Air Emission Management Practical Problem

 

Air Emission Management Practical Problem

 

 

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Institution

 

 

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Executive Summary

The operations carried out by the Engineering Metal Company include: joist production, bridging, as well as deck production. The relevant parts of the New York state regulations 6NYCRR that pertains the aforementioned activities include Part 201, Part 212, Part 228 (which is relevant for purposed of surface coating operations) and Part 229 (applicable for storage of volatile organic liquid). The company intends to develop an air emission management program for purposes of controlling and mitigating contaminated emissions from the new plants that the company intend to introduce. These products are intended to be sold for framing purposes in huge commercial structures. For purposes of helping the company to develop a viable Air Emissions Management program, my team has been retained by the Engineering Metal Company and also to assist the company to comply with the set regulations, as well as finalize with the process of acquiring a permit.

 

Identification Emission Unit and Control Device

For purposes of indentifying the emission units and the viable control device, my team conducted a thorough review of the projected amount of emission from the new projects as well as the applicable regulations that touches such activities carried out by the Engineering Metal Company. From the review conducted by my team, a number of prospective emission sources in the Engineering Metal Company were established. These emission sources included: flow coaters, welding activities, drying ovens, and dip tanks in the joist production; In bridging operations the emission sources include vacuum coaters, as well as fire ovens; and from the deck production, emission sources include the painting and cleaning activities. After the review, my team recommended that the Engineering Metal Company should adopt extra measures for purposes of mitigating the amount of contaminants discharged in the air, and also apply from the New York state a Title V permit. These kinds of operations necessitate the Engineering Metal Company to meet the NSPS TT as a federal requirement.In the assessment carried out by my team, no pollution control devices were put in place for purposes of mitigating and controlling pollution from these operations.

 

The table below summarizes the estimated emissions from the Engineering Metal Company

 

CAS Number

 

Contaminant PTE (Tons per Year)
000630-08-0 Carbon Monoxide

 

17
0NY100-00-0 Total HAPs

 

35
0NY210-00-0 Oxides of Nitrogen

 

>20
0NY075-00-5  

PM-10

18
007446-09-5  

Sulfur Dioxide

<1
0NY998-00-0  

VOC

156

 

Following the proposed changes in the Engineering Metal Company to introduce the three operations which include; the joist production, bridging, as well as deck production, and the fact that site is situated at a non attachment area of moderate Ozone, there is need for review of permit requirements in light of additional new sources.  It should however be noted that the Engineering Metal Company was not required to apply for a Title V permit before the proposed changes. This is because; the company had already undertaken to comply with an emission chapter which is enforceable across all federal states pursuant to subsection 201- 7 which is to the effect that the emissions from a facility should not exceed the levels set out under the Title V permit issued  to the facility.

 

It should also be noted that the new projects in the Engineering Metal Company will be subjected to Subpart 231-5 of the federal regulations for emissions of HAPs and Volatile Organic Compounds (VOCs). This is because the new projects are projected to exceed fifty tons

per year of Volatile Organic Compounds emissions. Prior to the introduction of the new projects the Engineering Metal Company did not discharge HAPs and Volatile Organic Compounds emissions that exceeded 100 and 50 tons per year respectively. Thus, the operations were not subjected to Subpart 231- 5. The emissions of fugitive Volatile Organic Compounds (VOSs) are commonly discharged during industrial activities that uses, produce, or stores Volatile Organic Compounds containing gasses or even liquids. Sources of such emissions may include among others; storage tanks, accidental release, as well as open mixing tanks and vats. In an effort to prevent and control of Volatile Organic Compounds emissions, it is recommended that the equipments should be modified accordingly, and a program of leak detection and repair (LDAR) should be implemented (Thad, 2007).

 

 

Emission and Operating Limits

For purpose of the company’s operations and emission limits, the company should acquire a Title V permit as aforementioned. Under the Title V permits certification there are a number of conditions that the company is required to comply with annually. Under the first condition, the applicable federal requirement is outlined under 6NYCRR 201-6. This regulation defines the term emission for purposes of this industry (Engineering Metal Company). The second condition is outlined under 6NYCRR 201-6.5(c), this condition requires that the Engineering Metal Company should keep the necessary records as well as reports of monitoring compliance. In addition, condition eight of the Title V permit is related to Volatile Organic Compounds which is captured under 6NYCRR 228.7. Further, the operations of surface coating should comply with the requirement outlined under 6NYCRR, Part 228.7. This federal requirement set the emission limit of VOC.

 

This program is a vital tool for purposes of controlling fugitive emissions through regular monitoring to identify any kind of leakages. For purposes of preventing and controlling Volatile Organic Compounds emissions emanating from using chemicals in open mixing processes as well as vats, several approaches are recommended which include;  use of substances that are less volatile like aqueous solvents,  vapor collection using air extractors. This should be followed by the extraction of Volatile Organic Compounds in the treatment of gas stream using activated carbon absorption or condensers.

