Publications
Recent Air Pollution Control and Permit Experience in the Lime Industry", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association,
Pittsburgh, PA 2007.
ABSTRACT
Full Text - 0.7 MB (.pdf format)
"The Challenge of Air Quality Permit Approval for a Glass Plant near Mount Rainier and Olympic National Parks", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, New Orleans, LA, 2006.
ABSTRACT
Locating a new air pollution source near national parks and wilderness areas increases the need for a more thorough evaluation of air quality impacts and available emission control methods. This paper discusses the complexity and unique hurdles of the air quality permit process for a 650 ton per day float glass plant proposed for western Washington State. This process required 24 months and resulted in the use of air pollution control measures more effective than similar projects in the U.S. The plant required air quality permits from both the local and state air pollution control agencies with oversight by five federal agencies. The state issued a Prevention of Significant Deterioration (PSD) air quality permit with requirements for the evaluation of Best Available Control Technology (BACT) and near-field air quality impacts. Selection of the emission control methods are discussed. A unique method developed to screen regional sources for the near-field modeling analysis is explained. In addition, the project was located within 200 kilometers of seven Class I air quality areas including Mount Rainier and Olympic National Parks. A separate evaluation was required by the National Park Service and U.S. Forest Service to assess far-field impacts on air quality standards, regional visibility and acid deposition. A review of impacts on endangered species was required by the National Marine Fisheries and US Fish and Wildlife Services. While prior float glass projects elsewhere in the U.S. had established BACT for the industry, the proximity to the Class I areas required greater control of the proposed air pollution emissions. Despite the effort taken to verify compliance with air quality permit requirements, the permit was challenged after issuance. Project construction was delayed until the USEPA Environmental Appeals Board verified compliance with the PSD and BACT requirements.
"New Source MACT and Residual Risk at an Iron Foundry", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, San Diego, CA, 2003.
ABSTRACT
“Evaluating Local Impacts of a Utility SCR Retrofit Project”, S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, Baltimore, MD, 2002.
In response to anticipated nitrogen oxide (NOx) emission control requirements, a Wisconsin utility proposed the installation of a selective catalytic reduction (SCR) control system at its largest power plant. This SCR control system would use anhydrous ammonia as the reagent. The surrounding municipality was given the opportunity to review the project prior to issuing a conditional use permit. While the SCR project would result in significant reductions in NOx emissions from the power plant, the surrounding community would experience several undesirable effects. These include generation of ammonia emissions from SCR slip and risks to large populations due to accidental releases during ammonia delivery, handling and storage. The Village evaluated the project and requested consideration of alternatives to the anhydrous ammonia SCR system which would pose fewer hazards, including the use of aqueous ammonia as a reagent. SCR systems using anhydrous and aqueous reagents were compared to determine the effects on project costs and the population impacted by accidental releases. During utility evaluation of these comments, the September 11, 2001 terrorist attacks in New York and Washington, D.C. occurred, increasing awareness of the public security hazards posed by the storage of hazardous materials. The final SCR design was changed to incorporate the use of the less hazardous aqueous ammonia as the reagent.
“Challenging a Title V Operation Permit with the Part 70(8) Petition Process: An Aluminum Foundry Case Study”, S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, Baltimore, MD, 2002.
ABSTRACT
The public can participate in the issuance of a Title V air quality operation permit by submitting comments to the reviewing agency during the comment period and hearing. If comments are not adequately addressed by the reviewing agency, federal operation permit regulations under 40 CFR Part 70(8) provide an opportunity to challenge a Title V operation permit by submission of a petition to the Administrator of USEPA. This case study presents the background, content, and outcome of a Title V petition. This petition was filed by neighborhood residents after the Wisconsin Department of Natural Resources issued a Title V operation permit to the Madison-Kipp Corporation in Madison, Wisconsin. This company is a zinc and aluminum die caster and foundry, located in the Schenk-Atwood neighborhood on the near east side of Madison. The factory is surrounded by homes, some located only a few feet from foundry buildings. While an industry has operated at the site for more than 100 years, the last ten years have seen a significant increase in production, air pollution discharges, and in the storage and release of hazardous air pollutants. During this expansion phase, complaints to the WDNR concerning MKC discharges increased. Extensive comments on the draft Title V operation permit were submitted both during the comment period and at a well-attended public hearing. After issuance of the Title V operation permit, neighborhood residents filed a Title V petition with the USEPA Administrator. The Title V petition asserted that the permit allows the foundry to discharge large quantities of uncontrolled emissions into a densely populated low income area; inaccurately estimates the foundry's impacts on residences and schools; and also, that it fails to require compliance with key air pollution control requirements. The petition requested USEPA review the permit and its supporting documents.
