Air Quality 101Air Quality 101

Kansas Air Quality Program Kansas Air Quality Program overviewoverview

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Kansas Air Quality Program Kansas Air Quality Program overviewoverview

Provide brief history of CAA Provide brief history of CAA and Kansas Air Quality and Kansas Air Quality ProgramProgram

Explain what it means to Explain what it means to your businessyour business Calculating your PTECalculating your PTE

Explain related features Explain related features NSR (reform)NSR (reform) Preconstruction reviewPreconstruction review Operating permitsOperating permits NSPSNSPS

Goal of protecting health Goal of protecting health and the environmentand the environment

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History of air regulationsHistory of air regulations

1273 – England1273 – England King Edward banned use of sea coalKing Edward banned use of sea coal

1881 – Chicago1881 – Chicago City passes first smoke control lawCity passes first smoke control law Adopted by other cities in 1990sAdopted by other cities in 1990s

1945 – Los Angeles 1945 – Los Angeles Air pollution control district formedAir pollution control district formed

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CatalystsCatalysts

1930 – Belgium1930 – Belgium 63 deaths 63 deaths Smelters and Smelters and

sulfuric acidsulfuric acid 1948 – 1948 –

PennsylvaniaPennsylvania 20 deaths20 deaths Steel mill and Steel mill and

sulfuric acid plantssulfuric acid plants

1952 – London1952 – London 4,000 deaths4,000 deaths

1953 – New York1953 – New York 250 deaths250 deaths

1956 – London1956 – London 1,000 deaths1,000 deaths

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The response…The response…

1955 - Congress passed the Air 1955 - Congress passed the Air Pollution Control Act (first Pollution Control Act (first commitment of federal funds)commitment of federal funds)

1963 – Clean Air Act1963 – Clean Air Act 1965 – Motor Vehicle Air Pollution 1965 – Motor Vehicle Air Pollution

Control ActControl Act 1967 - Air Quality Act1967 - Air Quality Act

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The response…The response…

1970 - EPA formed 1970 - EPA formed 1970 – Clean Air Act Amendments: 1970 – Clean Air Act Amendments:

NAAQS, SIPs, NSPS, NESHAPsNAAQS, SIPs, NSPS, NESHAPs 1977 – Clean Air Act Amendments1977 – Clean Air Act Amendments 1990 – Clean Air Act Amendments1990 – Clean Air Act Amendments 1990 – Pollution Prevention Act 1990 – Pollution Prevention Act

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NESHAP vs. MACT NESHAP vs. MACT 1970 Section 112 provisions1970 Section 112 provisions

EPA had to identify hazardous air pollutants EPA had to identify hazardous air pollutants (HAPs) and identify standards to prevent any (HAPs) and identify standards to prevent any adverse human health effects with “ample margin adverse human health effects with “ample margin of safety.”of safety.”

All risk-basedAll risk-based Courts directed EPA to determine safe air Courts directed EPA to determine safe air

pollutant levels without technological or cost pollutant levels without technological or cost concerns (NESHAP).concerns (NESHAP).

1990s1990s Congress saw setting health-based standards too Congress saw setting health-based standards too

long and difficult, so initiated new “technology-long and difficult, so initiated new “technology-based standards. Maximum Achievable Control based standards. Maximum Achievable Control Technology (MACT).Technology (MACT).

**Afternoon session on MACTsAfternoon session on MACTs

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1990 Clean Air Act 1990 Clean Air Act overviewoverview Title 1: Ambient air quality standardsTitle 1: Ambient air quality standards

Title 2: Mobile sourcesTitle 2: Mobile sources Title 3: Hazardous air pollutantsTitle 3: Hazardous air pollutants Title 4: Acid rainTitle 4: Acid rain Title 5: Operating permitsTitle 5: Operating permits Title 6: Ozone protectionTitle 6: Ozone protection Title 7: EnforcementTitle 7: Enforcement Title 8: MiscellaneousTitle 8: Miscellaneous Title 9: Clean air researchTitle 9: Clean air research Title 10: Disadvantaged businessesTitle 10: Disadvantaged businesses Title 11: Employment transitionTitle 11: Employment transition

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Kansas Air Quality Kansas Air Quality RegulationsRegulations

KAR 28-19KAR 28-19 The Kansas Air Quality Act (KAQA) The Kansas Air Quality Act (KAQA)

implements elements of the 1990 Clean implements elements of the 1990 Clean Air Act Amendments.Air Act Amendments.

