Proposed Permit System
            For
Sources  Of Air Pollution
            in the
       State Of Alabama
          November 1971
           Prepared For

      Environmental Protection Agency
        TRWt
        SYSTEMS CROUP
            WASHINGTON OPERATIONS

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     PROPOSED  PERMIT  SYSTEM
  FOR SOURCES  OF AIR  POLLUTION
            IN THE
        STATE  OF ALABAMA
        Steven  E.  Plotkin

          November 1971
          Prepared  For
 Environmental  Protection  Agency
TRW*
SYSTEMS GROUP
           WASHINGTON OPERATIONS
          7999 COLSHtHt DHtVf . MclFAW. WffOfJVM M»«f

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     The work upon which this publication is  based  was  performed  by
Resources Research, Inc., a subsidiary of TRW Inc., pursuant  to
Contract No. 68-02-0048 with the Office of Air Programs,  Environmental

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                             TABLE OF CONTENTS
Section Number

     1.
     2.
     2.1
     2.2
     2.3
     3.
     3.1
     3.2
     3.3
     4.
     5.
     6.
     7.
     7.1
     7.2
     8.
     9.
    10.
    10.1
    10.2
    10.3
    10.3.1
    10.3.2
    11.
    11.1
    11.2
    11.3
Appendix A

Appendix B
           Title                              Page
INTRODUCTION                                   1-1
GENERAL OVERVIEW                               2-1
New Sources                                    2-1
Existing Sources                               2-5
Data Bank                                      2-7
LEGAL AUTHORITY                                3-1
Review of New Sources and Modifications        3-1
Source Surveillance                            3-1
Enforcement                                    3-2
APPLICABILITY                                  4-1
PERMIT APPLICATIONS                            5-1
PERMIT UNITS                                   6-1
REVIEWING PERMIT APPLICATIONS                  7-1
Review Process                                 7-1
Conditional Permits                            7-3
VARIANCES                                      8-1
FACILITY INSPECTIONS                           9-1
AIR POLLUTION CONTROL AGENCIES                10-1
State/Local Jurisdiction                      10-1
Staff Logistics                               10-1
Personnel                                     10-3
Field Operations                              10-3
Office Staff                                  10-3
DATA MANAGEMENT                               11-1
Functional  Organization                       11-1
Data Operations                               11-3
Automated System Requirements                 11-9
Sample Permit Applications and                 A-l
Instructions

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                          TABLE OF CONTENTS
                             APPENDIX A
            SAMPLE PERMIT APPLICATIONS AND INSTRUCTIONS
                                                                 Page
GENERAL APPLICATION
     Form	A-5
     Instructions 	 A-6
FUEL BURNING EQUIPMENT (<    BTU/hr)
     Form	A-9
     Instructions 	 A-ll
FUEL BURNING EQUIPMENT (>	BTU/hr)
     Form	A-14
     Instructions 	 A-17
SMALL INCINERATORS
     Form	A-21
INCINERATORS (including TEEPEE Burners) .
     Form	A-23
     Instructions 	 A-26
PROCESS EQUIPMENT
     Form	A-30
     Instructions 	 A-34
STONE QUARRYING OPERATIONS
     Form	A-36
     Instructions 	 A-42
WOOD PROCESSING OPERATIONS
     Form	A-46
     Instructions  	   A-55
BULK STORAGE
     Form	A-60
     Instructions 	 A-62

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                         TABLE OF CONTENTS

                            APPENDIX A
                            (continued)
                                                                  Paqe
AIR POLLUTION CONTROL EQUIPMENT
     Form	A-63
     Instructions 	  A-65

EMERGENCY EPISODE INFORMATION (Fuel  Combustion Equipment)  ....  A-66

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                             1 .   INTRODUCTION


     The following is a description of the Alabama Permit System, which  is

designed to fulfill  the requirements delineated in §420.18,  Review  of  new

sources and modifications, and  §420.19,  Source Surveillance,  of  the

Requirements for Preparation, Adoption,  and Submittal  of Implementation

Plans (Chapter IV, Title 42, Federal Register, Vol.  36,  No.  150, Saturday,

August 14, 1971).


     The purpose of the Permit  System is the following:


          1.  To administer the  source surveillance  program.

          2.  To prevent construction of new sources,  or modifications
              of existing sources, that will violate the rules and
              regulations of the Air Pollution Control  Commission.


     The key advantages of a permit system are:


          1.  It enhances the legal position of the  control  agency
              (Alabama Division  of Air Pollution Control)  vis-a-vis
              the courts and industry.  Upon denial  or suspension of
              a permit, the burden of proof lies with  industry proving
              that it operates within the rules, rather  than  with the
              agency proving the converse.

          2.  The system provides an automatic review  of new  construction,
              thus benefiting the industrialist by preventing the con-
              struction of facilities he cannot legally  operate.

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                          2.  GENERAL OVERVIEW

     Figures 2-1 and 2-2 are flow diagrams describing the general  operation
of the Alabama, Permit System as it applies to new and presently operating
sources.

2.1  NEW SOURCES
     In order to build a new facility (or modify an old one) which has the
potential to emit dust, fumes, mist, smoke, particulate matter, vapor, gas,
or any combination thereof, it will be necessary to apply for and  obtain
a Permit to Construct in accordance with the requirements of the Alabama
Division of Air Pollution Control (DAPC).  The permit application  must
include all information relevant to the new source's potential impact on
the air environment.

     The application will undergo a careful review  by the staff of the
Division.  The review will determine whether or not the proposed facility
will be constructed and operated in accordance with State and Federal
laws and regulations.  An affirmative decision  results  in the granting
of a Permit to Construct, which grants the applicant the right to  build
the facility strictly according to the application and within a limited
amount of time.  If the application is rejected, the applicant will be
informed  as to the reasons for  rejection and be granted permission
to resubmit the application after necessary revisions have been made.  If
the application is found to be generally acceptable but requiring  some
minor modification, a conference will be scheduled with the applicant to
accomplish the required modifications without a complete recycling of the
review process.

     After construction of the facility, an application will be made for
a Permit to Operate.  An inspector from the Division will verify that the
actual construction has been in accordance with the original Permit to
Construct; a satisfactory inspection will lead to a Temporary Permit to
Operate, which will remain in force until a detailed inspection of the
facility under actual operating conditions can be made and the results
reviewed.  The applicant may hasten the granting of this Temporary Permit

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                             r
                                                                                                       DATA BANK
                                                                                  COMPLAINTS
REVIEW PROCESS

 • EMISSION  REDUCTION PLANS
 •LAND USE
 •EMISSION  STANDARDS
 •EQUIPMENT STANDARDS
 •AIR QUALITY STANDARDS
                                                         GRANT PERMIT
                                                         TO OPERATE
              CONTINUED
              ORDINARY
              OPERATIONS
                                                                                                           I
                                                                                                          JL
                                                                                                  ROUTINE INSPECTIONS
                                                                                                    PERIODIC REPORTS
ISSUE ORDER
WITH DEADLINE
                                                                                                                                   YES
                                      TEST AND
                                      INSPECTION
LEGAL
ACTION
                                                                                                                                                                           YES
                                                                                                                                                                      	— — INFORMATION FLOW

                                                                                                                                                                                 •  ACTIVITY FLOW




                                                                                                                                           NOTE:  ONLY MAJOR INFORMATION FLOWS TO DATA BANK ARE SHOWN
                                                     Figure 2-1.
OPERATION OF A NEW POLLUTION SOURCE
IN THE PERMIT SYSTEM

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 INDUSTRIAL  PLANT

(LARGER THAN
SPECIFIED MINIMUM
SIZE)
REVIEW PROCESS

 • EMISSION  REDUCTION PLANS
 • LAND USE
 • EMISSION  STANDARDS
 • EQUIPMENT STANDARDS
 • AIR QUALITY STANDARDS
                                                                                                                                                                                   INFORMATION FLOW

                                                                                                                                                                                   ACTIVITY FLOW
                                                                                                                                                                      NOTE: ONLY MAJOR INFORMATION FLOWS TO DATA BANK ARE SHOWN
                                                                                                                      Figure 2-2.
                                                                                       OPERATION OF AN EXISTING POLLUTION SOURCE
                                                                                       IN THE PERMIT SYSTEM

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by having his original application for a Permit to Construct signed by a
Professional Engineer well versed in air pollution control  techniques.
A Temporary Permit to Operate will immediately be granted to the applicant
upon receipt  by the Division of Air Pollution Control  of a letter from
the Professional Engineer testifying that the construction has been com-
pleted and is in accordance with the plans and specifications approved by
the DAPC.  If there is any doubt as to the acceptability of any particular
Professional Engineer's credentials, the DAPC may be contacted for a ruling
as to his acceptability.

     A full-scale operating inspection of the facility  will be conducted
by the DAPC within a reasonable time following the granting of the Temporary
Permit to Operate.  This inspection will determine whether a Permit to
Operate shall be granted to the facility.  In addition, prior to this time
the DAPC may require the facility to substantiate, by the submission of
data or the conducting of tests in the presence of officers of the DAPC,
the adequacy of its control equipment.  These data and  tests will  consist
of stack sampling and/or continuous  monitoring of emissions.  If  either
the inspection or the data submitted by the source indicates a lack of
compliance with the specifications in the permit application, the  DAPC
will issue an order requiring compliance with these specifications within
a limited period of time.  Continued non-compliance past the deadline of
the order will result in suspension or revocation of the Temporary Permit
to Operate, and legal action by the DAPC if the facility fails to  cease
operations.

     If the facility is found to conform to the specifications of  the permit,
a Permit to Operate shall be granted and the facility will  enter the routine
source surveillance loop of the Permit System.

     Source surveillance includes the issuing of periodic reports  by the
source and routine inspections of the source by the DAPC.  Periodic reports
may range from production reports and notification of unusual operations,
chemical spills, etc., to detailed emission reports required of the larger

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sources in the region.  The inspections will  be conducted at regular
intervals by agents of the DAPC and will be similar to but less  detailed
than the original operating inspection noted above.

      If either the periodic reports or inspections indicate non-compliance
with conditions specified by the Permit to Operate, the DAPC may repeat the
"order to comply with deadline" procedure outlined above.  A fine may be
levied against the facility whose amount will  depend on the plant size,
degree of non-compliance, previous record of the facility, and the nature
of the non-compliance, i.e., whether it was deliberate or accidental, known
or unknown to the plant operators.

2.2  EXISTING SOURCES
     The procedure for registering presently operating sources into the
Permit System is identical to that already described for new sources,
except that the review process focuses on an existing source rather than
merely on a set of blue prints and process descriptions.   In this case,
the application for a Permit to Operate is the equivalent, in level  of
detail, to the Permit to Construct application in the previous discussion.
The inspection to determine permit status can  be an extraordinary one
conducted at the time of the application submittal, or else it can simply
be the first of the routine inspection in the  "normal operation" cycle.
The latter is preferable where the control agency has limited personnel for
the task, but it is likely that a staggered permit application schedule
will be initiated anyway in order to avoid a sharply discontinuous demand
for engineering personnel in the agency.  At any rate, once the  Permit to
Operate has been granted to the source, operation in the system  is identical
to that described above for new sources.

     Under the Alabama Permit System, existing  facilities which do not
satisfy the emission standards and/or equipment and operational  specifications
defined in this Implementation Plan AT THE TIME OF ITS PROMULGATION may be
permitted to continue operating under Conditional  Permits to Operate.   These
permits specify certain conditions under which the facilities must operate,
and certain schedules under which the facilities must systematically reduce

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their emissions to satisfactory levels.   The DAPC will  require the facilities
to submit control plans with permit applications, but it may  impose additional
conditions and schedules.  In the latter case,  if the facilities  continue
operation under such permits, they will  be considered legally to  have accepted
the conditions and schedules specified.

     Conditional Permits may also be granted to a new source  which has  been
granted a Permit to Construct and Temporary Permit to Operate but cannot pass
operational inspection.  In these circumstances, the permits  will  be granted
to a period of time from 30 days to one  year, provided that a compliance plan
has been agreed to by the facility and the DAPC.  However,  under  no circum-
stances will the DAPC grant a Conditional  Permit (including renewals)  for  a
period of time greater than one year.

     In order for the Conditional Permit to remain in effect, periodic  progress
reports must be supplied by the facility to the DAPC.  A failure  to submit these
reports or lack of satisfactory progress will be grounds for  revocation of the
permit.  If the emission reduction plan  includes the addition  of control
devices to the facility, then an important milestone in the reduction plan
shall be the granting of a Permit to Construct  the devices.  Upon satisfactory
completion of the emission reduction program, a Permit to Operate will  be
issued and the facility will enter the routine  source surveillance loop.

     In cases where a facility cannot obtain a  Permit to Operate  from the
DAPC, it may appeal to the Air Pollution Control Commission for a variance,
which would exempt the facility from the requirement that it  satisfy one or
more of the air pollution rules, regulations, and laws.  The  process of
granting a variance  will often include  a public hearing called by either
the Commission itself or any citizen who files  an objection.   The variance
itself will often include conditions and schedules similar  to those in  a
Conditional Permit, but a key  difference is that the end result  of such
conditions and schedules in a variance need not be compliance with regular
air pollution emission standards or other regulations.

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2.3  DATA BANK
     All operations in the Permit System  create  information  to be fed into
a central Data Bank.   In Figures   2-1  and 2-2, the major sources of  informa-
tion from the permit  system are seen  to  be permit applications, periodic
reports, and the routine inspections.   In addition,  of  course, other sources
of information both inside and outside the Permit System exist, e.g., legal
action proceedings, air quality surveillance  inputs,  old emission inventories,
etc.

     Because of the great number of air  pollution sources  to be included under
the  Permit  System, and the requirement for speed of  data processing  for use
during emergency episodes, the air pollution  data  bank will eventually be
computerized.

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                            3.  LEGAL AUTHORITY


     The Alabama Air Pollution Act of 1971, Act #769, Regular Session, 1971,
provides full legal authority to the Air Pollution Control Commission and its

agent, the Division of Air Pollution Control, to initiate and maintain a permit
system in satisfaction of the new source review and source surveillance require-

ments in the Federal Register.  The following passages of the bill are relevant:
 3.1   RtVIttJ OF iJEW SOURCES  AiJD MODIFICATIONS

      1.  To deny construction:

          §18     The Commission may operate a permit system.

