Standard Evaluation for Permit to Construct

Please note that in accordance with Rule 201, "A person shall not build, install, erect, alter or replace any equipment, the use of which may cause the issuance of air contaminants or the use of which may eliminate, reduce or control the issuance of air contaminants without first obtaining written authorization for such construction from the Executive Officer".

General instructions, such as this, are italic hidden text. Before you print this evaluation for submittal, please hide this text by removing the checkmark from the "Hidden text" box under menu item File\Print\Options. This format is intended to supplement, not duplicate or replace the AQMD’s equipment specific Forms 400-E. Please add space between headings as necessary.

This evaluation, upon submittal, will become part of AQMD records subject to the California Public Records Act. If you wish to claim confidentiality, please make sure that all submitted information which you wish kept confidential is clearly marked as such and state the reason(s) for claiming confidentiality. Examples of acceptable reasons are trade secrets and proprietary information. Please note that information on emissions cannot be declared as confidential.

In general, use the minimum verbiage necessary to address all questions and demonstrate compliance with all regulations. You may complete one evaluation for multiple identical equipment submitted at the same time and you may complete one combined evaluation for basic equipment with its control equipment, but please submit one copy of the evaluation with each Application Form 400-A.

COMPANY NAME

Same as on the Application Form 400-A. Please indicate if this company is a separate corporation or a wholly owned subsidiary of another corporation.

EQUIPMENT LOCATION ADDRESS

Same as the Equipment address/location for the Facility on the Application Form 400-A. Remember to verify that this equipment is located within SCAQMD boundaries.

EQUIPMENT DESCRIPTION

In order to successfully complete this section, it helps to familiarize yourself with the format typically used by the AQMD. In general, please list the basic equipment separate from the control equipment. For each major component of process or control equipment, provide in this order the make, model, size (dimensions), type of fuel or material, hp rating, BTU/hr or electrical rating, and any peripheral item (i.e., serial number, pump or exhaust fan motors) that would aid identification of similar (and especially identical) equipment. For continuous process lines, please list the components of equipment in a process flow order. Include all Rule 219 exempt equipment used within the continuous process line. Upon agreement by the AQMD, this equipment description will be used on the permit. For examples to describe equipment: basic and control and to determine permit units, see Certified Permitting Professional Manual).

The following is a sample of command and control equipment description for two types of equipment: basic and control.

Basic Equipment Description:

FURNACE, BRASS MELTING, INDUCTOTHERM, LINEMELT, MODEL 60, 5100 POUNDS CAPACITY, 600 KW ELECTRIC INDUCTION HEATED.

Control Equipment Description

AIR POLLUTION CONTROL SYSTEM CONSISTING OF:

  1. BAGHOUSE, KELCO, MODEL J-2, WITH 25 FILTER BAGS, EACH 4" DIA X 6"-0" L, AND A MANUAL SHAKER.
  2. EXHAUST SYSTEM WITH A 3 H.P. BLOWER VENTING AN ABRASIVE BLASTING CABINET.

HISTORY AND PERMIT BACKGROUND

  • In general, what does the company do at this location?
  • When did the company start doing business at this location?
  • Was there a previous owner of this business?
  • Is this a RECLAIM and/or a Title V facility?
  • Identify in which Zone (I or II) the facility is located in? See Rule 2005 for map.
  • Did any noteworthy air quality events take place at this location? (Complaints? Notices to Comply for a Permit?, Notices of Violation?, Clean Air Awards?) For large facilities, focus on the equipment or process in question and any interdependent equipment/processes. Please provide details.
  • Is this application for new installation, change of ownership (with or without any change in operation) modification/alteration or change of condition for existing equipment?
  • If it is relocation, is it a partial or a full relocation of all the previously permitted equipment? Clearly indicate the previous location address and provide a list of permitted equipment that are to be relocated.
  • Does this company or any company have any existing equipment at the premises where this equipment will be installed? If yes, provide details including all company names and AQMD’s ID numbers.
  • Does this company or any company that the company has a business relationship with or that is under common control have any existing equipment at any contiguous facility. If yes, provide details including all company names and AQMD’s ID numbers.
  • If equipment is being removed from service (replacement, mitigation, etc.,) please provide the permit number of the equipment being removed.
  • If this equipment has a prior permit, list the previous permit number and attach copy of the permits, if available. Also, provide status of the permit – active or inactive.
  • What is expected start date of construction and start-up of operation for this equipment? Is this a multi-year project that may require more than a year to finish construction once the permit to construct is issued?
  • Provide information on any denials or Hearing Board Variances and Orders.
  • What permits have been issued within the last two years?
  • Please provide plot plan of entire facility showing location of equipment that are existing and that are proposed for construction. Also, indicate cross streets and location of any nearby (within 1,000 feet of the property boundary) sensitive receptors (schools –K-12, day care centers, etc.)

