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.”
You click on “How Do I Obtain Permit?”
And this is what you see.
You follow the steps.
You submit your forms and fees … and guess what happens.
Your permit get’s denied for having insufficient information.
You followed the steps, but for some reason you did not submit all of the information.
Here’s What Happened
The SCAQMD 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.
SCAQMD Permit Engineering Evaluation
A full permit application contains three core elements.
- Fees; and
- Engineering evaluation.
Each of these is critical the entire application.
Missing one element, can lead to a major delay in the processing of your permit application, and your entire project.
So it’s important to get your application right the first time.
The template for a standard permit application is on the SCAQMD website (but it is hard to find).
You can follow along, by printing it out (click here).
In this article, I’ve boiled down the entire template into ten components.
Let’s go down the list, so that you can successfully prepare a full permit application for the SCAQMD.
Component 1. Facility Identity
The first component of the application is what I call the facility identity.
- Company Name;
- Name of Owner;
- Physical address of the equipment; and
- Mailing address.
Now, when providing this information, be sure that the equipment will operate within the jurisdiction of the SCAQMD.
The mailing address, for the permit, does not need to be within the SCAQMD, but the actual location of the equipment must.
Also, keep in mind that this information must match what you enter on the Form 400A.
Component 2. Equipment Description
The second component is the equipment description.
This is the equipment description that will appear on the SCAQMD permit.
So you want it to be correct.
The SCAQMD uses a specific format when describing a piece of equipment.
NAME OF DEVICE, REFERENCE NUMBER, MATERIAL PROCESSED, MANUFACTURER’S NAME, TYPE, MODEL NUMBER, STYLE, SIZE, DIMENSIONS, SERIAL NUMBER, ENERGY INPUT AND HEATING METHOD, ACCESSORIES, PLANT OR EQUIPMENT ACCOUNTING NUMBER.
See an actual example of this format below.
INTERNAL COMBUSTION ENGINE, CATERPILLAR, MODULE G379 SI-NA, NATURAL GAS, FOUR CYCLE, RICH BURN, NATURALLY ASPIRATED, RATED AT 330 BHP, WITH A NON SELECTIVE CATALYTIC CONVERTER, MIRATECH, MODEL RHSS-3016-X3-08-EC2, AND AN AIR/FUEL RATIO CONTROLLER, ALTRONIC, MODEL EPC-100E, DRIVING A WATER PUMP
For more information on the SCAQMD-specific format, check out Section 4.2 in the CPP manual.
Component 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.
Some of the information you may want to include are:
- RECLAIM and/or Title V applicability;
- Location of any nearby schools or day care centers;
- Location of the facility;
- Type of permit application being submitted.
- Expected equipment start date.
- Type of equipment being permitted.
In this section, you are trying to give the permitting engineer enough information so that they can understand which rules are applicable to the equipment.
Component 4. Process Description
Now in component two, you gave the SCAQMD a description of the actual piece of equipment being permitted.
In this section, you need to tell the SCAQMD a little about the process that this equipment will serve.
You can include items like:
- What does the process make?
- It this process a new or existing process?
- What are the emission points of the process?
- What are the types of pollutants emitted from this process?
- Any control devices that will be used.
Component 5. Emissions Data
As part of your application, you will need to calculate emissions from the equipment that is being permitted.
While, the actual emissions calculations are part of component 6; this section presents the actual data sources that will be used to estimate emissions.
So you will need to ask yourself…how will you estimate emissions?
- Source test?
- A BACT limit?
- AP42 database?
- Manufacturer specification?
- Emissions guarantee?
- Specific rule limit?
Whatever the case, you need to identify clearly, the data source that will be used to estimate emissions.
Also, you will also want to attach any documentation as an appendix to your permit application.
Component 6. Emissions Calculations
There are eight 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).
In this section, you will also want to show an example calculation for each type of emission rate.
Component 7. Health Risk Assessment
The toxic pollutant emissions calculated in component 6, are used to determine compliance with Regulation XIV.
One of the ways that compliance with Regulation XIV is assessed is through the completion of a health risk assessment according to Rule 1401.
The AQMD has put together a comprehensive guidance document on how to complete an HRA according to Rule 1401.
Component 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 the each regulation, and determine, not only which rules apply, but how the equipment will demonstrate compliance with each rule.
When completing the rule evaluation, you need to keep in mind that the main focus of the permit application, is so that the SCAQMD can make a decision as to whether or not, the equipment can operate in compliance with all of the rules and regulations of the SCAQMD.
You will need to provide all of the information necessary that to demonstrate how compliance with the rules and regulations will be achieved.
Component 9. Summary Statement/Recommendation
In this component, you will 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.
You need to make a strong case that the equipment will comply with all the rules and regulations of district, and you need to back it up with examples of how the rule requirements will be met (think Component 8).
Component 10. Draft Permit Language
The SCAQMD will impose conditions on every permit, and as the permit holder, you will need to comply with the conditions of the permit in order to comply with the SCAQMD.
Here are a few things to keep in mind when drafting permit conditions.
One. Consider the points made in the rule evaluation that you did in component eight.
Did you state specific actions would be done in order to demonstrate compliance with the specific rule?
If so, draft a permit condition to ensure compliance. Include set points, operating ranges, monitoring frequencies, etc.
Two. Be sure that the conditions you draft up, are possible to comply with.
Don’t simply, and creatively, think up conditions in order to “tell” the SCAQMD that you will be in compliance.
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 those records 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 just want to be thinking ahead about how compliance with these draft conditions will be demonstrated.
The SCAQMD’s website is full of information, but what’s the use, if you can’t find what you need.
Don’t let that be your roadblock to preparing a successful permit application.
As I mentioned in earlier, knowing the core elements of a permit application will start your project off on the right foot.
…and knowing is half of the battle…
A quick rundown of the 10 components are:
- Facility identity (Name/address)
- Equipment description
- Process description
- Facility history/overview
- Sources of emissions data
- Emission calculations
- Rule evaluation
- Health risk assessment
- Proposed permit conditions.
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 is the job of the permit engineer to process all of the information, in order to decide if your equipment can operate in compliance with all of the rules and conditions of the SCAQMD.
It is your job to convince the engineer that your equipment will comply.
Let’s Take This Over To You …
Did you know about the SCAQMD’s standard permit template?
Will this help you prepare your next SCAQMD permit application?
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Image Credit: Rejected
Updated: July 10, 2015