“Influence of Emission Estimates on a BACT Determination for Iron Foundry Core Making Operations”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Baltimore, MD, 2002.
ABSTRACT
Under the Prevention of Significant Deterioration air quality regulations, new air pollution sources must control their emissions using Best Available Control Technology (BACT). This case study reviews the issuance of a new source permit for phenolic-urethane coldbox core making operations at an iron foundry in Indiana. The finished cores are subsequently used to form the internal spaces within the iron casting. The project BACT analysis required an estimate of emissions during each phase of the process, including mixing of the sand and binder resin, activation of the resin using a catalyst, and storage of the finished cores. Volatile organic compound (VOC) emissions are generated by the handling of the phenolic-urethane resin and release of the triethylamine catalyst. The traditional emission control system is a packed bed scrubber using a sulfuric acid reagent to capture the catalyst for reuse. An alternative control option considered in the BACT analysis was regenerative incineration. While the packed system would control the catalyst emissions, incineration would also control the VOC emissions from resin handling. The incineration system would be considered BACT if the overall cost effectiveness in units of dollars per ton of pollutant removed was deemed acceptable by the state regulatory agency. The cost effectiveness varied depending on the procedure used to estimate uncontrolled VOC emissions from resin handling. These procedures include the American Foundryman's Society Form R booklet, compliance stack test results on similar core making operations using USEPA Methods 25 and 25A, a laboratory study of evaporative resin losses by the Ohio Cast Metals Society, and laboratory tests by resin manufacturers. Accurate emission estimates were essential to establish that incineration was not cost effective and a traditional packed bed scrubber represented BACT.
“Using a Flexible Compliance Strategy to Issue a Title V Operation Permit”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Baltimore, MD, 2002.
ABSTRACT
The issuance of a Title V operation permit for existing industrial facilities requires development of an accurate inventory of air pollution sources and verification these sources comply with applicable emission limitations and air quality standards. In some cases, existing operations may not comply with applicable air quality requirements and necessitate changes to the facility design to achieve compliance. This case study presents the Title V experience at a large iron foundry in Wisconsin. An air quality dispersion modeling analysis was conducted to verify compliance with the National Ambient Air Quality Standards and acceptable air concentrations for hazardous air pollutants. Initial modeling based on worst-case emission rates predicted violations of air quality standards. Additionally, emission estimates for older, uncontrolled operations suggested non-compliance with process emission limitations. A compliance strategy was necessary to demonstrate compliance with emission limits and air quality standards. To provide time for development of a cost-effective compliance strategy, an operation permit was issued based on an initial design scenario, referred to as Scenario #1. This scenario included improvements in the ventilation system, consolidation of roof vents into single stacks, installation of numerous baghouse control systems, and increases in stack heights. "X" lbs/hr emission limitations were established as place holders for limitations to be developed under the final compliance strategy. A compliance schedule in the permit established deadlines for conducting an updated dispersion modeling study to verify compliance with air quality standards, development of a final compliance strategy more cost effective than Scenario #1, and installation of the necessary improvements and control systems. This flexible approach allowed issuance of a Title V operation permit and time for development of a cost-effective compliance strategy.
"Evaluation of Gas Turbine Air Quality Impacts from a Community Perspective”, S. Klafka
Presented at the Electric Utilities Environmental Conference, Tucson, AZ, 2002.
“Air Regulations: Permitting Basics”, S. Klafka
Presented at the Environmental Primer Workshop sponsored by the Federation of Environmental Technologists, Inc. Kimberly, WI, 2002.
“Recent New Source MACT Determinations and Air Quality Compliance Experience in the Iron Foundry Industry”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Orlando, FL, 2001.