 PROCESS DESCRIPTION

  • For air pollution control systems, please provide description of operation principles and operating parameters (temperatures, pressure drops, scrubbing liquid recirculation rates, etc). Also, provide detailed calculations showing how the control efficiency was determined (manufacturer’s data sheet, calculations etc.)
  • Please describe the new process (or existing process, and how it will be modified) and the purpose of this process and provide detailed drawings of proposed equipment. Include any manufacturer’s specification and technical data sheet if available.
  • Include process specifics such as a description of the raw materials, chemical reactions, physical changes, discharge products, throughput flow rates (lbs/hr), temperatures, pressure drops, and production rates (lbs/hr). This information should be supplied in the form of a material balance. In addition, please supply maximum expected operating time in hours/day, days/week and weeks/year.
  • Indicate if the process will be a batch or a continuous process. Please provide a process flow diagram (may be separate document) with major items of equipment labeled to supplement this descriptive material indicating the location of all transfer points and expected points of fugitive and controlled emissions. For large facilities, please indicate product/flow rates to and from other interdependent processes, and include application or permit numbers for equipment that requires or has a permit.
  • Identify emission points and whether these points will be controlled and the type of control equipment.

DATA AND EMISSION FACTORS

It is not necessary to repeat data specified on the equipment specific Form 400-E, but please include any other data and conversion factors with their reference source used in the subsequent "Calculation" section.

Sources of emission data for non-attainment air contaminants (criteria and non-criteria) and toxic air contaminants.

(Criteria pollutants include reactive hydrocarbons (ROG), oxides of nitrogen (NOx), oxides of sulfur (SOx), carbon monoxide (CO) and particulate matter less than 10 microns (PM-10) and toxic air contaminants include all pollutants listed in Rule 1401).

Identify and indicate for each emission source, and for criteria and toxic air contaminants, the data source used to determine emission rates.

___ Source Test Date: ______________________

          Reference No: _________________

Source Testing Company: ______________________

Report attached (Yes/No) _______________

___ Manufacturer’s Specification (attached)

___ Emission factor (choose one of the following):

___ RECLAIM emission factor ________________________

___ RECLAIM emission rate __________________________

___ RECLAIM concentration limit _______________________

___ BACT emission limit ______________________________

___ Command and control emission limit __________________

___ NSR applicability limit

___ NSPS _________________________________________

___ SCAQMD Reg XI emission limit _____________________

___ AP-42, specifically _______________________________

___ NESHAP/MACT requirement _______________________

___ AB2588 program emission factor

___ Other, reference _________________________________

EMISSION CALCULATIONS

Showing each step of your calculations and stating all assumptions will help avoid permitting delays.

  • Please provide emissions estimates for each contaminant from all emission points described in the Process Description section above. See Rule 1306 for procedures to calculate emission increases and offset amount for non-RECLAIM sources and Rule 2005 for RECLAIM sources.
  • Provide the following emission calculations:
  1. Average pounds per hour for uncontrolled emissions (AHU or "R1").
  2. Average pounds per hour controlled emissions (AHC or "R2").
  3. Maximum uncontrolled emissions pounds per hour (provide basis for determining maximums). (MHU)
  4. Maximum controlled emissions pounds per hour (MHC)
  5. Daily maximum uncontrolled emissions pounds per day (MDU)
  6. Daily maximum controlled emissions pounds per day(MDC)
  7. Annual average emissions (AA), pounds per year
  8. 30-day-average emissions (30DA, in lbs/day), which is the maximum daily controlled emission rate multiplied by the maximum days operated in a month divided by a constant of 30.Provide basis for process weight calculations and PM/PM10 emissions calculations.

 Please summarize your results for criteria pollutants using the following format as shown in the table below.

Emission rates ROG TOG NOx SOx CO PM PM10
AHU              
AHC              
MHU              
MHC              
MDU              
MDC              
AA              
30DA              
Offset ratio              
Offset amount***              
  • Provide basis for process weight calculations and PM/PM10 emissions calculations.

*PM-10 emissions are assumed to be 50% of the total particulate matter emissions (PM) unless there is supporting data to suggest otherwise. If available, please attach data.

**TOG- total organic gases. This is a total of the Reactive organic gases (ROG) and the unreactive organics such as CFCs’.

*** To determine offsets required, emissions greater than 0.5 pounds a day are rounded to 1.0.

 

Toxic air contaminants (TACs):

  1. Identify all the TACs' that are listed in Rule 1401,emitted from the emission sources. Indicate for each TAC:
    1. The hourly emissions (for TACs' with acute health effects only).
    2. The maximum annual emissions in tons/year for TACs' that causes chronic health effects and cancer.
  1. The closest receptor distances, outside the property boundary, for each of the emission sources.
  2. Release parameters of the source. Is it a point, volume or an area source? For point source, indicate stack temperature, diameter, flow rate, and stack release height.
  3. Calculate the health risk: cancer and non-cancer, from all applicable sources. For guidance to screening health risk assessment, please use District Health Risk Assessment Guideline, Version 5.1 or thereafter. If an alternate procedure was used to calculate the health risk assessment, please provide the reference and the methodology used.

