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Compliance and Technical Assistance Program

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Greenhouse Gas (GHG) Permitting – Guidance Available

Due to questions raised about air permitting for sources of greenhouse gas emissions regarding the June 23, 2014, U.S. Supreme Court decision in Utility Air Regulatory Group v. Environmental Protection Agency, 12-1146, the Indiana Department of Environmental Management’s (IDEM) Office of Air Quality (OAQ) has provided a guidance document to assist permittees in understanding what the circumstances are in which permitting will be needed for greenhouse gas emissions.

Pursuant to the U.S. Supreme Court ruling and the U.S. Environmental Protection Agency (EPA) guidance, IDEM will continue to require new sources or modifications to existing sources for which the new source or modification to an existing source is subject to Prevention of Significant Deterioration (PSD)/Best Available Control Technology (BACT) requirements based on the emission of conventional pollutants (“anyway sources”), to utilize BACT for greenhouse gas emissions if the potential to emit greenhouse gas emissions from the new source is equal to or greater than 75,000 tons per year of carbon dioxide equivalent (CO2e), or if the modification results in a greenhouse gas emissions increase and a net greenhouse gas emissions increase equal to or greater than 75,000 tons per year CO2e and greater than zero on a mass basis, until the U. S. EPA promulgates a revised threshold.

Pursuant to the U.S. Supreme Court Ruling and the U.S. EPA guidance, IDEM will not enforce greenhouse gas BACT limitations and supporting terms and conditions for sources/modifications which implemented BACT because of greenhouse gas emissions only, and did not trigger BACT for emissions of conventional pollutants. Such sources may apply to have their permits modified to remove the greenhouse gas BACT requirements.

Please refer to the OAQ’s Guidance Document for the complete statement of IDEM’s position.

Operating a Wood-Fired Boiler?

An area or major source of Hazardous Air Pollutants (HAP) utilizing a wood-fired boiler may be subject to the Boiler Maximum Achievable Control Technology (MACT) rules which may require stack testing, energy assessments, and boiler tune-up requirements.

A permitted source should evaluate the Potential to Emit (PTE) that was utilized to establish their air permit as it may need to be altered depending on the type of wood products combusted. The emission factor established for clean wood was most likely used to determine the PTE for an air permit issued to a facility utilizing a wood-fired boiler. Therefore, if a permitted source has been approved to combust clean wood but would like to combust or is combusting wood waste, the PTE should be re-evaluated to assist in gaining approval from the Indiana Department of Environmental Management (IDEM) and to update the air permit with correct information.

IDEM Offers Indiana Certified Wastewater Operators the Opportunity to Earn Four Technical Contact Hours

IDEM is offering an incentive of four technical contact hours toward the renewal of Indiana certified Wastewater Operator licenses for those who have not yet submitted their DMRs utilizing the NetDMR application and who enroll and successfully submit a DMR including the MMR/MRO utilizing NetDMR prior to December 31, 2014. This incentive is available once per operator and once per permit.

The U.S. EPA has proposed a new federal rule, the NPDES Electronic Reporting Rule, which will require all NPDES permit holders to submit/report NPDES compliance information electronically. This is an opportunity to start utilizing NetDMR and gain the incentive before it is federally mandated.

IDEM’s NetDMR webpage specifies more detailed information regarding the NetDMR tool and how to start utilizing it.

What Type of Solvent(s) Does Your Business Use?

Are you familiar with the solvent(s) being utilized within your cold cleaner degreaser operation?

Starting January 1, 2015, all persons who sell or purchase solvents for use in a cold cleaner degreaser operation will be required to keep the records specified within 326 IAC 8-3-8(c) including the true vapor pressure of the solvent. (The true vapor pressure is defined as “the equilibrium pressure exerted by a petroleum liquid as determined in accordance with methods described in American Petroleum Institute Bulletin 2517, “Evaporation Loss from Floating Roof Tanks,” 1962.”) A purchasing invoice or a copy of the manufacturer’s recommendation for the solvents utilized may include most of the required records.

In addition to speaking with Compliance and Technical Assistance Program (CTAP) staff, you may also visit the newly created Degreasing Operations webpage, for information on how to comply with state and federal regulations concerning degreasing, as well as tips to consider when evaluating solvent alternatives.

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