value of integrating air regulatory compliance and air pollution control with business strategies
TRANSCRIPT
Value of Integrating Air Regulatory Compliance and Air Pollution Control with Business StrategiesAir & Waste Management Association (A&WMA)109th Annual Conference & ExhibitionJune 20‐23, 2016New Orleans, LA
Who Needs a Permit?AIR POLLUTION CONTROL APPLICATIONS
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Regulatory Exemption Recordkeeping or Permits
AIR POLLUTION CONTROL APPLICATIONS
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Equipment or Operations that emits pollutants into atmosphere.
Equipment or Operations that emits pollutants into atmosphere.
If a permit to operate is
needed…so was a permit to construct.
If a permit to operate is
needed…so was a permit to construct.
Permits Required for Basic
Equipment.
Permits Required for Basic
Equipment.
Combustion‐based boilers, process heaters and steam generators
Internal combustion engines Bulk material transfer, storage, conveyance and
packaging Organic liquid storage Coating, adhesive and inking operations Solvent‐based operations Hot and warm mix asphalt production Plastic, rubber, leather and glass operations Commercial bakery ovens
Permitting for Basic Process EquipmentAIR POLLUTION CONTROL APPLICATIONS
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Industries/Operations That Require PermitsAIR POLLUTION CONTROL APPLICATIONS
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Food & Beverage Industry
Food & Beverage Industry
Commercial Baking Operations
Commercial Baking Operations
Food Flavoring & Ingredients
Food Flavoring & Ingredients
Commercial Printing
Commercial Printing
Data CentersData Centers Timber CompaniesTimber Companies Financial InstitutionsFinancial
InstitutionsCommercial &
Industrial CoolingCommercial &
Industrial Cooling
Coffee RoasterCoffee Roaster SmokehousesSmokehousesHospitalsHospitals
Federal Regulation Via Clean Air Act of 1990Clean Air Act requires EPA to regulate emissions of hazardous air pollutants from a published list of industrial [stationary] sources referred to as "source categories.”
Two Types of Pollutants
Air Regulatory OverviewAIR POLLUTION CONTROL APPLICATIONS
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Common Criteria Pollutant
Emissions – O3, CO, PM2.5/10, Pb, SO2, and NO2
Common Criteria Pollutant
Emissions – O3, CO, PM2.5/10, Pb, SO2, and NO2
EPA lists 187 Hazardous Air
Pollutants (HAPs)
EPA lists 187 Hazardous Air
Pollutants (HAPs)
Federal law, but state programs may be established to implement CAA at the local levelCalifornia legislature is the “legislative body” and established the Air Resources Board, and is further divided into 35 air jurisdictions (each of which may have differing rule implementation).
Minor New Source Review (NSR) Rule for Indian CountryEPA issued Tribal NSR under CAA establishes permit program for minor and major sources located in Indian Country.
Air Regulations: Complex and ContradictoryAIR POLLUTION CONTROL APPLICATIONS
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CARB and OEHHA list ~240 Toxic Air Compounds (TACs)
CARB and OEHHA list ~240 Toxic Air Compounds (TACs)
Types of PermitsAIR POLLUTION CONTROL APPLICATIONS
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Permit to Operate (PTO) identifies the specific
requirements or conditions that a facility must adhere to in order
to be in compliance.
Permit to Operate (PTO) identifies the specific
requirements or conditions that a facility must adhere to in order
to be in compliance.
Title V of the Federal Clean Air Act Amendments of 1990. Title V of the Federal Clean Air Act Amendments of 1990.
Permit to Construct (PTC) based on an approved permit
application.
PTCs are valid for a limited duration.
Permit to Construct (PTC) based on an approved permit
application.
PTCs are valid for a limited duration.