          §18,3   It is able to deny a permit.
          §8,a    It may prohibit construction of a new source if
                  it finds the source to be in violation of the rules.


      2.  To require sufficient information:

          §18,2   The Commission is able to require applicants for
                  a permit to furnish information necessary to grant
                  a permit.
          §5,f    It may institute  requirements for reporting
                  information on processes, stacks, fuels,  etc.
          §8a     It may require, prior to construction, the
                  submission of plans, specification, etc., to
                  allow it to determine whether such construction
                  should be allowed.


3.k:  SOURCE  SURVEILLANCE

      1.  To require reporting by owners:

          §7,0    It may require owners to install, use, and maintain
                  monitoring  equipment; sample emissions;  maintain
                  records of emissions, and report the results..
          §18,2   As described above.

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       2.   To  provide  for periodic  testing and inspection:

           §9,b     The Commission may conduct tests on the equipment
                   of  sources  and take necessary samples.  It may
                   require  owners to provide sampling and testing
                   facilities.
           §9a     Its agents  have  the right of entry into any business
                   during proper  hours  to inspect and find out what's
                   happening.
3.3  ENFORCEMENT
       §17,a     .   The  Commission may fine violators of the Control Act.
       §17,d        The  Act  establishes any knowing violation of the Act
                   or of  the  rules adopted under it as a misdemeanor.
       §17,c        The  Commission may commence prosecution of violators.
       §17,e        It may authorize  the Director of the DAPC to issue
                   citations  commanding appearance at a hearing.
       §17,i        It may conduct hearings, and sign, issue, and serve
                   subpoenas.
       §17,j        It may seek  injunctive relief.
       §18,3        It may suspend or revoke permits.

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                             4.  APPLICABILITY

     All equipment, machines, devices,  articles,  contrivances,  or  installations
presently operating, under construction,  or in  planning  in  the  State  of Alabama
that emit, or have the potential  to emit,  any form of  air pollution—dust,
fumes, mist, smoke, other particulate matter, vapor, qas, or  any combination
thereof—are subject to the Alabama Permit System. However,the uAPC  will
exempt several categories of air  pollution  sources from the  requirement  that
they obtain permits; furthermore, the DAPC shall  establish  size limitations
on facilities, based on factors such as yearly  emissions, process  rate, heat
input, and others, such that those facilities smaller  than  the  established
limit shall also be exempt from the application requirement.   (Exemption
from the permit system does not,  of course, exempt a pollution  source from
complying with all other rules and regulations, including all  applicable
emission standards, of the air pollution  program.)

     Because it is evident that a relatively small number of  very  large
pollution sources play a significant role  in determining the  quality  of the
air environment in the State of Alabama,  the DAPC will establish increased
permit application and emission monitoring and  reporting requirements  for
these sources.  For instance, a  "long" and "short" permit  application form
will be used for registering fuel-burning  sources into the  permit  systeiii--
the short form for the many small boilers  in Alabama,  and the long  form for
the larger sources, including power plants.

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                         5.   PERMIT APPLICATIONS

      Applications for Permit to Operate and Construct must include all
information relevant to the facility's potential impact on the air
environment.  This information includes:

         Facility identification - name, address, owner, etc.
         Details of construction procedures
         Description of the facility
         Description of air pollution control devices
         Details of operating procedures
         Plans for emission reduction during emergency episodes
         Emission estimates/measurements or information with
         which to estimate emissions
         Plans for permanent reduction of emissions, if necessary
         Signature of responsible party

      For a given type of facility, one form will normally serve as an
application for a Permit to Construct or Operate and, when approved,
as the Permit itself.  This will decrease the amount of paperwork to be
processed by the system.

      The DAPC will establish a Permit Advisory Unit to assist applicants
in filling out satisfactory permit applications.  This unit is primarily
designed to aid owners of small facilities.  Owners of larger  facilities
will be encouraged to obtain the services of a Professional Engineer to
assist them in filing the proper forms.

      The signature of the applicant will constitute an agreement that
the applicant assumes the responsibility for any alterations,  additions,
or changes in operation that may be necessary to achieve and maintain
emission standards or compliance with any other applicable regulations.

      The DAPC has the right to request the applicant to furnish any
additional information necessary to evaluate the facility's effect on
the air environment.

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                             6.    PERMIT UNITS

      All facilities not exempt from the Permit System must apply for
separate permits for each "permit unit" of equipment under operation  or
construction, or in planning.  A permit unit is defined as a piece of
equipment, or an equipment grouping, which operates  together as  a
functional unit.  In any and all cases where confusion exists as to what
constitutes a permit unit, the DAPC shall  decide.

      In the case of an equipment grouping involved  in a process, the
grouping will be considered a permit unit  if each  separate piece of
equipment is united to the others by conveyor or pipe or chute or hose,
provided that no item of the group will operate separately with  process
material not common to the group operation.   For instance, a small  con-
crete batching plant may be divided into 2 pen.iit units - a cement receiving
and storage system (hopper, conveyor, elevators, vibrators, aerators,
and storage silos) and a batching unit (conveyor or  receiving hopper,
vibrators, elevator, hoppers) and truck loading.  If a control device is
used, this constitutes a third separate permit unit.   A rock crushing
plant might only consist of 1 permit unit  (2 of a  control  system is
included), including charging hopper, various crushers, and storage.   If
the storage bin is physically separated from the crushers, it will  be con-
sidered a separate permit unit.

      Spare or standby equipment which forms a separate permit unit in
itself (e.g., a standby boiler in a hospital) will  require a separate
permit even if it is almost never used.  When spare  equipment forms a
part of a permit unit, it should be described in the permit application
for the unit.

      Equipment ;iterns or groupings in parallel, operated independently
and not physically united for the flow of material,will be considered as
separate permit units.

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                    7.   REVIEWING PERMIT APPLICATIONS
7.1  REVIEW PROCESS
      An application for a Permit to Operate or Construct will undergo a
rigorous review by a committee composed of members of the staff of the
DAPC.  In order for a source to successfully gain a Permit, it must
satisfy the review committee that:

      1.  The source does, or will,conform to all emission
          standards formulated by the DAPC.
      2.  The construction and/or operation of the source will
          not cause air quality standards to be violated.
      3.  The source has established a satisfactory emission
          reduction schedule for emergency episodes.

      One result of the second condition is that any newly constructed
source in an air quality "saturated" area* will have to emit at a lower
rate than the source it replaces.  This condition can easily be  stricter
than the established source emission standards, especially in heavily
developed areas.

      Characteristics of the review process will be:
      •  Full documentation of all  findings, for every permit
         application
      t  Standardized review procedures
      •  Procedures which are in accordance with existing legal
         authority for control, and the existing DAPC charter
      •  Availability to all applicants of clear standards for
         acceptance or rejection of permit applications
      Staff members reviewing permit applications will  be graduate
engineers (or have equivalent experience), specially trained in air
*  Saturated in the sense that any increase in emissions will  cause a
   violation of air quality standards, assuming a violation does not
   already exist.

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pollution control.  Since the State has a considerable variety of process

sources of air pollution, it is  likely that staff members specializing
in different types of industries will  have to be available.


      The review process will proceed  as follows:


      1.   The application will  be checked to insure that all
          information requirements have been met.   Plant size and type
          will be checked to insure that the equipment is not exempt.

      2.   Data contained in the  application will be checked  for
          internal consistency.   If old emission inventories  or other
          information on the source are available,  they will  be com-
          pared to the application.

      3.   An emission estimate will be derived using available emission
          factors.  If measured  emissions are included in the
          application, these will be compared to the estimates.

      4.   Allowable emissions will be  calculated using data  contained
          in the application and compared to the estimated or
          measured emissions.  If emission standards are not  met,
          the additional control needed will be specified and compared
          to that called for in  the emissions reduction plan  included
          in the application.

      5.   If the application is  for a  new facility, an estimate will
          be made of the source's potential impact  on the air quality
          at its selected site.   An allowable emission rate  based on
          air quality will  be calculated.  If this  rate is lower than
          that calculated in step 4, it becomes the determinant of
          the applications's acceptability, and a  new control
          efficiency is specified.

      6.   Plans for emission reductions during emergency episodes
          will be reviewed.

      7.   Operational and equipment standards will  be reviewed as
          they pertain to the source.

      8.   The application is either accepted, rejected, or alse,
          if only minor modifications  are necessary, the applicant
          will be called in for  consultation and, if he is agreeable,
          these modifications will be  made.  For a presently operating
          source, a Conditional  Permit will be issued if the  source
          does not satisfy emission standards but  has submitted a
          satisfactory plan for  emission reduction.

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      The DAPC will establish a time limitation on the review process
outlined above, so as to insure that no applicant shall suffer a hard-
ship because of a delay in obtaining a permit.  However, this time limit
will immediately be extended in the event of any obstruction or delay in
forwarding requested information on the part of the applicant.

7.2  CONDITIONAL PERMITS
      The main purpose of the Conditional Permit is to provide a mechanism
whereby an air pollution source will be required to adhere to or surpass
a fixed schedule by which it must reduce its pollutant emissions to the
legal limits.  As outlined in the Federal Register , the emission reduc-
tions scheduled by the State must achieve primary ambient air quality
standards within 3 years after approval of the Implementation Plan.  Since
a considerable proportion of the air pollution sources in Alabama will
have to resort to various means of control—fuel  switches,  stack devices,
etc.--to meet the new emission standards,  and since these means  will
require some time for their implementation, the Conditional Permit pro-
vides an efficient means for both granting this time and legally requiring
adherence to schedules.

      Although a variance can obtain the same effect as a Conditional Permit,
the variance is much too cumbersome a device to use extensively in the
early years of the program.  However, it should be made clear that the
Conditional Permit is not meant to circumvent  the variance procedure.
Rule 10 (see Appendix B) is written expressly so as to eliminate the use
of  Conditional Permits for establishing long-range reduction schedules
(and allowing operation above the emission standards for considerable
lengths of time) after the program is two years old.  After this time,
the Conditional Permit will merely provide a means whereby the DAPC can
specify conditions to be taken immediately, or within 90 days, in order
for a source to continue legal operations.  If a source cannot operate
within the standards and cannot correct this within a very short period
of  time, it will have to petition for and obtain a variance or else
shut down.
   Federal Register, Vol. 36, No. 150 - Saturday, August 14, 1971, Part
   420 -  Requirements for Preparation, Adoption, and Submittal of
   Implementation Plans.

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                                8.   VARIANCES


     The Alabama Air Pollution Act  of 1971, Act #769,  Regular Session,  1971,

grants the Air F'ollution Control  Commission the right  to exempt individual
sources of pollution from certain of the limitations imposed by the Act and by

the rules and regulations adopted by the Commission.  In order to obtain
a variance, a source must show that:
       1.   Compliance with  the limitation(s)  in  question  "would  impose
           serious  hardship without  equal  or  greater benefits  to the
           public ," and

       2.   The emissions  occurring or proposed to  occur with  the
           variance "do not endanger or tend  to  endanger  human
           health or safety,  human comfort, and  aesthetic values."

       The Act provides several  safeguards  against misuse of  the

 Commission's  power:
       1.   Every petition  for a  variance  must  be  published  in  a
           local newspaper.

       2.   Receipt by the  Commission  of a written objection  from
           any person within  21  days  of the  notice will  require
           a public hearing  to be  held, with the  burden  of  proof
           being on the petitioner.

       3.   Any person adversely  affected  by  a  variance or renewal
           may appeal to the  civil  courts to have the variance
           disallowed.

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                         9.   FACILITY INSPECTIONS

      The key enforcement tool of the Permit System will  be the facility
inspection, conducted on both a regular and an extraordinary basis by
trained inspectors.

      During the inspection, the DAPC inspector will inventory all
equipment in the facility, noting serial  numbers, equipment types and
location in plant, physical condition and operating procedures.  This
inventory will be immediately checked against the information provided
on the operating permits on file at the facility.  If the inspection
has been scheduled, the inspector will carry with him copies of the
facility's permits to provide an added check.

      An inspection will cover one primary activity (for instance, steel-
making, rendering, etc.).  When more than one activity appears in a
single facility, each merits a separate inventory form and inspection.

      The frequency of inspection will depend upon the following factors:

         available personnel
         history of complaints against the facility
         total emissions of the facility
         complexity of the facility
         facility's room for expansion
         history of violations
         time required to conduct inspections

      The DAPC shall establish a list of facilities which shall be subject
to a minimum of one inspection per year.   It will be considered undesirable
to permit any source to go uninspected for a period greater than two
years.  However, if adequate personnel are not available, the DAPC shall
establish an inspection schedule based on selective coverage of sources,
bypassing those sources which have minimum impact on the air environment
of the State of Alabama.  Also, inspections conducted in response to a
specific complaint or air pollution problem will concentrate only on the
equipment involved in the problem and will not constitute a complete
inspection.

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                  10.   AIR POLLUTION CONTROL AGENCIES

10.1  STATE/LOCAL JURISDICTION
      The Permit System shall  be jointly run by the Alabama DAPC and the
local control agencies, with the former playing the central, and major,
role.

      In practice, all permit applications will be reviewed by both the
local and the State agencies.   The local agency will collect the applica-
tions and perform an advisory service to the applicant.   The depth of the
local review will be determined by the local agency itself, since the
State DAPC will perform a standardized review regardless of the local
agency's actions.  The DAPC will also perform a second-level advisory
function for matters that the local agency cannot handle.  If either the
State or local agency  rejects  a permit application,  then a permit shall
be denied; however, the permit applicant may appeal to the Control
Commission to override the rejection.  Although the Commission, and
through it the DAPC, may override the local agency (Section 15d of
Act #769) in such matters, it may be expected that this  will rarely, if
ever, occur.

      The source surveillance portion of the system will also be conducted
jointly by the State and local agencies.  The local agency shall perform
the majority of routine inspections; the State DAPC will inspect facili-
ties requiring special expertise that should properly be concentrated in
the central (State) agency.