ABSTRACT
Construction and operation air quality permits recently issued to iron foundries reflect current air quality compliance issues facing the foundry industry. These issues include the determination of Best Available Control Technology or BACT under the Prevention of Significant Deterioration requirements for major source expansions; emission control strategies for hazardous air pollutants released during the pouring and shakeout of castings, and the establishment of Maximum Available Control Technology or MACT for air toxics regulated under Title III of the 1990 Clean Air Act Amendments. Recent construction permits for iron foundries in Wisconsin, Indiana and Tennessee have established BACT for the emissions of PM10, SO2, NOx, VOC, CO, Pb and Be, and new source MACT for inorganic and organic air toxics such as arsenic, chromium, cadmium, benzene and formaldehyde. Approved operations include continuous casting production lines with pouring, shakeout and sand handling operations, iron melting cupolas, and sand core manufacturing operations. BACT for PM10 continues to be the use of pulse jet fabric filter baghouses achieving outlet concentrations of 0.005 grains per actual cubic foot. BACT for VOC and CO emissions has required the use of incineration for cupola operations, and packed bed scrubbing systems for coldbox core making operations. New source MACT for air toxics has been determined to be the same as BACT with no additional requirements specific beyond that required for criteria pollutants. MACT for inorganic air toxics such as trace metals has been established as the same control methods required for PM10. MACT for organic air toxics such as formaldehyde and benzene has been established as the same control methods required for VOC. BACT and MACT control methods and emission limitations for these pollutants are summarized. Other foundry projects which have not been subject to the BACT and MACT requirements may also affect future control requirements. For example, two Georgia foundries will use thermal incineration for the control of VOC emissions from their pouring operations. As part of the Wisconsin hazardous air pollutant control program, state foundries must implement a pollution prevention program aimed at a reduction of benzene and other organic emissions from pouring, mold cooling and shakeout operations.
“Complexities of Air Quality Permit Issuance for an Iron Foundry near Great Smoky Mountains National Park”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Orlando, FL, 2001.
ABSTRACT
The issuance of air quality construction permits for new industrial projects is often a complex and time consuming process. This complexity increases dramatically when the project is subject to the Prevention of Significant Deterioration air quality regulations and particularly if the site is located near Class I air quality areas such as national parks and wilderness areas. The permitting experience for a new 160 ton per hour iron foundry located in eastern Tennessee is reviewed. This overview presents aspects of the project which will be useful for similar permitting projects. These aspects include air quality siting studies; interaction with state and federal air quality regulatory agencies including the National Park Service and U.S. Forest Service; development of Best Available Control Technology; use of the ISC3, VISCREEN, and CALPUFF air quality models to determine effects on air quality standards, visibility and acid deposition; and, development of a seven state emissions inventory to assess cumulative increment consumption at Class I and Class II air quality areas. While eastern Tennessee provided a desirable project site for logistical and economic reasons, it presented a complex and challenging situation for the issuance of a construction air quality permit. Preliminary ISC3 and CALPUFF modeling analyses were performed for several potential sites to assess their air quality impacts on nearby Class I air quality areas such as Great Smoky Mountains National Park and the Cohutta National Wilderness Area. After these analyses, the final site was selected for submission of the permit application. During the two year time period required to select a site and obtain an air quality permit, long-range modeling policies for Class I areas changed, resulting in the need for greater emission reductions beyond Best Available Control Technology to assure an insignificant and acceptable air quality impact on Class I areas.
“Air Quality Permit Issuance and Varying Interpretations of BACT in the Flat Glass Industry”, S. Klafka, M. Purcell, K. Jacobsen
Presented at the Annual Meeting of the Air & Waste Management Association, Orlando, FL, 2001.
ABSTRACT
During the past several years, six flat glass manufacturing facilities have received air quality construction permits under the Prevention of Significant Deterioration air quality regulations in the states of Wisconsin, Iowa, New York, Kentucky and North Carolina. While production methods and emissions were similar, interpretation of the Best Available Control Technology (BACT) requirement varied significantly depending on the state and the supervising office of the USEPA. Beginning in 1991 with facilities in Wisconsin, BACT had required the installation of a spray drier - electrostatic precipitator emission control system for the control of PM10 and SO2 emissions, with no provision to control NOx emissions. Subsequent BACT determinations by other states no longer required the spray drier - electrostatic precipitator system, based on the premise that this equipment was not cost effective. These same determinations did require use of the “3R Process”, an innovative control method, to reduce NOx emissions by approximately 50%. Litigation over the most recent BACT determination continues due to a petition filed under 40 CFR Part 70.8 of the Title V operation permit regulations. Evaluation of this petition by USEPA suggests the agency does not agree with the cost effectiveness criteria used in recent state determinations to establish BACT for flat glass plants. Consideration of the BACT determination history for flat glass plants will assist with future plant design and air pollution control determinations.
