Working with Agencies March 26, 2019 Kale Walch

Hexcel background Manufacturing of honeycomb blocks CAA permits RCRA On site since 1966 Dip Room RTOs for control of VOCs CAA permits PSD permit with BACT controls Title V operating permit RCRA Large Quantity Generator ISO 14001

Permits Permit applications Revisions Send comments on draft permits Pre-meeting with agency Explain the process Revisions Work with the agency before submitting Send comments on draft permits Call or email for interpretations Use the agency’s knowledge Understand your permit Use the citations to look up the rules

Permit Revisions Predictions are not always accurate Design changes Market changes Construction permit must be accurate Working with operations Permitting non-process or tangential items Leave enough time to obtain permit PCAQCD needs time to write the permit Public Comment period – 30 days EPA review period – 45 days

Stack Testing Protocol approval Requests for variances Opportunity to save time and money Might have to do it again Turn in timely Discussions between the agency and the source Miscommunication can be expensive Requests for variances Design impacts Some facility components were not built with stack testing in mind Weather impacts Safety, malfunctions

Stack Design

Weather impacts

Miscommunications

Inspection Entry Rights Utilized by City, County and State agencies Take the time to read Accompany inspector Take samples or read opacity with inspector Opacity readings versus screens Provisions designed to provide benefits for industry

Contractors Dust Permits Asbestos surveys Refrigeration servicing Who obtains the permit Who is responsible for dust control Asbestos surveys Stop and resolve problems Refrigeration servicing New rules Recycling, recharging, large units

Reporting and Recordkeeping Ask for interpretations Try not to procrastinate Use technology to your advantage Recent reductions in required reporting Facility Annual Report (FAR) MyDEQ defining who needs to submit Discharge Monitoring Reports (DMR) Pollution Prevention Plans (P2) going paperless

Wastewater Operations Work with the City Communication Reporting excursions Use their knowledge Total Suspended Solids monitoring

Enforcement Process Deviations Notice of Opportunity to Correct Notice of Violation Order of Abatement by Consent Many off ramps are built into the system The response is often more important than the original act Procrastination limits options typically increases costs

ISO 14001 Communication Log Calendar of events Outreach events Emergency Response Plan coordination Participation in voluntary programs Stakeholder participation ADEQ PCAQCD City Others

Government Apps and Technology PCAQCD forecast AirNow (https://airnow.gov/) Twitter MyDEQ (www.azdeq.gov) Pipeline and Hazardous Materials Safety Administration (https://www.phmsa.dot.gov/) ERG 2016 free app (National Library of Medicine) Chemical Safety Board (https://www.csb.gov/) Training Videos

Contact information Kale Walch Hexcel Kale.walch@hexcel.com 520-413-6407 (office) 520-840-2511 (cell)