10.2  STAFF LOGISTICS
      The impact of the Permit System on the DAPC staff manpower and
capability needs will be considerable.  The following new groups within
the Division will have to be formed:

      •  Permit Review Section
      •  Permit Advisory Unit
      •  Permit Inspection Unit

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      The Permit Review Section will consist of engineers and technicians

who will review permit applications.  The engineers in this section will

also provide technical support to the Permit Advisory Unit, which will

consist of one or two engineers who will  provide help to permit applicants
and will draw on all agency personnel for help on specific problems.

The Permit Inspection Unit will handle the non-operational and operational

inspections necessary to the permit granting process; this unit will  be a

subsection of the field operations staff of the DAPC.


      In addition to the increase in the permanent staff necessitated by
the System, there will be a sharp peak in manpower requirements during

the first year or two after the System is initiated.   This peak will  be

caused by the fact that every facility in Alabama subject to the require-

ment to obtain a Permit to Operate must apply during  this initial period.


      The DAPC shall put the following policies into  effect in order to

lessen the impact of initiating the Permit System:


      1.  Although it is anticipated that sources of  air pollution below
          some specified size will never be required  to obtain a Permit to
          Operate from the DAPC, the Director will designate an intermediate
          size limitation such that those sources below that limit but are
          still above the minimum will be exempt from the permit require-
          ment for one year, or until such time, not  to exceed two years
          past the promulgation of this Implementation Plan, that the
          Director shall decide that the Permit System staff is fully
          trained and able to handle the additional influx of new permit
          applications.  This policy will apply to existing sources only;
          new sources in the above category will be required to apply for
          Permits to Construct and Operate in the same manner as those
          larger non-exempt sources.

      2.  The DAPC will establish a schedule whereby  existing sources
          subject to permit requirements may apply for Permits to Operate
          on a staggered basis during the first year  that the Permit
          System is in operation.

      3.  The Permit Staff will schedule permit reviews so as to favor
          applications for Permits to Construct, to minimize any hard-
          ships to individuals and corporations seeking to install new
          equipment.

      4.  The DAPC will establish a source-location priority system to
          first concentrate manpower resources on sources located in urban
          areas in Alabama, where the problem is most acute.


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10.3  PERSONNEL
      The following is a brief description of the types of technical
personnel needed, job requirements, and job descriptions for implementation
of the Permit System.

10.3.1  Field Operations
      1.  Patrol Inspector
          a.  Job Requirements - No formal academic requirements,  good
basic writing skills and intelligence.  Training in combustion processes
and equipment operation will be needed (can be done by DAPC).   Possibly
training in stack sampling and smoke reading.
          b.  Job Description - General patrolling duties, investigation
of complaints against nor.-industrial polluters, simple inspections of small
pollution sources, surveillance of suspected violators, smoke  observations,
stack testing, etc.
      2.  Industrial Engineering Inspector
          a.  Job Requirements - Bachelor's degree in chemical or mechanical
engineering or equivalent experience; detailed knowledge of industrial
processes and equipment, control  devices and procedures, etc.; specialized
training in stack sampling and smoke reading.
          b.  Job Description - Conduct full-scale inspections of  major
pollution sources, investigate breakdowns of control  equipment,  advise
owners as to proper operation of equipment, handle complaints  against
industry, take opacity readings,  conduct air quality  sampling, etc.
      3.  Special Industry Inspectors
          Same requirements and job descriptions as Industrial Engineering
Inspector, but with training concentrated on a few complex processes.

10.3.2  Office Staff
      1.  Air Pollution Control Officer
          a.  Job Requirements -  Bachelor's degree in chemical or  mechanical
engineering or equivalent experience; detailed knowledge of industrial
processes and equipment, control  devices, and procedures,  etc.

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          b.  Job Description - Review applications for permits to operate
or construct, consult with applicants on procedures for applying, consult
with plant owners and operators on effective control techniques, review
reports from Field Operations, review regular source reports, etc.
      2.  Technical Aide
          a.  Job Requirements - High school graduate or equivalent, with
excellent reading and writing skills and intelligence, ability to make
independent judgements.  Basic training in combustion and industrial
processes and equipment, use of emission factors.
          b.  Job Description - Conduct preliminary review of all permit
applications, handle complete review for small source applications, code
information in application forms for computerization, record results of
sampling stations, etc.
      3.  Systems Analyst/Programmer
          a.  Job Requirements - Master's degree in Operations Research or
equivalent experience; background in air pollution control; programming
ability in language selected for data information system (probably COBOL).
          b.  Job Description - Supervise operation of data information
system; perform incremental program changes to allow generation of new
kinds of reports as their need becomes apparent; revise permit application
forms and design new forms; perform statistical analyses of available data
as necessary; etc.

      Since the Alabama DAPC is a relatively small agency, a key feature
of the staff members must be their flexibility in handling a variety
of tasks.  Thus, it is entirely conceivable that an Air Pollution Control
Officer may handle the duties of an Industrial Engineering Inspector, or
vice versa.  The job descriptions above should not, therefore, be considered
as creating rigid boundaries between separate staff positions, but instead
as defining broad areas of expertise which must be filled.

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                           11.   DATA MANAGEMENT

      The purpose of this section is to identify the functional organi-
zation of the Permit System, the data sources and information generated
and used by the functional organizations, and the structures necessary
to accommodate the data handling.

11.1  FUNCTIONAL ORGANIZATION
      There are four functional organizations involved in using the data
generated in a permit system.  They are:  (1) administrative operations,
(2) field operations, (3) engineering evaluation operations, and (A)
data management operations.  Figure 11-1 graphically depicts this organization
with sub-functions and responsibilities.  They are as follows:

                         Administrative Operations
      a.  Responsible for program and budget requirements
      b.  Responsible for permit system personnel requirements
      c.  Responsible for submitting required Federal reports
      d.  Responsible for procedures to process applications
      e.  Responsible for actual issuance of permits
      f.  Responsible for administrative details and coordination
          of legal actions
                             Field Operations
      a.  Responsible for conducting tests as prescribed by statutes
      b.  Responsible for conducting routine inspections of registrants
      c.  Responsible for conducting visitations, interviews, special
          tests and investigations, as required for exceptional
          applicants and/or registrants
                     Engineering Evaluation Operations
      a.  Responsible for technical review and analysis of
          applications
      b.  Responsible for approval or disapproval of applications
          for permits
      c.  Responsible for recommendations for legal action as
          required

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                                       PERMIT SYSTEM
                                        OPERATIONS
Administrative
  Operations
       Field
    Operations
Program/Budget
Requirements
Personnel
Requirements
Federal/State
Report Requirements
Application
Processing
Procedures
Permit Issuance
Legal Action -
Administrative
» Tests
0 Inspections
• Special  Reports
  Engineering
  Evaluation
  Operations
 Data Management
   Operations
Engineering Review
and Analysis
Approval for Permit
Issuance
Disapproval for
Permit Issuance with
Recommendations
Legal Action
Recommendations
Special Instructions
for Tests and
Inspections
• Data Organization
• Data Storage and
  Maintenance
t Information Retrieval
  and Dissemination
t Continued Data Handling
  Development

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      d.  Responsible for requesting special tests and/or
          inspections as required
                        Data Management Operations
      a.  Responsible for proper organization of data associated
          with applications and permits
      b.  Responsible for data storage and maintenance of files
          associated with applications and permits
      c.  Responsible for information retrieval  and dissemination
      d.  Responsible for continued system development of data
          handling and management techniques

11.2  DATA OPERATIONS
                              Data Sources
      The primary data sources within the permit system are applications
for Permits to Construct, applications for Permits to Operate, issued
permits, and routine tests, inspections, and source reporting require-
ments.
      Secondary data sources consist of special  reports generated for
exceptional applicant/registrant cases, engineering review evaluation,
and analysis reports, special  tests and inspections that may occur, and
reports generated due to legal actions.
                           Information Generated
      The following  data generated by primary sources are as  follows:
      •  Resume of pertinent information of the applying business
         organization
      §  Engineering data on plant equipment and processes
      •  Emission data on pollutants
      •  Schedule of plant operations
      •  Inventory of air pollution control devices
      •  Emergency episode procedures and plans
      •  List of businesses approved and disapproved for permits
      •  Test and inspection data
      •  Source periodic  reports

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      The information generated by secondary sources include the
following:
      t  Special reports on equipment, control devices and
         emissions for exceptional cases
      •  Engineering evaluations, analyses, and recommendations
         on applications requiring modifications and those which
         were denied permits.
      •  Reports on special tests and inspections
      •  Legal action information giving offense, pertinent
         dates of inquiries or hearings, and related company
         and violation information
                             Information Files
      To assure access of information to the users identified in Figure 11-1,
a central depository is necessary for all applications, issued permits,
and the generated reports related to them.   A manual system can accommo-
date the initial requirement of storing a hard copy of the application and
maintaining a simplified system of tracking the application, and its
related documents, through the permit-granting process.  However, data
generated in the permit system will be used in future air pollution
control and prevention analysis.  This will require that permit system
data be readily accessible and in a usable  form as a possible data source
input in modeling studies, comparative analysis, and control procedures
during emergency episodes.  Therefore, the  intent of the data handling
procedures set forth in this description is to identify how to begin
manual operations, yet allow the basic structural and procedural flexibility
for a transition to computerized phases of  operation.

      The organization of information generated by primary data sources
must accommodate three basic categories:  (1) applications for Permits to
Construct, (2) applications for Permits to  Operate, and (3) Registrants,
that is, a category for issued Permits to Operate.

      The information generaged by secondary data sources will be used
to update the files within the three categories previously mentioned.
The files associated within each category are shown in Figure 11-2.  A
description of each file follows:

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PERMIT TO CONSTRUCT FILES
PERMIT TO OPERATE FILES
REGISTRANTS FILES
  Application to
     Construct
    Master File
      Application To
          Operate
       Master File
     Registrants
     Master File
    Review and
     Approval
       File
         Review and
          Approval
            File
   Test/Inspection
      Schedule
        File
  Modify-Reject
       File
        Modify-Reject
            File
   Legal  Action
       File

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1.   Permit to Construct Category
    •  Application to Construct Master File
       This file maintains a hard copy of the original  application.
       All actions, until  issuance of a Permit to Construct, are
       recorded in this file to maintain a current status of the
       application.  Each  application is filed alphabetically-
       chronologically by  the name of the company and date of
       application.  Any action through the permit-granting
       process is updated  in this master file.  After issuance
       of a Permit to Construct, the application may be purged
       and stored in an inactive historical file for reference
       purposes.

    •  Review and Approval File
       This file is primarily a control device to assist the
       engineering review  board in scheduling applications for
       review.  It contains only the name of the applicant, date
       of application, and date of the scheduled review.  The
       company and date of application are supplied by  data manage-
       ment operations to  the appropriate engineering review board
       authority; the company is scheduled for review and this
       information is returned to data management for updating.
       After approval or. disapproval, the application is purged
       from the file upon  notification by the engineering review
       board to data management operations.

    •  Modify-Reject File
       This file is maintained in order to have ready access to
       the number of modifications and rejections and the reasons
       for them.  Only the applicant's name, date of application,
       and date of the review board's conclusions need appear.
       Details of the review board can be obtained from the
       Application to Construct Master File since all actions
       affecting an application update this file.  The Modify-

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       Reject File should assist in ready access of information
       in field operations when special  tests and/or inspections
       are required and, in addition, in any legal  action processes.
       The file may be purged after the applicant has resubmitted
       an application for a Permit to Construct and received approval.

2.  Permit to Operate Category
    •  Application to Operate Master File
       This file has the same relationship to the application for
       a Permit to Operate as does the application  to Construct
       Master File has to the application for a Permit to Construct.
       An application is received and a  hard copy  is maintained  in
       the Application to Operate Master File.   All actions, until
       issuance of a permit, are recorded in this file, giving a
       current status of the application.  Each application is
       filed alphabetically-chronologically by the  name of the
       company and the date of application.  Any action through
       the permit-granting process is updated in the master file.
       After issuance of a Permit to Operate, the application with
       all updates and date of permit issuance is transferred to
       the Registrants-Master File.

    •  Review and Approval File
       The file operates in conjunction with the Application to
       Operate Master File exactly as the Review and Approval File
       operates with the Application to Construct Master File
       described in the Permit to Construct Category.

    •  Modi fy-Re j ect Fi1e
       This file operates in conjunction with the Application to
       Operate Master File exactly as the Modify-Reject File  operates
       with the Application to Construct Master File described in the
       Permit to Construct Category.

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3.  Registrants
    •  Registrants Master File
       This file is created by the transfer of applications,  and
       all related information, from the application to Operate
       Master File upon issuance of a Permit to Operate.   The data
       is filed alphabetically by company name; each permit unit
       will be assigned a file number indicating site location, SIC
       number, process type, site number and a one digit code
       signifying relative impact on the air environment.   The
       Master File becomes the permanent record of sources operating
       with permits, contains periodic tests and inspection reports,
       assists in the scheduling of these tests and inspections,
       and contains all critiques, evaluations, etc., that may lead
       to legal actions due to non-compliance with regulations.
       Purging of this file would occur when a need for a new
       permit arises, e.g., change of ownership or expiration of
       the old permit, or if the source  goes out of business.

    •  Test/Inspection File
       This file contains only the name of the company due for
       testing and/or inspection, the date of issuance of a Permit
       to Operate, and the scheduled date for the test and/or
       inspection.  It is used primarily as a control device  to
       assist field operations.  Field personnel may develop
       schedules based on the date of issue obtained from the
       Registrant Master File and cross-reference the registrant
       in the Test/Inspection File by date of test and/or inspec-
       tion and the alphabetical filing of the registrants.  This
       file can be maintained by assigning a new schedule date
       after a test/inspection in the Test/Inspection File.  The
       registrant would be purged from the File only if his permit
       was revoked or expired.

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          •  Legal Action File
             This file contains only the name of the registrant and
             the fact that legal action is pending.   Details of the
             legal action can then be obtained from  the Registrant
             Master File.

11.3  AUTOMATED SYSTEM REQUIREMENTS
      The Alabama Permit System will be run on a manual basis at the onset
of operations.  However, because of the sheer bulk of the data to be
collected and stored, and the processing speed necessary when handling an
Emergency Episode, an automated information system will eventually be
placed into operation.

