1. Kansas Air Quality Seminar March 5, 2008
Who Needs a Permit?
Kansas Air Quality Seminar
March 5, 2008
Ryan Hamel, Small Business Environmental Assistance Program

2. Overview Common industries needing a permit
Evaluating permit requirements
Potential applicable regulations
FAQ

3. Common Industries Needing a Permit (All facilities should check)

4. Common industries Painting/coating operations Printing operations
Industries with:
Large boilers
Furnaces
Kilns
Ovens
Generators

5. Common industries Sandblasting operations Solvent use operations
Grain elevators, flour mills, food processing
Woodworking
Asphalt, concrete, rock-crushing

6. Common industries Petroleum refineries Incinerators
Chemical manufacturing
Livestock and meat processing

7. Evaluating your need
for a permit

8. Steps to take
Identify all equipment or processes that produce air pollutants
Identify the pollutants they emit (materials used)
Calculate the potential-to-emit (PTE) for each pollutant from each process

9. Potential-to-emit (PTE)
Represents the source’s maximum capacity or worst case scenario emissions
The maximum amount of air pollution your facility can emit if:
Each process operates at 100% of its capacity
All equipment is operating 24/7 (8,760 hrs/yr)
Materials that emit the most air pollution are processed 100% of the time
No pollution control equipment is used

10. PTE – Emission factors Emission factors
Manufacturer’s emission factors are best
AP-42 is a compilation of factors for specific processes accepted by EPA
Emission factors software and tools

11. PTE – Material balance Material balance
Product in = product out (assumes constant inventory)
Product in can be the purchased material
Product out can be the emissions
Material balance can be applied to individual units or the whole process

12. Calculating PTE - Other
Other approved methods
Computer programs
Industry-specific emission factors
Approved by KDHE on an individual basis

13. (Kansas Air Quality Act)
Types of Air Permits
(Kansas Air Quality Act)

14. Air construction permit
KAQA standards
Air operating permit
Air construction permit
Air construction approval

15. Construction approval
If your PTE exceeds these thresholds, you will need a construction approval:
Construction Approval Thresholds
Pollutant PTE threshold
Lead or lead compounds 0.1 pounds per hour
SO2 or SO3 2 pounds per hour
PM pounds per hour
PM 5 pounds per hour
NOX 50 pounds per 24 hours
CO 50 pounds per 24 hours
(In Wyandotte and Johnson Counties)
VOCs 3 pounds per hour
15 pounds per 24 hours
(All other Kansas counties)
VOCs 50 pounds per 24 hours
Source: Kansas Air Quality Regulations (K.A.R (b)(3)) available at

16. Construction permit
If your PTE exceeds these thresholds, then you’ll need a construction permit:
Construction Permit Thresholds
Pollutant PTE threshold
Lead tons per year
PM tons per year
PM 25 tons per year
SOX 40 tons per year
VOC 40 tons per year
NOX 40 tons per year
CO tons per year
HAPs (individual) 10 tons per year
HAPs (any combination) 25 tons per year
Source: Kansas Air Quality Regulations (K.A.R (a)(2)-(5)) available at

17. Operating permit (Class I)
Required if PTE exceeds these thresholds:
100 tons per year NOX, SOX, PM10, VOC, CO
10 tons per year of any single hazardous air pollutant (HAP)
25 tons per year of combined HAPs
Source: Kansas Air Quality Regulations available at

18. Operating permit (Class II)
If actual emissions are below Class I thresholds but PTE is above – then limit your emissions and apply for a Class II operating permit
A Class II permit requires minimal record keeping and is simpler than maintaining a Class I permit
Class II permit-by-rule (KAR to )

19. Operating permit (Class II)
Limit emissions by
Implementing pollution prevention
Change the material
Change the process
Change the technology
Limiting process rate
Limiting hours of operation
Limiting amount of material processes
Installation of a pollution control device

20. Permitting Web site www.kdheks.gov/air-permit/download.html
Web site includes forms for:
Construction approvals
Construction permits
Operating permits (Class I and II)
Emergency generators
Expedited boiler form (available soon)

21. Potential applicable regulations
KAQA Standards (Kansas Air Quality Act)
NSPS (New Source Performance Standards)
PSD (Prevention of Significant Deterioration)
NESHAP (National Emission Standard for Hazardous Air Pollutants)
MACT (Maximum Achievable Control Technology)

22. Boiler sheltered initiative
Small Boiler NSPS, 40 CFR subpart Dc
Compliance date: September 30, 2008
The heat input capacity of the boiler is between 10 and 100 MMBtu/hr
The boiler was constructed, modified, or reconstructed after June 9, 1989
The boiler is not subject to NSPS requirements
Yes
Complete the expedited KDHE boiler form No

23. Future additions or modifications
Evaluate PTE for new or modified equipment.
Compare PTE to construction approval or permit thresholds
Add new source’s PTE to facility-wide PTE and compare against operating permit thresholds

24. FAQ

25. What’s a HAP? HAP = Hazardous air pollutant
Currently 187 different HAPs
Known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects.
List available at:

26. I installed an emission source quite a while ago
I installed an emission source quite a while ago. Do I still need to apply for a permit?
Emission sources installed many years ago should still be evaluated. If there are any questions about the need to submit appropriate forms, contact SBEAP or KDHE. They can provide assistance on a case-by-case basis.

27. How much do permits cost?
Air construction approval – no fee
Air construction permit
Minimum: $100
Maximum: $4,000
Based on 0.05% of estimated capital cost

28. How much do permits cost?
Air operating permit (Class I)
Initial and renewal application: $1,000
Significant modification application: $500
Additional annual fee based on emissions
Air operating permit (Class II)
Initial application: $200
Modification application: $100
Class II Permit-by-rule fee: $50

29. Are emergency generators included?
Emergency generators are an emission source that should be evaluated
Emergency = only used when power is out
PTE based on 500 hours/year

30. How long does it usually take to get a permit or an approval?
Based on complexity of application
Backlog is 2–6 weeks depending on season
If public comment period is required, length of process is increased.
See for more details

31. I need a construction permit or approval for the equipment I want to install. Can I order the equipment before getting the permit?
See
Equipment cannot be permanently affixed or installed prior to issuance of the permit/approval.

32. Environmental Hotline
Questions or comments?
SBEAP
Environmental Hotline