 

RULES EVALUATION

List all AQMD rules that are relevant to this project, state the rule requirements that you must comply with and why you believe you comply with these requirements. Focus on the following regulations; for any that are not applicable, state "Not applicable." If the equipment is subject to a rule, but exempt from part or all of the rule, please identify the exemption claimed and explain why that exemption applies:

REGULATION II

RULE 212:

  • Is this a significant project as defined in Rule 212? Is the emission source located within 1,000 feet of the outer boundary of any school (K-12) or facility emissions greater than the values in Rule 1304, Table A or if the risk is greater than the allowed risk.

RULE 219:

  • Is operation of this equipment dependent on any Rule 219 exempt equipment (e.g. forklifts, small IC engines, etc.)? If so, identify equipment and its emission potential.

Other Reg II as applicable.

REGULATION IV

Rule 402: What is the potential of this equipment to cause a nuisance (odors, etc)

Other Reg IV as applicable.

REGULATION IX: New Source Performance Standards

REGULATION X: National Emission Standards for Hazardous Air Pollutants

REGULATION XI: Source Specific Regulations

REGULATION XIII New Source Review

Address compliance with Best Available Control Technology (BACT), Offsets and Modeling, as follows:

BACT

  • Is the equipment subject to BACT or LAER or is it exempt? (if maximum emission increase is less than 1 pound a day – emissions less than 1.5 are rounded to 1.0)
  • How does it comply with the requirements?
  • Indicate reference sources used to demonstrate compliance with BACT or LAER.

(Information on BACT/LAER determinations can be obtained from AQMD’s website, www.aqmd.gov in the "Getting Permits" section.

Offsets:

  • Is the facility potential to emit (PTE) for all the criteria pollutants less than 4 tons (29 tons for CO) per year after the emissions from this equipment is added? (attach NSR facility balance data if available)
  • If offsets are required, are ERCs, RTCs provided? (attach certificates)

Modeling

  • Do the emissions from this equipment for NOx, CO, and PM-10 equipment pass the screening limits in Table A-1 in Rule 1303?
  • If not, provide modeling results to demonstrate compliance with the limits established in Table A-2 in Rule 1303. (attach modeling input and output files)

REGULATION XIV

Rule 1401

  • Indicate how compliance with this rule will be achieved. Is the evaluation for risk based on Tier I, or higher Tier analysis or is it exempt from the rule? Indicate the methodology used to calculate the risk.
  • If T-BACT is needed to demonstrate compliance with the rule, indicate why the control equipment should be considered T-BACT.
  • Is the equipment subject to any other Reg. XIV rules?

REGULATION XVII - Prevention of Significant Deterioration (PSD)

Compare actual emissions (from Emission Fee Billing Reports) to new potential to emit emissions for NOx and SOx. If emission increases are greater than 40 tons per year for NOx or SOx, PSD analysis is required.

REGULATION XX: RECLAIM

REGULATION XXX: Title V

 CEQA

    • Is this equipment part of a project subject to CEQA? Has a CEQA document been prepared and certified for this project? Was the project granted a Notice of Exemption or a Negative Declaration? (attach copy)
    • Has the CEQA form been completed? Are there any significant impacts?

RECOMMENDATION

Include any additional information here that helps "make the case" that the equipment/process will comply with all AQMD Rules and Regulations when in operation.

Compliance with SCAQMD’s applicable Rules and Regulations is expected.

___ Issue a Permit to Construct subject to the following conditions:

PROPOSED PERMIT CONDITIONS

In order to successfully complete this section, it helps to familiarize yourself with the permit conditions that are typically added to an AQMD permit. Consider the amount of operating flexibility needed. Propose operating, material usage, and production limits that the company can "live within." These limits become the basis for the (maximum) emission calculations, emission offset requirements and rule compliance. Upon agreement by the District, these conditions will be used on the permit.

SCAQMD use only:

Permit processor’s Name: _______________________ Date: ____________
___ I concur with the evaluation and recommendation in this document.
___ I concur with the evaluation, but recommend issuing a Permit to Construct/Operate subject to the same conditions.

___I concur with the evaluation, but recommend using a different set of permit conditions. See attached dated document.

___I do not agree with the evaluation and/or recommendation in this document. See attached dated document.

Reviewers Name: ____________________________ Date: _____________
___ I also concur with the evaluation and recommendation in this document.
___ I do not agree with the evaluation and/or recommendation in this document.

Returned to permit processor on Date: ____________________