under an enforceable general permit (or a facility s case-specific permit, if one exists), consistent with the printer type, control equipment, and monitoring approaches [see 40 Code of Federal Regulations (CFR) 70.6(d)]. Note that the mass-balance formula approach is generally available to permit writers for use in establishing compliance provisions with a PTE limit for other VOC emitting operations, as shown in the United States (U.S.) Environmental Protection Agency s (EPA s) 2002 Evaluation of Implementation Experiences With Innovative Air Permits - Results of the U.S. EPA Flexible Permit Implementation Review (EPA, 2002b). Consistent with 40 CFR 70.6(a)(3)(i)(A) and our July 10, 1995 guidance, White Paper for Streamlined Development of part 70 Permit Applications, (EPA, 1995a) equipment should be described in detail sufficient to be linked to applicable requirements. The information should also allow your inspectors to match each individual emissions unit observed during a plant visit with the permit s description for that unit. Only the requisite information regarding emissions limits from equipment descriptions should be included in the permit [see 40 CFR 70.6(a)(1)]. Consistent with 40 CFR 70.4(b)(14), 70.7(d) and (e): our July 10, 1995 guidance, White Paper for Streamlined Development of part 70 Permit Applications (EPA, 1995a) and our March 5, 1996 guidance, White Paper Number 2 for Improved Implementation of the part 70 Operating Permits Program, a permit can contain provisions to operate/add/delete any activities subject to only generally applicable requirements (GARs), provided that such activities meet all relevant GARs on the permit

8 CHAPTER 2 TITLE V PERMITTING REQUIREMENTS 2.1 WHAT ARE THE TITLE V APPLICABILITY CRITERIA THAT APPLY TO PRINTING FACILITIES? 2.2 HOW CAN OWNERS OR OPERATORS OF NEW SOURCES BE EXEMPT FROM TITLE V? 2.3 WHAT ARE THE APPLICABLE REQUIREMENTS? 8

9 Table 2-2. SUMMARY OF POTENTIALLY APPLICABLE REQUIREMENTS Product and Packaging Rotogravure or Wide-Web Flexographic (WWF) with Oxidizer Control Strategy Applicable Requirement Emissions/ Operating Limits Example SIP-RACT (all subject sources) 1 90% VOC destruction efficiency 65% overall control efficiency for packaging rotogravure and 60% for flexographic Generally applies to emissions from the application of inks and coatings by each individual printing press May apply hourly or daily with compliance based on performance test and monitoring of control system temperature(s) May require parameter monitoring for capture and control systems including development and submittal of compliance assurance monitoring (CAM) plan with the initial and/or renewal title V application [ ] Example NSR Requirements 1 Requirements generally follow SIP-RACT requirements with same or greater stringency for control of emissions Ranging from 70% to 98% overall control efficiency May include mass VOC emissions limits and/or mass VOC usage limits to hold potential emissions below permitting thresholds Generally applies to emissions from the application of inks and coatings by the individual new or modified press or collectively by a group of new/modified presses controlled by the same oxidizer Requirements established through preconstruction review NSPS (part 60) MACT (part 63) Subpart A Subpart FFF Subpart A (General (General Provisions) Provisions) No additional Applies to new New requirements [40 product rotogravure reconstructed CFR 60, subpart printing and/or major sources A]. coating of flexible must submit (sheet or web) vinyl application for or urethane products preconstruction (e.g., vinyl wallpaper, review by EPA, or upholstery) by State program [ (a)] that has been Packaging delegated MACT rotogravure and wide standard web flexographic enforcement printing are NOT responsibilities subject to subpart FFF [ 63.5] Applies to emissions from the application of inks and coatings by each new rotogravure printing line constructed after 1/18/83 [ (b)] 85% overall VOC control of each affected facility [ (a)(2)] Subpart A (General Provisions) Applies to major sources of HAPs with product and packaging rotogravure and WWF presses. Applies to all roto./flexo. presses (together) plus other optional equipment [ (a)(2)] Overall organic HAP control efficiency of at least 95% each month, or Emissions rate of no more than 0.2 kg organic HAP per kg. solids applied, monthly average, as-applied basis, or Emissions rate of no more than 0.04 kg organic HAP per kg material applied, monthly average, asapplied basis or option based on weighted calculations between alternatives [ (7), (8), (9), or (10)] 9

10 CHAPTER 3 MACT STANDARDS PERMITTING 3.1 OVERVIEW OF SUBPART KK 3.2 MAINTAINING COMPLIANCE FLEXIBILITY UNDER SUBPART KK 3.3 INTERFACE OF SUBPART KK WITH THE MACT GENERAL PROVISIONS 3.4 OVERVIEW OF SUBPART JJJJ 10

