The Indiana Department of Environmental Management (IDEM) Air Permitting section, in my opinion, has made some great strides. Currently, they have been hiring excellent people at all levels of the organization. This is resulted in more reasonable and technically correct permitting determinations. We recently had some success working with an IDEM permit writer. The process being controlled was a wood milling operation. The control device was a cyclone as the first stage, and a baghouse as the second stage. The company which manufactured the control device and their local distributor had excellent documentation of control efficiency for various sized particles. They also had a well described methodology for determining the outlet grain loading for their equipment, based on the amount of material collected in the hopper of the second stage, which the IDEM liked very much.
Only particles less than 100 microns are defined as “Particulate Matter” in the rules. This means that the IDEM has no legal jurisdiction to issue air permits based on the amount of particles present which are greater than 100 microns. Sawdust from woodworking operations contains only a very small percentage of Particulate Matter (particles under 100 microns). In the past there have been administrative barriers to getting reasonable estimates for PM/PM10 PTE from woodworking operations, but DECA is beginning to have some success in eliminating those barriers. We are dedicated to doing this for our clients, because DECA is committed to representing its clients in the regulated community well, and to obtaining reasonable, technically correct permitting decisions. This is good news for those industries who are currently suffering from unreasonable determinations made by the IDEM in the past.
Many industries that have woodworking operations are frustrated by the fact that the IDEM has historically over estimated their PM/PM10 PTE. Many companies are Title V or FESOP based solely on woodworking operations. In some cases, had a proper permitting determination been made, they would have only needed an Exemption Letter or a Registration. Instead they have to pay $3000 to get a Federally Enforceable State Operating Permit (FESOP) and then $1500 per year after that; or $1500 per year and $33 per ton for a Title V Permit. Many times, in order to get a reasonable estimate for PM/PM10, companies have had to do stack testing. DECA is leading the fight to gain reasonable estimates from the IDEM for PM/PM10 from woodworking operations without having to do stack testing. We are gaining ground, thanks to some good permit writers and administrators at the IDEM.