Deck coating under 6NYCRR, Part 228.7, should not go beyond 2.6 lbs VOC/gal per gallon of coating. In addition, bridging coating and joist coating under the above federal requirement must not surpass the set threshold of 3.0 lbs VOC per gallon of coating or 3.5 lbs VOC/gal (air dried). This does not include solvents and water during application. The determination of compliance shall be calculated pursuant to 6 NYCRR, Part 228.2(b)(11). It should also be noted that 40CFR60 outlines the analytical methods that are acceptable for purposes of evaluating the water content, density weight of solids, volatile content, as well as density volume of solids of surface coatings. This program is a vital tool for purposes of controlling fugitive emissions through regular monitoring to identify any kind of leakages. For purposes of preventing and controlling Volatile Organic Compounds emissions emanating from using chemicals in open mixing processes as well as vats, several approaches are recommended which include;  use of substances that are less volatile like aqueous solvents,  vapor collection using air extractors. This should be followed by the extraction of Volatile Organic Compounds in the treatment of gas stream using activated carbon absorption or condensers.

 

All the new proposed projects must apply Lowest Achievable Emission Rate (LAER) under condition nine of the Title V permit. The federal requirement capturing this condition is 6NYCRR 231-2.5(a). In an effort to achieve this, the Engineering Metal Company coatings shall always adhere to the limits set out under the Lowest Achievable Emission Rate. The categorical standards of NESHAP sometimes referred to as MACT must be implemented in the new projects. The limits that shall apply under MACT the Engineering Metal Company include:

 

Flow coatings or water based dip coating shall be used in joist production and the two coatings shall not go beyond 4.5 lbs VOC/gallon of solids. The procedure outlined under 40CFR63, Subsection MMMM, should be applied. In an effort to exhibit VOC compliance the procedure in set out under the aforementioned subpart should be applied to convert references. In the bridging operations, water-based flow coatings shall be applied and they shall not exceed the limits set out under subpart MMMM, of 1.25 lbs VOC/gallon of solids. Finally, in the decking production, water-based coatings shall also be used pursuant to procedure outlined under 40CFR63, Subpart SSSS, and the coating shall not go beyond the threshold of 1.0 lbs VOC/gallon of solids.

 

Adherence to the outlined limits shall be ensured through calculations of weighted averages from each operation on the tenth day of every month. The coating solids weight of VOC per gallon calculation shall continue throughout the year. The average arrived at through adding the averages of the twelve months shall not exceed the limits set under the regulation. The records of weighted average pounds of VOC obtained after calculations are done should be submitted every year under the process outlined under 40CFR63, regulations.

 

For purposes of operations such as steel deck coating and Steel Joist coating, the Engineering Metal Company requires permit approvals for each process point emission units set out under the 15th condition of the permit and the procedure is outlined under 6NYCRR 201-6 regulations. Since 40CFR63, Subpart MMMM is the regulations applicable for operations regarding bridging and joist coating, emissions of organic HAP from the activities should not exceed 2.6 lb/gal (0.31 kg per liter) of coating solids applied at any one month of the compliance year. Where there are numerous emissions sources in a project or facility, stack heights should be established with regard to other project sources emissions which should include consideration of fugitive and point sources. In an effort to achieve these strategies the metal company should establish air pollution control equipment which is designed to effectively remove most of the pollutant emissions. In a research conducted by Evans & Scott, (2006) air pollution control equipments that are properly operated in the United States were able to eliminate about 99 percent of furans and dioxins, more than 99 percent of hydrogen chloride, about 99 percent of particular toxic matter, about 65 percent of nitrogen oxides, and more than 90 percent of components such as sulfur dioxide.

It should be noted that 40CFR63, section 3920 outline the procedure through which the Engineering Metal Company report of Semi-annual compliance shall be submitted. In addition, the Engineering Metal Company use the procedure set out in 40CFR63, section 3920 for purposes of its record keeping.

 

Testing

The Engineering Metal Company calculate the monthly emission volume- weighted average of VOCs in lb/gal in relation to applied coating solids emanating from operations of decking coating. This is a requirement enshrined under 40CFR 60, NSPS Subpart TT. Source testing does not require other process.

 

Procedures of Calculation

The company must be able to calculate the pollution in terms of material description or name, products’ density in pound per gallon. 8.34 pounds per gallon should be multiplied a specific gravity in case density is not given. In addition the products VOC percentage should also be calculated. Where the content of VOC is provided in terms of pound/gallon of material, then the Engineering Metal Company should divide VOC provided in pound/gallon by the product’s density for purposes of arriving at the VOC percentage in the product. All the Volatile Organic Compounds should be accounted for in the product. Where the total Volatile Organic Compounds content for a particular product is not outlined the Engineering Metal Company should add all the constituencies’ percentage that is Volatile Organic Compounds including HAPs

 