      This information system will require computer  software capable of
rapid updating and retrieval of information, i.e., a real-time capability.
An on-line terminal will be utilized for retrieval of specific information
requirements and for updating the status of applications throughout the
permit-gathering process.  Bulk data will  be loaded  via punched cards read
through a card reader; this stored information will  be accessible either
through the on-line terminal by specific inquiry or  by reports processed
using application programs and printed by a high-speed printer.

      The tasks required to develop and implement the permit information
system are identified in  Figure  11-3.  This  effort will  require six  informa-
tion systems specialists (full time) for twelve months.  Additional
personnel within DAPC will be involved in the development and implementation
of this system as required.

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TASKS
1. SYSTEM DEFINITION AND DESCRIPTION
A. COMPUTER SUBSYSTEM
B. DATA OPERATIONS SUBSYSTEM
II. SYSTEM REQUIREMENTS ANALYSIS
A. USER REQUIREMENTS ANALYSIS
1. INFORMATION REQUIREMENTS
ANALYSIS
2. DATA SOURCE REQUIREMENTS
ANALYSIS
3. DATA MANIPULATION REQUIRE-
MENTS ANALYSIS
B. SOFTWARE REQUIREMENTS ANALYSIS
1. INFORMATION SYSTEM REQUIREMENTS
2. EXISTING PROGRAM ANALYSIS
3. APPLICATION PROGRAM REQUIREMENTS
C. SOFTWARE SYSTEM ANALYSIS AND DESIGN
D. HARDWARE REQUIREMENTS ANALYSIS
1. COMPUTER
2. PERIPHERAL EQUIPMENT
3. TERMINAL
III. IMPLEMENTATION
A. FILE DESIGN
B. FILE TEST
C. FILE IMPLEMENTATION
D.. OPERATING PROCEDURES DEVELOPMENT
E. USER TRAINING
MONTHS
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                                APPENDIX A
                       SAMPLE PERMIT APPLICATIONS
                           AND INSTRUCTIONS
      The following sets of sample permit applications and instructions
include the following:
      •  Sample letter to equipment owners
      •  General identification form, to be included with all
         permit applications
      •  "Short form" for small fuel  combustion equipment
      •  "Long Form" for large fuel combustion equipment
      •  "Short Form" for small incinerators
      •  "Long Form" for small incinerators
      •  Form for "general processes"
      t  Form for stone quarrying operation
      •  Form for wood processing operation
      •  Form for air pollution control  devices
      t  Emergency Episode Questionnaire for key fuel  combustion sources
These forms are neither all inclusive 	 separate forms should be
designed for special process types, for instance 	  nor final  and
complete.  Filing information formats will be evolved with further
development of the data management system.  Evolution  of both  the kinds
of information asked for, and the precise manner in which it is  asked
for, will continue with further development work and with information
gained by using the Permit System.

      The application forms are to be used as follows:
      The general application form, "application for a Permit  to Construct/
Permit to Operate," will be sent to each potential  applicant along with
whatever additional specialized forms apply to him.  Thus, an  asphalt
batching plant will be sent a process form, (possibly) a storage pile
form, (possibly) some control device forms, some boiler forms  (for space
heating, at the very least), and general forms for  each.

      Each completed applicatton^general form plus specific form—will
be assigned a 12-digit file number of the following form:


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      - (2-digit political  jurisdiction number)
      - (4-digit Standard Industrial  Classification)
      - (2-digit process code)
      - (3-digit site code)
      - (1-digit "pollution significance" code depending upon
        emission potential)

      It is conceivable that a 4-  or  5-digit  site  code  may  be necessary  if
the Permit System is to include very small  pollution sources.  In any case,
the file number will uniquely identify each and every "permit unit" in
Alabama and also provide important information at a glance.  The file
number, coupled with the "type of pollutant"  box on the general  form, will
provide a means by which the computerized system can assemble various
reports for any future pollution control needs.

      The notation "required 	optional	" appears  on several of the
forms.  This refers to specialized information that shall be required from
major sources only; the DAPC officer issuing  the application form (or his
counterpart in the local agencies) shall check the appropriate space and
sign his name.

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                   Sample Letter to Owners of Equipment
Dear Sir:
      Under the laws of the State of Alabama (Act #769, General  Session,
1971 Section 18§4), operators of equipment which has the potential  to
emit dust, fumes, mist, gas, or any other contaminant into the air  must
obtain a Permit to Operate with the Alabama Division of Air Pollution
Control (DAPC).  In addition, a Permit to Construct must be obtained
from the DAPC in order to build a new facility or modify an existing
facility in any way that might affect the location, amount, or type of
its emissions of contaminants.  Since certain types and/or sizes of equip-
ment are exempt from this obligation, please check the enclosed list to
determine your eligibility.

      If you operate, intend to operate, or plan to construct, modify,
purchase, or relocate any equipment as described above, you must obtain
the proper permit application forms from the DAPC and fill them out
according to the accompanying instructions.  The DAPC has established
special units to advise operators on the proper procedures for completing
these forms; a telephone number to call is included with the instructions.

      I urgently request your complete cooperation in joining with  us to
make the air of Alabama a natural resource we may all be proud of.   We
have  earnestly attempted to make the air pollution permit system as fair
to both the industry and the people of Alabama as is possible.  We  welcome
any comments or suggestions you may have concerning how we may improve our
system to better serve Alabama.
      Thank you for your cooperation.
                                      Sincerely yours,
                                      (Signature)
                                      (Name)
                                      Director, Division of Air Pollution
                                                       Control

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 STICKER TO VALIDATE A PERMIT TO OPERATE
   (Place over "Application For ....)
           PERMIT TO OPERATE XXXX
              (equipment type)
Alabama Division of Air Pollution Control
Approved (date), Valid Until (date)
Owner 	(name)	
Equipment Address: 	
Official Signature

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                                             APPLICATION FOR A
                                   PERMIT TO CONSTRUCT/PERMIT TO OPERATE
Deviations from approved plans and specifications are not permissible without securing the formal
approval of the Alabama Division of Air Pollution Control
1.  Firm Name:
    Telephone:
2.  Present Legal Owner:
3.  Date Business Acquired:
4.  Nature of Business at this Location:
                                                Address of Premises:
                                               Address of Legal  Owner:
                                               Former Owner:
5.
6.
Responsible Person to Contact/Applicant:  	
Telephone: 	  Signature of Above:
Title:
Reason for Application:
Initial Application: 	Construct New Unit 	Modify Existing Unit	Change Owners 	
Renewal 	Change Location 	
If "Construct New Unit"  or "Modify Existing Unit" are checked,  indicate starting date of construction/
modification 	.  Indicate expected completion date	.
Indicate the year for which data applies 	.
                                        DO NOT WRITE BELOW THIS LINE
TYPES OF POLLUTANTS
Part.
SO?
NO 2
HC
CO






                                                                                        UATt RECEIVED


LOC




SITE


PROC
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bITE
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i
                                                                              Initial cneck
                                                                              Reviewed 	
                                                                              Inspected 	
                                                                                                  by

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                         INSTRUCTIONS FOR COMPLETION
                APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
PLEASE NOTE:   You may contact your regional air pollution control office
to obtain advice in filling out permit application form.
IN THE
Area Name
AREA, CALL
Telephone
Number

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      All applicable sections on the forms must be completed.   Incomplete
forms will be  returned for further action.  Please type or carefully print
all  answers.   Separate forms must be filed for each collection of equip-
ment that form a  "permit unit."  A permit unit is defined as equipment
which operates  together as a single functional unit and constitutes a
separate emission  source or operates independently from other equipment
within  a plant.  Examples of independent equipment which can be considered
as  permit units are:

      • boilers
      • metal  melting furnaces
      • galvanizing kettles
      • cookers
      • paint spray booths

In  the  case of an  equipment grouping involved in a process, the grouping
will be considered a permit unit if each separate piece of equipment is
united  to the  others by conveyor or chute or pipe or hose, provided that
no  item of the group will operate separately with product material not
common  to the  group operation.  Any questions as to what constitutes a
permit  unit may be referred to the Division of Air Pollution Control.
NOTE:   "Equipment" should be interpreted in the broadest possible way,
e.g., a storage pile is a possible source of air pollution and is con-
sidered process equipment ... and thus requires a Permit to Operate.

      If there is  information in this application that you feel is of a
confidential  nature, indicate this by lightly circling the appropriate
sections and noting their  confidential  nature.

      Sections 1 - 3 are self-explanatory.

Nature  of Business
      Describe the activity of which this equipment is a part (i.e., quarry/
rock-crushing  if the equipment is a hammermill .   For a boiler, describe
the business it is associated with—hospital, apartment house, etc.,--
rather  than "space heating.").

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Responsible Person
      Name the person who has managerial  responsibility for the operation
of this piece of equipment.  This person  may be telephoned in the event
of an air pollution emergency episode to  verify compliance with the Episode
Plan.  This person is responsible for the accuracy of the Permit Application.

Reason for Application
      Initial application indicates the first application for a Permit to
Operate by an existing facility.  New unit indicates an application for
a Permit to Construct a proposed facility.  Change on existing unit
indicates an application for a Permit to  Construct major modifications on
an existing facility.  Change o^f ownership indicates an application for
a Permit to Operate by an existing facility under new ownership.  Renewal
indicates an application to extend the present Permit to Operate for
another permit period.

      Indicate the expected starting and  completion data of any construction,
Where data from records  are  given—for instance, fuel burned per year--
indicate the year in which the data are recorded.

      NOTE:  In the portions of the permit applications that call for
      descriptions of operating procedures and/or equipment, if the
      application is for a Permit to Construct, be sure to include a
      description of construction procedures sufficiently detailed to
      allow the DAPC to determine the dust and spray emissions that
      may be caused in the construction process.

-------
1
UD
                                          APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                                                 FUEL BURNING EQUIPMENT RATED AT
                                                    LESS THAN       BTU/HR
       7.  Type of Equipment:
       8.  Fuel Usage:  Percent of total fuel used for space heating 	

             Fuel Used . Amount/Year    Heat Content    Sulfur Content (%)
                                 ?  Process heating

                                    Ash Content (%)
  Unit Cost
























       9.  Height of Stack above ground, feet:
      10.  Maximum Firing Rate (Rated Capacity):  Input 	

           	 gallons/hour oil, 	 ft /hour gas

      11.  Operating Schedule: 	hours/day, 	days/week,
                          Million BTU/hr,
Ibs/hour coal,
                              weeks/year,
           Peak Periods:
Periods of Zero Operation
      12.  Gas Cleaning or Emission Control Device: 	

           Estimated Efficiency: 	Basis: 	

           Date of Installation: 	

      13  EMERGENCY EPISODE PROCEDURES:


-------
     9  Alert:
     •  Warning:
     •  Emergency:
14.  Plans for permanent reduction  of emissions  (if  installation  of control devices or modifications of
     equipment are  contemplated,  an application  for  a  Permit  to Construct  must be submitted):

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                        INSTRUCTIONS  FOR COMPLETION
                APPLICATION FOR A PERMIT TO  OPERATE/CONSTRUCT
                      FUEL BURNING EQUIPMENT RATED LESS
                            THAN      BTU/HOUR
 7.   Type of Equipment
       Describe fully the type  of equipment  operated,  both  by  its  common
 name (e.g., spreader stoker,  pressure  type  oil  burner)  and by its
 manufacturer's model name and  number,  its date  of installation  and
 condition.   Enclose a drawing  to scale showing  its  location in  your
 facility.

 8.   Fuel Usage
       Estimate the percentages of fuel  used for space heating and
 process heating.

       Indicate the type of fuel  used,  the amount per  year, the  heat
 content in  BTU's  per unit quantity (coal  -  tons;  oil  -  gallons;
 gas - cubic feet), sulfur and  ash (for coal)  content  as a  percentage
 by  weight,  and the average cost in dollars  per  unit capacity.   If you
 do  not know the heat content  and/or sulfur  and  ash  content of the fuel
 you use, ask your local distributor.   As  a  last resort, give  the  name
 and address of the distributor.   For a Permit to Construct, estimate
 these values based on the actual fuel  suppliers you intend to use.  For
 a Permit to Operate, use the  values incurred during the last  12 months
 of  operation.  If you have reason to believe that you will be forced
 to  utilize  a lower grade fuel  mix in the  coming year, enclose a
 statement detailing the expected change and giving the reasons  for the
 change.

 9.   Height  of Stack
       Give  the height above ground level  of the stack to which  the equip-
 ment is connected.

10.   Maximum Firing Rate
       Indicate the maximun input firing rate in BTU's per  hour.   If this
 is  unknown, indicate either the input  horsepower or maximum fuel  firing
 rate.

-------
11.  Operating Schedule
       Indicate the average number of hours/day,  days/week,  and  weeks/
 year that the equipment operates.   Give the starting and closing  dates
 of peak periods of operation.   If operation is  fairly constant  over the
 complete operating period, indicate "none."  Indicate the starting  and
 closing dates of periods where the equipment is  not in operation.

12.  Gas Cleaning or Emission Control  Device
       Specify the general type of control  device installed on the equip-
 ment (settling chamber, baghouse,  etc.) and the  manufacturer's  model name
 and number.   Give the estimated control efficiency for each pollutant
 and the basis for the estimate.  Indicate  the date of installation  or  last
 major modification.

       If you take any measures for the control  of air pollution that would
 not be strictly considered a "device," enclose  a statement describing
 the measures.

13.  Emergency Episode Procedures
       A strong requirement for the protection of the health and safety
 of the people living and working in the State of Alabama is that
 operators of all potential air pollution sources be aware of the  procedures
 to be taken  during all stages  of a declared Air  Pollution Emergency.
 List here the procedures that  will be used during the three stages  of  an
 Emergency Episode.

14.  Plans for Permanent Reduction  of Emissions
       This question applies ONLY to presently operating sources  applying
 for an initial  Permit to Operate.   If the source does  not conform to
 State air pollution control regulations,  an implementation plan  for
 reducing emissions to below legal  limits  must be outlined here.   If the
 plan is judged to be acceptable by the Division of Air Pollution Control
 and if the remainder of the application is satisfactory,  a Conditional
 Permit to Operate will  be issued to the applicant which will  remain in

-------
force as long as satisfactory progress towards emission reduction is
demonstrated.  Under no circumstances shall a Conditional Permit be
granted for a period greater than one year; and under most circumstances,
a considerably shorter period will be granted.

