Air Permitting of a Unique Recycling Process
Unless specifically exempted by regulation or below a de minimis limit, industrial processes that generate air emissions are required to obtain a permit to install and operation (PTIO). In general, the permit application package consists of various forms, process flow diagram and description, and emission factor and rate calculations. The calculation of emission rates is a critical component of the permit application as these rates will, in part, determine the type of restrictions to be included in the permit issued by the regulatory agency. It will then be up to the facility to operate within these restrictions.
Cox-Colvin assisted a permitted treatment, storage, and disposal facility (TSDF) in obtaining a PTIO for a future battery recycling process line that was considered the first of its kind. Given the extremely unique nature of this recycling process, air emission factors or stack testing data were not available from any resources, which presented a challenge in determining the anticipated air emissions. Prior to preparing the permit application, Cox-Colvin negotiated an approach for determining anticipated air emissions with the regulatory agency. The approach consisted of identifying potential air pollutants and potential air emission equipment/processes associated with the recycling line. Following this identification, Cox-Colvin worked closely with the facility’s research and development department to design and complete bench-scale testing to simulate full-scale processes and measure air emissions.
Using the data obtained from bench-scale testing, Cox-Colvin completed the permit application. Although several pieces of equipment and processes within the recycling line were considered emission sources, Cox-Colvin was able to permit the entire recycling line as a single emissions unit. This provided the facility with a great degree of flexibility to continuously refine the design of the recycling line without the need to obtain permit modifications.