Seafood Processing Facilities
Seafood Processing Facilities typically operate diesel-fired generators, a diesel-fired compressor for an ammonia refrigeration plant, fishmeal dryers, process heat boilers, a fish meal plant with a wet scrubber for odor control, a vapor extraction system, an assortment of small heaters and various tanks to store fuels and oils.
18 AAC 50.055
Visible Emissions
18 AAC 50.055(a) applies to the operation of fuel-burning equipment and industrial processes and prohibits Permittees from causing or allowing visible emissions in excess of the applicable standard in 18 AAC 50.055.
The Permittee must establish by visual observations of emissions unit exhaust, which may be supplemented by other means (e.g., a defined stationary source operation and maintenance program), that the stationary source is in continuous compliance with the state emission standards for visible emissions.
Particulate Matter
18 AAC 50.055(b) applies to the operation of all fuel-burning equipment and industrial processes and prohibits emissions in excess of the applicable State particulate matter standard.
The Permittee must establish by actual visual observations which can be supplemented by other means, such as a defined Operation and Maintenance Program that the emissions unit is in continuous compliance with the State's emission standards for particulate matter.
Sulfur Compound Emissions
18 AAC 50.055(c) applies to the operation of fuel-burning equipment and industrial processes and prohibits emissions in excess of the applicable State sulfur emissions standard.
The Permittee may not cause or allow the affected equipment to violate the applicable sulfur compound standard. Sulfur dioxide comes from the sulfur in the fuel (e.g., coal, natural gas, fuel oils).
Seafood Processing Facilities typically use diesel fuel, fish oil, and/or used oil blends to run the emissions units at the stationary source. Fuel sulfur testing will verify compliance with the SO2 emission standard. Liquid fuel containing no more than 0.75 percent sulfur by weight will always comply with the emission standard (e.g., No. 2 diesel fuel is 0.5 percent by weight or less by grade specification).
18 AAC 50.508(5)
This section of the Administrative Code contains provisions for owners or operators of seafood processing facilities to take Owner Requested Limits (ORLs) to avoid classification as a Title V, Hazardous Air Pollutants (HAP), or Prevention of Significant Deterioration (PSD) major source and the correlating State and Federal permitting requirements.
40 CFR. 60
The New Source Performance Standards (NSPS) are regulatory standards issued by the U.S. Environmental Protection Agency (EPA) under Section 111 of the Clean Air Act. These standards are designed to control air pollution from new, modified, and reconstructed sources in various industrial sectors, including seafood processing facilities. The NSPS subparts for seafood processing facilities outline the specific emission limits and operational requirements needed to minimize environmental impact.
Subpart A - General Provisions and Definitions
Subpart A sets forth several key definitions and general provisions relevant to seafood processing operations. These include:
Affected Facility: Any apparatus, equipment, or installation at a seafood processing plant that emits pollutants.
Emission Standards: Limits established by the EPA for specific pollutants emitted by seafood processing facilities.
Performance Testing: Tests that facilities must conduct to demonstrate compliance with the emission standards.
Subpart A - Compliance Obligations
Seafood processing facilities must comply with various obligations under NSPS Subpart A, including:
Notification: Facilities must notify the EPA before constructing or modifying any equipment that may affect emissions.
Recordkeeping: Comprehensive records of emissions, performance tests, and maintenance activities must be maintained.
Reporting: Regular reports detailing emissions levels, compliance status, and any deviations from standards must be submitted to the EPA.
Subpart A - Performance Testing Requirements
Performance testing is a critical component of NSPS Subpart A. Seafood processing facilities are required to:
Conduct Initial Tests: Performance tests must be conducted when new equipment is installed or existing equipment is modified.
Periodic Testing: Regular testing must be carried out to ensure ongoing compliance with emission standards.
Testing Methods: Specific EPA-approved methods must be used for performance testing to ensure accuracy and reliability.
Subpart A - Emission Standards
Seafood processing facilities are subject to stringent emission standards for various pollutants, including:
Particulate Matter: Limits on the amount of particulate matter that can be emitted during processing activities.
Volatile Organic Compounds (VOCs): Restrictions on VOC emissions, which can contribute to air pollution and health issues.
Hazardous Air Pollutants (HAPs): Standards for HAPs, which include substances that are harmful to human health and the environment.
Subpart A - Recordkeeping and Reporting
Compliance with NSPS Subpart A requires diligent recordkeeping and reporting. Seafood processing facilities must:
Maintain Records: Detailed records of all emissions, testing results, and maintenance activities must be kept for a specified period.
Submit Reports: Regular reports must be submitted to the EPA, including information on emissions levels, compliance status, and any corrective actions taken.