      The plan as outlined here must briefly describe the operational
changes, installation of new control devices, fuel switches, and other
measures, and their control efficiencies which will reduce emissions
to satisfactory levels.  No product of any specific supplier of control
devices need be mentioned here UNLESS the device type described does
not normally achieve the efficiencies claimed.  In the latter case,
the applicant should supply detailed justification for such claims.

      If a facility is operated under a Conditional Permit, the applicant
is considered legally to have formally agreed to abide by the conditions
attached to the permit and, thus, is legally responsible for carrying
out those conditions.

-------
                                    APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                                          FUEL BURNING EQUIPMENT RATED AT
                                           GREATER THAN 	BTU/HOUR
 7.  Equipment Description:
 8.  Rated Capacity (in BTU/hour):
 9.  Fuel  Usage:   Percent of total  fuel  used for space heating
                                                               ?  Process heating
                                            ?  Power generation

Fuels Used




Amount/Year




Heat Content




Sulfur Content




Ash Content




Cost




10.
Stack Data:

Height above ground, feet:
     Gas Temperature at exit,  °F
     Moisture Content of exit gas,

     Basis:
     Are sampling ports available:
Inner Diameter at Exit, feet:

Gas Velocity at exit, f/s:

-------
       11
Operating Schedule:
	 hours/day,
                to
            From
            Peak  Periods:
	 days/week, _
 on:      M    T
weeks, year
 T     F     S
                         to
           W     T     F     S     S
Periods of little or no operation:
       12.   Description of Control Equipment:
                                                        to
3=-
I
           Manufacturer's Rated Efficiency:
       13.  Emissions:
                                                 Actual Measured Efficiency:
Type
Part.
so2
N02
HC
CO
Total Yearly Tons
Uncontrolled Controlled





Peak, Tons/Hr
Uncontrolled Controlled






-------
14.   Emergency Episode Procedures:

     How do you intend to comply  with  the  requirements  for  reduced  emissions  during  an  air  pollution  episode:


     •  Alert
        Warning:
     •  Emergency:
15.   Plans for permanent reduction  of emissions  (if  installation  of control  devices  or modifications  of
     equipment are contemplated,  an application  for  a  Permit  to Construct  must  be  submitted):

-------
                        INSTRUCTIONS FOR COMPLETION
               APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                        FUEL BURNING EQUIPMENT RATED
                         GREATER THAN 	BTU/HR

7.  Type of Equipment
      Describe fully the type of equipment operated, both by its common
name (e.g., spreader stoker, pressure type oil burner)  and by its
manufacturer's model name and number, its date of installation and
condition.  Enclose a drawing to scale showing its location in your facility.

      If so indicated by the DAPC, supply an assembly drawing, dimensioned
and to scale, in plan and elevation.  Show all details  including locations,
sizes and shapes of all  internal chambers, and all doors, holes, vents,
and other openings.  Show all stack details.

      If the application is for a Permit to Construct (construct new unit,
modify existing unit), include a statement describing how this construction
will be accomplished.  Specify in particular those operations which may
cause contaminants to be injected into the air, e.g., blasting and demoli-
tion, concrete mixing, spraying operations, etc.

8.  Rated Capacity
      Give the maximum input firing rate in BTU's per hour.

9.  Fuel Usage
      Estimate the percentages of fuel, by heat capacity, used for space
heating and process heating.

      Indicate the type of fuel used, the amount per year, the heat content
in BTU's per unit quantity (coal - tons; oil - gallons; gas - cubic feet),
sulfur and ash (for coal) content as a percentage by weight, and the
average cost in dollars per unit quantity.  For a Permit to Construct,
estimate these values based on the actual fuel suppliers you intend to
use.  For a Permit to Operate, use the values incurred during the last
12 months of operation.  If you have reason to believe that you will be

-------
 forced to utilize a lower grade fuel  mix in  the  coming year,  enclose  a
 statement detailing the expected change  and  giving  the reasons  for  the
 change.

10.   Stack Data
       Give the height of the stack above the ground and  the  inner diameter
 at the uppermost part (exit), in feet.   Give the temperature, velocity,  and
 moisture content of the exit gas,  and indicate the  basis  for these  figures.
 Indicate whether sampling ports for stack tests  are available.

11.   Operating Schedule
       Indicate the average number of hours per day, days  per week,  and
 weeks per year the equipment is in operation.  Indicate  the  normal  starting
 and ending times, and circle the days of the week the equipment is  in
 operation.  If there is a period when operations are increased  over the
 average, indicate the approximate starting and ending date of this  period.
 Indicate starting and ending dates for periods when operations  are  curtailed
 or stopped altogether (ignore short periods  of a week or  two, or less).

       If the schedule varies seasonally, include an additional  sheet
 showing the operating hours and days  of  the  week for each period or season.

12.   Description of Control Equipment
       Specify the general type of control device installed on the equip-
 ment (settling chamber, baghouse, electrostatic  precipitator, etc.) and
 the manufacturer's model name and number.  Indicate the  manufacturer's
 rated efficiency and actual measured efficiency  (and its  basis).  If  an
 Application for a Permit to Operate/Construct Air Pollution  Equipment for
 this control device is submitted with this application,  no further
 information is necessary.  Otherwise, enclose a  detailed  assembly drawing,
 dimensioned and to scale, in plan and elevation, of the  device.  Enclose
 a discussion of the maintenance procedures used  for the  device,  including
 a schedule of standard maintenance actions.

-------
13.  Emissions
      Indicate the estimated annual  emissions,  in tons,  of participates,
sulfur dioxide, nitrogen dioxide, hydrocarbons,  and carbon monoxide,
both before and after control.   Indicate the peak rate,  in tons  per hour,
for the same pollutants.  Give  the basis for the estimate.

14.  Emergency Episode Procedures
      A strong requirement for  the protection of the health and  safety  of
the people living and working in the State of Alabama is that operators
of all potential  air pollution  sources be aware  of the procedures  to  be
taken during all  stages of a declared Air Pollution Emergency.   List  here
the procedures that will be used during the three stages of an Emergency
Episode.

      The following information must be included:
      t  type of air pollutant
      •  amount of reduction of contaminants
      •  time involved in the reductions
      §  procedures used in achieving the reductions

15.  Plans for Permanent Reduction of Emissions
      This question applies ONLY to presently operating sources  applying
for an  initial Permit to Operate.  If the source does not conform  to  State
air pollution control regulations, an implementation plan for reducing
emissions to below legal limits must be outlined here.  If the plan is
judged to be acceptable by the  Division of Air Pollution Control and  if
the remainder of the application is satisfactory, a Conditional  Permit  to
Operate will be issued to the applicant which will remain in force as
long as satisfactory progress towards emission reduction is demonstrated.
Under no circumstances shall a  Conditional Permit be granted for a
period greater than one year; and under most circumstances, a considerably
shorter period will be granted.

-------
      The plan as outlined here must briefly describe the operational
changes, installation of new control devices, fuel  switches,  and other
measures, and their control  efficiencies which will  reduce emissions
to satisfactory levels.  No  product of any specific supplier  of control
devices need be mentioned here UNLESS the device type described does
not normally achieve the efficiencies claimed.  In  the latter case,
the applicant should supply  detailed justification  for such claims.

      If a facility is operated under a Conditional  Permit, the applicant
is considered legally to have formally agreed to abide by the conditions
attached to the permit and,  thus, is legally responsible for  carrying
out those conditons.

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ro
                                    APPLICATION  FOR PERMIT TO OPERATE/CONSTRUCT
                                         SMALL INCINERATORS  (<     LBS/HR)
     7.   Equipment  Description:

         a.   Type of  Incinerator

             Single chamber
             (without primary burner)
             Teepee
Pathological
            Others  (Describe):

          b. Manufacturer:
             Date  of  first operation:

          c.  Waste Feed Method
             Flue fed
Chute fed
 Single  chamber
 (with primary burner)

	       Open pit 	
                                                 Multiple chamber
                           Model  name and/or number:
     Continuous direct
Batch direct
          d.   Rated  Capacity =
          pounds/hour
         e.  Condition of incinerator - describe:
     8.  Operating Schedule:

        Normally operates  (or will operate) about

     9.  Type of Waste Burned/Amount:
                         hours  per day,
                              days per week,
                   weeks per year
        (Check as many as are appropriate; write in the amount burned last year, or during a normal  year if

-------
no
po
    10.
    11.
    12.
          Wood Waste
 Moist organic waste 	
 General municipal-type waste
 Liquid waste 	
 Other 	
Height of stack above ground:
   (
   (
   (
feet
tons/year)
tons/year)
tons/year)
tons/year) (type:
tons/year) (type:
a.  Pollution Control Device: None
    Simple Cyclone 	   Other	
      Settling Chamber or Bafflers
                                Afterburner
                                               (Type:
         b.  Rated efficiency =
                                           c.  Date installed:
tmergency Episode Procedures:
Describe what actions you shall take to comply with requirements for reducing emissions during
an air pollution episode?
•  Alert Stage

•  Warning Stage

»  Emergency Stage
    13.  Do you plan to install new pollution control  equipment?    Yes
                                                                         HO
         If yes,
             What kind?  	

-------
                                        APPLICATION  FOR PERMIT TO OPERATE/CONSTRUCT
                                                       INCINERATORS
                                                (INCLUDE TEEPEE BURNERS)
       7.   Equipment  Description:
           Type: 	Rated Capacity: 	Auxiliary Burners? 	
           Location:  	Waste Feed Method: 	Manufacturer: 	
           Model No.: 	Date of  Installation:	Condition: 	
       8.   Operating  Schedule:
           	hours/day, 	days/week, 	weeks/year
           From  	to	onMTWT      FSS
^          Peak  Periods: 	to 	          Periods of little or no Operation: 	to
ro
           Moisture Content of exit gas, % 	     Basis: 	
           Are sampling  ports available? 	     Describe:
       9.   Type  of  Waste  Burned:

      10.   Amount of waste burned per peak day of operation: 	, per year: 	
      11.   Auxiliary Burners:
           Capacity: 	 Fuel Type 	     	  Amount/Year
      12.   Stack Data:
           Height above ground, feet: 	      Inner Diameter at exit, feet: 	
           Required: 	 Optional 	

-------
      13.   Description  of Gas  Cleaning  or  Emission  Control  Device:
           Required:
      14.   Emissions
Optional
Manufacturer's Rated Efficiency
Actual Measured Efficiency 	
Date of Installation 	
Model Name and Number
ro


Type
Part.
so2
N02
HC
CO
Required Optional

AMOUNT
Total Yearly Tons
Uncontrolled Controlled










Peak, Tons/Hour
Uncontrolled Controlled











-------
ro
tn
       15.  Emergency Episode Procedures:


            How do you intend to comply with the requirements for reduced emissions during an air pollution episode:


            t  Alert:




            t  Warning:




            t  Emergency:





       16.  Plans for permanent reduction  of emissions (if installation of control  devices or modifications of
            equipment are contemplated, an application for a Permit to Construct must be submitted):

-------
                        INSTRUCTIONS TO COMPLETE
              APPLICATION FOR PERMIT TO CONSTRUCT/OPERATE
                             INCINERATORS
                      (INCLUDING TEEPEE BURNERS)

7.  Equipment Description
      Indicate the general  type of incinerator (single chamber,  teepee,
etc.).  Indicate the rated capacity of the unit in pounds per hour.
Give the location of any auxiliary burners.   Indicate the waste  feed
method (flue fed, chute fed, continuous direct, batch direct).   Give
the manufacturer's name, his model name and number.  Indicate the date
of installation and present condition of the unit.  Enclose a diagram
indicating the unit's location on the premises and its relation  to
surrounding roads and lots.  If the unit is  larger than 	 pounds/
hour capacity, include an assembly drawing,  dimensioned and to scale,
in plan and elevation, of the unit and stack, and. if the aoolication
is for a Permit to Construct  (construct new unit, modify existing unit),
include a statement describing how this construction will be accomplished.
Specify in particular those operations which may cause contaminants  to be
injected into the air, e.g., blasting and demolition, concrete mixing,
spraying operations, etc.

8.  Operating Schedule
      Indicate the average number of hours per day, days per week, and
weeks per year the equipment is in operation.  Indicate the normal
starting and ending times,  and circle the days of the week the equipment
is in operation.  If there is a period when operations are increased over
the average, indicate the approximate starting and ending date of this
period.  Indicate starting and ending dates for periods when operations
are curtailed or stopped altogether (ignore short periods of a week  or
two, or less).

      If the schedule varies seasonally, include an additional  sheet showing
the operating hours and days of the week for each period or season.

9.  Type of Waste Burned
      Indicate the major type of waste burned in the unit.  If a mix is
burned, indicate different types and percentages (if Permit to Construct,
estimate).

-------
10.   Amount of Waste
       Indicate amounts burned on a peak day and per year (estimate  if
 Permit to Construct, otherwise use records  from last 12  months).

11.   Auxiliary Burners
       Indicate the total  rated capacity, in BTU/hour,  and fuel  burned per
 year, or any auxiliary burners.

12.   Stack Data
       Give the height of the stack above ground level  and the inner
 diameter at the top (exit), in feet.   If required,  indicate the gas
 temperature (degrees Fahrenheit), velocity  (feet per second), and moisture
 content (%) at the exit,  and give the basis for  tnese data.   Describe any
 stack sampling ports available.

13.   Description of Gas Cleaning or Emission Control Device
       Indicate the general  type of control  device (settling chamber,
 cyclone, iruilticyclone, etc.).  Give the manufacturer's rated efficiency
 and, if required, the actual efficiency.  Indicate  the date of installa-
 tion and manufacturer, model name, and number.   If  the incinerator  has
 a rated capacity greater than 	pounds  per  hour, include a detailed
 assembly drawing, dimensioned and to  scale, in  plan and  elevation,  of
 the control device.  Enclose a discussion of the maintenance procedures
 used for the device, including a schedule of standard maintenance items.
 (The assembly drawing and maintenance discussion may be  omitted if  an
 Application for a Permit to Operate/Construct an Emission Control Device
 is  filed simultaneously with this application.)

