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Air Quality Permitting Fact Sheet

Introduction

The Maryland Department of the Environment (MDE) has established regulations governing emissions of pollutants into the ambient air. The State's program is based upon its compliance with the Federal Clean Air Act (CAA) which establishes the US Environmental Protection Agency's authority to set national air quality standards. In Maryland, parts of the State, such as Prince George's County, are not in compliance with the national standards and are therefore known as "non-attainment areas" subject to more stringent regulation and permitting.

Congress has implemented significant modifications to the Clean Air Act including the new operating permit requirements in Title V. The purpose of Title V was to consolidate all federal air quality requirements for a source in one permit document. Title V permitting is conducted by MDE and applies to any "major source". According to MDE regulations, a major stationary source in Prince George's County is any stationary facility that emits 25 tons or more per year of volatile organic chemicals or oxides of nitrogen (NOx), or 10 tons per year or more of any single Hazardous Air Pollutant, or 25 tons per year or more of combined Hazardous Air Pollutants. It is significant to note that in determining whether a facility is a major source, the potential emissions must be used to determine the need for a permit and not the facility's actual emissions.

The University of Maryland campus is considered a major source primarily due to nitrogen oxide (NOx) emissions from the central steam plant. The Maryland Public Service Commission has issued a Certificate of Public Convenience and Necessity (CPLN) authorizing and imposing operating conditions at the Central Heat and Power Plant. In addition, MDE has issued a Title V Permit which identifies air quality regulations applicable to the University, sources of air emissions (registered equipment), an emissions inventory and compliance demonstration.

Applicable University Policy

University of Maryland Environmental, Safety and Health Management Policy

Applicable Regulations

Summary of Requirements

MDE has established a broad air quality permitting program that requires a permit or approval for all installations which may emit pollutants. ESSR must be notified of the installation, modification, or removal of all University owned and operated fuel-burning equipment and fuel/oil storage tanks. Examples of these miscellaneous equipment or tanks include, but are not limited to: fuel tanks for generators and equipment with a storage capacity greater than 55 gallons, boilers, oil-water separators, cooking oil storage tanks/drums, hydraulic elevators, electrical devices and electrical generators.

Specifically, the University may not construct or modify any air emission sources without first obtaining a permit or approval. Air emission sources include, but are not limited to: boilers, furnaces, water heaters, emergency generators, gasoline storage tanks, solvent degreasers, printing presses and charbroilers. The MDE regulations exempt the following sources from permitting:

