The Catholic University of America

Environmental Health & Safety Manual

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27 - Title V Compliance

27.1  General Conditions

27.2  Power Plant Boilers

27.3  Emergency Generator Sets

27.4  Spray Paint Booth

27.5  Glass Melters

27.6  Gasoline Above-Ground Storage Tank

27.7  Miscellaneous/Insignificant Activities

 

This information provides a basic summary for compliance with the University's Title V Operating Permit (010-R2).  It is not intended to act as a substitute for the Permit; Individuals with responsibilities pertaining to permit compliance must be familiar with the actual permit language in its entirety where applicable.

 

27.1 General Conditions

 

27.1.1  Contact Environmental Health & Safety prior to the construction, installation or modification of any equipment which emits air pollutants to verify whether additional permitting may be required.

 

27.1.2  Control of Fugitive Dust

  • Use engineering controls as necessary to minimize visible emissions from unpaved roads.  
  • Maintain paved roadways and parking lots in a reasonably clean condition at all times. 
  • For vehicles transporting dusty material, fully cover the material with a tarp or other material; ensure no spillage of the materials during transport, loading and unloading.
  • Minimize emissions from stockpiles of dusty material; keep material wetted or covered.

Fugitive dust emissions from the following are prohibited:

  • Any material handling, screening, crushing, grinding, conveying, mixing or other industrial-type operation or process;
  • Heater-planers in repairing asphaltic concrete pavement;
  • Portable tar melters, unless close fitting lids in good repair for the tar-pots are used;
  • the ventilation of tunneling operations;
  • the cleaning of exposed surfaces through the use of compressed gases.

 

27.1.3 Open Fires

Open fires are prohibited unless otherwise provided for in 20 DCMR 604.2.

 

27.1.4 Asbestos

Comply with 20 DCMR 800 when handling asbestos-containing materials.

 

27.1.5 Fuel Oil Requirements

  • Use only ultra low sulfur No. 2 fuel oil, containing no more than 15 parts per million sulfur by weight.
  • Conduct sampling of all No. 2 fuel oil deliveries to independently verify sulfur content. Sample analysis shall be performed using one of the following methods: ASTM D129, D1266, D1552, D2622, D4294 or D5453.
  • Maintain Bills of Lading for all fuel oil deliveries.  Documentation must contain:
  1. the date of delivery;
  2. the name, address and telephone number of the transferor;
  3. the volume of fuel oil sold/transferred;
  4. the fuel oil grade; and
  5. the sulfur content of the fuel oil.

 

27.1.6  Engine Idling

Ensure compliance with 20 DCMR 900.1 regarding on-road engine idling.  Nonroad diesel engines shall not be idled for more than three consecutive minutes (emergency generator sets are exempt.)

 

27.1.7 Fleet Maintenance

Maintain fleet vehicles to prevent visible fumes or smoke for more than ten consecutive seconds.

 

27.1.8 Odors and Nuisance Pollutants

Ensure no emissions of odorous air pollutants from any source in any quantity, which is or likely to be injurious to public health or welfare, or which reasonably interferes with the enjoyment of life and property.

 

27.1.9 Protection of Stratespheric Ozone

Ensure compliance with 40 CFR 82. 

 

27.1.10 Architectural and Maintenance Coatings

For all surface coating and painting operations: 

  • Maintain Safety Data Sheets (SDSs) for all chemical compounds including solvents, reagents, paints and other surface coatings;
  • Document the volatile organic compound (VOC) content, measured in weight percent, of solvents used;
  • Record the quantity of all solvents used, in pounds per hour, and the number of hours that solvents are applied each day.

Paints and refinishing coatings that contain VOCs in excess of the limits specified in the table below, including any VOC containing materials added to the original coating supplied by the manufacturer, are prohibited:

VOC Content Limits for Architectural Coatings1

Coating Category

VOC Content Limit (grams VOC per liter)2

Flat Coatings

100

Non-flat Coatings

150

Non-flat High-Gloss Coatings

250

Specialty Coatings:

 

Antenna Coatings

530

Antifouling Coatings

400

Bituminous Roof Coatings

300

Bituminous Roof Primers

350

Bond Breakers

350

Calcimine Recoater

475

Clear Wood Coatings:

 

          Clear Brushing Lacquers

680

          Lacquers (including lacquer sanding sealers)

550

          Sanding Sealers (other than lacquer sanding sealers)

350

          Varnishes

350

Concrete Curing Compounds

350

Concrete Surface Retarders

780

Conjugated Oil Varnish

450

Conversion Varnish

725

Dry Fog Coatings

400

Faux Finishing Coatings

350

Fire-Resistant Coatings

350

Fire-Retardant Coatings: Clear

650

Fire-Retardant Coatings: Opaque

350

Floor Coatings

250

Flow Coatings

420

Form-Release Compounds

250

Graphic Arts Coatings (Sign Paints)