 14.  Emissions
       Indicate the estimated annual emissions,  in tons,  of particulates,
 sulfur dioxide, nitrogen dioxide, hydrocarbons, and carbon monoxide both
 before and after control.  Indicate the peak rate,  in tons per hour,  for
 the same pollutants.  Give the basis  for the estimates.

-------
15.  Emergency Episode Procedures
       A strong requirement for the protection of the health  and  safety
 of the people living and working in the State of Alabama  is  that operators
 of all potential  air pollution sources  be aware of the  procedures to  be
 taken during all  stages of a declared Air Pollution Emergency.   List  here
 the procedures that will be used during the three stages  of  an  Emergency
 Episode.

       The following information must be included:
       •  type of air pollutant
       •  amount of reduction of contaminants
       •  time involved in the reductions
       •  procedures used in achieving the reductions

16.  Plans for Permanent Reduction of Emissions
       This question applies ONLY to presently operating sources  applying
 for an initial Permit to Operate.  If the sources  do   not conform to State
 air pollution control regulations, an implementation plan for reducing
 emissions to below legal limits must be outlined here.   If the plan is
 judged to be acceptable by the Division of Air Pollution Control  and if
 the remainder of the application is satisfactory,  a Conditional  Permit to
 Operate will be issued to the applicant which will  remain in force as long
 as satisfactory progress towards emission reduction is  demonstrated.  Under
 no circumstances shall a Conditional Permit be granted  for a period greater
 than one year; and under most circumstances, a considerably shorter period
 will be granted.

       The plan as outlined here must briefly describe the operational
 changes, installation of new control devices, fuel  switches, and other
 measures, and their control efficiencies which will reduce emissions to
 satisfactory levels.  No product of any specific supplier of control
 devices need be mentioned here UNLESS the device type described does not
 normally achieve the efficiencies claimed.  In the latter case, the
 applicant should supply detailed justification for such claims.

-------
      If a facility is operated under a Conditional  Permit, the applicant
is considered legally to have formally agreed to abide by the conditions
attached to the permit and, thus, is legally responsible for carrying
out those conditions.

-------
        7.  Type of Equipment:
                                              APPLICATION FOR A PERMIT TO OPERATE
                                                    OR PERMIT TO CONSTRUCT
                                                       PROCESS EQUIPMENT
        8.  Organic solvents used
or produced
by this installation:
CO
O

Type




Quantity/Year




Used or Produced




        9.  Process Fuels:
Type



Quantity/Year



-------
      10.  Materials Input (process rate):
OJ
Type



Quantity/Year



Peak Rate (per hour)



      11.  Products Produced:
Type



Quantity/Year



Peak Rate (per hour)



      12.  Description of Gas Cleaning or Emission Control Device:
           Required
Optional
   Manufacturer's  Rated Efficiency
   Actual  Measured Efficiency 	
   Date of Installation 	
   Model  Name and  Number
      13.
Operating Schedule: 	
From	to 	on:
Peak Periods:
         _ hours/day,
             M     T
          to
	days/week,  	weeks/year
 W     T     F      S     S
       Periods  of little or no Operation

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OJ
ro
      14.   Stack  Data:
           Height above  ground,  feet: 	
           Required 	Optional
           Moisture Content  of Exit  Gas,
           Are  sampling  ports  available?

      15.   Emissions  Data:
                             Inner Diameter at exit, feet
                                             No stack
                      Gas temperature at exit, °F 	Gas velocity at exit,f/s
                                                 Basis:
                  Describe:
Type
                             Part.
                             SO,
                             NO,
                             HC
                             CO
                                                            Required
                                                               Optional
                                                                                AMOUNT
    Total Yearly Tons
Uncontrolled   Controlled
     Peak, Tons/hour
Uncontrolled   Controlled

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      16.   Emergency  Episode  Procedures:


           How do you intend  to  comply with  the  requirements  for  reduced emissions during an air pollution  episode?


           •  Alert:





           •  Warning:





           •  Emergency:
      17.   Plans  for permanent  reduction  of  emissions  (if  installation of control devices or modifications  of

•f          equipment are  contemplated, an application  for  a Permit to Construct must be submitted):
GO
GO

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                         INSTRUCTIONS TO COMPLETE
              APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                            PROCESS EQUIPMENT

      If the process equipment is in the following categories,  this form
is not the proper application for a permit.   Consult the Alabama Division
of Air Pollution Control for the proper forms.

      •  Manufacture of organic solvents
      •      (To be filled
      0                in by the
      •                      DAPC)

7.  Type of Equipment/Process
      Describe each process to be carried out in the equipment  and the
function of the equipment itself in the process.  In particular, care-
fully describe all stages in the process where  the discharge of any
materials might contribute to air pollution.  Use additional sheets where
necessary.  Include a flow diagram of the process indicating equipment
capacities.

      Include a drawing, to scale, showing the  location of the  equipment
in the facility.

      Give the manufacturer's name, model name, and number of each equip-
ment item in the "permit unit."  Indicate date  of installation  and condition
of equipment.

      If so indicated by the DAPC, include an assembly drawing, dimensioned
and to scale, in plan and elevation of the equipment.

      If the application is for a Permit to Construct (construct new unit;
modify existing unit), include a statement describing how this  construction
will be accomplished.  Specify in particular those operations which may
cause contaminants to be injected into the air, e.g.,  blasting  and
demolition, concrete mixing, spray operations,  etc.

-------
 8.  Organic Solvents Used
       Specify the chemical nature of all  solvents used in or produced by
 the equipment in excess of 50 gallons per year.   Specify the quantity per
 year.  If more than 50 gallons are used or produced, a special  form for
 regulating users/producers of solvents must be completed.

 9.  Process Fuels
       Indicate types and quantities of fuels used for direct heating or
 as a process charge in this equipment.  If this  form is for a Permit to
 Operate, use data from the last consecutive 12 months'  period.   Otherwise,
 estimate usage.

10.  Materials Input
       Specify the type of materials input to this equipment, the total
 quantity per year, and the peak hourly rate.

11.  Products Produced
       Specify the type of all materials or products which are produced
 by this equipment, the total  quantity per year,  and the peak hourly
 rate.  If the units selected may be ambiguous, supply a conversion factor
 (e.g., 10,000,000 bricks per year, 6.5 pounds per brick).

12.  Description of Gas Cleaning or Emission Control Device
       Specify the general type of control  device attached to this equipment.
 Indicate the manufacturer's rated efficiency, his name, and model name  and
 number.  If required, indicate the actual  measured efficiency of the
 device(s).  Indicate the date of installation and the condition of the
 device.  If an application for a Permit to Construct/Operate Air Pollution
 Control Equipment is submitted along with this application, no further
 information is required.  Otherwise, if so indicated by the DAPC, submit
 an assembly drawing of the device and a discussion and schedule of the
 maintenance procedures utilized.

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                                                 APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                                                           STONE QUARRYING OPERATION
                 This application is divided into two parts:  quarrying and rock processing,
                 fill out additional forms; CHECK INSTRUCTIONS CAREFULLY.
                                                                 A.   QUARRYING
                 7.  Description of Operation:
                                                                         It may be necessary to
GO
en
                 8.
                 9.
Raw Material  Produced:   Type of Rock
Maximum One Day's Production 	
       Production
tons/year
How much raw material  is stored at one time?
Covered? 	   If yes, describe:
tons
 tons  Is it wetted down?
                10.  Operating Schedule:	hours/day,	days/week,  	weeks/year
                     Peak Period	to	Periods  of little or no  operation
                11.  Dust control procedures used now:  	
                                                                                   to

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       If more than one device and/or more  than  one  piece  of  equipment  are
 involved, indicate in (7)  which equipment  is  attached  to  each  device.

13.   Operating Schedule
       Indicate the average number of hours per  day,  days  per week,  and
 weeks per year the equipment is in operation.   Indicate the  normal  starting
 and ending times,  and circle the days of the  week the  equipment  is  in
 operation.  If there is a  period when operations are increased over the
 average, indicate  the approximate starting and  ending  date of  this  period.
 Indicate starting  and ending dates for periods  when  operations are  curtailed
 or stopped altogether (ignore short periods of  a week  or  two,  or less).

       If the schedule varies seasonally, include an  additional sheet
 showing the operating hours and days of the week for each period or season.

14.   Stack Data
       If there is  no stack, check the appropriate line.   Otherwise,
 indicate the height above  ground level and the  inner diameter  at the top
 (exit), in feet.   If required, indicate the gas temperature  (°F), velocity
 (feet/second) and  moisture content (%) at  the exit,  and give the basis
 for these data.  Describe  any sampling ports  on the  stack.

       If the permit unit contains more than one stack, include an additional
 sheet describing each stack separately. Indicate which equipment units are
 connected to each  stack in a Flow Chart for question (7).

15.   Emission Data
       Indicate the estimated annual emissions,  in tons, of particulates,
 sulfur dioxide,  nitrogen dioxide, hydrocarbons, and  carbon monoxide, both
 before and after control.   Indicate the peak  rate,  in  tons per hour, for
 the same pollutants.  Give the basis for the  estimates.

16.   Emergency Episode Procedures
       A strong requirement for the protection of the health  and  safety of
 the people living  and working in the State of Alabama  is  that  operators

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 of all potential air pollution sources be aware of the procedures to be
 taken during all stages of a declared Air Pollution Emergency.   List here
 the procedures that will be used during the three stages of an  Emergency
 Episode.

       The following information must be included:
       •  type of air pollutant
       •  amount of reduction of contaminants
       •  time involved in the reductions
       •  procedures used in achieving the reductions.

17.   Plans for Permanent Reduction of Emissions
       This question applies ONLY to presently operating sources  applying for
 an initial Permit to Operate.   If the source does not conform to State air
 pollution control regulations, an implementation plan for reducing emissions
 to below legal  limits must be  outlined here.  If the plan is  judged to be
 acceptable by the Division of  Air Pollution Control  and if the remainder of
 the application is satisfactory, a Conditional  Permit to Operate will  be
 issued to the applicant which  will remain in force as long as satisfactory
 progress towards emission reduction is demonstrated.  Under no circumstances
 shall a Conditional Permit be  granted for a period greater than  one year;
 and under most circumstances,  a considerably shorter period will be granted.

       The plan as outlined here must briefly describe the operational  changes,
 installation of new control devices, fuel switches,  and other measures, and
 their control efficiencies which will  reduce emissions to satisfactory levels.
 No product of any specific supplier of control  devices need me mentioned here
 UNLESS the device type described does not normally  achieve the efficiencies
 claimed.  In the latter case,  the applicant should supply detailed justification
 for such claims.

       If a facility is operated under a Conditional  Permit, the  applicant is
 considered legally to have formally agreed to abide  by the conditions
 attached to the permit and, thus, is legally responsible for  carrying  out
 those conditions.


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                                     B.  ROCK PROCESSING (Number
13.   Equipment Description:
14.   Production and  Emissions:
Type of Operation
a.
b.
c.
d.
e.
f.
Equipment






Material In
Tons/Year






Product Out
Tons/Year






Product Size
Diameter, Inches






Control Device
Type






Efficiency
°i
fa
a.
b.
c.
d.
e.
f.
Emissions
Tons/Year






Stack Height
Feet






- Stack Dia.
Feet






Exit Velocity
F/S






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i>

o
             15,
List storage piles,  size of rock stored,  and  average amount in pile.  For each pile, note
whether the rock is  wetted down or covered.
a.
b.
c.
inches ,
inches ,
inches ,
tons ,
tons ,
tons ,
wetted?
wetted?
wetted?
covered?
covered?
covered?
             16.  Any  additional process information not described above:
             17.  Operating Schedule:

                 	 hours/day, 	
                  Peak  Period
                       days/week,

                            to
                  Periods of  little or no operation
weeks/year

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18.   Emergency Episode Procedures:

     How do you intend to  comply  with  the  requirements for reduced emissions during an air pollution
     episode?
     •  Alert:
     •  Warning:
     •  Emergency:
19.   Plans for permanent  reduction  of  dust.   (If  installation of control devices or modifications
     of equipment are  contemplated,  an application for a Permit to Construct must be submitted
     and approved before  construction  begins):

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                      INSTRUCTIONS FOR COMPLLTION
             APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                       STONE QUARRYING OPERATION
     The applicant should fill out the Quarrying application for each
 location where blasting, drilling , etc., of rock is carried out.  Part B,
 Rock Processing, should be filled out for each size reduction system,
 starting with the discharge from storage (or with the charging hopper
 or grizzly) and ending with storage or packaging.  If there are two
 or more systems in parallel, each requires a separate Rock Processing
 form.  Fill out an Application for Permit to Operate/Construct Air
 Pollution Control Equipment for each control device.

 A.  QUARRYING
    7.  Description of Operation
        Describe how the rock is quarried and stored.  Note blasting
 and drilling operations, use of machinery, etc.  Be brief, but be
 sure to cover all aspects of the operation which affect the production
 of dust.

    8.  Raw Material
        Indicate the kind of rock quarried and the total amount produced
in a year.  Use data from the past 12 months if the quarry was in opera-
tion  then,  if  the  production shown  is  for  some  other year,  indicate the year
in parenthesis.  If the production shown is not representative of expected
production in the near future -- i.e., if production is going to be
expanded or curtailed, attach a statement to this application  indicating
the expected change in production.

        Indicate the maximum number (approximately) of tons of rock
produced in one day during  the production year used for data.

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    9.  Storage Piles
        How much rock is stored in piles (or otherwise)  at  any  one
time?  Is the rock wetted down or covered to prevent dust?   If  the
rock is trucked to a separate storage area removed from  the quarry
site, a separate Storage Pile application should be filled  out.

   10.  Operating Schedule
        Indicate the average number of hours per day,  days  per  week,
and weeks per year the quarry is in actual operation.   If there is
a period when operations are increased over the average, indicate the
approximate starting and ending date of this period.   Indicate  starting
and ending dates for periods when operations are curtailed  or stopped
altogether (ignore very short periods).

