Using a Flexible Compliance Strategy to Issue a Title V Operation Permit

摘要

The issuance of a Title V operation permit for existing industrial facilities requires development of an accurate inventory of air pollution sources and verification these sources comply with applicable emission limitations and air quality standards. In some cases, existing operations may not comply with applicable air quality requirements and necessitate changes to the facility design to achieve compliance. This case study presents the Title V experience at a large iron foundry in Wisconsin. An air quality dispersion modeling analysis was conducted to verify compliance with the National Ambient Air Quality Standards and acceptable air concentrations for hazardous air pollutants. Initial modeling based on worst-case emission rates predicted violations of air quality standards. Additionally, emission estimates for older, uncontrolled operations suggested non-compliance with process emission limitations. A compliance strategy was necessary to demonstrate compliance with emission limits and air quality standards. To provide time for development of a cost-effective compliance strategy, an operation permit was issued based on an initial design scenario, referred to as Scenario #1. This scenario included improvements in the ventilation system, consolidation of roof vents into single stacks, installation of numerous baghouse control systems, and increases in stack heights. "X" lbs/hr emission limitations were established as place holders for limitations to be developed under the final compliance strategy. A compliance schedule in the permit established deadlines for conducting an updated dispersion modeling study to verify compliance with air quality standards, development of a final compliance strategy more cost effective than Scenario #1, and installation of the necessary improvements and control systems. This fiexible approach allowed issuance of a Title V operation permit and time for development of a cost-effective compliance strategy.