Administered by the Kansas Administered by the Kansas Department of Health and Environment Department of Health and Environment Bureau of Air and RadiationBureau of Air and Radiation

KAQA includes the following KAQA includes the following requirements for air pollution sources requirements for air pollution sources in Kansas…in Kansas…

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Kansas Air Quality ActKansas Air Quality Act

Preconstruction reviewPreconstruction review Operating permitsOperating permits Annual air emissions feesAnnual air emissions fees Other air requirementsOther air requirements

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What this means to your What this means to your businessbusiness

Assess your air emission sources for Assess your air emission sources for compliance with the KAQA.compliance with the KAQA.

Existing sources not permittedExisting sources not permitted New businesses or sourcesNew businesses or sources Existing sources permitted, modifying or Existing sources permitted, modifying or

adding new equipmentadding new equipment Determine KAQA applicability and maintain Determine KAQA applicability and maintain

records on site (not unlike RCRA records on site (not unlike RCRA determinations).determinations).

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Steps to making a Steps to making a determinationdetermination

Identify all emission sources (units or Identify all emission sources (units or processes) at your facility.processes) at your facility. Activity that emits or has the potential Activity that emits or has the potential

to emitto emit Does not necessarily have to be Does not necessarily have to be

connected to a stack or ventconnected to a stack or vent Identify the pollutants being emitted.Identify the pollutants being emitted.

Use MSDS, contact vendorsUse MSDS, contact vendors NOx, SOx, CO, VOC, PM, HAPNOx, SOx, CO, VOC, PM, HAP

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Steps to making a Steps to making a determinationdetermination

Calculate your actual emissions and Calculate your actual emissions and then your PTE or “potential to emit.”then your PTE or “potential to emit.”

Based on your PTE, do you trigger Based on your PTE, do you trigger standards?standards? PreconstructionPreconstruction Operating permitsOperating permits

Do you trigger other emission Do you trigger other emission standards based on equipment type standards based on equipment type or HAP use?or HAP use?

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What is potential to What is potential to emit?emit?

The maximum amount of air pollution your The maximum amount of air pollution your facility can emit iffacility can emit if Each process is operated at 100% of its physical Each process is operated at 100% of its physical

and operational capacity.and operational capacity. All equipment is operating 24 hours per day, 365 All equipment is operating 24 hours per day, 365

days per year (8,760 hours per year).days per year (8,760 hours per year). Materials that emit the most air pollution are Materials that emit the most air pollution are

processed 100% of the time.processed 100% of the time. No pollution control equipment is used.No pollution control equipment is used.* * See SBEAP fact sheetSee SBEAP fact sheet

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Potential to emitPotential to emit

Calculation methodsCalculation methods Emission factorsEmission factors Material balancesMaterial balances Other approved methodsOther approved methods

Computer programsComputer programs Industry-specific emission factorsIndustry-specific emission factors Approved by KDHE on an individual basisApproved by KDHE on an individual basis

Represent the source’s maximum Represent the source’s maximum capacity or worst case scenario capacity or worst case scenario emissionsemissions

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Potential to emitPotential to emit

Emission factorsEmission factors Manufactures emission factors are bestManufactures emission factors are best Ap-42 is a compilation of factors for Ap-42 is a compilation of factors for

specific processes accepted by EPAspecific processes accepted by EPA http://www.epa.gov/ttn/chief/ap42/index.hthttp://www.epa.gov/ttn/chief/ap42/index.ht

mlml

Emission factor software and toolsEmission factor software and tools http://www.epa.gov/ttn/chief/efpac/http://www.epa.gov/ttn/chief/efpac/

efsoftware.htmlefsoftware.html

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Potential to emitPotential to emit

Material balance:Material balance: Product in = product out (assumes Product in = product out (assumes

constant inventory)constant inventory) Product in can be the purchased Product in can be the purchased

material.material. Product out can be the emissions.Product out can be the emissions. Material balance can be applied to Material balance can be applied to

individual units or the whole process.individual units or the whole process.

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Potential to emit Potential to emit SBEAP fact sheetSBEAP fact sheet

Here’s how to calculate your potential to emit Here’s how to calculate your potential to emit (Tab 5)(Tab 5)

Material balance example – most Material balance example – most common method for solvent emissions common method for solvent emissions (painting, coating, printing)(painting, coating, printing)

Emission factor example – most common Emission factor example – most common for non-solvent emissions (oil-fired boiler)for non-solvent emissions (oil-fired boiler)

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Does the PTE trigger Does the PTE trigger standards?standards?

