6 NYCRR Part 212. Ignorance is Bliss, But What You Don t Know Could Cost You

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1 6 NYCRR Part 212 Ignorance is Bliss, But What You Don t Know Could Cost You Tracey A. Karatas, P.E. Senior Engineer ERM Consulting & Engineering, Inc.

2 Contents I. Background A. Air Emission Sources B. Applicable Requirements C. NYS Air Permit Program D. 6 NYCRR Part 212 II. Information Required to Assess Part 212 Applicability & Compliance A. Physical Inventory B. Emission Calculations C. Applicable Requirements III. Assessment of Part 212 Applicability A. Identification of Emission Sources Subject to Part 212 B. Identification of Emissions Subject to Part 212 C. Identification of Emissions Subject to Part 212 Modelling IV. Air Quality Impact Analysis Requirements A. Air Dispersion Modelling Software Requirements B. Modelling Protocol Requirements C. Modelling Results V. Compliance Requirements of Part 212 A. Compounds with Emissions Less than Mass Emission Limit (if HTAC) or 100 Lb/yr (if Non-HTAC) B. Compounds that Require Modelling VI. Conclusions

3 I. Background A. Air Emission Sources Air contamination source or emission source: Any apparatus, contrivance or machine capable of causing emission of any air contaminant to the outdoor atmosphere, including any appurtenant exhaust system or air cleaning device. Where a process at an emission unit uses more than one apparatus, contrivance or machine in combination, the combination may be considered a single emission source. [6 NYCRR 200.1(f)]

4 I. Background B. Applicable Requirements Federal Regulations New Source Performance Standards (NSPS) Approx. 100 National Emission Standards for Hazardous Air Pollutants (NESHAP) more than 160 Other federal regulations State Regulations More than 20 air regulations in New York State that could be applicable to a facility. 4

5 Background C. New York State Air Permit Program An air permit is required to construct or operate an air emission source. Construction or operation of a new, modified or existing air contamination source without a registration or permit issued pursuant to this Part is prohibited. [6 NYCRR 200.1(f)] Types of Air Permits Title V Air Permit (5 yrs.) State Facility Air Permit (10 yrs.) Air Facility Registration (10 yrs.) 5

6 I. Background D. New York State Air Permit Program Air Permits Must Identify All Applicable Requirements 40 CFR 63 Subpart HHHHH 6 NYCRR CFR 60 Subpart SSS 40 CFR 63 Subpart EE 40 CFR 63 Subpart JJJJ 6 NYCRR NYCRR 212

7 I. Background D. 6 NYCRR Part 212 Applicability Part 212 applies to process emission sources and/or emission points associated with a process operation, unless excepted pursuant to [6 NYCRR (a)] Process Emission Source: Any apparatus, contrivance or machine, including any appurtenant exhaust system or air cleaning device capable of causing emissions of any air contaminant to the outdoor atmosphere from a process operation. Process operation: Any industrial, institutional, commercial, agricultural or other activity, operation, manufacture or treatment in which chemical, biological and/or physical properties of the material or materials are changed, or in which the material(s) is conveyed or stored without changing the material(s) if the conveyance or storage system is equipped with a vent(s) and is non-mobile, and that emits air contaminants to the outdoor atmosphere. A process operation does not include an open fire, operation of a combustion installation, or incineration of refuse other than by-products or wastes from a process operation(s). 7

8 I. Background D. 6 NYCRR Part 212 Types of Requirements in Part 212 Particulate emission standards Opacity standards Reasonably Available Control Technology (RACT) for emissions of Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx) Emission control requirements for emissions of air toxics 8

9 I. Background D. 6 NYCRR Part 212 History of Part 212 Air Toxics NYCRR Part 212 Processes and Exhaust and/or Ventilation Systems. Process Source Handbook (Chapters 3900 & 4100) NYSDEC Air Guide 1 developed (updated 1983, 1985, 1991, +++). Included Table of Chemicals with - Toxicity classifications - Annual Guideline Concentration (AGC) value - Short-term Guideline Concentration (SGC) value 9

10 I. Background D. 6 NYCRR Part 212 Revision of Part 212 Air Toxics Revised Part 212 became effective 14 June 2015 Supported by NYSDEC DAR-1 ( Guidelines for the Evaluation and Control of Ambient Air Contaminants Under Part 212, 10 Aug 2016) - Guidance - Updated AGC/ SGC Tables Timeline to address new Part 212 requirements 1. upon issuance of new or modified permit or registration 2. upon issuance of a renewal for an existing permit or registration 10

