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LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permitting
November 14, 2001
Keith JordanEnvironmental Scientist Sr. OES/Permits Division(225) [email protected]
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Organization of Permits Division
H ilry L a n tzP e tro c h e m ic a l
B e th S c a rd in aM u n ic ip a l
& C o m m erc ia l W a s te
Je sse C h a n gL e v e l 1
In d u s tr ia l
J im D e la h o u ssa y eL e v e l 2
In d u s tr ia l
Jo d i M ille rR e g is tra t io n s
& C e rtific a tio n s
M ic h a e l V in ceA d m in is tra to r
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Reviewers by Section
o Petrochemical: 11
o Level 1: 13
o Level 2: 5
o Municipal/Commercial: 0
o Registrations/Certifications: 0
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Petrochemical Permits
o Catalyst Regeneratorso Ethanol plantso Herbicide Manufacturerso Organic Chemical Producerso Pesticide Manufacturerso Refineries
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Level 1 Industrial
o Bulk terminal/storage (petroleum)o Oil & Gas exploration, production
and developmento Pipelineso Paper mills / Sawmillso Ship/boat building & repair (includes
ships, boats, barges)o Power Generating
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Level 2 Industrial
o Concrete/Asphalt Plantso Auto Repair Shopso Transportation (Airports)o Food Processing Facilitieso Animal Farmso Machine Shopso Sandblasting/Painting
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Municipal and Commercial Waste
o Municipal Solid Waste Landfillso Commercial Hazardous Waste
treatment, storage, disposal facilitieso Municipal Sewage Treatment
Facilitieso Construction and Demolition Debris
Landfillso Waste Tire Processing
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permitting Program
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permitting Universe Criteria pollutants
• NOx, CO, SO2, VOC, PM Toxic Air Pollutants
• Federal and state list, ~200 total “Air contaminants” broad inclusion Universe of Sources
• ~ 800 criteria pollutant major sources• ~ 250 air toxic pollutant major sources• Very large universe of minor sources
Issue ~1000 permit actions yearly Issue ~1000 other actions yearly
• Applicability, exemptions, ownership
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permit Programo 2 Combined Federal Permit Programs
New Source Review (PSD, Nonattainment)
Operating Permit (Title V, Part 70)o History
Began air permitting in 1969, “grandfathered” existing facilities
Permits utilized to address both state and federal requirements/concerns
Preconstruction program approved by EPA in State Implementation Plan (SIP)
Title V program approved by EPA in 1995
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
New Source Review (NSR) Encompasses:
Prevention of Significant Deterioration (PSD)
LAC 33:III.509
Nonattainment New Source Review (NNSR)
LAC 33:III.504
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
PSD
Steps in LDEQ review process
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2. Determine major source status. (LAC 33:III.509.B)
The source is major if:
A) It is listed in Table A of LAC 33:III.509 and it emits, or has the potential to emit, 100 tons per year or more of any attainment pollutant; or
B) It emits, or has the potential to emit, 250 tons per year or more of any attainment pollutant; or
C) Any physical change at an existing minor source, if the change would constitute a major stationary source in and of itself. This modification is not eligible for netting.
1. Administrative completeness review (AVT)
- Don’t forget 1701 forms. They’re the most common request by AVT.
- Approximately 30 days (60 day regulatory limit).
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
3. Determine if a modification has occurred.
Can the change be classified as routine repair and replacement?
Is the change due to another exemption outlined in the definition of major modification? LAC 33:III.509.B
• Upstream sources may include additional steam demand from a boiler, increased throughput from tanks, etc.
• Potential-to-emit of downstream sources may be increased due to debottlenecking.
Review not only the source(s) in question, but also any upstream or downstream sources affected by the project.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
4. Determine if the increase is significant.
An increase in a pollutant is significant for PSD if:
o Facility is a new major stationary source and a pollutant is emitted in amounts equal to or greater than its specified significance level; or
o Facility is an existing major stationary source and both the potential increase in emissions due to the modification itself, and the resulting net emissions increase is equal to or greater than its specified significance level; or
o Any emissions rate at a new major stationary source (or any net emissions increase associated with a modification to an existing major stationary source) that is constructed within 10 kilometers of a Class I area (Breton Sound), and which would increase the 24-hour average concentration of any regulated pollutant in that area by 1 ug/m3 or greater.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
6. Review BACT.
Ensure that any reductions claimed are based on actual emissions, NOT permitted emissions.
5. Determine the proper contemporaneous period/review netting analysis.
Required for sources that undergo physical change or change in method of operation.
Each BACT analysis is done on a case-by-case basis.
Top-down analysis ranks all available control technologies in descending order of effectiveness.
Sources of information include but are not limited to the RACT/BACT/LAER Clearinghouse.http://209.42.208.109/rblc/cfm/rbeasy.cfm
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
7. Make sure other analyses have been completed.
1. Modeling exercises (Patrick Pakunpanya)2. Source related growth impacts3. Soils, vegetation, and visibility impacts4. Class I area impacts (Breton Sound)5. Toxic emissions impact (Chapter 51 or
112(g), if applicable)
8. Public notice:• 30-day public review period• 30-day EPA review period
9. Draft Basis of Decision.• Required for all PSD permits.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
NNSR
Steps in LDEQ review process
1. Administrative completeness review (AVT)
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
2. Determine major source status. (LAC 33:III.504.G)
The source is major if:
A. It emits, or has the potential to emit, 50 TPY or more in a serious nonattainment parish (see Table 1 in 504); or
B. Any physical change at an existing minor source, if the change would constitute a major stationary source in and of itself. This modification is not eligible for netting.
