Preparing A Permit Application. Aaron Matijow

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1 Preparing A Permit Application Aaron Matijow

2 Application Processing Timeline for Minor Sources (Non-Title V) Refer to MCAPCO Regulation Application Processing Schedule MCAQ will review the air permit application for completeness within 45 days of receipt. Permit will be issued within 90 days* of receipt of complete application. *This time includes the mandatory 15-day public comment period

3 Public Notice Required by MCAPCO Regulation Action of Application; Issuance of Permit Public Notice is provided by advertising permit approvals on the Air Quality Commission (AQC) agenda. The AQC meets on the 4 th Monday of each month. Public comment is received during the meeting and 15 days afterward. A 15 day public comment period is not required for changes in insignificant activities, ownership/name changes, permit reissuance due to new/modified regulation or modificaitons that do not result in an increase in emissions.

4 Application Processing Fees See MCAPCO

5 For a new facility or a facility expanding their footprint Zoning Consistency Determination Submit a written request for a Zoning Determination letter for your facility to the appropriate Planning / Zoning Department. Include the following information with the request letter: A Zoning Consistency Determination Form and, A copy of the completed General Information air permit application form (ie. Form S1 for gasoline dispensing facilities, Form T1 for parking facilities, or Form A1 for all other air pollution facilities). Submit the original, signed copy of the Zoning Determination to MCAQ or a copy of the request letter submitted to the Zoning Department

6 Application Forms Zoning Consistency Determination

7 Application Forms Overview Where do I get them? Which forms do I need? Helpful appendices and instructions

8 Application Forms Where do I get them? Through the mail Via From the internet

9 Application Forms

10 Application Forms Web Page View

11 Application Forms What Forms do I need? Start with the Application Forms Matrix located in the General Instructions: REQUIRED AIR PERMIT APPLICATION FORMS MATRIX NON-TITLE V APPLICATIONS A1 A2 A3 A4 A5 A6 SECTION B SECTION C SECTION D NEW FACILITY X X X X X X X E1 E2 E3 E4 ADMINISTRATIVE AMENDMENT X X MODIFICATION X X X X X X X X LIKE-FOR-LIKE REPLACEMENT CHANGE OF OWNERSHIP X X X X X X X X X

12 Application Forms by Sections Section A (facility information) Section B (process equipment) Section C (control equipment) Section D (emission estimations) Section E (Title V facilities) Section M (air dispersion modeling) Section S (stage I/II) Section T (transportation sources)

13 Application Forms Helpful Items General Instructions

14 Application Forms Helpful Items Completeness Checklist

15 Application Forms Helpful Items Regulated Pollutant List

16 Permit Application Common Errors/Omissions No application processing fee Little or no supporting documentation Emission Calculations Manufacturer s Specs for Equipment Control Efficiency Inaccurate emission summaries Rule applicability errors Zoning verification form omission

17 Application Forms Common Errors/Omissions A-1 form not signed No recycle reduction form (A-6) All required forms are not completed and submitted Complete modeling demonstration

18 Example of a Permit Application A new facility that has: 20 MMBtu/hr boiler fueled by natural gas or No. 2 fuel oil Widget Manufacturing Process Widget Maker controlled by a baghouse Parts Cleaner Two (2) Oil Storage Tanks One 12, 000 gallon No. 2 fuel oil UST One 275 gallon waste oil tank

19 Example Permit Applications (cont.) A1 A2 A3 A4 A5 A6 SECTION B SECTION C SECTION D NEW FACILITY X X X X X X X E1 E2 E3 E4 ADMINISTRATIVE AMENDMENT X X MODIFICATION X X X X X X X X LIKE-FOR-LIKE REPLACEMENT CHANGE OF OWNERSHIP X X X X X X X X X Use form matrix located in the Air Permit Application General Instructions to determined what forms are needed: A1, A4, A5, A6 Section B Section C Section D Further analysis needed to determine which from Section B, C and D

20 Example Permit Applications (cont.) Section B Emission Sources B Emission Source (Required for All Sources) B-1 Emission Source (General) B-2 Emission Source (Fuel Combustion) B-2g Emission Source (Internal Combustion Engines) B-3 Emission Source (Incinerator) B-4 Emission Source (Coating/Finishing/Printing) B-5 Emission Source (Manufacture of Chemicals/Coatings/Inks) B-6 Emission Source (Storage Silos/Bins) B-7 Emission Source (Liquid Storage Tank) Section C Control Devices C-1 Control Device (General) C-2 Control Device (Fabric Filter) C-3 Control Device (Electrostatic Precipitator) C-4 Control Device (Thermal or Catalytic Incinerator) C-5 Control Device (Cyclone/Multicyclone) C-6 Control Device (Adsorber) C-7 Control Device (Scrubber) C-8 Control Device (Condenser)

21 Example Permit Applications (cont.) Section D Emission Calculations D-1-1 Master List of Materials D-1-3 Determination of Pounds VOC per Gallon Solids (MCAPCO ) D-1-4 Total VOC Emissions Calculations (Mass Balance Method) D-1-5 Toxic and Hazardous Air Pollutant Emission Calculations (Mass Balance Method) D-2-1 Emission Calculations By Methods Other Than Mass Balance as Calculated on Forms D- 1-4 D-2-2 Summary of Emissions form the D2-1 Forms (Methods Other Than Mass Balance) D-3-1 Facility-Wide Summary of Criteria Pollutant, TAP and HAP Emissions

22 Example Permit Applications (cont.) It s important to notice that two B forms are required for each process Boiler B (required for all sources) and B-2 (fuel combustion source) Widget Manufacturing B (required for all sources) and B-1 (general) The B1, B2, etc. compiles process specific information, emissions information and documents rule applicability

23 B Form

24 Form B-1 (General) Form

25 Form B-2 (Fuel Combustion)

26 Form B-7 (Liquid Storage Tanks)

27 Form C-2 (Fabric Filter)

28 Form D-3-1 (Facility-Wide Emission Summary)

29 Example Permit Applications (cont.) Boiler emissions are calculated by using the natural gas and fuel combustion spreadsheet Parts cleaner VOC emissions are determined by the material balance method, which based upon product usage and MSDS information Widget making PM emissions are based upon process specific knowledge, manufacturer specifications and/or performance testing of a similar unit. Don t worry, emission calculation spreadsheets will be covered later!!

30 Things to Remember Read and use the instruction and appendices for assistance Use of the completeness checklist (Appendix A) will minimize the risk of your application review being delayed Use emission estimation tools from the MCAQ website and EPA as needed Be mindful of the application processing timelines and plan proactively Contact your MCAQ representative for assistance

31 Questions??

This rule shall apply to any stationary source which is a major source of regulated air pollutants or of hazardous air pollutants.

This rule shall apply to any stationary source which is a major source of regulated air pollutants or of hazardous air pollutants. RULE 2530 FEDERALLY ENFORCEABLE POTENTIAL TO EMIT (Adopted June 15, 1995; Amended April 25, 2002; Amended December 18, 2008, but not in effect until June 10, 2010) 1.0 Purpose The purpose of this rule