11 I. Background D. 6 NYCRR Part 212 General Requirements of Part 212 Air Toxics 1. Provisions for High Toxicity Air Contaminants (HTACs) Table 2 High Toxicity Air Contaminant List (only 6 of 61 chemicals are shown below) CAS Number Contaminant Name Mass Emission Limit (pounds per year) Formaldehyde 100 PB Trigger Applicable Carbon tetrachloride Aniline Diethyl sulfate Chloroform Benzene

12 I. Background D. 6 NYCRR Part 212 General Requirements of Part 212 Air Toxics 2. Emission Control Requirements Table 3 Degree of Air Cleaning Required for Criteria Air Contaminants Degree of Air Cleaning Required for Criteria Air Contaminants Gases and Liquid Particulate Emissions (Environmental Rating A, B, C or D) and Solid Particulate Emissions (Environmental Rating A or D) EMISSION RATE POTENTIAL (LBS/HR) Environmental Less 1 to 10 to 20 to to 1,000 1,500 4,000 10,000 or Rating than to 500 1,000 to 1,500 to 4,000 to 10,000 greater A NAAQS * 99% B NAAQS * 90% 91% 94% 96% 97% 98% C NAAQS * 70% 75% 85% 90% 93% 95% 99% or greater 98% or greater D NO AIR CLEANING REQUIRED 12 * Using air dispersion modeling demonstrate that the maximum offsite air concentration is less than the respective National Ambient Air Quality Standard.

13 I. Background D. 6 NYCRR Part 212 General Requirements of Part 212 Air Toxics 2. Emission Control Requirements Table 4 Degree of Air Cleaning Required for Non-Criteria Air Contaminants Degree of Air Cleaning Required for Non-Criteria Air Contaminants Gases and Liquid Particulate Emissions (Environmental Rating A, B, C or D) and Solid Particulate Emissions (Environmental Rating A or D) EMISSION RATE POTENTIAL Environmental Rating Less than 0.1 lbs/hr and lbs/yr PB trigger 0.1 to 1 lbs/hr or lbs/yr > PB trigger 1 to 10 lbs/hr 10 to 25 lbs/hr Greater than 25 lbs/hr A Guideline Concentration* 90% 99% 99.5% 99.5% B Guideline Concentration* 90% C Guideline Concentration* 75% D NO AIR CLEANING REQUIRED * Using air dispersion modeling demonstrate that the maximum offsite air concentration is less than the respective National Ambient Air Quality Standard. 13

14 I. Background D. 6 NYCRR Part 212 General Requirements of Part 212 Air Toxics 2. Emission Control Requirements Environmental ratings are determined by NYSDEC. Environmental ratings are generally based upon the toxicity classification in DAR-1 NYSDEC has the ability to increase the environmental rating if the ambient air concentration is above the AGC and/or SGC value in DAR-1. Air dispersion modeling must be performed to demonstrate that the ambient air concentration is below the AGC and/or SGC value in DAR-1. 14

15 II. Information Required to Assess Part 212 Applicability & Compliance A. Physical Inventory Sources Exempt from Permitting (Sources are exempt from Part 212) Emission Source Description Permit Exemption Description of Permit Exemption Sources Subject to Permitting (Sources must be reviewed to determine whether they are subject to Part 212) Emission Source ID Emission Source Description Control ID Control Description Emission Point ID 15

16 II. Information Required to Assess Part 212 Applicability & Compliance B. Emission Calculations for All Emitted Contaminants Facility Potential to Emit (PTE) justifies type of permit issued by NYSDEC - May be a starting point for Part 212 evaluation - Calculations may by done for criteria contaminants, including (but not limited to) Carbon Monoxide Nitrogen Oxides (NOx) Particulate Matter Sulfur Dioxide Volatile Organic Compounds (VOCs)** Hazardous Air Pollutants (HAPs)** ** Information may be of limited value as will require chemicals to be speciated. 16

