A Pollution Prevention in Permitting Project (P4) in a Title V Permit
New Hampshire Department of Environmental Services
The New Hampshire Department of Environmental Services (NH DES) administers the Federal Clean Air Act Title V operating permit program and encourages the use of pollution prevention and other innovative methods as air quality compliance methods to meet the provisions of federal and state laws and regulations. Title V of the Federal Clean Air Act established the framework under which major stationary sources obtain a federally enforceable operating permit. The Title V operating permit incorporates all of the air requirements for a facility into one document. According to the Title V program, a major source is defined as any source that emits at or above the following thresholds: 50 tons per year (tpy) of volatile organic compounds (VOCs), 50 tpy of nitrogen oxides (NOX) in non-attainment areas and 100 tpy of NOX in the Ozone Transport Region, 100 tpy of sulfur dioxide (SO2), 100 tpy of carbon monoxide (CO), 100 tpy particulate matter, and 10 tpy of a single hazardous air pollutant (HAP) or 25 tpy of any combination of HAPs.
Under the provisions of the state regulations, Anheuser-Busch, Inc. (Anheuser-Busch) was subject to Reasonable Available Control Technologies (RACT) requirements. Anheuser-Busch proposed to achieve the required reductions through pollution prevention measures because no known add-on control technologies or other pollution reduction methods had been used in similar processes. As a result, NH DES partnered with Anheuser-Busch to develop a comprehensive RACT order to implement the P2 activities. The proposed pollution prevention methods to achieve compliance with RACT also met the more stringent requirements of Best Available Control Technologies (BACT) and Lowest Achievable Emissions Rates (LAER) at other plant locations. From 1996-2002, Anheuser-Busch implemented numerous P2 activities according to the RACT Order that were incorporated into the facility's Title V Operating Permit.
The major provisions of the RACT Order include minimization of product loss through better bottling practices, the use of state-of-the-art bottle fillers, enhanced operator training, improved information management systems, and defined performance objective and metrics; recycling of lost product to ethanol; reduction and capture of air emissions from laser and ink production date coders; and minimization of glue application with variable speed labelers. The RACT Order also caps the VOC emission rate (lb VOCs/barrels of beer packaged) on a monthly and annual basis and requires Anheuser-Busch to track the VOC emissions on a monthly basis.
This effort was primarily driven by the Air Division within NH DES with assistance from EPA Region 1 and Anheuser-Busch. Control Technologies (BACT) and Lowest Achievable Positive Results
This opportunity has provided Anheuser-Busch with the incentive to constantly improve its state-of-the-art packaging equipment by integrating pertinent equipment as existing equipment is replaced. While the technological improvements reduce outputs (air emissions) and track daily production and material inputs, the implemented technologies do not measure reductions, except through the establishment of an environmental management (or tracking) system. Emissions are tracked for compliance with the emissions rate cap, but not for a correlation between pollution prevention measures and associated emission reductions.
Key Elements, Suggestions, and Challenges
This project forged a strong relationship between the NH DES Air Resources Division, Anheuser-Busch, and EPA Region 1. It also increased the awareness among permit writers of flexible compliance alternatives by incorporating pollution prevention into the performance evaluation of permit staff. Sharing common goals and needs, the stakeholders continually communicated effectively and compromised often. All members of the project team agreed that having laws and regulations that support pollution prevention were necessary to ensure project success. Initially, the facility feared that modifying existing processes to incorporate the state-of-the-art technology would increase regulatory requirements. To a certain extent, this fear will probably always exist, but developing and fostering a collaborative, trustworthy relationship between the regulator and industry is one way to allay these fears. Support from top management at the company, the U.S. EPA, and state regulators provided the incentive for the company to proceed with the P2 efforts.
The greatest challenge was getting Anheuser-Busch, NH DES, and U.S. EPA to agree on the provisions of the RACT Order and the permit. The U.S. EPA Region 1 was heavily involved because of the RACT requirement. Once these parties agreed, through numerous meetings and negotiations, implementing the project proceeded smoothly.
More InformationNew Hampshire Department of Environmental Services, Air Resources Division, Title V Operating Permit Program