"Using a Flexible Compliance Strategy to Issue a Title V Operation Permit"
Steven Klafka, PE, DEE
Kurt Jacobsen, PE
Wingra Engineering, S.C.
ABSTRACT
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 flexible
approach allowed issuance of a Title V operation permit and time for
development
of a cost-effective compliance strategy.