  1. Motor vehicles.
  2. Fuel-burning equipment and space heaters using gaseous fuels or No. 1 or No. 2 fuel oil with a heat input less than 1,000,000 Btu per hour.
  3. Fuel-burning equipment using a solid fuel with a heat input of less than 350,000 Btu per hour.
  4. Stationary internal combustion engines with less than 500 brake horsepower (373 kilowatt) operating less than 2,000 hours per year and are not used to generate electricity for sale, for peak shaving or load shaving. For sources that install more than one stationary internal combustion engine over a 5-year period, the above exemption does not apply if the total potential to emit emissions from the engines installed over the 5-year period exceeds the major source threshold as defined in Regulation .01C of this chapter.
  5. Bench scale laboratory equipment used exclusively for chemical or physical analysis or experimentation.
  6. Portable brazing, soldering or welding equipment.
  7. Comfort air conditioning or comfort ventilating systems which are not designed to remove emissions generated by or released from specific units of equipment.
  8. Water cooling towers and water cooling ponds unless used for evaporative cooling of water from barometric jets or barometric condensers, or used in conjunction with an installation requiring a permit to operate.
  9. Grain, metal, plastic, or mineral extrusion presses.
  10. Porcelain enameling drying ovens.
  11. Unheated VOC dispensing containers or unheated VOC rinsing containers of 60 gallons capacity or less.
  12. Equipment used for hydraulic or hydrostatic testing.
  13. The following equipment or an exhaust system or collector servicing exclusively this equipment:
    • Blast cleaning equipment using a suspension of abrasive in water
    • Kilns used for firing ceramic ware, heated exclusively by natural gas, liquefied petroleum gas, electricity, or any combination of these
    • Confection cookers where the products are edible and intended for human consumption
    • Drop hammers or hydraulic presses for forging or metal working.
    • Die casting machines.
    • Photographic process equipment used to reproduce an image upon sensitized material through the use of radiant energy.
    • Equipment for drilling, carving, cutting, routing, turning, sawing, planing, spindle sanding, or disc sanding of wood or wood products.
    • Equipment for surface preparation of metals by use of aqueous solutions, except for acid solutions.
    • Equipment for washing or drying products fabricated from metal or glass provided no VOCs are used and that no oil or solid fuel is burned.
    • Laundry dryers, extractors, or tumblers for fabrics cleaned with only water solution or bleach or detergents.
    • Containers, reservoirs, or tanks used exclusively for electrolytic plating work, or electrolytic polishing, or electrolytic stripping of brass, bronze, cadmium, copper, iron, lead, nickel, tin, zinc, and precious metals.
  14. Natural draft hoods or natural draft ventilators.
  15. Containers, reservoirs, or tanks used for dipping operations for coating objects where no VOCs are used; dipping operations for applying coatings of natural or synthetic resins which contain no VOC; storage of butane, propane or liquefied petroleum or natural gas; storage of lubricating oils; unheated storage of VOC with an initial boiling point of 300 degrees F or greater; storage of Nos. 1,2,4,5, and 6 fuel oil and aviation jet engine fuels; storage of gasoline having an individual tank capacity of 2000 gallons or less; storage of VOCs normally used as solvents, diluents, thinners, inks, colorants, paints, lacquers, enamels, varnishes, liquid resins or other surface coatings and having a capacity of 2,000 gallons or less.
  16. Gaseous fuel-fired or electrically heated furnaces for heat-treating glass or metals, the use of which does not involve molten materials.
  17. Crucible furnaces, pot furnaces, or induction furnaces, with a capacity of 1,000 pounds (454 kilograms) or less each, in which no sweating or distilling is conducted, or any fluxing conducted, using chloride, fluoride, or ammonium compounds and from which only the following metals are poured or in which only the following metals are held in a molten state:
    • Aluminum or any alloy containing more than 50 percent aluminum, if no gaseous chloride compounds, chlorine, aluminum chloride, or aluminum fluoride is used,
    • Magnesium or any alloy containing more than 50 percent magnesium,
    • Lead or any alloy containing more than 50 percent lead,
    • Tin or any alloy containing more than 50 percent tin,
    • Zinc or any alloy containing more than 50 percent zinc,
    • Copper, or
    • Precious metals.
  18. Vacuum cleaning systems used for house-keeping purposes.
  19. Charbroilers and pit barbecues with a total cooking area of 5 square feet or less.
  20. Sheet-fed letter or lithographic printing presses with a cylinder width of less than 18 inches.

MDE charges a one time fee of $500 to $1,000 for permitting air emission sources ($200 for charbroilers.)

Training

All individuals associated with the maintenance of fuel burning equipment are required to undergo training every three years to ensure proper operations. Individuals involved in the removal and recycling of chlorofluorocarbons must be trained and certified (see CFC Appliance Recycling and Recovery Practices Fact Sheet).

Reporting

The University must submit an annual air quality emission report by April 1 covering the preceding year. The report provides an estimated quantity of each air pollutant emitted from all permitted sources. The tabulation of the report requires the maintenance of fuel use records for each permitted source and the calculation of emissions based on USEPA published emission factors for different types of equipment and fuels. In addition, the University must submit an air quality compliance certification report by April 1 that certifies compliance with all applicable air quality requirements.

Inspections

Facilities Management (HVAC Shop) has established a routine maintenance and inspection program for permitted sources. Routine maintenance, including the changing of filters, cleaning of burners, etc. is key to minimizing air emissions and is required as part of the University's Title V operating permit.

Recordkeeping

Operators of permitted equipment must maintain records of all monthly fuel usage by fuel type, preventive maintenance schedules and gasoline tank testing and gauging records.

Written Program

ESSR and departments associated with air emissions must adhere to the conditions contained in UMD's Title V air quality permit.

University Resources

Department of Environmental Safety, Sustainability and Risk (301) 405-3960
ESSR Fax No.    (301) 314-9294
Department of Facilities Management (301) 405-3231
ESSR Website: https://essr.umd.edu

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