A presentation at the 2015 Midwest Environmental Compliance Conference, May 13-14, 2015, Overland Park, KS

1. Air Quality and Permitting Basics
Midwest Environmental Compliance Conference
Overland Park, KS – May 13th, 2015
Tony Barlage
Olsson Associates
Air Consulting Services Team Leader
Email: tbarlage@olssonassociates.com
Phone: 303-237-2072

2. Why all the fuss about air?
Kb
ZZZZ
KKK
JJJJJJ
PSD
Title V
RACT / BACT / LAER
GHG
CEMS
Method 9
TPY

3. Industries With Air Quality Permitting
Considerations
• Agriculture / Farming / Grain handling
• Aggregate / Gravel / Cement / Asphalt / Rock Crushing / Coal handling
• Biofuel facilities (ethanol and biodiesel)
• Commercial / Industrial / Rail
– Metal fabrication
– Maintenance shops (welding, painting, etc.)
– Manufacturing (chemicals, hard goods, etc.)
• Mining
• Oil and Gas
– Exploration and production sites
– Refining
– Storage and transloading
• Power Generation (coal, natural gas, diesel, etc.)
• Waste Incineration

4. Primary Air Pollutants
Regulated air pollutants, require a finding that the pollutant
endangers the public health or welfare (e.g., visibility), and/or
the environment.
Criteria Pollutants
Those pollutants for which the U.S. EPA has established national
ambient air quality standards (NAAQS)
– CO, Pb, NO2 , O3 (VOC + NOx + sunlight), PM10 & PM2.5 , SO2

5. NAAQS & Attainment
EPA determines whether or not an area is attaining (“attainment” vs. “non-
attainment” areas) the NAAQS for all criteria pollutants.
St. Louis is a marginal non-attainment
Area for the 8 hour ozone standard 
Indirect impact comes from state’s obligation to protect ‘attainment’ areas and
mitigate ‘non-attainment’ areas (i.e. new permits can be delayed, additional
requirements in permits, etc.)

6. Pollutant
[final rule cite]
Primary/
Secondary
Averaging Time Level Form
Carbon Monoxide
[76 FR 54294, Aug 31, 2011]
primary
8-hour 9 ppm
Not to be exceeded more than once per year
1-hour 35 ppm
Lead
[73 FR 66964, Nov 12, 2008]
primary and
secondary
Rolling 3 month
average
0.15 μg/m3 (1) Not to be exceeded
Nitrogen Dioxide
[75 FR 6474, Feb 9, 2010]
[61 FR 52852, Oct 8, 1996]
primary 1-hour 100 ppb
98th percentile of 1-hour daily maximum concentrations,
averaged over 3 years
primary and
secondary
Annual 53 ppb (2) Annual Mean
Ozone
[73 FR 16436, Mar 27, 2008]
primary and
secondary
8-hour 0.075 ppm (3)
Annual fourth-highest daily maximum 8-hr concentration,
averaged over 3 years
Particle Pollution
Dec 14, 2012
PM2.5
primary Annual 12 μg/m3 annual mean, averaged over 3 years
secondary Annual 15 μg/m3 annual mean, averaged over 3 years
primary and
secondary
24-hour 35 μg/m3 98th percentile, averaged over 3 years
PM10
primary and
secondary
24-hour 150 μg/m3 Not to be exceeded more than once per year on average
over 3 years
Sulfur Dioxide
[75 FR 35520, Jun 22, 2010]
[38 FR 25678, Sept 14, 1973]
primary 1-hour 75 ppb (4) 99th percentile of 1-hour daily maximum concentrations,
averaged over 3 years
secondary 3-hour 0.5 ppm Not to be exceeded more than once per year

7. Primary Air Pollutants
Non – Criteria Pollutants
Reportable or regulated pollutants that are not criteria
pollutants (no NAAQS)
• Hazardous Air Pollutants (HAPs)
– formaldehyde, benzene, toluene, ethyl benzene,
xylenes, and more
• Greenhouse Gases (GHG)
– CO2, CH4, SF6, etc.

8. Permitting Triggers
• New facilities (thresholds, varies in different states)
• Facility Modifications
• Equipment changes / swap outs, process changes, throughput
changes, production changes, operating and maintenance changes
• Permit expiration / renewals (operating permits)
• Regulatory changes

9. Types of Permits and Sources
Construction vs. Operating Permit (TV)
NSR/PSD vs. Major vs. Minor vs. Synthetic Minor Sources
-Initial, pre-construction
(some exceptions)
-After construction and commencement of operation
-Has an expiration/renewal date
-Rolls in construction permits
- Are potential emissions greater than NSR/PSD or major source thresholds?
- If so, can they be controlled to be below?
Other permit sub types: general permits, permit by rule (PBR), etc.

10. General Permitting Process
• Understand the process – flows, equipment, scope of activity, interconnections
(source aggregation?)
• Establish technical assumptions and complete a first-pass estimate of emissions –
controlled and uncontrolled, compare to applicable thresholds (PTE vs. Actual)
• Arrange and attend pre-application meeting (especially for complex construction
permits or Title V projects)
• Identify all potentially applicable rules and requirements – high level review
• Complete a detailed Applicability Analysis – i.e., read the rules, assess the
applicability and requirements (controls, operations, recordkeeping, reporting)
• Fix technical assumptions, refine emissions estimates, and draft permit application
documents
• Revise and finalize permit application
• Submit permit application and wait (depending on the process and/or backlog of
certain states…keep waiting…) *AIR PERMITTING CAN BE A BOTTLENECK*
• Review draft permit from regulatory agency, verify conditions (very important)
• Depending on state, complete required self certification requirements

11. Monitoring
Compliance monitoring
– Visible emissions
– CEMS
– Operating parameters, etc.
Related to modelling data
– PSD / NSR projects
– When representative meteorological and ambient air
quality data are not available.

12. Dispersion Modeling
• Compare impacts to NAAQS or to permit specific standard
• Required for larger projects initially or for major modifications
to facilities
• Slows process down, can be costly, new short term NAAQS
can be difficult to comply with

13. Questions?
Additional Resources:
• IDNR, KDHE, MDNR, and NDEQ (or other state regulatory agencies)
• EPA
• Air Consultants
Tony Barlage
Olsson Associates
Air Consulting Services Team Leader
Email: tbarlage@olssonassociates.com
Phone: 303-237-2072