Subpart A - Inspection and Enforcement
The EPA conducts inspections and enforces compliance with NSPS Subpart A. Facilities may face:
Routine Inspections: Scheduled inspections to verify compliance with emission standards and recordkeeping requirements.
Penalties: Financial penalties for non-compliance, including fines and legal actions.
Corrective Actions: Mandated actions to address any deviations from standards and ensure future compliance.
Subpart IIII - Compression Ignition Internal Combustion Engines (CI ICE)
For seafood processing facilities, CI ICE, must meet stringent emission standards. These standards are set to limit the emission of pollutants such as nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), and hydrocarbons (HC). The NSPS requirements categorize engines based on their manufacture date and power output:
Engines manufactured after April 1, 2006, must meet specific Tier standards, which progressively tighten the allowable emission levels. For instance, engines above 30 liters per cylinder must adhere to Tier 2 standards until 2011, after which Tier 4 standards apply.
For smaller engines, such as those below 30 liters per cylinder, Tier 4 standards commenced in 2014, mandating advanced emission control technologies.
Subpart IIII - Spark-Ignition Engines
Spark-ignition engines, commonly running on gasoline or natural gas, are subject to NSPS requirements that target reductions in NOx, VOCs (volatile organic compounds), and CO emissions. These engines, utilized in ancillary equipment within seafood processing facilities, must comply with:
Engines above 25 horsepower must meet the emissions standards based on their manufacture date and type of fuel used.
Regular maintenance schedules and operational practices must be followed to ensure engines perform within the stipulated emission limits.
40 CFR 63
The National Emission Standards for Hazardous Air Pollutants (NESHAP) are regulations established by the EPA to control emissions of HAPs from various industrial sources, including seafood processing plants. These regulations are designed to protect human health and the environment by setting emission limits and operational standards for equipment that emits HAPs.
NESHAP Subpart A: General Provisions
Subpart A of the NESHAP regulations contains the general provisions applicable to all sources subject to NESHAP standards. These provisions establish the framework for compliance and include requirements pertaining to:
Notifications and Reports: Facilities must submit notifications of compliance status, performance testing, and other required reports to the EPA.
Recordkeeping: Facilities are required to maintain detailed records of emissions, control measures, and compliance activities.
Compliance Testing: Performance tests must be conducted to demonstrate compliance with emission limits and control efficiency.
Monitoring and Maintenance: Continuous monitoring systems must be installed and maintained to ensure ongoing compliance with emission standards.
Startup, Shutdown, and Malfunction Plan: A plan must be in place to address emissions during periods of startup, shutdown, and malfunction.
NESHAP Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE)
Subpart ZZZZ imposes specific requirements on facilities operating stationary RICE units, including but not limited to:
Emission Limits: Establishes limits for hazardous air pollutants emitted from RICE units, such as formaldehyde, acetaldehyde, and other toxic compounds.
Control Technologies: Requires the installation of control technologies such as catalytic converters and diesel particulate filters to reduce emissions.
Operating Standards: Defines operating standards and maintenance practices to ensure optimal performance of emission control systems.
Monitoring and Compliance: Outlines requirements for monitoring emissions and conducting regular compliance checks.
Reporting and Recordkeeping: Mandates the submission of periodic reports and maintenance of records related to emissions and control measures.
NESHAP Subpart JJJJJJ for Industrial, Commercial, and Institutional Boilers Area Sources.
Subpart JJJJJJ is a federal rule that took effect on May 20, 2011. This subpart applies to owners and operators of industrial, commercial, or institutional boiler as defined in 40 C.F.R. 63.11237 that is located at, or is part of, an area source of HAP emissions.
Subpart JJJJJJ covers boilers used at seafood processing facilities that are classified as area sources of HAPs. An area source is any source of HAPs that does not meet the threshold for a major source, which is defined as emitting 10 tons per year or more of any single HAP or 25 tons per year or more of any combination of HAPs.
Emission Standards
The regulation sets specific emission limits for particulate matter (PM), carbon monoxide (CO), and other air pollutants emitted by boilers. These standards are designed to reduce the impact of hazardous emissions on the environment and human health.
Particulate Matter (PM)
Seafood processing facilities must ensure that their boilers meet the PM emission limits specified in the regulation. This typically involves the use of pollution control technologies such as fabric filters or electrostatic precipitators.
Carbon Monoxide (CO)
The standards also set limits on CO emissions from boilers. Proper combustion practices and regular maintenance are essential to keep CO emissions within the allowable limits.
Compliance Requirements
Facilities must conduct regular performance tests to demonstrate compliance with the emission standards. The regulation outlines specific testing procedures and frequency requirements. Additionally, facilities must maintain records and submit reports to the Environmental Protection Agency (EPA) to document compliance.
