Regulatory Drivers for Reducing Solvent Emissions Barbara Johnson, PE Kansas State University Kansas Small Business Environmental Assistance Program March 10,

Presentation Overview Kansas air regulation overview –Construction permits –Operating permits NESHAP – HHHHHH Regulatory drivers 2

Air regulations KAQA Standards –Air construction approval/permit –Operating permit NSPS (New Source Performance Standards) PSD (Prevention of Significant Deterioration) NESHAP (National emission standard for hazardous air pollutants) / MACT (Maximum achievable control technology) 3

Future Additions or Modifications Evaluate PTE for new or modified equipment If PTE exceeds construction approval or permit thresholds, contact KDHE –Thresholds: –Forms: 4

Construction Approval If your PTE exceeds these thresholds, then you’ll need a construction approval: Source: What is the Kansas Air Quality Act? - 5

Construction Permit If your PTE exceeds these thresholds, then you’ll need a construction permit: Source: What is the Kansas Air Quality Act? - 6

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 7

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 ) 8

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 9

Permitting Web site Includes forms for: –Construction approvals –Construction permits –Operating permits (Class I and II) –Emergency generators – Small boilers 10

NESHAP and MACT –NESHAP (National Emission Standards for Hazardous Air Pollutants) –MACT (Maximum Achievable Control Technology) are technology-based standards –Apply to sources of HAPs (hazardous air pollutants) –Known or suspected to cause cancer or other serious health affects 11

HHHHHH Affected Sources 1.Paint stripping operations using methylene chloride (MeCl) to remove dried paint from wood, plastic, metal or other substrates 2.Spray-applied surface coating operations on motor vehicles and mobile equipment –including both stationary operations at fixed locations, and mobile repair and refinishing operations 3.Spray-applied surface coating operations on other metal or plastic parts or products with coatings containing target HAPs (i.e. Cr, Pb, Mn, Ni, or Cd)

New Sources A source is only new if it commenced construction after September 17, 2007 by installing new paint stripping or surface coating equipment, and it had no paint stripping or miscellaneous surface coating activity prior to that date

Compliance Dates New sources must be in compliance by January 9, 2008 or by initial startup thereafter –Initial notification by July 7, 2008 or 180 days after initial startup thereafter Existing sources must be in compliance by January 9, 2011 –Initial notification by January 11, 2010

Most Important Exemptions Hobby exemption Exemption by petition Use of 3 oz cup or less Facility maintenance exemption

Basic HHHHHH Compliance Paint stripping 1.Minimize MeCl emissions 2.Written plan for > 1 ton MeCl annual usage Spray-applied surface coating 1.Apply in filtered enclosure 2.HVLP guns or equivalent 3.Limit spray gun cleaning overspray 4.Painter training

Reminder! 1:00 p.m. optional session SBEAP will assist with air quality permitting and regulatory questions Sedgwick Room 17

Why reduce solvents? Avoid regulatory requirements –Permits –Notifications –Recording keeping requirements –Annual fees –Annual emissions inventory 18

Regulatory drivers Permits may limit emissions NESHAP may require change in materials NESHAP may require change in process NESHAP may require change in technology 19

Questions or Comments? Contact Information Barb Johnson Nancy Larson