PTE. Potential to Emit

Transcription

1 PTE Potential to Emit

2 What is PTE? K.A.R 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.

3 What is PTE? 24-hour operation, 365 days per year Operate at maximum capacity No pollution control devices or practices

4 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

5 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

6 Primary thresholds 100 tons Major sources above the line Minor source below the line 25 tons 10 tons

7 Various thresholds Operating permit Class I (Title V) Class II Permit by rule NESHAP MACT NSPS RACT Construction permit Approval Permit

8 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)

9 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 through 564)

10 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

11 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: (helpful resource- Five steps to determine whether your facility needs an air permit) Forms:

12 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 -

13 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 -

14 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

15 SBEAP s air emissions tools

16 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)

17 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

18 PTE calculators input needed PTE calculator Painting/coating Boilers/furnace Engines Welding Grain elevator (being revised) Blasting (not yet posted) Plasma cutting (not yet posted) Possible info needed for PTE calculation (spreadsheet inputs) Density, VOC wt%, each HAP wt% (SDS); monthly usage amts; annual hrs operated; spray gun transfer efficiency; JO or WY county? Heat input capacity or HP, fuel burned, JO or WY county? Fuel burned; HP or power output/fuel heat input; emergency or non-e Welding process, electrode type, amt. wire/rod consumed Annual throughput, elevator type, Amt. blasting material, wind speed Steel type, steel thickness; cut dry, semidry, or wet; HAP in steel

19 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

20 Material balance calculations painting/coating emissions

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23 So you want to build/expand your facility/process

24 Step 1: Identify emissions What are possible emission sources from equipment performed at your facility?

25 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

26 Step 1: Identify emissions What are possible emission sources from activities performed at your facility?

27 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

28 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

29 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?

30 Step 4: Apply for the appropriate permit To be discussed in the next few sessions

31 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

32 Questions or comments? Contact information Barb Goode