   11.  Dust Control Procedures
        Describe any procedures presently used to curtail  dust  at  the
s i te.

   12.  Dust Reduction Plans
        Indicate your plans for further reduction of dust  for future
operation of the quarry.  The staff of your local  air pollution control
agency and/or the Alabama Division of Air Pollution Control  will assist
you in formulating such plans.
B.  ROCK PROCESSING
   13.  Equipment Description
        Describe each piece of equipment used in the operation.   Include
a flow diagram showing how the rock is processed, which equipment belongs
where, etc.  For all equipment, indicate the generally recognized name,

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 manufacturer, model  name and  number, and year of installation or
 manufacture.  Include a drawing showing where each piece of equipment
 is  located  on the  site.  Use  separate sheets when necessary.

    14.  Types of Rock Crushing Operations
        List each  type of rock crushing operation -- primary, secondary,
and tertiary crushing,  fines  milling, and  recrushing  and screening --
and the associated  equipment.   (If these operation names are  unfamiliar
to you, simply  list the  equipment.)   Indicate  the input and output to
the equipment and  the average size of the  product from this operation
(even if it is  only an  intermediate product.)  Note  any control devices,
and their  efficiencies,  attached  to the equipment and indicate, if known,
the annual emissions and  exit velocity of  the  exhaust.  Indicate  the
stack height and diameter  in  the  appropriate columns.  (If there  is no
stack, indicate  "none."   If  there  is  an exhaust, write "exh"  and  the
height and diameter in  place  of the stack  data.)

     15.  Storage Piles
         How much rock,  either as  final or intermediate product,  is
 stored in piles (or otherwise) at any  one time?   Is  the rock wetted
 down or covered to suppress  dust?  If  the rock  is  trucked  to a separate
 site for storage,  a Storage Pile application  should be filled out.

     16.  Other Information
         Any processing information that  is not  covered by  any of the
 categories above should be described here.

     17.  Operating Schedule
          Indicate the average number of hours  per  day, days  per week,
 and weeks per year the quarry is in actual operation.   If  there  is
 a  period when operations are increased over the average,  indicate the

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approximate starting and ending date of this period.   Indicate starting
and ending dates for periods when operations are curtailed or stopped
altogether (ignore very short periods).

   18.  Emergency Episode Procedures
        A strong requirement for the protection of the health and
safety of the people living and working in the State  of Alabama is
that operators of all  potential air pollution sources be aware of  the
procedures to be taken during all stages of a declared Air Pollution
Emergency.  List here the procedures that will be used during the
three stages of an Emergency Episode.

   19.  Dust Reduction Plans
        Outline the operational changes or installation of new control
devices planned in order to reduce dust emissions to  satisfactory  levels.
Estimate the efficiency of these changes or devices.   No specific  product
of any specific supplier need be mentioned here UNLESS the device-type
described does not normally achieve the efficiencies  claimed.  In  the
latter case, the applicant should supply a justification for such
claims.

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                                     APPLICATION FOR PERMIT TO OPERATE/CONSTRUCT
                                             WOOD PROCESSING OPERATION
                               (Sawmills, Planer Mills, Veneer Mills, Plywood Mills)

    This application is divided into three parts - Wood Processing, Boilers and Furnaces, and Waste
    Disposal.  Fill out all three parts.

                                                A.  WOOD PROCESSING

    7a.  Type of Mill: (Check one only)

         Sawmill 	     Veneer Mill 	     Planer Mill 	     Plywood Mill 	

    7b.  Equipment Description:
cr>

    8.  Operating Schedule:
              hours/day          _ days/week          _ weeks/year
        Peak Periods _ to _     Periods of Little or No Operation _ to

    9.  Production/Input:

        •  SAWMILL

           Annual production = _ thousands board feet green lumber

           Maximum daily production = _ thousands board feet green lumber


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     t  PLANER MILL
        Annual intake = 	 thousand board  feet  lumber
        Maximum daily intake =  	 thousand board  feet  lumber
        	% hardwood                   	%  softwood
     §  VENEER AND PLYWOOD MILLS
        Annual intake = 	 thousand board  feet, log  scale,  Doyle  rule
        Maximum daily intake =  	 thousand board  feet,  log  scale,  Doyle  rule
        	% hardwood                  	% softwood
10.   Wood Was Produced:
     (Estimate total  wood waste produced at  this site  annually.)

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I
.£>
CO
        11.  Dust Control Devices  and  Procedures:

             •  DEVICES
Type




Attached To




Manufacturer




Model Name
and Number




Date
Installed




Efficiency
01
h




Basis




Stack Height




Emissions
Tons/Year




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           •  PROCEDURES

      12.  Emergency Episode Procedures:

           How do you intend to comply with the requirements for reduced emissions  during  an air pollution
           episode:

           •  Alert
              Warning
I
>c          •  Emergency
      13.  Plans for further reduction of emissions ( if installation of control  devices  or modifications  of
           equipment are contemplated, an application for a Permit to Construct must be submitted and approved
           before construction or installation):

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                                              B.  BOILERS AND FURNACES



      (Use this form only if major fuel used is wood waste -- otherwise, fill out standard boiler form.)





      14.  Equipment Description:



          Boiler Type: 	  Manufacturer's Name, Model Name & Number:	
          Date of Installation:	  Base diameter, ft: 	     Top diameter, ft:



          Rated Capacity (maximum firing rate):  Input 	Million BTU/Hr



                  or_  	pounds of wood waste/hour


                  0£  	input boiler horsepower



?*         % Excess air used in firing 	
en                                   J 	
O

          Type overfire:        tangential 	       or        radial 	 (check one)



          Method of charge:     bulldozer	     conveyor	     or   other	




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3=»
I
cn
      15.   Fuel  Use:
           a.  Wood Waste
              t Sawdust/Chips/Shavings
              • Bark	tons/year 
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I
cn
        19.   Emergency  Episode  Procedures:

             How do you intend  to  comply with  the requirements for reduced emissions during an air
             pollution  episode?

             •   Alert
             •   Warning
             •   Emergency
        20.   Plans  for  reduction of emissions  (if installation of control devices or modifications of
             equipment  are  planned, an application for a Permit to Construct must be approved before
             construction begins):

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                                            C.   WASTE DISPOSAL
21.  Method of Disposal (Check one or more)
     a.  Open Pit Burning          	
     b.  Off-Site Disposal         	
     c.  Incinerator               	
     d.  TeePee Burner
         (conical metal burner)    	
     •  If c or d are checked, fill  out Form	,  Application for  Permit  to  Operate/Construct
        Incinerators.  Also, answer question 22.
     •  If b is checked, indicate type of disposal  -*•  landfille,  municipal  incinerator,  etc.  --  and  site:
     •  If a is checked, complete the remainder of the questionnaire.
22.  Waste Burned;
    a.  Sawdust	tons/year Cm 	percent of total  produced  in  (A.  WOOD  PROCESSING)
    b.  Chips/Shavings 	 tons/year OR	percent of total  produced  in  (A. WOOD PROCESSING)
    c.  Bark 	 tons/year OR_	 percent of total  produced  in  (A.  WOOD PROCESSING)

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I
en
      23.   Emergency  Episode Procedures:

           How  do you  intend to comply with the requirements for reduced emissions during an air pollution
           episode?

           •  Alert
           t  Warning
          t   Emergency
      24.  Plans for  reduction of emissions (if plans include construction of an incinerator or teepee burner,
          an application for a Permit to Construct must be approved before construction or installation
          can begin):

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                         INSTRUCTIONS TO COMPLETE
                APPLICATION FOR PERMIT TO OPERATE/CONSTRUCT
                         WOOD PROCESSING OPERATION
     Fill out all three sections of the questionnaire.   Any mill  that has
more than one "process" -- sawmill, planer mill,  etc.  -- must fill  out a
separate Wood Processing section for each process.   Fill out a separate
Section B. - Boiler and Furnaces for each boiler  or furnace operated.   Boilers
of a capacity greater than 	 tons of wood waste per hour should file
Form	, Application for a Permit to Operate/Construct Fuel  Burning
Equipment Greater than 	 BTU/Hr.

A.  WOOD PROCESSING
    7a.  Type of Mill
         Check the appropriate mill type,  if the site contains more than
one sawmill, planer mill, etc., separate forms should  be filed.

    7b.  Equipment Description
         List and describe each piece of equipment  used in  each mill.
Include a flow diagram showing how the wood is processed, which equipment
belongs where, etc., for all major equipment, indicate  the  generally
recognized name, manufacturer, model name and number,  and year of installa-
tion.  Include a drawing showing where each piece of equipment is located
on the site.  Use separate sheets where necessary.

    8.  Operating Schedule
        Indicate the average number of hours  per  day,  days  per week,  and
weeks per year the mill is in actual operation.   If there is a period
when operations are increased over the average, indicate the approximate
starting and ending date of this period.  Indicate  starting and ending
dates for periods when operations are curtailed or  stopped  altogether
(ignore periods of two weeks or less).

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    9.  Production/Input
        Indicate either the production or intake,  as  called for,  of
lumber on an annual and maximum daily basis.   For  a sawmill,  indicate
the average diameter of logs processed.   Indicate  the percentage  of
hardwood and softwood used (e.g., if only hardwood is processed,  indicate
100 and 0 percent).

   10.  Wood Waste Produced
        If estimate is based on some conversion factor rather than  from
actual weighing, indicate the assumptions used.

   11.  Dust Control Devices and Procedures
        List the general types of control devices  used,  the equipment
to which they are attached (refer to 7b), and the  device manufacturer,
model name and number, date installed, and efficiency.   Indicate  the
basis for the efficiency estimate -- i.e., stack test,  manufacturer's
rating, or other means.  Indicate the stack  height and,  if  known,
the dust emissions per year.

        Describe any dust control procedures  you use  at the mill.

   12.  Emergency Episode Procedures
        A strong requirement for the protection of the health and safety
of the people living and working in the State of Alabama is that  operators
of potential air pollution sources be aware  of the procedures to  be taken
during all stages of a declared Air Pollution Emergency.  List here the
procedures that will be used during the three stages  of an  Emergency
Episode.

   13.  Dust Reduction Plans
        Outline the operational changes or installation of new control
devices planned in order to  reduce dust emissions  to satisfactory  levels.
Estimate the efficiency of these changes or devices.   No specific product
of any specific supplier need be mentioned here UNLESS the device-type
described does not normally achieve the efficiencies  claimed.   In the
latter case, the applicant should supply a justification for such claims.


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B.  BOILERS AND FURNACES
    14.  Equipment Description
         Give the information called for.   Enclose a  drawing  showing  the
location of the boiler on the site (or show the boiler on  the drawing
included for 7b).  If you need any help with this  section  (or for  any
section), contact either your local  air pollution  control  agency or
else the Alabama Division of Air Pollution Control.

    15.  Fuel Use
         Indicate the amount of wood waste burned  in  the boiler annually.
If this figure is unknown, estimate the percent of the total  wood  waste
produced in the wood processing that is used in this  boiler.   List any
auxiliary fuels used, their amounts, heat  contents, and sulfur and ash
contents.

    16.  Operating Schedule
         Indicate the average number of hours  per  day, days per week, and
weeks per year the mill is in actual operation.  If there  is  a period
when operations are increased over the average, indicate the  approximate
starting and end date of this period.   Indicate starting and  ending dates
for periods when operations are curtailed  or stopped  altogether (ignore
periods of two weeks or less).

    17.  Stack Height

    18.  Emission Control Device
         Indicate the general type of control  device  used  --  scrubber,
cyclone, etc. -- its estimated efficiency, and the basis for  the estimate.
Indicate the date the device was installed, and the manufacturer's name,
model name, and number.

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    19.  Emergency Episode Procedure
         A strong requirement for the protection of the health  and  safety
of people living and working in the State of Alabama is that  operators  of
all potential air pollution sources be aware of the procedures  to be  taken
during all stages of a declared Air Pollution Emergency.   List  here the
procedures that will be used during the three stages of an Emergency
Episode.

    20.  Plans for Reduction of Emissions
         Outline the operational changes, installation  of  new control
devices, or equipment modifications planned in order to reduce  emissions
of air pollutants.  Estimate the efficiency of these changes  or devices.

C.  WASTE DISPOSAL
    21.  Method of Disposal
         Check those disposal methods used.  For off-site  disposal, indicate
the type of disposal and the site.   You do not have to  complete the remainder
of the questionnaire if all wastes  are disposed of off  site.   Note: include
on-site landfill in this category.

    22.  Waste Burned
         Either estimate the amounts of waste burned, for  each  category,
per year or else give the percent of all waste produced in the  processing
operation disposed of by burning (open pit, incinerator, or teepee  burner).

    23-  Emergency Episode Procedures
         A strong requirement for the protection of the health  and  safety
of the people living and working in the State of Alabama is that operators
of all potential air pollution sources be aware of the  procedures to  be taken
during all stages of a declared Air Pollution Emergency.   List  here the
procedures that will be used during the three stages of an Emergency
Episode.

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    24.  Plans for Reduction of Emissions
         Outline the operational  changes,  installation of new control
devices, or equipment modifications planned in order to reduce emissions
of air pollutants.  Estimate the efficiency of these changes  or devices.

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                                   APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                                          BULK STORAGE OF PETROLEUM PRODUCTS
          Equipment  Description:  above 	or below	ground
          Fixed 	or  floating 	roof
          Paint color of  outside walls 	(if exposed)
          Storage  capacity,  1000 gallons 	        Diameter, feet _
          Product  Stored: 	
          Vapor pressure  	
          Average  temperature, °F 	
          Throughput,  1000 gallons/day 	
          Loading  Procedure:
o     9.  Average wind  velocity of area where facility is located, mph 	 (if exposed)
     10.  Working Schedule:
         Hours  facility  is usually loaded/unloaded	 to 	
     —   Days of week  facility is usually loaded/unloaded (circle)
          S          M         T          W          T          F           S

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     12.  Emergency Episode Procedures:


          How do you intend to comply with the requirements for reduced emissions  during  an air
          pollution emergency:

          •  Alert:
          t  Warning:
          t  Emergency:
?°    13.  Plans for permanent reduction of emissions (if installation of control  devices  or modifications  of
Hi         equipment are contemplated, an application for a Permit to Construct must be submitted and approved
          before construction begins):

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                         INSTRUCTIONS FOR COMPLETION
                APPLICATION FOR A PERMIT TO OPERATE/CONSTRUCT
                      BULK STORAGE OF PETROLEUM PRODUCTS
     A separate application form should be filled out for every tank  with
     over	gallons storage capacity.
 7.   Equipment Description
       Give the data asked for.  Include with  the permit application  a
 schematic diagram of the tank showing all  construction details:   label  all
 significant dimensions.