500

High-Temperature Coatings

420

Industrial Maintenance Coatings

340

Impacted Immersion Coatings

780

Low-Solids Coatings

120

Magnesite Cement Coatings

450

Mastic Texture Coatings

300

Metallic Pigmented Coatings

500

Multi-Color Coatings

250

Nuclear Coatings

450

Pre-Treatment Wash Primers

420

Primers, Sealers, and Undercoaters

200

Reactive Penetrating Carbonate Stone Sealer

600

Quick-Dry Enamels

250

Quick-Dry Primers, Sealers and Undercoaters

200

Recycled Coatings

250

Roof Coatings

250

Rust Preventative Coatings

400

Shellacs – Clear

730

Shellacs - Opaque

550

Specialty Primers, Sealers and Undercoaters

350

Stains

250

Stone Consolidants

450

Swimming Pool Coatings

340

Swimming Pool Repair and Maintenance Coatings

340

Temperature-Indicator Safety Coatings

550

Thermoplastic Rubber Coatings and Mastics

550

Traffic Marking Coatings

150

Waterproofing Sealers

250

Waterproofing Concrete/Masonry Sealers

400

Wood Preservatives

350

1 Limits are expressed in grams of VOC per liter of coating thinned to the manufacturer's maximum recommendation, excluding the volume of any water, exempt compounds, or colorant added to tint bases. Manufacturer’s maximum recommendation means the maximum recommendation for thinning that is indicated on the label or lid of the coating container.

2 Conversion factor: one pound VOC per gallon (U.S.) = 119.95 grams per liter.

3 Units for this coating are grams of VOC per liter (pounds of VOC/gallon) of coating, including water and exempt compounds.

 

27.2  Power Plant Emission Units - Kewanee Boilers

27.2.1  Operational Limitations

  • Primary fuel shall be natural gas.  Use of No. 2 fuel oil is permitted only during gas supply emergencies or curtailments, or for periodic testing not to exceed a combined total of 48 hours during any calendar year.
  • Total fuel usage, tracked on a rolling 12-month basis, for all boilers in aggregate shall not exceed 555 million cubic feet of natural gas and 250,000 gallons of No. 2 fuel oil.

 

27.2.2  Monitoring and Testing

At least once per quarter when firing natural gas and once per week when firing No. 2 fuel oil, during operation of the boilers, conduct visual observations of emissions.  If there are no visible emissions, such observations shall be noted.  If visible emissions are observed, arrange for prompt independent testing by a certified opacity reader, using Method 9 testing.

Regardless of whether any visible emissions are observed during quarterly or weekly monitoring, conduct at least one Method 9 opacity test annually for each boiler.

 

27.2.3  Record-keeping

Maintain records for:

  • fuel deliveries including bills of lading and sampling reports;
  • visible emissions monitoring: For the Method 9 opacity testing, include:
  1. the date and time of each test;
  2. the name, address and telephone number of the tester;
  3. proof of certification of the tester pursuent to Reference Method 9;
  4. Identification of the emission unit(s) being observed during the test;
  5. the operation rate of the unit(s) being tested (boiler load in pounds of steam per hour and the percent of rated capacity at which the boiler operated during the test);
  6. the amount and type of fuel fired during the test; and
  7. data from a minimum of 30 minutes of visible emissions observations.
  • the number of hours each boiler is operated on No. 2 fuel oil each month and the reason for fuel oil use.  Operating hours shall be maintained in a rolling 12-month sum format;
  • the amount of each type of fuel used each month, maintained in a rolling 12-month sum format;
  • all boiler adjustments: Maintain in a permanently bound logbook records of all combustion process adjustments including:
  1. the date on which the combustion process was last adjusted;
  2. the name/title/affiliation of the person who made the adjustment;
  3. the NOx emission rate in parts per million by volume, dry basis (ppmvd) after adjustments were made;
  4. the CO emission rate in ppmvd after adjustments were made;
  5. the CO2 concentration in percent (%) by volume dry basis after the adjustments were made; and
  6. the O2 concentration in % by volume dry basis after adjustments were made.

 

27.3 Emergency Generator Sets

27.3.1 Operational Limitations

  • Each emergency generator shall be operated for fewer than 500 hours in any given 12-month period;
  • Emergency generators shall be used only during emergencies resulting in electrical power outages due to the failure of the electrical grid; on-site disaster; local equipment failure; or public service emergencies (Flood, fire, natural disaster, etc.);
  • Each emergency generator may be operated for maintenance checks and readiness testing for no more than 100 hours per calendar year.  This 100 hours is considered part of the 500 hour operational limit above.
  • The units shall fire only ultra-low sulfur diesel fuel that contains a maximum sulfur content of 15 ppm, and either a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.

 

27.3.2 Monitoring and Testing

  • Monitor the total hours of operation each month with the use of a properly functioning, non-resettable hour metering device.
  • Maintenance shall include changing the oil and filter every 500 hours of operation or annually (whichever comes first); inspecting the air cleaner every 1,000 hours of operation or annually (whichever comes first); and inspecting all hoses and belts every 500 hours of operation or annually (whichever comes first).
  • Minimize engines time spent at idle during start-up operations; minimize the engines start-up time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes.