“Evaluation of Gas Turbine Air Quality Impacts from a Community Perspective”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Orlando, FL, 2001.
ABSTRACT
The recent deregulation of the utility industry and the simultaneous demand for additional electrical generating capacity has resulted in the construction of new gas turbine generation stations throughout the U.S. This has presented many communities with their first experience evaluating new electrical generating facilities. Like other states, Wisconsin has seen numerous turbine stations proposed by independent power producers as well as by more familiar utility companies. Some communities have rejected outright the construction of a new turbine station. Others have accepted the construction of new generating stations after extensive consideration of the economic and environmental impacts on the community. In the case study presented here, the Village of Pleasant Prairie evaluated the air pollution control permit application, draft permit and technical support documents provided by the Wisconsin Department of Natural Resources. Based on this review, the Village provided comments and suggestions to assure that the project minimized its air quality impacts on the community, utilized Best Available Control Technology to control its emissions, left room for economic growth in the area, and incorporated sufficient monitoring and reporting requirements to keep the Village updated on the facility air quality compliance status. The review of the proposed 1,050 combined cycle gas turbine generating station included a comparison with recent BACT determinations for similar turbine stations, an evaluation of the percentage of air quality increment to be consumed by the project, and an a modeling evaluation of the project. As a result of this review, the Village requested that the state agency incorporate the following additional requirements: emission offsets for the ozone nonattainment area were to be obtained from sources upwind of the project site; emission limitations were to be reduced to levels comparable to recently permitted turbine generating stations; emission limitations were to be lowered or stack heights increased to minimize the consumption of the air quality increment for PM10 and leave room for future industrial growth in the nearby industrial park; and, the Village was to receive copies of all pertinent testing, monitoring and compliance certification documents.
“Benzene Emissions and Exposure - Targeting Sources for the Greatest Benefit”, S. Klafka, et al.
Presented at the Annual Meeting of the Air & Waste Management Association, Orlando, FL, 2001.
ABSTRACT
Issuance of recent air quality construction and operation permits for iron foundries in Wisconsin has generated public concern over the air quality impacts of trace benzene emissions. These emissions are a product of incomplete combustion which occurs when molten iron comes in contact with organic binders in the sand core and molds. In Wisconsin, approval of industrial benzene emissions requires control by use of Best Available Control Technology (BACT) and a demonstration that the residual emissions are not injurious to humans or the environment. The results of the BACT determination and of the air quality impact analysis for benzene are presented at a public hearing prior to permit issuance by the state agency. To better inform the general public about foundry benzene emissions, public informational materials were developed by Wisconsin foundries. These compare of foundry benzene emissions with other sources of benzene exposure. Emissions and exposure data were taken from the permit support documents for foundries, USEPA National Air Toxics Assessment and existing literature. Current benzene emission inventories indicate that less than one percent of benzene emissions result from industrial operations. The remainder is generated by area and mobile sources. The predicted health risks due to foundry benzene emissions are much less than background concentrations and other common sources of risk. These comparisons place industrial emissions and impacts in context with other more familiar activities. If they were more widely publicized, members of the general public would be able to make more informed decisions about the risk posed by local industries. These comparisons also suggest that everyone will benefit if the focus of benzene control strategies includes non-industrial as well as industrial sources.
"Understanding Benzene Emissions from Iron & Steel Foundries", S. Klafka
A fact sheet developed for the Wisconsin Cast Metals Association, 2000.
"Measurement of Organic Air Toxics at Iron Foundries", S. Klafka, J. Loeffler
Presented at the Annual Meeting of the Air & Waste Management Association, San Antonio, TX, 1995.
Since 1988, air toxics emissions from foundries have been regulated in Wisconsin. Emission estimates and compliance evaluations have been based on minimal data, especially for organic air toxics. In recent years, compliance testing for new iron foundry operation has expanded the data base for these air pollutants. This paper summarizes stack tests conducted at two Waupaca Foundry facilities. Test results are presented for volatile organic compounds, acrolein, benzene, and formaldehyde. Test methods, measured emission rates, production throughput and raw materials are described. Foundry processes tested include pouring, mold cooling, and shakeout operations. Emission factors for these operations are developed from the results. These factors have been used to improve emission estimates and serve as a reliable tool for demonstrating compliance with air permit requirements.