Title V Major Source facility potential to emit (PTE) of any criteria
pollutant or HAPs ≥ Major Source Thresholds (MST);
Major Source facility PTE
≥ 10 tons of any single HAP
≥ 25 tons of any combination of HAPs
MST for criteria pollutants vary depending on attainment/non‐attainment status of the
geographic area in which the facility is located – see next slide;
Local air jurisdiction may have authority to issue permits to operate, Title V permits must also be
reviewed by EPA prior to issuance;
Title V permits are required only for facilities that are Major Sources of a criteria pollutant(s) or
Hazardous Air Pollutants (HAPs);
Types of Permits Continued – Generally Major or Minor
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Air Regulatory Overview Continued
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Exceeding the National Ambient Air Quality Standard for a criteria pollutant will affectthe major source threshold (MST).
For example, Bay Area AQMD is Marginal for Ozone (O3) Extreme non‐attainment forO3 in South Coast AQMD and San Joaquin Valley APCD.
Air Regulatory Overview Continued
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Direct consequence: a facility that might be a minor source in one jurisdiction mightbecome a major source in another jurisdiction.
“But we don’t need a Title V permit for that at our Springfield facility.”
“Well you aren’t in Springfield anymore.”
Rules of Thumb1. Always review local air jurisdiction regulations.2. Always read your permits.3. If unsure, hire an air regulatory consultant.
Why Permits May Need to be RevisitedAIR POLLUTION CONTROL APPLICATIONS
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Mergers and AcquisitionsMergers and Acquisitions Company GrowthCompany Growth Due Diligence and
DiscoveryDue Diligence and
Discovery
Older or incomplete regulatory compliance framework Proper recasting or forecasting of “forward‐going, operational liability” Equipment or process modifications may require permitting/modifications
Develop a Robust Regulatory, Operations and Business Compliance Framework
Shows up on corporate sustainability metrics andbalance sheet
Helps to optimize or maximize production
So What Should We Do?AIR POLLUTION CONTROL APPLICATIONS
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SiteSite JurisdictionalJurisdictional StateState RegionalRegional NationalNational GlobalGlobal> > > > >
Work with a knowledgeable air permitting consultant who understands your business and the regulations
Know your emission factors and BACT Databases Develop and Implement robust O&M, compliance
procedures and systems – integrated with business and financial systems
Facility operations and corporate compliance work in unison
Communicate with you regulator Integrate all of the above with a data management
solution
How to AccomplishAIR POLLUTION CONTROL APPLICATIONS
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Achieve and maximize production and utilization
Maintain a robust compliance framework
Determine production methods and/or permits to be modified
Monitor and control equipment and process parameters
Validate emission credits
Ensure plant, employee and public safety
Public perception reports, corporate goodwill and environmental
justice
Why You Need a Data Management SolutionAIR POLLUTION CONTROL APPLICATIONS
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iEHS® is a comprehensive information management system for environmental, health, safety and sustainability
Measure, monitor, forecast & report performance Track accountability and manage change Use audits to ensure compliance Keep workers safe Prevent recurrence of accidents Retain and organize important information
Antea Group’s Data Management SolutionAIR POLLUTION CONTROL APPLICATIONS
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Questions?AIR POLLUTION CONTROL APPLICATIONS
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Ravi BhatiaConsultant+1 323‐229‐[email protected]
John BarryConsultant+1 512‐342‐[email protected]
Bill MacDonaldSenior Consultant+1 435‐645‐[email protected]
B E T T E R B U S I N E S S , B E T T E R WOR L D℠
Antea Group Offices
USA Headquarters5910 Rice Creek Parkway, Suite 100St. Paul, MN 55126, USAUSA Toll Free: +1 800 477 7411 International: +1 651 639 9443
BelgiumRoderveldlaan 12600 Antwerpen
ColombiaCalle 35 No. 7‐25, Piso 12Bogota, DC
France29 avenue Aristide Briand ‐ CS 1000694117 Arcueil Cedex
NetherlandsMonitorweg 291322 BK Almere
www.anteagroup.com