ems lecture 9 permits 2015

8/16/2019 EMS Lecture 9 Permits 2015

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Environmental Management Systems

BITS Pilani, Pilani Campus

• Permits

• PTC

• NSR

• BACT

• LAER

Contents


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Permit to Construct

•

An air quality permit to construct (PTC) is required priorto construction or modiication o – Buildin!s

– Structures

– "nstallations t#at emit, or may emit, pollutants into t#e air $#ic#

$ould result in moderate increase in air emissions

• PTCs are required or certain porta%le equipment as

$ell, suc# as –

!enerators – crus#in! equipment

– asp#alt plants

– concrete %atc# plants


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PTC applicants are required to submit the following information:

A complete description of the

• proposed process from raw material feed to final product

output, including operating design capacity, hours of

operation, and feed material characteristics.

Manufacturers' guarantees for stated control efficiencies of all

control equipment.

mission estimates for all regulated air pollutants withsupporting calculations, assumptions, or manufacturer

guarantees for emission control de!ices.

Permit to Construct


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PTC (Specific Application Requirements)

A PTC application requires the applicant to supply detailed

information on the proposed new source, modification of ane"isting source, or process change.

• Process Description

• Site Plans• Equipment List• Air Emission Inventory


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t!er Potential PTC Application Requirements

#ome state rules require that a PTC be accompanied by asimplified Environmental Impact Statement (EIS) or site

review application

#ome states also require the applicant to submit an air dispersionmodel analysis to demonstrate that air quality will not be

significantly impacted by the proposed wor$

%ne state requires PTC applicants to complete Best Available

Control Technology (BACT) review for criteria pollutants

for any project that increases air emission more than over

ton!year


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Ne$ Source Re&ie$

•

NSR and Pre&ention o Si!niicant 'eterioration (PS')$as esta%lis#ed as part o t#e ** Clean Air Act

Amendments

•

T#e construction or modiication o a ma+or stationarysource t#at results in si!niicant- increase in air

emissions is su%+ect to t#e NSR pro!ram

• T!e permit specifies

– $#at construction is allo$ed

– $#at emission limits must %e met

– oten #o$ t#e emissions source must %e operated


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Attainment an" #on Attainment Areas

Attainment areas

Any area that meets the national primary or secondary

ambient air quality standard for the pollutant is called

as attainment areas

"on attainment areas

Any area that does not meet the national primary or

secondary ambient air quality standard for the pollutant


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&f the air quality of an area for a particular pollutant isattainment# the proposed facility will be subect to the

requirements of the Pre!ention of #ignificant

(eterioration )P#(* program

+nder the rules of P#( permitting, you must procee$

with air mo$eling to determine whether you will

increase the concentration of the pollutant beyond

acceptable le!els

ach pollutant in a gi!en attainment area has a

ma"imum allowable ambient concentration


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% points to be consi$ere$

irst, you will ha!e to determine what control

technology or process design specifications are

required to meet the ambient air quality standards

#econdly, a facility subect to P#( program must

install -est A!ailable Control Technology )-ACT*


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or non attainment areas# the permit application will

be subect to a much more stringent re!iew under the"ew Source &eview ("S&) rules

Instea$ of BACT# the facility will be re'uire$ to

meet the lowest achievable emission rates (*AE&)

ill also be necessary to establish emission offsets for

the proposed proect which demonstrate a netimpro!ement in air quality would result from the

construction of the proect


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Permittin$ %a&or Sources ' PSD an" #SR

• -oth P#( and /#0 permitting in!ol!e a significant• amount of documentation• air dispersion modeling• and regulatory agency re!iew

hen permitting a maor source, the facility permitting

team should include in its schedule a significant

amount of time for en!ironmental agency re!iew andresponse to comment


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#e or %o"ifie" Source Determinations

To determine whether a proposed proect is subect to

P#( or /#0 re!iew requirements,

• the initial step is to establish an emission in!entory

%nce an emission in!entory is complete, data on the

specific annual emission of each pollutant will be

a!ailable


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Pre Application %onitorin$

These requirements are triggered by lac$ of specificambient air quality data for the pollutant you are

proposing to increase

Although monitoring may not be technically difficult,amount of time required to collect the data is often a

surprise to the proect team

A full year of air quality monitoring may be necessaryto satisfy the en!ironmental agency


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Determinin$ BACT

PA requires that the -ACT analysis be done using thetop+$own approach

This means that the most effecti!e method of

controlling a pollutant is analy1ed first2 then lesseffecti!e controls are e!aluated in descending order


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Determinin$ BACT

or each potential technology, you will need the

following information:• (escription of the technology or process• Capital cost of installation• 3uantity of pollutant remo!ed )annually*, and

• Cost4effecti!eness calculation

%nce the cost effecti!e calculation is made, !arious

pollution control technologies are compared


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PSD an" #SR Application Process

Application for a P#( or /#0 permit is a !oluminous

document, which includes the following items:

• proect application form and fee• proect description• 5ist of #ources• mission &n!entory• Applicability analysis• Air modeling information• 6isibility analysis )if required*

• -ACT75A0 (eterminations• #upport appendi"es• (rawing and site map


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A $ey to managing the permit re!iew process is to meet

frequently with the permitting agency and to beginthese meetings well before the permit application is

submitted

&tems that should be preliminary re!iewed with the

agency include the following:

• An o!er!iew of the proect

• Potential public concerns• Air emission in!entory• P#( pollutant analysis• Air modeling requirements

• Pre!ious -ACT75A0 determinations

S


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After the permitting agency has re!iewed and acceptedthe permit application as complete, you must still

respond to questions posed by the agency and pro!ide

the agency with any additional information it requests

E i t l M t S t


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Implementin$ Permit Requirements

&t is necessary to obtain the permit before beginning the

construction and to comply with the terms of the permit once itis issued

PA can issue significant penalties to companies that commence

construction of a new source or modification of an e"isting

source prior to recei!ing final P#( or /#0 permit

Permit compliance will li$ely require new operator training

manuals, new monitoring or testing equipments, and re!isions to

the reporting and data systems

These requirements should be identified and implemented well

in ad!ance of the actual start of a new facility or modification

ems lecture 9 permits 2015

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