17 II. Information Required to Assess Part 212 Applicability & Compliance B. Emission Calculations for All Emitted Contaminants Emission Calculations by Source and/or Emission Point (IDEAL) Emission Rate Potential (ERP): The maximum rate at which a specified air contaminant from an emission source would be emitted to the outdoor atmosphere in the absence of any control equipment... The maximum emission rate used for calculating the emission rate potential is not the emission rate during catastrophic or malfunction conditions. [6 NYCRR 200.1(u)] Control Efficiency (%) - Actual control efficiency - Enforceable control efficiency Actual Annual Emissions (Use as reference) Strategy to Ensure that Emissions are Conservative - Maintain future flexibility - Minimize potential for operational limitations in the permit 17

18 II. Information Required to Assess Part 212 Applicability & Compliance C. Applicable Requirements for Each Source Permit will be a starting point to identify regulations. Understand regulations that are applicable to each source. Understand requirements identified in the permit that may limit emissions, i.e., - Emission caps; - Material throughput limitations; - Required use of emission control and control efficiency 18

19 III. Assessment of Part 212 Applicability A. Identification of Emission Sources Subject to Part 212 The following emission sources are not subject to Part 212: Emission sources exempt from permitting. Emission sources that do not qualify as a process emission source - stationary combustion installations - conveyance or storage system not equipped with a vent Other emission sources exempted under , including - iron and steel processes subject to Part dry cleaning facilities subject to Part gasoline dispensing sites and transport vehicles subject to Part

20 III. Process to Assess Part 212 Applicability B. Identification of Emissions Subject to Part 212 The following emissions are not subject to Part 212: Emissions not subject to permitting, including - carbon dioxide and methane, except where specifically regulated by a Federal or State law or regulation Other emissions listed in that are unconditionally exempted, including - emissions of NOx produced by catalytic or thermal oxidizers. - emissions of oxides of sulfur, attributable solely to sulfur in fuel. - emissions of carbon monoxide or VOCs produced solely to incomplete combustion of any fuel, except where produced under oxygen deficient conditions by design. 20

21 III. Process to Assess Part 212 Applicability B. Identification of Emissions Subject to Part 212 Some emissions are conditionally exempted from Part 212.: Conditional exemptions in include: - process emission sources subject to Subpart or process emission sources exempt from Subpart 228-1, only with respect to emissions of VOCs that are not given an A rating ; - pharmaceutical and cosmetic manufacturing process operations subject to Part 233 of this Title and process operations exempt from Part 233 of this Title pursuant to Section 233.1(g), only with respect to emissions of VOCs that are not given an A rating Emissions that are conditionally exempt must be included in an air dispersion modeling analysis to demonstrate that the ambient impacts do not warrant an environmental rating of A. 21

22 III. Process to Assess Part 212 Applicability C. Identification of Emissions Subject to Part 212 Modeling The following emissions will require air dispersion modeling: HTAC emissions where total from Part 212-regulated sources are greater that the Mass Emission Limit; Emissions of all air contaminants that are not regulated by an applicable NSPS or NESHAP; Emissions of all air contaminants that are regulated by an applicable NSPS or NESHAP, only if the contaminant is also emitted by a source that is not regulated by a NSPS or NESHAP for that contaminant. 22

23 IV. Air Quality Impact Analysis Requirements A. Air Dispersion Modeling Software Calculations using Cavity Method are no longer acceptable. USEPA AERSCREEN Modeling Software (use current version) conservative estimation of air emission concentration each source modeled individually does not require submission/approval of an air dispersion modeling protocol before results are submitted to NYSDEC USEPA AERMOD Modeling Software (use current version) more-refined estimation of air emission concentration each source modeled concurrently custom meteorological data sets provided by NYSDEC requires submission/approval of an air dispersion modeling protocol NOTE RE. AERMOD in screen mode : NYSDEC recently indicated that use of the screen mode will now require the submission and approval of an air dispersion modeling protocol. 23

24 IV. Air Quality Impact Analysis Requirements B. Air Dispersion Modeling Protocol Must be submitted and approved by NYSDEC if use AERMOD Cost to develop Modeling Protocol Approval time by NYSDEC Modeling considerations - operating scenarios for equipment - equipment that cannot be simultaneously operated 24

