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Proposed regulations for control of emissions from indirect heat exchangers were recently filed by the Kentucky Division for Air Quality (DAQ) on September 14, 2017.  The regulations are revisions of existing regulations for both existing and new indirect heat exchangers.  “Indirect heat exchanger” means a piece of equipment, apparatus, or contrivance used for the combustion of fuel in which the energy produced is transferred to its point of usage through a medium that does not come in contact with or add to the products of combustion.  In general, existing heat exchangers include heat exchangers installed before April 9, 1972 and “new” heat exchangers include any heat exchangers installed after that date.

For existing heat exchangers (401 KAR 61:015), emission standards for particulate matter are established in Appendix A (lb/MMBtu) and opacity is restricted to 20% or less for Priority I classified regions and 40% or less for Priority II or III classified regions.  There are no substantial changes to the particulate matter emissions standards including the allowable pound of particulate per million Btu actual heat input and percent opacity restriction.  There are no substantial changes to sulfur dioxide standards.

For new heat exchangers (401 KAR 59:105), emission standards for particulate matter are established in Section 4 of 401 KAR 59:015 and are based on the total heat input for affected facilities.  Opacity is restricted to 20% except for specific scenarios as stated in the regulation.  There are no substantial changes to the particulate matter emissions standards including the allowable pound of particulate per million Btu actual heat input and percent opacity restriction.  There are no substantial changes to sulfur dioxide standards.  Standards for nitrogen oxides have been removed from the regulation and the proposed regulation for new heat exchangers reflects this change.

Work practice standards during a startup period or shutdown period have been added to both regulations, and these additions represent the substantial difference between current regulations and the proposed regulations.  During periods of startup and shutdown, indirect heat exchangers are to be operated with good air pollution control practices for minimizing emissions.  “Good air pollution control practices” is also called the “general duty” clause which means the regulatory expectation is that operators are to follow manufacturer recommendations.  The frequency and duration of startup and shutdown periods are to be minimized as much possible.  Documented records such as logs are to be kept for each action associated with startup or shutdown period.  Definitions for “startup period” and “shutdown period” are included in the proposed regulations.  The work practice standards are based on the general provisions of the federal regulations for National Emission Standards for Hazardous Air Pollutants for Source Categories as listed in Subpart A of 40 CFR Part 63.  Specific federal regulations for work practice standards during periods of startup and shutdown are referenced in the proposed regulations for boilers at major sources of emissions, boilers at area sources of emissions, and boilers at coal and oil-fired electric utility steam generating units.  For boilers at area sources (excluding natural gas fired boilers), facilities must comply with Table 2 of Subpart JJJJJJ during periods of startup and shutdown.  For boilers at major sources, facilities must comply with items 5 and 6 of Table 3 of Subpart DDDDD during periods of startup and shutdown.

Please contact Smith Management Group at (859) 231-8936 or (502) 587-6482 if you would like more information or need assistance with air permitting or environmental compliance strategies for sources located in Kentucky.

(Note:  Sources within Jefferson County are not subject to these particular regulations; however, sources in Jefferson County are subject to similar regulations and are regulated by the Louisville Metro Air Pollution Control District.)


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FEATURED PROJECT

Environmental Management & Engineering

New Facility Permitting


PROBLEM

A large alcoholic beverage company was planning to construct a distillery along a lake in Kentucky and use the fresh limestone water for bourbon production. The proposed site was a former farm with historic activities dating back to the 1880s. A water intake structure was required in the lake and along the adjacent shoreline which was owned by others. Several ephemeral and intermittent streams would be impacted by the construction. The client needed a US Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit, a Kentucky Division of Water 401 Water Quality Certification, a water withdrawal permit, a permit for construction in and along a stream, and a construction stormwater permit. Additionally, an air permit was required prior to construction for the aging warehouses, distillery equipment, and other emission units. Evaluation for cultural and historic resources and endangered species evaluations were required under the National Environmental Policy Act (NEPA) and Endangered Species Act (ESA).
As the construction proceeded and operations began, a number of operating permits and environmental and hazardous materials compliance plans were required. The project required coordination with the nearby city for drinking water use and industrial wastewater pretreatment and discharge. Recordkeeping and reporting were needed prior to facility personnel being mobilized to the site. Set up and management of environmental systems during the transition to full operations was needed.


SMG'S APPROACH

During the planning and initial construction phases, SMG managed the environmental permitting and environmental compliance for the site. The process involved application preparation and coordination with multiple regulatory agencies including the USACE, Kentucky Division of Water, Kentucky Division of Air Quality, US Fish and Wildlife Services, Kentucky Department of Fish and Wildlife Resources, Kentucky Heritage Council, and local agencies. Permits included stream mitigation, cultural and historic resources investigation, coordination with state and federal Fish and Wildlife agencies, and State 401 water quality certification, and the Section 404 permit, which required wetland and stream delineation. SMG coordinated with the client’s project team to minimize stream impacts and to adhere to the schedule by expediting the permit processing. State stream construction, water withdrawal, and air permits were also obtained. SMG provided onsite observation to assess contractor compliance with the stormwater permit and managed environmental permit reporting.
During the later construction phase, SMG managed the environmental permitting and compliance for the new distillery. The initial environmental and hazardous material compliance plans (GPP, HMPC, and SWPPP) were prepared and applications for operating permits, such as industrial wastewater pretreatment and discharge and industrial stormwater discharge, were readied and submitted. SMG provided training to the initial employees regarding hazardous material management and groundwater/stormwater protection. SMG worked with the new Risk Manager for the site to transition responsibility for environmental and hazardous material compliance.


RESULTS

SMG’s management of the environmental planning and permitting for the facility, successfully supported the construction schedule and managed environmental compliance for the initial site operations. SMG continued to work with the owner to obtain remaining operational permits and to transition environmental compliance responsibilities to the new facility staff to support startup and initial operations. The facility was completed on schedule and provides a significant economic benefit to the surrounding community.