 

27.3.3 Record-keeping

In a logbook for each emergency generator; record the following:

  • the date, time, duration and reason for each start-up, including whether it is operating for emergency or non-emergency situations. If for an emergency, classify the type of emergency;
  • the total hours of operation for each month and the cumulative 12-month rolling period, which shall be calculated and recorded within 15 days of the end of each calendar month for the previous month;
  • the total hours of operation for readiness testing and maintenance checks each month, also recorded within 15 days of the end of each calendar month, and totaled for each calendar year by January 15.
  • total fuel used in the engine/generator, kept in a 12-month rolling format;
  • records of maintenance performed on the unit;
  • results of any visible emissions monitoring performed;
  • records of the occurrence and duration of each/any malfunction of operation, and the resulting corrective actions;

All logbook entries must be initialed.

Maintain a copy of the emergency generator manufacturer's maintenance and operating recommendations.

For the emergency generators located at Centennial Village, Dufour, Marist, Opus, O'Connell and the Portable (2) unit, maintain copies of the EPA Certificates of Conformity.

 

27.4 Spray Paint Booth - Crough Center

27.4.1 Emission Limits

Emissions of more than 15 pounds of VOCs in any one day, and/or more than 3 pounds in any one hour, is prohibited unless the uncontrolled VOC emissions are reduced by at least 90% overall capture and control efficiency.

No visible emissions shall be emitted from the spray paint booth.

 

27.4.2 Operational Limitations

  • No chemical strippers containing methylene chloride (MeCl) shall be used;
  • Adhesives, sealants, adhesive primers or sealant primers shall not be used unless they are contact adhesives sold by the manufacturer in one-gallon or less containers;
  • Coatings shall be primarily applied by the following methods: powder coating; hand-held non-refillable aerosol containers; and non-atomizing application technology (paint brushes, rollers, dip coating, hand wiping, etc.);
  • If the spray gun is used:
  1. the coatings shall not contain any compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd); and
  2. cleaning of spray guns shall be performed in enclosed, recycling equipment which must remain closed when not in use. 
  • The booth must be fitted with filter technology to achieve at least 98% capture of paint overspray;
  • Exhaust filters shall be replaced as specified by the manufacturer;
  • The unit shall be ventilated at negative pressure;
  • All fresh and used coatings and solvents, and cloth/paper/other absorbent applicators moistened with coatings or solvents, shall be stored in non-absorbent, non-leaking containers; and
  • Keep all containers closed except when in active use.

 

27.4.3 Record-keeping

  • Maintain SDSs for any chemical paint strippers used to detail their chemical make up;
  • Document the quantity, type and VOC content of all paints and refinishing coatings applied;
  • Maintain SDSs for the coatings used in spray gun equipment, to detail the type of coating and any hazardous air pollutants content; and
  • Keep records of the specifications and replacement dates of spray booth filters and all other maintenance performed on the spray paint booth.

 

27.5 Glass Melting Equipment

Refer to Permit 010-R2 for detailed information.

 

27.6 Gasoline Above-Ground Storage Tank (Grounds Complex)

27.6.1 Operational Limits

  • Ensure the tank is equipped with a Stage I Vapor Recovery System which is operational whenever gasoline is transferred into the tank;
  • The tank shall only be filled by delivery vehicles with posted certificates showing that the vehicle passed a leak test within the past year;
  • Gasoline throughput shall be below 10,000 gallons every calendar month;
  • Clean any spills as expeditiously as possible; and
  • Cover all open gasoline containers and all fill-pipes with a gasketed seal when not in use.

 

27.6.2 Record-keeping

  • Maintain records of any leaks identified and the resulting corrective actions;
  • Keep records of each fuel delivery and document that each delivery vehicle was checked to ensure appropriate leak testing as detailed above;  The person ensuring that an appropriate certificate is posted on the delivery vehicle shall initial and date the record of this check;
  • Keep records of monthly throughput. Such records must be available within 24 hours of a request by DOEE or the EPA.

 

27.7 Miscellaneous/Insignificant Activities

Emissions from miscellaneous activities must be reasonable estimated.  Estimated emissions shall be reported in annual certification reports along with details of the methods utilized to generate the estimates.  A current inventory of miscellaneous activities must be kept updated and shall also be submitted in annual certification reports.

Miscellaneous sources include:

  • Laboratory Fume Hoods;
  • Hannan Hall, Tile Cutting Room: Water controls must be utilized to minimize particulate matter emissions. Control devices must be inspected at least annually.  Results of the inspections shall be documented;
  • Carpentry and Wood-working Facilities:  Dust collection equipment shall be visually inspected and emptied every three months or more frequently as needed.  Top filter bags shall be changed out as needed or annually, whichever is more frequent.  Inspection and maintenance activities must be documented;
  • Air Conditioning and Refrigeration Operations, including cooling towers;
  • Photo Developing Activities in Salve Regina Hall and McCort-Ward Hall;
  • Underground (2) and Above-ground (27) Storage Tanks;
  • Natural Gas Clay Kiln in Salve Regina Hall;
  • Chillers (21);
  • Small Glass Melters;
  • Diesel Fuel Dispensing Pump at the Grounds Complex; and
  • Other Fuel-burning Equipment, burning natural gas only with heat input ratings of less than 5 MMBTU per hour (small boilers, hot water heaters, kitchen equipment.)