Environmental Management Systems

Contents

Permits
PTC
NSR
BACT
LAER

BITS Pilani, Pilani Campus

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Permit to Construct
An air quality permit to construct (PTC) is required prior
to construction or modification of
Buildings
Structures
Installations that emit, or may emit, pollutants into the air which
would result in moderate increase in air emissions

PTCs are required for certain portable equipment as

well, such as

generators
crushing equipment
asphalt plants
concrete batch plants

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Permit to Construct
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.
Emission estimates for all regulated air pollutants with
supporting calculations, assumptions, or manufacturer
guarantees for emission control devices.

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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 an
existing source, or process change.

Process Description
Site Plans
Equipment List
Air Emission Inventory

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Other Potential PTC Application Requirements

Some state rules require that a PTC be accompanied by a
simplified Environmental Impact Statement (EIS) or site
review application
Some states also require the applicant to submit an air dispersion
model analysis to demonstrate that air quality will not be
significantly impacted by the proposed work
One 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 1
ton/year

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New Source Review

NSR and Prevention of Significant Deterioration (PSD)
was established as part of the 1977 Clean Air Act
Amendments
The construction or modification of a major stationary
source that results in significant increase in air
emissions is subject to the NSR program
The permit specifies
what construction is allowed
what emission limits must be met
often how the emissions source must be operated

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Attainment and Non 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
Non attainment areas
Any area that does not meet the national primary or
secondary ambient air quality standard for the pollutant

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Attainment and Non Attainment Areas

If the air quality of an area for a particular pollutant is
attainment, the proposed facility will be subject to the
requirements of the Prevention of Significant
Deterioration (PSD) program
Under the rules of PSD permitting, you must proceed
with air modeling to determine whether you will
increase the concentration of the pollutant beyond
acceptable levels
Each pollutant in a given attainment area has a
maximum allowable ambient concentration

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Attainment and Non Attainment Areas

2 points to be considered
First, you will have to determine what control
technology or process design specifications are
required to meet the ambient air quality standards
Secondly, a facility subject to PSD program must
install Best Available Control Technology (BACT)

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Attainment and Non Attainment Areas

For non attainment areas, the permit application will
be subject to a much more stringent review under the
New Source Review (NSR) rules
Instead of BACT, the facility will be required to
meet the lowest achievable emission rates (LAER)
Will also be necessary to establish emission offsets for
the proposed project which demonstrate a net
improvement in air quality would result from the
construction of the project

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Permitting Major Sources PSD and NSR

Both PSD and NSR permitting involve a significant
amount of documentation
air dispersion modeling
and regulatory agency review
When permitting a major source, the facility permitting
team should include in its schedule a significant
amount of time for environmental agency review and
response to comment

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New or Modified Source Determinations

To determine whether a proposed project is subject to
PSD or NSR review requirements,
the initial step is to establish an emission inventory

Once an emission inventory is complete, data on the

specific annual emission of each pollutant will be
available

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Pre Application Monitoring

These requirements are triggered by lack of specific
ambient 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 project team
A full year of air quality monitoring may be necessary
to satisfy the environmental agency

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Determining BACT
EPA requires that the BACT analysis be done using the
top-down approach
This means that the most effective method of
controlling a pollutant is analyzed first; then less
effective controls are evaluated in descending order

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Determining BACT
For each potential technology, you will need the
following information:

Description of the technology or process

Capital cost of installation

Quantity of pollutant removed (annually), and
Cost-effectiveness calculation

Once the cost effective calculation is made, various

pollution control technologies are compared

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PSD and NSR Application Process

Application for a PSD or NSR permit is a voluminous
document, which includes the following items:

project application form and fee

project description
List of Sources
Emission Inventory
Applicability analysis
Air modeling information
Visibility analysis (if required)
BACT/LAER Determinations
Support appendixes
Drawing and site map

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PSD and NSR Application Process

A key to managing the permit review process is to meet
frequently with the permitting agency and to begin
these meetings well before the permit application is
submitted
Items that should be preliminary reviewed with the
agency include the following:
An overview of the project
Potential public concerns
Air emission inventory
PSD pollutant analysis
Air modeling requirements
Previous BACT/LAER determinations

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PSD and NSR Application Process

After the permitting agency has reviewed and accepted
the permit application as complete, you must still
respond to questions posed by the agency and provide
the agency with any additional information it requests

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Implementing Permit Requirements

It is necessary to obtain the permit before beginning the
construction and to comply with the terms of the permit once it
is issued
EPA can issue significant penalties to companies that commence
construction of a new source or modification of an existing
source prior to receiving final PSD or NSR permit
Permit compliance will likely require new operator training
manuals, new monitoring or testing equipments, and revisions to
the reporting and data systems
These requirements should be identified and implemented well
in advance of the actual start of a new facility or modification