"Air Toxics Emission from Two Wood and RDF-Fired Fluidized Bed Combustors", S. Klafka, D. Welder
Presentated at the Annual Meeting of the Air & Waste Management Association, Cincinnati, OH, 1994.
ABSTRACT
Northern States Power Company operates two atmospheric fluidized bed combustors (AFBC) in LaCrosse, Wisconsin. Each AFBC is rated at 245 million BTU per hour while burning a 50/50 mixture of woodwaste and refuse derived fuel. Each AFBC is equipped with a multicyclone and electrified filter bed for air pollution control. Stack testing has been conducted for the following air pollutants: particulates, carbon monoxide, hydrogen chloride, arsenic, benzene, beryllium, cadmium, chromium, formaldehyde, lead, mercury, nickel, zinc, polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans. Results from stack tests at the facility are summarized and efforts to improve emissions control are described. Results from an air quality impact analysis and risk assessment are summarized, and compliance with state and federal air quality regulations is addressed.
"Recent Air Quality Compliance Experience at Wisconsin Gray and Ductile Iron Foundries", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, Cincinnati, OH, 1994.
Since the mid-1970's, a Wisconsin company has operated four gray and ductile iron foundries. Recent expansions at these facilities were subject to new air pollution control regulations and policies. Of these, the Prevention of Significant Deterioration, or PSD regulations and Wisconsin regulations controlling the emission of hazardous air pollutants have most significantly affected the design and planning of new processes. Fabric filter baghouses have successfully controlled dust emissions from new pouring, cooling and shakeout operations. State air toxics regulations have required estimation and testing of organic emissions resulting from the decomposition of core and molding sand raw materials. Pollutants receiving significant attention were benzene and formaldehyde. Air permit applications have required the technical and economic evaluation of emission control systems such as incinerators, carbon adsorption, biofiltration and mist scrubbing. With modest increases in stack heights, compliance air quality standards for criteria and hazardous air pollutants has been achieved.
"Composition of VOC Emissions from the Sycamore Landfill", S. Klafka, M. Anders, M. Hollifield, J. Hung, D. Keenan, A. Kolb, D. Kraut, C. Wright
Presented at the Annual Meeting of the Air & Waste Management Association, Cincinnati, OH, 1994.
ABSTRACT
Landfill gas (LFG) samples were taken from various locations at the Sycamore Landfill in Madison, Wisconsin. The LFG was analyzed for volatile organic compounds (VOC) including vinyl chloride, benzene, toluene, ethyl benzene, and xylene. Sampling locations include leachate extraction wells, the perimeter gas extraction blower system, and the landfill surface. Surface measurements required the development of gas collection chambers, and included areas of known fractures in the landfill cap as well as randomly selected locations. Measurements indicated that, except for fractured areas of the cap, much of the surface released negligible VOC to the atmosphere. Variations in the LFG composition suggests the attenuation of biodegradable VOC in the emissions from the unfractured landfill surface and gas extraction system. The least biodegradable compound, vinyl chloride, showed the least reduction in all sampling locations. The VOC composition of LFG from the interior of the landfill was most comparable to LFG from the surface fractures.
"Sulfur Dioxide Control in a Rotary Lime Kiln", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, Denver, CO, 1993.
Air Toxics Control Alternatives for Iron Foundry Pouring, Cooling and Shakeout Operations", S. Klafka
Presented at the Annual Meeting of the Air & Waste Management Association, Kansas City, MO, 1992.
ABSTRACT
Total suspended particulates (TSP) and volatile organic compounds (VOC) are released during the pouring, cooling and shakeout of iron castings. Contained in the TSP and VOC emissions are air toxics now receiving greater attention by regulatory agencies. The TSP emissions can be effectively controlled using fabric filter baghouses and wet scrubbers. The VOC emissions historically have not required control. Case studies are used to describe the air quality impacts associated with the TSP and VOC emissions. The use of stacks which are not equipped with obstructions and avoid excessive building downwash effects may be required to comply with the air standards for TSP and air toxics. The VOC emissions are generated by the degradation and evaporation of organic binders and raw materials contained in the molding sands or core binders. Potential methods for controlling the VOC emission and associated air toxics include the following: alternative core binder materials; reduced mold organic content; extended/reduced mold cooling time; use of tighter molds; and, add-on control equipment such as regenerative incineration, catalytic incineration, carbon adsorption, and biofiltration. Factors controlling the technical and economic feasibility of each of the potential VOC control methods are discussed.