Work Practice Standards
NESHAP Subpart JJJJJJ also includes work practice standards that seafood processing facilities must follow. These standards involve implementing best management practices for boiler operation and maintenance to minimize emissions. Examples include periodic tune-ups and energy assessments.
Notifications and Reporting
Facilities are required to notify the EPA of their compliance status, including initial notifications of applicability, notifications of compliance status, and annual compliance certifications. Detailed records of all notifications, performance tests, and maintenance activities must be kept on-site for a specified period.
40 CFR 64
Compliance Assurance Monitoring (CAM) is a requirement under 40 C.F.R 64 designed to ensure that facilities comply with emission standards set by the Environmental Protection Agency (EPA). Seafood processing facilities, like other industrial operations, must adhere to these requirements to monitor and maintain compliance with air quality regulations.
Applicability of CAM
Under 40 CFR 64, CAM applies to emissions units that:
Are subject to emission limitations or standards for pollutants.
Have pre-control emissions equal to or greater than major source thresholds.
The regulation requires that these emissions units have a compliance assurance monitoring plan if they use a control device to meet these emission limitations.
Monitoring Plan
If applicable, Seafood processing facilities must develop a comprehensive monitoring plan that outlines the methods and procedures for measuring emissions, including the type and frequency of monitoring. The plan should describe the equipment and techniques used to ensure accurate and reliable data collection.
Performance Criteria
Facilities must establish performance criteria for their monitoring systems, ensuring that the methods used are capable of detecting deviations from the allowable emission limits. These criteria should include accuracy, precision, and reliability standards.
Recordkeeping and Reporting
Facilities are required to maintain detailed records of monitoring data, including the dates, times, and results of each measurement. These records must be kept for a specified period and be available for inspection by regulatory authorities. Additionally, facilities must submit regular reports to the EPA, summarizing their compliance status and any deviations from the emission limits.
Corrective Actions
If monitoring data indicates that a facility is not in compliance with the emission standards, corrective actions must be taken promptly to address the issue. This may include adjustments to the monitoring systems, changes in operational procedures, or other measures to reduce emissions.
Quality Assurance and Quality Control
Facilities must implement quality assurance and quality control (QA/QC) procedures to ensure the accuracy and reliability of their monitoring data. This includes routine calibration and maintenance of monitoring equipment, as well as periodic audits of the monitoring systems.
Title I Permit
Requirements
Permittees in Alaska are required to comply with all stationary source-specific requirements that were carried forward from previous SIP-approved Permits to Operate issued on or before January 17, 1997 and operating permits issued between January 18, 1997 and September 30, 2004, and with all stationary source-specific requirements in EPA Prevention of Significant Deterioration (PSD) permits, State Implementation Program (SIP)-approved construction permits, SIP-approved minor permits, and owner requested limits established under 18 AAC 50.225.
These requirements include Best Available Control Technology (BACT) limits, limits to ensure compliance with the attainment or maintenance of ambient air quality standards or maximum allowable ambient concentrations, and owner requested limits.
Background
Title I of the Clean Air Act encompasses preconstruction permits, which include New Source Review (NSR) and Prevention of Significant Deterioration (PSD) permits. These permits are designed to control emissions from new or modified sources before they commence operation. Title I requirements are aimed at preventing air quality degradation and ensuring that any new developments adhere to stringent environmental standards.
Ensuring Comprehensive Regulatory Oversight
Including Title I Permit requirements in Title V operating permits ensures that all regulatory obligations are documented and accessible in one comprehensive permit. This integration allows for a more streamlined approach to compliance monitoring and enforcement. By having all requirements in one place, regulatory agencies can more efficiently oversee and verify compliance, reducing the likelihood of violations and ensuring that facilities adhere to preconstruction obligations.
Preventing Air Quality Degradation
Title I permits play a crucial role in preventing air quality degradation by setting emission limits and control technologies for new or modified sources. The inclusion of these requirements in Title V permits helps maintain the integrity of air quality standards by ensuring that facilities continue to comply with pre-established limits and controls. This continuity is essential for sustaining long-term environmental protection and preventing any backsliding in air quality improvements.
Facilitating Transparency and Public Participation
Title V permits, which are subject to public review and comment, provide an opportunity for stakeholders to participate in the regulatory process. By including Title I Permit requirements in these permits, regulatory agencies enhance transparency and ensure that the public is fully informed about all aspects of a facility's operations and emissions controls. This openness fosters greater community involvement and support for environmental protection initiatives.
The inclusion of Title I Permit requirements in Title V operating permits is a critical practice that ensures comprehensive regulatory oversight, prevents air quality degradation, and facilitates transparency and public participation. By integrating these requirements, regulatory agencies can more effectively enforce compliance, safeguard environmental standards, and promote a healthier and more sustainable future.