Total all PTE emissions at your facilityTotal all PTE emissions at your facility Compare against KAQA standardsCompare against KAQA standards

Preconstruction standards Preconstruction standards

Operating permitsOperating permits

Other requirement Other requirement

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KAQA standardsKAQA standards

Existing ProgramExisting Program Preconstruction Preconstruction

categories 28-19-300categories 28-19-300 ApprovalsApprovals PermitsPermits

Operating permitsOperating permits Class IClass I Class IIClass II Class IIIClass III General permitsGeneral permits

New ProgramNew Program Preconstruction Preconstruction

categories categories (new fact (new fact sheet)sheet) Registration Registration ApprovalApproval

Operating permitsOperating permits Class IClass I Class IIClass II (Class III)(Class III) (General)(General)

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Class IClass I

If your PTE exceeds these If your PTE exceeds these thresholds, then you’ll need a Class I thresholds, then you’ll need a Class I operating permit:operating permit: 100 tons per year NOx, SOx, PM10, 100 tons per year NOx, SOx, PM10,

VOC, COVOC, CO 10 tons per year of any 10 tons per year of any singlesingle

hazardous air pollutant (HAP)hazardous air pollutant (HAP) 25 tons per year of 25 tons per year of combinedcombined HAPs HAPs

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Class IIClass II

If your actual emissions are below the If your actual emissions are below the Class I thresholds but your PTE is above Class I thresholds but your PTE is above – then you can – then you can limitlimit your PTE and apply your PTE and apply for a Class II operating permit.for a Class II operating permit.

A Class II permit requires minimal record A Class II permit requires minimal record keeping and is simpler (and cheaper) keeping and is simpler (and cheaper) than maintaining a Class I permit.than maintaining a Class I permit.

Class II permit-by-rule (KAR 28-19-561 - Class II permit-by-rule (KAR 28-19-561 - 564)564)

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Solvent evaporative Solvent evaporative sourcessources

Class II permit-by-rule for solvent users (9 Class II permit-by-rule for solvent users (9 ton rule) KAR 28-19-562ton rule) KAR 28-19-562

Purchase or use less than 9 tons of Purchase or use less than 9 tons of VOC’s or HAPs or both in a 12-month VOC’s or HAPs or both in a 12-month periodperiod Don’t have to calculate PTE, just need to Don’t have to calculate PTE, just need to

maintain records to show below 9 tonsmaintain records to show below 9 tons If exceed 9 tons in 12-months have 60 days If exceed 9 tons in 12-months have 60 days

to notify and apply for a Class II operating to notify and apply for a Class II operating permitpermit

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Limit your PTE byLimit your PTE by

Implementing pollution preventionImplementing pollution prevention Change the materialChange the material Change the processChange the process Change the technologyChange the technology

Limiting your process rateLimiting your process rate Limiting hours of operationLimiting hours of operation Limiting amount of material processesLimiting amount of material processes Installation of a pollution control deviceInstallation of a pollution control deviceMust be federally enforceableMust be federally enforceable

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Other air requirementsOther air requirements

New Source Performance Standard New Source Performance Standard (NSPS)(NSPS)

Trigger a NESHAP or MACT standardTrigger a NESHAP or MACT standard Located in Johnson and Wyandotte Located in Johnson and Wyandotte

Counties subject to RACT rulesCounties subject to RACT rules Have an incineratorHave an incinerator

New Source Review (NSR) ReformNew Source Review (NSR) Reform

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New Source Performance New Source Performance StandardStandard

Applies to newly constructed, Applies to newly constructed, reconstructed, or modified sourcesreconstructed, or modified sources

Based on date of construction, Based on date of construction, reconstruction, or modificationreconstruction, or modification

KAR 28-19-720 40 CFR Part 60KAR 28-19-720 40 CFR Part 60

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Questions? Questions? Our goal is Our goal is

protection of protection of human health and human health and the environment.the environment.

Our mission is to Our mission is to help small help small businesses comply businesses comply with environmental with environmental regulations and regulations and identify pollution identify pollution prevention prevention opportunities.opportunities.

www.sbeap.orgwww.sbeap.org