Using a Flexible Compliance Strategy to Issue a Title V Operation Permit Steven Klafka, PE, DEE Wingra Engineering, S.C. A&WMA Conference 2002 Wingra Engineering, S.C. Full text available at: www.wingraengineering.com

Case Study Title V experience of a WI iron foundry. Some processes grandfathered and subject to lenient limitations. (i.e. Allowable PM = 17.31P0.16) Use of roof vents and short stacks. Compliance with air quality standards via dispersion modeling never evaluated. Wingra Engineering, S.C.

Challenge Application initially submitted in 1994. Agency modeling evaluation in 1999 predicted air quality standard violations. Initial emission estimates showed potential emission limit exceedences. Title V permit could not be issued. Compliance strategy needed. Wingra Engineering, S.C.

Initial Agency Modeling Results Wingra Engineering, S.C.

Development of Compliance Strategy Update 1994 inventory of stacks, vents, control equipment and processes. Improve emission estimates from published data or stack tests. Assure compliance with emission limitations. Assure compliance with air quality standards by internal dispersion modeling analysis. Wingra Engineering, S.C.

Review Facility Inventory Facility expanded since 1994. Updated process and stack inventory to reflect current configuration --- 112 roof vents or stacks 32 processes 83 buildings or structures Wingra Engineering, S.C.

Existing Foundry Layout Wingra Engineering, S.C.

Review Emission Estimates Verify raw materials & production capacities. Update emission estimates using test results. Iron pouring operations exceeded PM limits. Uncontrolled emissions exhausted thru roof vents. Flagged for either testing or add-on controls. Wingra Engineering, S.C.

Review Air Quality Standards Analysis Dispersion modeling analysis using ISC3 National Ambient Air Quality Standards Acceptable Air Concentrations for air toxics Verify modeling by state agency. Update stack and emission inventory. Begin new internal modeling analysis. Wingra Engineering, S.C.

New PM Modeling Evaluation Evaluate PM first, then other pollutants. Agency PM results = 600 > 150 ug/m3 New PM results = 2,519 > 150 ug/m3 Identify culpable vents and stacks. Improve largest contributors to high PM concentrations. Wingra Engineering, S.C.

PM Compliance Improvements Incorporate new baghouse controls as needed to comply with state or anticipated MACT emission limitations for PM at 0.005 gr/acf. Consolidate roof vents into stacks. Raise stacks heights incrementally. Repeat until facility complies with NAAQS. Wingra Engineering, S.C.

Incremental Improvements via ISC3 Analysis Wingra Engineering, S.C.

Other Air Pollutants After PM compliance strategy finalized, other air pollutants evaluated for compliance with NAAQS and AAC. No additional changes necessary for other air pollutants to comply. Wingra Engineering, S.C.

Title V Application Amendment Original 1994 application amended with updated inventory, modeling analysis, and compliance strategy. Compliance strategy includes vent consolidation into stacks, stack height increases, baghouse installation, and imposition of emission limitations. Strategy referred to as Scenario #1. Wingra Engineering, S.C.

Issuance of a Flexible Permit Scenario #1 not specified in Title V permit Demonstrates one feasible compliance alternative. “X” lbs/hr PM emission limits for 22 processes. Serve as placeholders for final compliance plan. Compliance schedule included in Title V permit. Ten month deadline for compliance plan with final improvements and limitations. Deadlines for 50% and 100% completion. Deadline for compliance testing. Wingra Engineering, S.C.

Compliance Plan Development Title V permit issued in 2000. Initiate development of new compliance strategy. Identify processes requiring controls to comply with state and MACT limitations for PM. Initiate new round of air quality modeling. More time taken to evaluate compliance options. New strategy required fewer changes than Scenario #1. Submit compliance plan in 2001. Wingra Engineering, S.C.

Final Compliance Plan Vents & stacks reduced from 112 to 51. 5 new baghouses proposed with total capacity of 400,000 acfm. 22 new PM limitations established to replace “X” lbs/hr limits. Total capital investment $7.2 million over three years. Wingra Engineering, S.C.

Final Facility Layout Wingra Engineering, S.C.

Operation Permit Revision Agency will incorporate final compliance strategy as significant revision to permit. All revisions incorporated during renewal every five years. If necessary, additional facility changes will be incorporated during permit renewal. Wingra Engineering, S.C.

Summary Original Title V permit application could not be issued due to potential emission limitation and air quality standard violations. Viable compliance strategy developed to allow issuance of initial Title V permit. Title V permit included placeholder “X lbs/hr” limitations and compliance plan schedule. Flexible approach allowed issuance of Title V permit and time for development of a cost-effective compliance strategy. Wingra Engineering, S.C.