Title V Air Permit Policy

Policy

The following policy has been developed to ensure that University air emission sources are installed and operated to protect the environment and control air pollution.

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Scope

The Federal Clean Air Act regulates building operations and equipment at the University of Chicago that contribute to air pollution.  The Clean Air Act delegates authority to individual states under Chapter 40 of the Code of Federal Regulations (CFR) Part 70: State Operating Programs.  The United States Environmental Protection Agency (USEPA) and/or Illinois Environmental Protection Agency (IEPA) regulate certain equipment, set performance standards for regulated equipment, and enforce reporting/recordkeeping requirements.  The USEPA's program is known as the Clean Air Act Permit Program (CAAPP).  The IEPA's state air regulations are located in the Illinois Administrative Code (IAC) Title 35, Parts 201 through 291.

Mostardi Platt manages a combined Clean Air Act operating permit for the campus and Medical Center, known as a Title V CAAPP Permit.  According to the precedent set by the Green House Ga-Mandatory Reporting Rule (40 CFR 98.6), the definition of "facility" means any physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right-of-way and under common ownership...."

The consultant submits periodic reports in regards to emissions and file updates when equipment is added or removed.  IEPA construction permits are required before construction, renovating, or ordering equipment that meet the definition of "significant" or qualify as a major modification to an existing emission unit.  Construction permits are subsequently incorporated into an existing operating permit by submitting a CAAPP permit modification application.

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Applicability

The University of Chicago's Title V CAAPP Permit applies to the following equipment which meets the definition of "Significant Sources":

South Steam Plant Boilers

  • Boiler One
  • Boiler Two
  • Boiler Three
  • Boiler Four

West Campus Combing Utility Plant Boilers

  • Boiler 1
  • Boiler 2

Select Residential Property Boilers

  • 5532 South Kenwood Boiler
  • 6021 South Kimbark Boiler
  • 5801-11 South Dorchester (two units)

Emergency Generators

  • DCAM (two units)
  • Comer (three units)
  • KCBD (two units
  • Center for Care and Discovery (four units)
  • West Plant (one unit)
  • GCIS (two units)

Motor Pool Storage Tank

  • 12,000 gallon gasoline storage tank

Decommissioned units - sterilizers, incinerators, and boilers have been retired from the Title V operations permit.  If you would like information, please contact Environmental Health and Safety.

The University and Medical Center have several sources and equipment which are considered "insignificant" by IEPA under 35 IAC 201.210.  These include:

  • Boilers less than 2.5 mmBTU/hr that fire only natural gas, propane, or liquefied petroleum gas;
  • Boilers less than 1.0 mmBTU/hr that fire only oil or oil in combination with only natural gas, propane, or liquefied petroleum gas;
  • Boilers that slightly exceed 2.5mmBTU/hr that fire only natural gas, that do not exceed pollution thresholds detailed in the exemption granted in 201.211(a);
  • Storage tanks of organic liquids less than 10,000 gallons and an annual throughput of less than 100,000 gallons/year, provided the tank is not used for the storage of gasoline;
  • Printing operations less than 750 gallons/year;
  • Stationary reciprocating internal combustion engines less than 112 kW (150 horsepower) power output;
  • Stationary reciprocating internal combustion engines between 1,118 and 112 kW (1,500 and 150 horsepower) that are emergency or standby units;
  • General vehicle maintenance and servicing activities; and
  • Bench scale laboratory equipment and laboratory equipment used for chemical and physical analysis, including laboratory fume hoods.

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Authority and Responsibility

The Environmental Compliance Consultant under contract (Mostardi Platt) is responsible for:

  • Maintaining a current CAAPP permit with the IEPA, including the modification of existing permits when new CAAPP sources become operational (time and material basis);
  • Performing emissions calculations monthly, annually, or on a running total of 12 months of data, as determined by the CAAPP permit specifications for each emission unit;
  • Submitting the Annual Emissions Report for each calendar year by May 1st of the following year;
  • Submitting the Compliance Certification Report for each calendar year by May 1st of the following year;
  • Submitting the Semi-Annual Monitoring Report and/or Deviation Report, pursuant to Section 39.5 (7) (f) (i) for the applicable monitoring conditions on July 31st for the January through June period and on January 31st for the July through December period.
  • Coordinating and as necessary submitting the quarterly calibration gas audits(CGAs) and Relative Accuracy Testing (RATA), associated with the Continuous Emissions Monitoring System operating on the West Plant Boilers and the Predictive Emissions Monitoring System on the South Boilers (1 and 2).
  • Storing reports required by the CAAPP permit for at least five years;
  • Assisting Project Managers with design review for new air emission units and if necessary development of a construction permit application (time and material basis);
  • Managing the web-based compliance site (Compliance Management Process - CMP);
  • Supporting Title V and Greenhouse Gas compliance as outlined in the term contract: and
  • Accompanying outside regulatory inspectors on air compliance audits (time and material basis) and informing the Environmental Health and Safety Offices in the University and Medical Center.

