# Presentation: 742528

## Air Pollution Source Permitting

**For Boat Manufacturers**
**The Boat Manufacturing MACT**
** ****an EPA Workshop**
- 	**February 8, 2002**
- 	**IBEX conference **
**Ft. Lauderdale Convention Center**** **

## Nationwide Permitting...

-     A Boat Manufacturing facility that is subject to the NESHAP standard 40 CFR 63 Subpart VVVV
- is a major source of hazardous air pollutants (HAPs)
- and should already have a Title V (Part 70) Permit.
- However, at this point in time, unless it is also
- a major source of volatile organic compounds
- (VOCs) there may not be much more than
- recordkeeping requirements in the permit.

## Nationwide Permitting (cont’d)...

- Reopening of the Title V Permit for Cause when additional requirements become applicable.
- Title V permits with expiration dates of **August 22, 2004** or later, must be reopened and significantly modified by **February 22, 2003** to include the NESHAP requirements.

## Nationwide Permitting (cont’d)...

- Reopening of the Title V Permit for Cause when additional requirements become applicable (cont’d)...
- Proceedings to reopen and reissue a permit
- shall follow the same procedures as apply to initial permit issuance, and
- shall affect only those parts of the permit for which cause to reopen exists.

## Nationwide permitting (cont’d)...

- In order to escape complying with the NEHSAP regulations, an existing facility that is currently a major facility has until the compliance date of the NESHAP (August 23, 2004) to become permitted as a non-major (area) source.
- If a facility uses the material consumption option described in
-    Sec. 63.5686(b) to demonstrate that it is not a major source, the facility must start keeping records no later than
-    August 23, 2003.

## Florida Permitting for Area Source Boat Manufacturers

- Permitting Options
- Federally Enforceable State Operation Permit (FESOP)
- Air Construction / Air Operation Permits
- Non-Title V General Permit
- Exemption

## Florida Permitting for Area Source Boat Manufacturers(cont’d)

- Permitting Options (cont’d)
- Federally Enforceable State Operation Permit (FESOP)
- Good choice for a facility that is currently a major source and wants to become an area source
- Good choice for an existing area source that has never had an air construction permit and can not qualify for a General Permit.

## Florida Permitting for Area Source Boat Manufacturers(cont’d) 

- Permitting Options (cont’d)
- Air Construction / Air Operation Permits
- Good for a new area source facility that can not qualify for a General Permit.

## Florida Permitting for Area Source Boat Manufacturers(cont’d)

- Permitting Options (cont’d)
- Non-Title V General Permit (GP) for “Polyester Resin Plastic Products Fabrication”
- Good for most area sources.
- Gap in material consumption applicability criteria for General Permit and applicability of NESHAP.
- GP limit: 38 tons per year (tpy)
- NESHAP limit: less than 50 tpy

## Florida Permitting for Area Source Boat Manufacturers(cont’d)

- Permit Exemption (No Permit Required)
**Generic Facility Exemption** if the facility emits or has the potential to emit ...
- Less than 1 tpy of any hazardous air pollutant;
- Less than 2.5 tpy of total hazardous air pollutants;
- Less than 25 tpy of CO, NO**X**, and SO**2**;
- Less than 1000 pounds per year of lead; _and_
- Less than 10 tpy of any other regulated pollutant [example: Volatile Organic Compounds (VOCs)]
-    ...and there are no unit-specific applicable requirements.

## For further information

- call...

## Florida Permitting Authorities

- _District Air Programs_	_Phone          #_
- West Palm Beach 	561-681-6600
- Ft. Myers			941-332-6975
- Orlando			407-894-7555
- Tampa			813-744-6100
- Jacksonville		904-807-3300
- Pensacola			850-595-8300

## Florida Permitting Authorities(cont’d)

- _Local Air Programs_		_Phone       #_
- Broward County			954-519-1220
- Dade County			305-372-6925
- Palm Beach County		561-355-3070
- City of Jacksonville		904-630-4900
- Orange County			407-836-1447
- Hillsborough County		813-272-5530
- Sarasota County			941-378-6128