11 CHAPTER 4 MONITORING AND PRACTICAL ENFORCEABILITY 4.1 WHAT MONITORING IS APPROPRIATE UNDER THE CAM RULE? 4.2 WHAT MONITORING MAY BE AVAILABLE TO DEMONSTRATE COMPLIANCE WITH A PTE LIMIT? 4.3 HOW CAN MATERIALS MONITORING BE USED TO DEMONSTRATE COMPLIANCE? 4.4 WHAT MAY BE APPROPRIATE OPACITY MONITORING FOR CLEAN FUEL COMBUSTION? 4.5 SPECIFIC ISSUES RELATED TO MONITORING UNDER SUBPART KK 11

12 CHAPTER 5 TESTING REQUIREMENTS 5.1 WHAT ARE SOURCES OF MATERIAL COMPOSITION DATA? 5.2 WHAT ARE THE ISSUES CONCERNING THE USE OF M24 AND M24A WITHIN THE PRINTING INDUSTRY? 5.3 ARE NON-LITHOGRAPHIC PROCESSES ELIGIBLE FOR USE OF A RETENTION FACTOR TO ESTIMATE EMISSIONS FROM MANUAL CLEANING ACTIVITIES WHEN USING LOW VAPOR PRESSURE CLEANING SOLVENTS WITH SHOP TOWELS? 5.4 UNDER WHAT CONDITIONS CAN METHOD 25A (M25A) BE USED TO DETERMINE THE DESTRUCTION EFFICIENCY OF AN OXIDIZER? 12

13 CHAPTER 5 TESTING REQUIREMENTS (continued) 5.5 WHAT GENERAL PRINCIPLES ARE RELEVANT TO PERFORMING CONTROL DEVICE AND CAPTURE EFFICIENCY TESTING? 5.6 SPECIFIC ISSUES RELATED TO PERFORMANCE TESTS UNDER SUBPART KK 5.7 WHAT ARE THE APPROPRIATE PERFORMANCE TEST CONDITIONS? 5.8 HOW CAN DESTRUCTION EFFICIENCY REQUIREMENTS BE MET DURING PERIODS WITH LOW CONTROL DEVICE INLET CONCENTRATIONS? 13

14 CHAPTER 6 ADDITIONAL PERMITTING APPROACHES 6.1 OVERVIEW 6.2 STREAMLINING PERMITS FOR PRINTING FACILITIES 6.3 EXISTING PERMIT CONDITIONS RESTRICTING OPERATION 14

15 APPENDICES APPENDIX A - PRINTING INDUSTRY DESCRIPTION AND RELATIONSHIP TO GUIDANCE APPENDIX B - EXAMPLE APPLICABLE REQUIREMENTS APPENDIX C - MACT COMPLIANCE OPTIONS FOR COMPLIANCE COATINGS APPROACH 15

16 APPENDICES (continued) APPENDIX D - MONITORING PROTOCOLS FOR THE PRINTING AND FLEXIBLE PACKAGING INDUSTRIES APPENDIX E - EXAMPLE QA/QC PLAN FOR A SOURCE THAT MONITORS MATERIAL USAGE 16

17 FINAL TSD Available at: 17

18 FLEXIBLE AIR PERMITTING RULEMAKING 18

19 BACKGROUND 1992: Part 70 Regulations, AOS, 502(b)(10) 1994: Proposal Advance NSR 1995: Proposal AOS : Pilots 2000: White Paper #3, Draft Released for Comment 2006: FAP Rule Proposal 19

20 POTENTIAL BENEFITS Administrative Fewer Revisions Market Response Certainty Flexibility Environmental 20

21 MONITORING KNOWLEDGE BASE

22 MKB Website Objective Provide access to range of available monitoring from central site Audience General public Technical staff EPA, state, local, tribal personnel Industry personnel 22

23 MKB Website Design Approach Follow EPA web format and IT guidelines Layer access to information (basic to detailed) Provide links to existing information Minimizes development of new materials Access information via Control technology type Industry type 23

24 MKB Website Focus Basis Monitoring primer FAQs (with responses) Regulatory drivers for monitoring Monitoring techniques for different control types Monitoring requirements and techniques by industry type 24

25 MKB Initial Pollutants PM and VOC Controls Fabric Filters Wet Scrubbers Catalytic Oxidizers Condensers ESPs Thermal Oxidizers Carbon Adsorbers Absorbers 25

26 MKB Initial Pollutants PM and VOC Industries Printing and Publishing Pharmaceutical Batch Chemical Computer Chip Design Auto Manufacturing Surface Coating Fiberglass Resin 26

27 MKB Successes Provide organized access to information Basic monitoring concepts Monitoring approaches for control devices Monitoring examples (CAM and title V) Provide access to State permit websites 27

28 MKB Challenges Designing to accommodate broad range of knowledge Providing specific example monitoring requirements of permits Providing links to permits by industry type, emissions source, or control type 28

29 MKB Next Steps Incorporate PM Controls Expand to Include Other Source Categories Visit the MKB at 29