1. Working with Agencies
March 26, 2019
Kale Walch

2. 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

3. 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 for interpretations
Use the agency’s knowledge
Understand your permit
Use the citations to look up the rules

4. 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

5. 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

6. Stack Design

7. Weather impacts

8. Miscommunications

9. 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

10. 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

11. 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

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

13. 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

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

15. Government Apps and Technology
PCAQCD forecast
AirNow (
Twitter
MyDEQ (
Pipeline and Hazardous Materials Safety Administration (
ERG 2016 free app (National Library of Medicine)
Chemical Safety Board (
Training Videos

16. Contact information
Kale Walch Hexcel (office) (cell)