Notes:• Fugitive emissions shall not be included in
the major source determination unless: The source is listed in Table A on LAC 33:III.509 or the stationary source category is being regulated under Section 111 or 112 of the Act.
• A stationary source shall not be a major stationary source due to secondary emissions.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
4. Determine if the increase is significant.An increase in a pollutant is significant for
NNSR if it:
o Occurs at a new major stationary source and VOC emissions are greater than or equal to 50 TPY; or
o Occurs at an existing major stationary source, and the net emissions increase is equal to or greater than 25 TPY.
See Table 1 in 504.
3. Determine if a modification has occurred.
See definition of modification (PSD section).
5. Review netting analysis if increase is greater 5 TPY.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Like PSD, ensure that any reductions claimed are based on actual emissions, NOT permitted emissions.
6. Determine the proper contemporaneous period.
8. Review LAER and/or check to see if the necessary offsets are available.
Currently, sources must have banked ERC to “net out.”
7. If “netting out,” check to see source has sufficient ERC in the bank.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
9. Public notice:
• 30-day public review period• 30-day EPA review period
If NNSR review is accomplished through the Title V process, EPA will have 45 days to review significant modifications.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title V
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title Vo Required for all major sources [LAC 33:III.502].o Permits have five year life span.o Renewal applications must be received at least
six months prior to the date of permit expiration, but no earlier than eighteen months prior to expiration.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title V Permit Renewal Status
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title V Permit Renewal Status o Currently, we have 88 General Permit renewals
and 9 Regular Permit renewals in-house.o All Title V General Permits will be renewed
through TEMPO: First draft of General Permit Templates
under review. Regulations are being added to the
Requirements Library. Implementation of General Permits
renewal program tentatively scheduled for April, 2002.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title V Permit Renewal Status (Cont.) o All Title V Regular Permits will be renewed
through current methods.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Initial Title V Permits Status
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Initial Title V Permits Statuso Currently, we have 324 initial Title V
Permits under review.o EPA has tentatively requested that we
issue all remaining permits within 18 months.
o As part of our agreement, DEQ must implement a schedule of permit issuance deadlines and submit it to EPA.
o We will send out letter to all affected companies and ask for suggested schedule per company.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Title V Permit Renewal Status (Cont.) o Suggested schedule will give companies
time to update each application while giving DEQ time to issue permit.
o I will be primary contact for this project:
Keith JordanEnvironmental Scientist Sr.OES/Permits Division(225) [email protected]
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Other Permit Actions
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Other Permit Actions
o State Permitso Title IV (Acid Rain Permits)o Emissions Banking (ERCs)o Exemptionso Varianceso Name/Ownership Changeso Determinations
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permit Content
o Origin and Descriptiono Facility wide emission limitso Site specific requirements
(specific conditions)o Applicable regulatory standardso Testing, monitoring and
reporting requirementso Lb/hr and ton/year limits by
emission point by pollutant
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Common errors in applications
1. Failure to use actual to potential to determine the increase for a project - particularly common if permitted limits do not have to be modified.
2. Contemporaneous reductions based on potential-to-emit rather than actual emissions (2-year annual average).
3. Including paper changes (i.e., decreases based on emission factor changes, stack test results, etc.).
4. Addressing sources that were never constructed.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Common errors in applications (Cont.) 5. Taking credit for all reductions where
baseline was above permitted limits.
6. Failing to consider only increases when determining if a netting analysis is required.
7. Failure to include 1701 form when required. This is the most common request by Application Verification.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Suggestions to facilitate process
o Complete an adequate IT analysis, with special attention to the alternative sites analysis.
o Submit application as far in advance as possible.
o Include detailed reference or background information with application.
o Alert permit writer of any unusual situations or concerns.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Suggestions to facilitate process (Cont.)
o Don’t underestimate public interest in the proposed facility or project. Hold informational meetings with community if necessary.
o Notify permit writer of any changes in company’s priority of the application, particularly if the construction schedule has been delayed. Please. . .
o Submit LPDES application and air application concurrently.
o If possible, the Department prefers to hold joint air and water public hearings.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Monitoring and Reportingo Stack testing
As required by rules As determined appropriate
o On-going monitoring of operating parameters, specific to source
o Monitoring and Compliance reporting 7 days, quarterly, semiannual, annual Must report any emission exceedance,
any permit deviation Major sources must certify compliance
status annuallyo Annual reporting of actual emissions
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Quality Modeling
o Permit application review includes dispersion modeling
o Federal PSD and Nonattainmento State air toxics modeling protocol
Designed to assure compliance with Louisiana Ambient Air Standards
Includes cumulative modeling of surrounding sources
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Performance Indicator for DEQ Permitting
o Based on “410-day Rule” (RS 30:2022 & LAC 33:I.Ch 15)
o Quarterly & FY goals for final permit decisions, based on applications for new facilities & major mods reaching 410-day deadline
o Goal for FY 2000-2001: 75%o Actual: 80%
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Public Participation Process Improvements
o Created Central Public Records Room, 4th floor
o Provided public access to ALPS, 4th floor
o Created Public Notice Web pageo Working with State Library
Association to improve document handling at libraries
o Combined public hearings
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Public Participation Process
Response to Commentso The PP Group maintains records
of all individuals who submit written comments or provide oral comments at public hearings.
o When a final decision is made, Permit Writers send notice of response to comments and basis for decision to all commentors.
LouisianaLouisiana
Department ofDepartment of
EnvironmentalEnvironmental
QualityQuality
Air Permitting
November 14, 2001
Keith JordanEnvironmental Scientist Sr. OES/Permits Division(225) [email protected]
