Permitting Process

Although the permitting process varies from state to state, typical steps include:

1. Permit to Construct Application — submitted by the applicant prior to installation, construction, or operation of new equipment.

2. Review — conducted by the state regulatory agency to check for completeness.

3. Processing — done by the state regulatory agency to determine that the proposed equipment installation will be built and operated in accordance with all necessary regulations. Permit conditions are set and public review may occur. If there is no compliance problem, the agency issues a permit to construct.

4. Permit to Construct — authorizes the applicant to install the equipment. It also can serve as a temporary permit to operate until a permit to operate is issued.

2. Inspection — is conducted after the equipment has been installed and before operation. The purpose of the inspection is to determine if the equipment was built and installed as indicated in the application and permit to construct. In addition, the inspection confirms that the equipment operates in compliance with state and federal regulations. This may involve emissions testing and other types of actual measurements.

Typical Pre-construction Permitting Requirements

Most states have standardized permit applications that are used by the applicant to convey the needed information to the state. Required information includes a detailed description of the new source or modification, as well as additional information such as emissions estimates and proposed control strategies.

Typically, states require minor source permit applicants to estimate the emissions resulting from the new construction or modification. States often require that the applicant detail the expected physical and chemical characteristics of the air contaminant stream, both before and after the installation of any emissions control equipment. This information may include emissions rate, concentration, exhaust gas volume and temperature, and exhaust stack locations and characteristics. Maximum annual and hourly emissions representations are required, which are subsequently used to set permit limits.

The applicant is required to select and propose emissions control equipment for all new or modified sources. Details of the equipment, including description, design parameters, and expected performance, are normally required. If wastes will be generated from using the pollution control equipment, the applicant may need to describe the intended disposal method to the state. Data on performance of alternative controls may also be required. The applicant may also need to provide cost data for the controls to show the state that more stringent controls are not cost-effective for the proposed application.

Some states require that an applicant perform air quality impact modeling to demonstrate the effect of the source's air emissions on the local air quality. States use this modeling to verify that the potential emissions are below prescribed air quality standards.

Representative Information Requirements

Representative information requirements for a state pre-construction permit for fuel-burning equipment are indicated in Figure 16-1. While the precise requirements will vary from state to state, the exhibit shows eight major information categories.

A project overview narrative is required to summarize the scope of the project as it relates to emissions generation, with background information on the location, the need for the project, and the pollution control strategies to be employed. Generally, the submission will be based primarily on a completed application form, which is obtained from the state environmental protection office. Supporting data for numerical entries in this form should be provided wherever necessary.

As Figure 16-1 indicates, site, engineering, and process flow drawings are typically required with a pre-construction permit application, as is engineering specification for fuel-burning equipment. Certified vendor pollution generation performance data also may be required. While available from qualified vendors, meaningful certifications may be difficult to obtain. An alternative approach is to require performance data, and also state performance requirements in the product specification. Penalty clauses for not meeting the specified requirements can serve two important purposes. They offer assurance to the state reviewer and the owner that the performance levels will be met, and place performance responsibility on the vendor/manufacturer.

Examples of supporting data formats to consider are presented in Figures 16-2 through 16-5. Figure 16-2 provides supporting data for projected fuel use estimates. Note that the data addresses several future years and indicates changes in fuel source use. Figure 16-3 indicates typical emissions factors that are used to calculate total emissions generation rates. Standard reference sources or boiler test data are typically used. If available, actual test data is preferred. Figure 16-4 indicates future trends for pollutant generation from the facility. Note that in this case, despite a proposed increase in steam generation

State Pre-Construction Permit Representative Application Information Requirements

Project Overview Narrative:

- Location

- Need for project

- New or expansion/modernization

- Types of equipment involved

- General description of pollution control strategy:

Fuel switching, combustion control, aftertreatment, etc.

Application (State Environmental Office Form):

- Owner, location, contac

- Type of equipment - technical performance characteristics

- Annual fuel use, by type

- Stack height

- Emissions control devices

Net Emissions Analysis (Typical Supporting Technical Data):

- Recent and projected fuel use, by fuel type (See Table)

- Projected Emissions generation levels (See Tables, Graph)

Engineering Drawings and Specifications: - Drawings (locate emissions points)

Schematic and Process Flow Diagrams: - Energy and mass (emissions outputs)

Certifled Vendor Performance Data:

- Unit emissions factors

- Full load, part load

Site Drawings:

- Major topographical conditions

- Identify adjacent uses, e.g. residential, industrial, etc.

Air Dispersion Modelling Results: - Ground level pollutant concentration averages: 1 hour 3 hour 8 hour Annual

Fig. 16-1 Representative Pre-construction Permit Filing Requirements Summary.

capacity and projected increasing annual loads, pollution generation rates are projected to decrease significantly. This decrease is shown graphically in Figure 16-5 for SOx and NOX pollutants.

Frequently, air dispersion modeling is required in conjunction with permit applications. Air dispersion models are designed to simulate the dynamic dispersion of the pollutants into the atmosphere for varying climactic conditions in the proximity of the site being evaluated. Of particular importance are indicators of the pollution concentration at user-selected ground points. In addition to overall peak pollution levels, average concentrations during periods of one hour, three hours, eight hours, twenty-four hours, and annually are determined. Figure 16-6 provides an example of a summary of air dispersion modeling results.

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