In the process of introducing new production sites, the Engineering Metal Company must undertake the following procedure: there should be an application by the company for a permit authorizing it to construct new production sites as required under the New Source Review. Secondly, the Engineering Metal Company must present to the New York DEC particular information for purpose of review and assessing whether or not to it qualifies to be given the permit. The information required include: description of the project, the design capacity of the project, the schedule of project operation, and location of the project. The information should further present drawings as well as specifications detailing the applicable plant layout and design of the project. The efficacy of emissions management program can be assessed using air quality and emissions monitoring program. To ensure that the collected data are sufficient for the purpose they are intended to achieve it is recommended that a system planning process should be used (Williamson, 2000). This may help to avoid collecting data that is not needed. The process outlines the purpose of data collection and sometimes known as   data quality objective processes. The following essentials should be included in the air quality monitoring program; monitoring parameters, baseline calculation, monitoring type and frequency, monitoring locations, and sampling and analysis methods.

 

In addition a construction schedule of the new projects should be shown in details. The necessary calculations as well as collaborating documentations of potential project emission should also be presented. Finally, the Engineering Metal Company ought to present to the New York DEC the company’s reporting provisions, its recordkeeping, and projected emission monitoring. The Engineering Metal Company must notify the New York DEC of the new construction within thirty days of the project commencement. Actual construction of the new facility by the Engineering Metal Company shall not commence without express approval by the Engineering Metal Company

 

The projects or facilities with considerable levels of pollutant air emissions, as well as a possible impact on the ambient air quality, and must mitigate or avert such impacts by ensuring that; the pollutant concentration emitted by such projects do not reach or surpass the ambient quality standards set by the national legislations or other international standards that are recognized in that country. In addition, the company should ensure that its projects or facilities do not contribute a significant portion of pollutant emissions that contribute to the achievement of set standards of ambient air quality. The estimation of impacts at facility or project level should be estimated through quantitative or even qualitative assessment. This can be done through the use of atmospheric dispersion and assessment of baseline air quality models for purposes of assessing the potential concentrations in the ground level (Wark et al, 2002). The data on local air quality, climate as well as atmosphere should be used for purposes protection against current effects of the source, atmospheric downwash, wakes, terrain features and structures that are nearby and such date can be used for modeling dispersion. It is worth noting that the dispersion model used by the company ought to be compatible with the international standards or should be recognized internationally.

Monitoring Process

During the monitoring process, the selected monitoring parameters should reflect the relevant pollutants with regard to the project processes. For processes of combustion, indicators parameters include inputs qualities for instance the sulfur content found in fuel. The baseline calculation on the other hand is done before development of a project. The calculation of baseline air quality should be done for purposes of assessing key pollutants background levels. This will help in distinguishing between impacts that are project related and the already existing ambient conditions. In monitoring type and frequency the information regarding ambient air quality and emissions attained through the program of monitoring. These should be a representative of the discharged emissions by the facility over a given period.

There should be a frequent sampling of highly variable processed. In addition, monitoring locations establishes the location of air quality based on the scientific methods results for purposes estimating potential consequences other feature such as communities that are likely to be affected as well as the wind directions that are prevailing. The monitoring program under the sampling and analysis method ought to use the international or national approaches of collecting samples as well as analysis. A trained individual should be charged with the responsibility of supervising sampling. In addition, certified or permitted entities should undertake analysis for this purpose. To ensure that the quality of data is adequate for its intended purpose, there should be documentation of quality control and sampling. The monitoring reports should take account of quality control/quality assurance documentation (Thad, 2007).

Conclusion

Indeed, for a company for achieve an effective air emission management program it should ensure that its projects or facilities do not contribute a significant portion of pollutant emissions that contribute to the achievement of set standards of ambient air quality. The estimation of impacts at facility or project level should be estimated through quantitative or even qualitative assessment. This can be done through the use of atmospheric dispersion and assessment of baseline air quality models for purposes of assessing the potential concentrations in the ground level (Evans & Scott, 2006). The data on local air quality, climate as well as atmosphere should be used for purposes protection against current effects of the source, atmospheric downwash, wakes, terrain features and structures that are nearby and such date can be used for modeling dispersion. In addition, the air emission management program should ensure that the pollutant concentration emitted by such projects do not reach or surpass the ambient quality standards set by the national legislations or other international standards that are recognized in that country.

It is also important to establish monitoring practices as well as ambient quality assessment within projects and facilities with potentially substantial emissions from fugitive sources (Williamson, 2000). To ensure the effectiveness of air emission management program the company should use air quality and emissions monitoring program. This program will ensure that the collected data are sufficient for the purpose they are intended to achieve it is recommended that a system planning process should be used.

References

Evans, J., & Scott, W. (2006). “Modeling of Air Pollution Impact. Harvard: Harvard University    Press.

Thad, G. (2007). Health Effects: Air Quality. New York: Lewis publishers.

Wark, K, et al. (2002). Air Pollution its Origin and Control.  California: Addison-Wesley.

Williamson, S. (2000). Fundamentals of Air Pollution Control, Reading. PA: Addison-

 

 

 

 

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