Understanding State and Federal Air Quality Regulations for Permits (Full Transcript)

Speaker 1: All right, good morning, everyone. My name is Tom Hercula. The permits that I've been working on include anaerobic digesters, as well as some emergency engines, engine test cells and some oil and gas facilities. And I will be going over the regulatory discussion today. An important part of the application is determining the state and federal rules and regulations that may apply to the proposed equipment. If you know what the requirements are for each regulation, you will better understand what your obligations are. We understand that navigating the laws can be challenging. So please feel free to contact the permit section to discuss any questions you may have. The applicability of rules depends on several criteria. The rules generally regulate a specific air pollutant or group of pollutants, such as carbon monoxide or formaldehyde. Many rules apply only if your annual emission rate exceeds a certain amount. Some regulations apply to a specific source type. For example, one regulation applies to plastics parts coating, and another regulation applies to metal parts coating. The installation date is important because many regulations apply to sources or emission units installed or modified after a certain date. All of the state of Michigan

Speaker 2: air quality rules are available from our website. If you go to the website, then click on the

Speaker 1: News and Info tab, click on State Air Laws and Rules, and then on Air Pollution Control

Speaker 2: Rules. This will open the latest version of the AQD rules. Michigan's air pollution control

Speaker 1: rules are under Part 55 of Act 451 to help us meet the requirements of the Federal Clean Air Act. The rules are grouped into parts. I'll briefly introduce you to some of the key parts now. Part 1 contains the definitions which are useful when using the rules. Part 2 includes requirements related to permits to install, the requirements related to renewable operating permits, the air toxics rules, and the permit to install exemptions. Part 3 contains the particulate matter emission limits for various emission units, including open burning and visible emissions. Part 4 contains sulfur dioxide emission limits for boilers and other fuel burning equipment. The Part 6 rules were created to reduce VOC, or volatile organic compound emissions, from a variety of sources installed prior to the dates in the rules. The Part 7 rules were established to reduce VOC emissions from emission units installed after July 1st, 1979. Part 8 limits the emissions of nitrogen oxides from fossil fuel and gas-fired combustion devices. Part 9 can apply to any facility regardless of the type of air pollutant emitted or emission unit installed. It includes rules about malfunction abatement plans and emissions during abnormal conditions. Part 10 contains rules related to emission testing. If sources need to verify, they are meeting with emission limits. Part 11 contains the requirements if a source has continuous monitoring equipment to verify compliance. Federal rules are found in the Code of Federal Regulations, or the CFR. All air quality rules are in Title 40 of the CFR. Parts 61 and 63 of Title 40 list the National Emission Standards for Hazardous Air Pollutants, or NESHAPs, and Part 60 lists the New Source Performance Standards, or NSPS. NESHAPs are regulations for sources of hazardous air pollutants, and NSPS are regulations for other pollutants. Both the NESHAPs and the NSPS apply to specific source categories, such as turbines, incinerators, pharmaceutical manufacturing, or surface coating. You may want to look through the table of contents of each part to see if any sections apply to your operation. We may be repeating ourselves here, but since navigating the applicable regulations can be a challenging task for many, we want to reiterate that you can call us with questions if you have a specific project in mind and you are looking for what regulations might apply. We can steer you in the right direction and tell you which regulations are likely to apply to your project.