Environmental Engineering for Air Emissions

Background 

In three previous papers we dealt with an overview of environmental engineering, industrial wastewater permits, and industrial wastewater environmental engineering. In this paper, we will discuss environmental engineering required to address air emissions to the outside environment. Environmental engineering for air emissionsThese emissions result from manufacturing and industrial operations. They may be from a point source such as a smoke stack or from a non-point source and are called fugitive emissions. The latter result from processes typically inside a building or in an outside designated area. Environmental engineering is required to determine the best reasonably achievable control technology to minimize the emissions to the environment outside of the facility. The environmental air engineer must be involved in the design, testing, and adjusting the controls. Applications for Title V Air permits and Federally Enforceable State Operating Permits (FESOPs) must be signed and sealed by a Florida licensed Professional Engineer (P.E.). A P.E. in Florida is only allowed to practice in areas that he or she has the required education, training, and experience. Thus, the P.E. must be an environmental engineer with air emissions knowledge and experience and is quite often called the Air Engineer and is usually with an Environmental Consulting firm such as ours, Environmental Safety Consultants, Inc. 

Start with the Pollutants 

To engineer the air emissions controls, you have to know the process generating the emissions. The environmental engineer must review the raw materials, the industrial or manufacturing process, the resultant air emissions, and the control options. Following are a few pollutants which may be of concern: 

  • Particulate Matter (physical particles or dust) 
  • Nitrogen Oxides 
  • Sulfur Dioxide 
  • Carbon Monoxide 
  • Volatile Organic Compounds (VOCs) 
  • Ozone 
  • Lead 

All of these except VOCs are criteria air pollutants established by the U.S. Environmental Protection Agency (EPA, https://www.epa.gov/criteria-air-pollutants).  Each type of pollutant may require a different environmental engineering design to remove or reduce it before being emitted to the outside environment.

Clean It Up 

The goal is to clean up the air so the pollutants are eliminated or below State standards prior to emission. These standards are thresholds for public health concerns. If the pollutants are below these criteria, there is not a public health concern, but there still may be a concern for unborn babies (pregnant women), children, the elderly, and individuals with certain lung conditions, such as emphysema, asthma, chronic obstructive pulmonary disease (COPD), etcetera. 

Control Design 

The control design is selected to address the pollutants. Following are a few examples: 

  • Alternative raw materials 
  • Industrial process modifications 
  • Filters (cloth, baghouses) 
  • Cyclones (gravitational) 
  • Air scrubbers 
  • Precipitators (electrostatic) 
  • Equipment maintenance and cleaning 

Role of the Environmental Air Engineer

First, the environmental engineer reviews the industrial process, including materials and chemicals, generating the air emissions. The engineer then evaluates several control design options and runs calculations to determine which one will work best and will be cost-effective. He or she then prepares the air permit application; submits it to FDEP and, if required, to the County; provides additional information requested by the FDEP and County; reviews the permit making sure that it meets good engineering practice and is manageable for the client; and, if requested, monitors the treatment process in light of the permit conditions. 

Environmental Safety ConsultantsSo there is a discussion of air emissions environmental engineering and what the environmental engineer’s role is! If you need any assistance, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a P.E. on staff. We have the credentials and experience to help you with your industrial wastewater needs. We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!

Air Emissions Permits

Certain businesses often ask us at Environmental Safety Consultants if they are required to apply for air emissions permits.  The air emissions permitsanswer depends on what types of equipment they operate, what chemicals they use, and what kinds of pollutants they generate.  Although the State of Florida reserves the right to permit any sources of pollution, it does not want to get bogged down with a multitude of small or “de minimis” sources.Why then are sources such as paint spray booths, dry cleaners, and fiberglass spa manufacturers regulated?  The answer lies in the pollutants generated.  Certain chemicals such as methyl ethyl ketone (MEK) in paint or solvents, tetrachloroethylene or perc used in dry cleaning, and styrene in fiberglass manufacturing are categorized as hazardous air pollutants (HAPs) by the U.S. Environmental Protection Agency (EPA).  You can find information on the EPA at www.epa.gov.These chemicals present a higher risk to human health than others and, consequently, are regulated more strictly.  Beyond HAPs, those sources that can generate a significant nuisance such as blowing dust, paint overspray, metals, or fuel odors are also targeted for permitting.  General usage of solvents and chemicals inside a facility can require an air permit for fugitive emissions since there is no single emissions point such as a smoke stack.

Obtaining an air emissions permit for a source, even a small one, can be a lengthy, complicated, and expensive process for any business.  Fortunately, there are some less harrowing alternatives for certain sources.  Additionally, modifying the process or substituting less hazardous materials or chemicals may eliminate the need for a permit or may simplify the permit.  Reducing the amount of material escaping to the atmosphere can drop a source’s emissions below a permitting threshold.For common sources with similar operations, there may be a general permit available with less rigorous application and compliance requirements.  To determine permit requirements, businesses must review their operations, chemicals, controls, and pollutants.  With this information, they will be ready to determine permit requirements.

There are a few different types of air emissions permits.  Title V Permits cover the largest sources and are the most complicated to obtain.  For smaller sources which still require an individual permit, there is the Federally Enforceable State Operating Permit (FESOP).  Finally, there are General Permits for commonly encountered sources such as concrete ready-mix plants, crematories, and other facilities.For individual air emissions permits such as Title V Permits or FESOPs, the air permit application is a two-step process.  First, the Construction Permit application is submitted so the source can be constructed or installed.  After it is up and running, an Operating Permit application is submitted.  There may be inspections, engineering certifications by a Florida Professional Engineer (P.E.), and emissions testing required before the Operating Permit application can be submitted.  The Operating Permit will contain general conditions and specific conditions which can include record keeping, testing, and reporting.Permitting requirements all originate with the Clean Air Act (CAA) passed years ago by Congress.  EPA has promulgated regulations to implement the CAA.  Florida Department of Environmental Protection (FDEP) has passed its own state regulations to enforce the EPA’s federal regulations.  Check FDEP out at https://floridadep.gov.  Therefore, in Florida the FDEP is the air permitting authority.  So typically, the appropriate FDEP district office is contacted to determine permit requirements.  For some of the larger counties, the counties themselves are the permitting authority for the FDEP.  But, FDEP can tell you that.

So, there you have it.  A broad picture of air emissions permits in Florida.  Let us know at (941) 795-2399 if we at Environmental Safety Consultants can help you.  You will be able to breathe a lot easier!