Picture this: You need to apply for a permit from the South Coast Air Quality Management District (SCAQMD). So you start browsing on their website, and you find a link that says “Getting Permits,” then click on “How Do I Obtain Permit?”
And this is what you see:
You follow the steps, submitting your forms and fees — and guess what happens. Your permit gets denied for having insufficient information.
The AQMD failed to tell you that forms and fees are only about two-thirds of the entire permit application. You’re missing the most important element of the entire application.
AQMD Permit Engineering Evaluation
A full permit application contains three core elements:
- Engineering evaluation
Each of these is critical to the entire application. Missing one element can lead to a major delay in the processing of your permit application — and, thus, your entire project.
The template for a standard permit application is on the AQMD website, but it’s hard to find, so here’s the quick link: click here.
In this article, I’ve boiled down the entire template into ten components.
1. Facility Identity
The first component of the application is what I call the facility identity, which consists of:
- Company name
- Name of owner
- Physical address of the equipment
- Mailing address
When you provide this information, be sure that the equipment will operate within the jurisdiction of the AQMD. Although the mailing address for the permit does not need to be within the AQMD, the actual location of the equipment must.
Also, keep in mind that this information must match what you enter on Form 400-A.
2. Equipment Description
The equipment description will appear on the AQMD permit, so it needs to be accurate, especially because the AQMD uses a specific format for the description. Here are the required components for the description, along with some example data:
- Name of device (internal combustion engine)
- Reference number
- Material processed (natural gas)
- Manufacturer’s name, type, and model number (Caterpillar, model G379 SI-NA)
- Style (four cycle)
- Serial number
- Energy input and heating method
- Plant or equipment accounting number
For more information on the AQMD-specific format, see Section 4.2 in the CPP manual.
3. Facility Overview and History
For this section, you need to create a facility overview, as well as a little background on the history of the facility, in order to give the permitting engineer enough information to determine which rules apply to the equipment. Some of the information you may want to include is:
- RECLAIM and/or Title V applicability
- Location of any nearby schools or daycare centers
- Location of the facility
- Type of permit application being submitted
- Expected equipment start date
- Type of equipment being permitted
4. Process Description
Here’s where you tell the AQMD a little about the process the equipment will serve. You can include information like:
- What the process makes
- Whether it’s a new or existing process
- The emission points of the process
- The types of pollutants emitted from the process
- Any control devices that will be used
5. Emissions Data
As part of your application, you need to calculate emissions from the equipment being permitted. While the actual emissions calculations are part of the next section, the emissions data section presents the actual data sources used to estimate emissions.
So you have to ask yourself: How will you estimate emissions? Here are some options for answering that question:
- Source test
- BACT (best available control technology) limit
- The EPA’s AP-42 database
- Manufacturer specification
- Emissions guarantee
- Specific rule limit
Whatever the case, you need to clearly identify the data source that will be used to estimate emissions. You should also attach any documentation as an appendix to your permit application.
6. Emissions Calculations
There are 11 emission rates that need to be calculated within your permit application: eight for the criteria pollutants and three for any air toxics:
- AHU: Average Hourly Uncontrolled
- AHC: Average Hourly Controlled
- MHC: Maximum Hourly Controlled
- MHU: Maximum Hourly Uncontrolled
- MDC: Maximum Daily Controlled
- MDU: Maximum Daily Uncontrolled
- 30DA: 30-Day Average
- AA: Annual Average
- MHU: Maximum Hourly Uncontrolled
- MHC: Maximum Hourly Controlled
- MAC: Maximum Annual Controlled
All 11 of these emission rates are used to determine compliance with Regulation XIII (New Source Review), and Regulation XIV (Toxics). You should also show an example calculation for each type of emission rate.
7. Health-Risk Assessment
The toxic pollutant emissions calculated in bullet #6 are used to determine compliance with Regulation XIV. One of the ways Regulation XIV compliance is assessed is through the completion of a health risk assessment (HRA) according to Rule 1401, for which the AQMD has put together a comprehensive guidance document.
8. Rule Evaluation
The rule evaluation is a major component of the entire engineering evaluation because it requires you to identify all of the rules that apply to the piece of equipment being permitted. To complete the rule evaluation, you need to go through each regulation and determine not only which rules apply but also how the equipment will demonstrate compliance with each rule.
When completing the rule evaluation, keep in mind that the goal of the permit application is to enable the AQMD to determine whether or not the equipment can operate in compliance with all of its rules and regulations, so you must provide all information necessary to demonstrate how compliance will be achieved.
9. Summary Statement/Recommendation
In this component, you need to provide a summary statement that makes the case to the AQMD as to why the permit should be issued for this piece of equipment. Build as strong a case as possible to prove that the equipment will comply with all AQMD rules and regulations, then back it up with examples of how the rule requirements will be met (see: bullet #8).
10. Draft Permit Language
The AQMD imposes conditions on every permit. As the permit holder, you must comply with the permit conditions. Here are a few points to keep in mind when drafting permit conditions:
- Consider the points made in the rule evaluation that you did in bullet #8. Did you state specific actions would be done in order to demonstrate compliance with a rule? If so, draft a permit condition to ensure compliance, including set points, operating ranges, monitoring frequencies, etc.
- Be sure that the conditions you draft are possible to comply with. The conditions must be practical because, as the permit holder, it is your duty and responsibility to follow all of the conditions.
If you are going to keep records, be sure that maintaining and generating those records are not a problem. If you are going to monitor a parameter, be sure that the monitoring equipment is already installed or can be installed without a problem.
Whatever the case, you want to think ahead about how compliance with these draft conditions will be demonstrated.
In the end, preparing a good engineering evaluation comes down to understanding the job of both the permit engineer and the applicant (that’s you). It’s the permit engineer’s job to process all information to decide if your equipment can operate in compliance with all of the AQMD’s rules and conditions.
It’s your job to convince the engineer that your equipment will comply.
If you’re still having trouble with your engineering evaluation, contact us and we’ll guide you through the process.
Updated: July 10, 2015