Facilities Services - Capital Project Delivery and Medical Center-BSD - Facilities, Design and Construction shall be responsible for:

  • Notifying the Environmental Consultant of any equipment/operational changes that could affect facility air emissions as soon as it is known (project-planning stage);
  • Utilizing the Renovation/Construction Checklist when selecting equipment;
  • Purchasing emergency generators that are certified according to 40 CFR Parts 89, 94, or 1039 (diesel units) or 40 CFR Parts 90, 1048, or 1054 (natural gas units), as appropriate;
  • Providing Environmental Health and Safety and the Environmental Consultant with documentation of the manufacturer certified generator;
  • Absorbing the cost for the technical consultant (permit writer, compliance review) in the project budget; and
  • Submitting an IEPA construction permit application for new equipment installed during a project.

Facilities Services - Engineering and Utilities, Operations and Maintenance, Residential Managers, and the Medical Center - Physical Plant, shall be responsible for the following general requirements;

  • Completing a comprehensive commissioning process to train engineers in accordance with the requirements of the construction and/or CAAPP permit;
  • Arranging periodic testing as required by the permit conditions;
  • Conducting inspections and maintaining records as required by the CAAPP;
  • Submitting fuel usage data on a monthly-basis for significant units to the Compliance;
  • Managing the vendor responsible for the Continuous Emission Monitoring System on the West Plant boilers to ensure periodic maintenance, testing, and calibration is completed;
  • Managing the vendor responsible for the Predictive Emission Monitoring System on the South Plant boilers to ensure periodic maintenance, testing, and calibration is completed;
  • Immediately notifying Environmental Health and Safety of any operational issues that deviate from the requirements of the CAAPP permit; and
  • Complying with more detailed responsibilities based on specific sources as outlined below.

Facilities with boilers greater than 2.5 mmBTU/hr (natural gas, propane, or liquefied petroleum gas), or boilers greater than 1.0 mmBTU/hr (fuel oil in combination with natural gas, propane, or liquefied petroleum gas)

South Steam Plant (four boilers at 195.5 mmBTU/hr)

  • Comply with Section 4.4.1 of the CAAPP, detailing requirements associated with natural gas combustion; and
  • Comply with Section 4.4.2 of the CAAPP, detailing requirements associated with distillate oil combustion.

West Steam Plant (two Boilers at 300 mmBTU/hr)

  • Comply with Section 4.4.3 of the CAAPP, detailing requirements associated with natural gas combustion; and
  • Comply with Section 4.4.4 of the CAAPP, detailing requirements associated with distillate oil combustion.

Residential Boilers (four boilers on or adjacent to campus >2.5 mmBTU/hr natural gas fired)

  • Comply with Section 4.4.8 of the CAAPP, detailing requirements associated with natural gas combustion

Facilities with significant storage tanks

Motor Pool (12,000 gallon gasoline dispensing tank)

  • Comply with Section 4.4.5 of the CAAPP, detailing requirements associated with the gasoline storage tank.

Facilities with emergency generators (Engine size > 1,118 kW) 

DCAM (two units), GCIS (two units) and Comer (three units)

  • Comply with Section 4.4.6 of the CAAPP, detailing requirements associated with significant generators installed prior to September 2006;

West Plant (one unit), KCBD (two units) and Center for Care and Discovery (four units)

  • Comply with Section 4.4.7 of the CAAPP, detailing requirements associated with significant generators installed after September 2006:

In the event a permit condition is exceeded, or a unit is not functioning properly, immediately contact the environmental consultant, as outlined in the on-line compliance platform. 

In the event a regulatory inspector from USEPA or IEPA arrives to conduct an inspection, notify Environmental Health and Safety by calling (773) 702-9999.  An EHS representative from the University and the Medical Center will accompany the environmental consultant as they escort the inspector during their inspection.

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Reporting and Recordkeeping

An environmental consultant currently manages an on-line compliance management platform to simplify tasks and recordkeeping associated with emission sources.  If needed, please contact Environmental Health and Safety for a summary of quarterly, semi-annual and annual reports.

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Maintenance and Inspection

Facilities Services-Operations and Medical Center Physical Plant have established routine maintenance and inspection programs for applicable 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.

Reviewed:  January 2016

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