25 IV. Air Quality Impact Analysis Requirements B. Modeling Results and Report Compare the predicted 1-hour model concentration against the SGC value Compare the predicted annual model concentration against the AGC value EXAMPLE Air Contaminant Modeling Analysis Air Contaminant CAS No. Toxicity Rating Initial Env l Rating SGC (μg/m 3 ) Facility 1-Hr Conc. (μg/m 3 ) Below SGC? AGC (μg/m 3 ) Facility Annual Conc. (μg/m 3 ) Below AGC? formaldehyde* High A Yes No *HTAC methanol Medium B 33,000 3,864 Yes 4, Yes N-butanol Low C ,500 3 Yes

26 V. Compliance with Part 212 A. Compounds with Emissions Less than Mass Emission Limit (if HTAC) or 100 lb/yr (if Non-HTAC) 1. If facility emissions of the HTAC will not exceed the Mass Emission Limit. Maintain annual emissions of the compound below the Mass Emission Limit. Annual emission limitation will be added to permit. 2. If facility emissions of the non-htac will not exceed 100 lb/yr. Maintain annual emissions of the compound below 100 lb/yr. Annual emission limitation may or may not be required. 26

27 V. Compliance with Part 212 B. Compounds that Require Modeling 1. If air dispersion modeling demonstrates that the ambient impact is less than the AGC/SGC. For emissions that are regulated by an NSPS: Part 212 is satisfied if - operate in compliance with the NSPS. For emissions that are regulated by a NESHAP: Part 212 is satisfied if - operate in compliance with the NESHAP, and - provide a Toxicity Impact Assessment (TIA) for HTAC(s) that demonstrates that the ambient impacts are less than the AGC/SGC For emissions that are not regulated by NSPS/NESHAP: - ensure level of emission control dictated by Part 212 Table 4, or - submit a Toxic Best Available Control Technology (T-BACT) evaluation for non-criteria air contaminants (or BACT evaluation for criteria air contaminants) for NYSDEC approval. T-BACT or BACT: A case-by-case evaluation that considers the following parameters to reduce emissions: (i) process, fuels and raw material available and to be used; (ii) use of various types of control technology; (iii) process and fuel changes; (iv) respective costs of identified control technologies, process changes, alternative fuels, etc.; and the (v) toxicity of the air contaminant. 27

28 V. Compliance with Part 212 Emission Control Requirements Table 4 Degree of Air Cleaning Required for Non-Criteria Air Contaminants Degree of Air Cleaning Required for Non-Criteria Air Contaminants Gases and Liquid Particulate Emissions (Environmental Rating A, B, C or D) and Solid Particulate Emissions (Environmental Rating A or D) EMISSION RATE POTENTIAL Environmental Rating Less than 0.1 lbs/hr and lbs/yr PB trigger 0.1 to 1 lbs/hr or lbs/yr > PB trigger 1 to 10 lbs/hr 10 to 25 lbs/hr Greater than 25 lbs/hr A Guideline Concentration* 90% 99% 99.5% 99.5% B Guideline Concentration* 90% C Guideline Concentration* 75% D NO AIR CLEANING REQUIRED * Using air dispersion modeling demonstrate that the maximum offsite air concentration is less than the respective National Ambient Air Quality Standard. 28

29 V. Compliance with Part 212 B. Compounds that Require Modeling 2. If modeling demonstrates that ambient impact is greater than the AGC. For sources that are subject to a NSPS that regulates the specific HTAC: Part 212 is satisfied if operate in compliance with the NSPS. For all other sources, submit a Toxic BACT Analysis. 3. If modeling demonstrates that ambient impact is greater than the SGC. Submit a Toxic BACT Analysis. NOTE: If exceedance of SGC is expected to occur on an infrequent basis, contact NYSDEC to discuss probability and frequency of SGC exceedence. 29

30 VI. Conclusions Facility must address Part 212 applicability and compliance requirements when renewing or modifying the permit. Evaluating and complying with Part 212 can be complicated. Information to perform evaluation that may not be up-to-date (or available). - current inventory of emission sources that are subject to permitting - detailed emission rate calculations for all air contaminants An air dispersion modeling analysis will most likely be required. A strategic approach should be utilized to ensure that operational flexibility is not compromised. Addressing Part 212 requirements could add costs and time that include: - Emission inventory and calculations; - Air dispersion modeling (including costs to develop/submit Air Dispersion Modeling Protocol); - T-BACT or BACT Assessments; and - Installation of emission control. 30

31 Any Questions? 31

32 Contacts Tracey A. Karatas Senior Engineer Northeast Business Unit T (585) E Tracey.Karatas@erm.com 32

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