 8.   Product Stored
       Give the type of produce stored, both by its  common name—gasoline,
 crude oil, etc.--and its chemical composition.  Indicate the vapor
 pressure and average temperature of the product in  the tank, and  give  the
 throughput in 1000's gallons per day.  Describe the loading procedure,
 i.e., connected directly to pipeline, etc.

 9.   Average Wind Velocity
       If the tank is above the ground and exposed,  indicate the average
 wind velocity in the area.

10.   Working Schedule
       Unless the loading schedule is random,  indicate the normal  schedule
 (starting and finishing time) for a working day.  Indicate days of the
 week the tank is normally loaded or unloaded.

11.   Emission Control
       Specify the type of control  device on the tank and give the manu-
 facturer's name, model name and number.   Indicate the date installed and
 efficiency (actual and rated, if both are known).  Indicate any special
 procedures taken to minimize vapor loss.

12.  Emergency Episode Procedures
       A strong requirement for the protection of the health and safety of
 the people living and working in the State of Alabama is that operators  of
 all potential air pollution sources be aware of the procedures to be taken
 during all stages of a declared Air Pollution Emergency.  List here the
 procedures that will be used during the three stages of an Emergency
 Episode.

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1
er>
GO
                                    APPLICATION  FOR PERMIT TO OPERATE/CONSTRUCT
                                          AIR POLLUTION CONTROL EQUIPMENT
      7.   Description  of  Control  Equipment:
          Manufacturer: 	 Model Name & Number  :	
          Ins
          Installation  Date: 	 Manufacturer's Rated Efficiency:


          Condition of  Equipment: 	

          Required. 	    Optional: _____        Actual Measured Efficiency; 	


      8.   Type of  equipment  to which control equipment is attached?
      9.   Operating Conditions:
          a.  Gas flow  rate: 	ACFM at	°F and 	 inches W. G. pressure

          b.  Inlet pressure: 	         Outlet pressure: 	

          c.  Moisture  content of  gas: 	volume percent    Dry bulk temperature	°F    Wet bulb temperature

          d.  If scrubber,   Inlet gas temperature 	°F

                           Outlet gas temperature	°F


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         e.  Gas Dust Loading:
                Inlet	grain/ACFM
               Outlet
     10.  Stack Tests:

     11.  Device Efficiency:
grain/ACFM

         conducted?
to be conducted?
date:
>
en
Pollutant




Manufacturer's
Rated Efficiency




Measured
Efficiency




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                          INSTRUCTIONS TO COMPLETE
                 APPLICATION FOR PERMIT TO OPERATE/CONSTRUCT
                       AIR POLLUTION CONTROL EQUIPMENT

 7.  Description of Control  Equipment
     Indicate the type of equipment this is and any special  features.   Give
 the data called for.  Include a drawing showing the location of the  control
 device in the facility.   Include an assembly drawing, dimensioned and to
 scale, in plan and elevation showing clearly each part of the device.   Describe
 the operational and maintenance procedures used with the device,  including
 schedules of maintenance actions.   Include a flow diagram showing the
 progress of exhaust gas  from the process or boiler to the stack exit.

     If the application is for a  Permit to Construct (Construct new  unit;
 Modify existing unit), include a statement describing ohow this construction
 will be accomplished.  Specify in  particular those operations which  may
 cause contaminants to be injected  into the air, e.g., blasting and demolition,
 concrete mixing, spraying operations, etc.

 8.  Type of Equipment to Which Control Equipment is Attached
     Briefly describe the equipment being controlled; give some indications
 as to its size, rated capacity, or process rate.   If the equipment has  a
 permit, indicate its permit identification number.

 9.  Indicate the data called for.

10.  Stack Tests
     If stack tests have  been or will be conducted, answer yes in  the appro-
priate space and specify  the date.

11.  Device Efficiency
     Indicate the manufacturer's rated and actual  efficiency for each, pollutant
the device is designed to control.

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                        EMERGENCY EPISODE INFORMATION
                          FUEL COMBUSTION EQUIPMENT
 I.  Dual Fuel capacity

     1.  How much advance notice is needed for you to begin
         switch to alternate fuel? 	

     2.  Ash            and sulfur	content of
         normal fuel.

     3.  Ash 	and sulfur	 content of
         alternate fuel.

     4.  How much time does it take for you to switch
         fuels? 	

     5.  Describe the  seasonal availability of the
         alternate fuel:

         Available:  January 	        July 	
                     February 	        August	
                     March 	        September

                     April 	        October _

                     May 	        November _

                     June                      December
     6.   What is the added (or reduced)  costs  of dual  fuel
         capability to you?

         Capital Costs:

         Operating Costs:

II.   Curtailment of Business

     1.   How much advance  notice is  needed for you  to  being  curtailing
         operations (lowering  firing rate or shutting  down)?

     2.   Given an emission time-history  during curtailment  (if  known):
     3.   Indicate emission rate after shutdown:
     4.   Indicate the most desirable rate of achieving  curtailment
         (indicate total  time):  	
     5.   How fast could you  achieve curtailment  in  the  event  of
         an emergency:  	

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6.  How many employees would be released upon curtailment:

7.  What is the curtailment period allowable without
    substantial loss:
8.  What is your estimated economic loss  per day of curtailment:

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                              APPENDIX B
                                 RULES

     The following rules are meant to supplement the regulations  in  the
Alabama Air Pollution Control Act of 1971,  Act #769, Regular Session,
1971, where they concern the operation of a Permit System by the  Air
Pollution Control Commission and its agent, the Division of Air Pollution
Control.

     Since in some areas the Control Act is very specific, it is  not
necessary to cover certain territory twice  by including  it in these
rules.  Thus, these rules do not form a complete working set of rules
for the Permit System but must be combined  with the appropriate regula-
tions established by the Act.

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Rule 1.  DEFINITIONS
     •   "Air Contaminant" means  any  dust,  fumes, mist, smoke, particulate
         matter, vapor,  gas odor, or  any  combination  thereof, from
         whatever source.
     t   "Emission" means  the release into  the  outdoor atmosphere
         of air contaminants.
     •   "Director" means  the Director of the Division of Air Pollution
         Control of the  Department of Public Health.
     t   "Commission" mean the Air Pollution Control  Commission.
     •   "DAPC" is used  to refer  to the Division of Air Pollution Control.
     •   "Person" means  the State, any individual, partnership, firm,
         municipality, public or  private  corporation  or institution,
         political subdivision or agency  of the State, any  trust, agent,
         or agency of the  foregoing,  the  United States or any department,
         agency, or instrumentality of the  executive, legislative, or
         judicial branches of the Federal government.
     •   "Control Act" means the  Alabama  Air Pollution Control Act of
         1971, Act #769, Regular  Session, 1971.

Rule 2.  PERMITS REQUIRED
     a.  Permit to Construct
         Any person, building, erecting,  altering or  replacing any
         article, machine, equipment  or other contrivance,  the use of
         which may cause the issuance of  or an  increase in  the issuance
         of air contaminants or the use  of which may eliminate or
         reduce or control the issuance of  air  contaminants, shall first
         obtain authorization for such construction from the DAPC in the
         form of a Permit  to Construct.  A  Permit to  Construct shall
         remain in effect  until the permit  to operate the equipment for
         which the application was filed  is granted or denied  or the
         application is  canceled.

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b.  Permit to Operate
    Before any  article, machine,  equipment or other contrivance
    described in Rule 2a may be operated or used,  a  written  permit
    shall  be obtained from the DAPC.   No permit to operate shall
    be granted for any article, machine, equipment or contrivance
    described in Rule 2a, constructed or installed without
    authorization as required by Rule 2a, until the  information
    required is presented to the DAPC and such article,  machine,
    equipment or contrivance is altered, if necessary,  and made
    to conform to the standards established by the Commission.

    Any article, machine, equipment or other contrivance described
    in Rule 2a  which is presently operating (or which  is not  presently
    operating but which is capable of being operated) without  a Permit
    to Operate, may continue to operate (or may restart)  only  if
    its operator obtains a Permit to Operate prior to a  date to be
    set by the Director (or prior to restarting).

    The Director shall have the authority to decide  cases where an
    article, machine, equipment, or other contrivance is  not clearly
    subject to nor exempt from the Permit System.  In addition,
    The Director may rule that a particular article, machine,  equip-
    ment or other contrivance is subject to the Permit System  even
    though it is exempt from the system according  to Rules 2a, 2b,
    and 3.  The operator or builder of such an article,  amachine, equip-
    ment or other contrivance may appeal the Director's  classification
    to the Commission, which shall overrule the Director only  if it is
    shown that he acted arbitrarily and contrary to  the  purposes of
    the Control Act.

c,  Display of Permit to Operate
    A person who has been granted a Permit to Operate any article,
    machine, equipment, or other contrivance shall keep  such Permit
    under file or on display at all times at the site where  the

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         article, machine, equipment, or other contrivance is located and
         will make such a permit readily available for inspection by any
         and all persons who may request to see it.
Rule 3.  EXEMPTIONS
         From time to time the Director may specify certain classes or
         sizes of articles, machines, equipment, or other contrivances
         which would normally be subject to the requirement to obtain
         Permits to Operate or Construct, as being exeiv.pt from the
         requirement to obtain such permits.  Exempt sources are subject
         in every other way to the Rules and Regulations of the Commission.
Rule 4.  TRANSFER
         A Permit to Construct or Operate shall  not be transferable
         whether by operation of law or otherwise, either from one
         location to another, from one piece of equipment to another, or
         from one person to another.

Rule 5.  APPLICATIONS
                                                                 \
                                                                 x
         Every application for a Permit to Construct or Operate required
         under Rule 2 shall be filed in the manner and form prescribed
         by the DAPC and shall give all the information necessary to
         enable the DAPC to make the determination required by Rule 9
         hereof.

Rule 6.  CANCELLATION OF APPLICATIONS
         A Permit to Construct shall expire and the application shall be
         canceled two years from the date of issuance of the Permit to
         Construct if the construction has not begun.

Rule 7.  ACTION ON APPLICATIONS
         DAPC shall act, within a reasonable time, on an application for
         authority to construct, Permit to Operate or permit to sell or

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         rent, and shall  notify the applicant in writing of its  approval,
         conditional  approval  or denial.

Rule 8.   PROVISION OF SAMPLING AND TESTING FACILITIES
         A person operating or using any  article,  machine,  equipment  or
         other contrivance for which these rules require a  permit  shall
         provide and  maintain  such sampling and  testing  facilities  as
         specified in the Permit to  Construct or Perrm't  to Operate.
Rule 9.  STANDARDS FOR GRANTING APPLICATIONS
     a.   DAPC shall deny  a permit  except  as provided in  Rule  10, if the
         applicant does not show that every article, machine, equipment
         or other contrivance,  the use of which  may cause the issuance
         of air contaminants,  or the use  of which  may  eliminate  or  reduce
         or control the issuance of air contaminants,  is so designed,
         controlled,  or equipped with such air pollution control equip-
         ment, that it may be  expected to operate  without emitting  or
         without causing  to be  emitted air contaminants  in  violation of
         these Rules  and  Regulations.

     b.   The DAPC shall deny a  permit if  the applicant does not  present,
         in writing,  a plan whereby the emission of air  contaminants
         by every article, machine,  equipment, or  other  contrivance
         described in the permit application, will be  reduced during
         periods of an Air Pollution Alert, Air  Pollution Warning,  and
         Air Pollution Emergency in accordance with the  Emergency  Episode
         Plan.

     c.  Before a Permit to Construct or Permit to Operate is  granted,
         the DAPC may require  the  applicant to provide and  maintain such
         facilities as are necessary for  sampling  and  testing purposes
         in order to  secure information that will  disclose  the nature,
         extent, quantity or degree of air contaminants  discharged  into
         the atmosphere from the article, machine, equipment  or  other
         contrivance  described  in  the Permit to  Construct or Permit to
         Operate.  In the event of such a requirement, the  DAPC  shall


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          notify the applicant in writing of the required size, number and
          location of the sampling platform; the access to the sampling
          platform; and the utilities for operating the sampling and
          testing equipment.

      d.  The DAPC may also require the applicant to install,  use and
          maintain such monitoring equipment or methods;  sample such
          emissions in accordance with such methods, at such  locations,
          intervals and procedures as may be specified; and provide such
          information as the DAPC may require.

      e.  Before acting on an application for Permit to Construct or
          Permit to Operate, the DAPC may require the applicant to furnish
          further information or further plans  or specifications.

      f.  In acting upon a Permit to Operate, if the DAPC finds that the
          article, machine, equipment or other  contrivance has been con-
          structed not in accordance with the Permit to Construct, and
          if the changes noted are of a substantial  nature in  that the
          amount of air contaminants emitted by the article, machine,
          equipment or other contrivance may be increased, or  in that the
          effect is unknown, then it shall  deny the Permit to  Operate.
          The DAPC shall not accept any further application for a  Permit
          to Operate until the article, machine, equipment or  other con-
          trivance has been reconstructed in accordance with the Authority
          to Construct, or until  the applicant  has  proven to the satisfaction
          of the DAPC that the change will  not  cause an increase in the
          emission of air contaminants.

Rule 10.  CONDITIONAL APPROVAL
          The DAPC may issue a Permit to Construct or a Permit to  Operate
          subject to conditions which will  bring the operation of  any
          article, machine, equipment or other  contrivance within  the
          standards of Rule 9, in which case the conditions shall  be
          specified in writing.  Commencing work under such a  Permit to


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Construct or Operate such a Permit to  Operate        shall be
 deemed  acceptance  of  all  the  conditions specified.  The
 DAPC  shall  issue a Permit  to Construct or a Permit to  Operate
 with  revised  conditions  upon  receipt of a  new application, if
 the applicant demonstrates  that  the article, machine, equip-
 ment  or other contrivance  can operate within the standards of
 Rule  9  under  the revised  conditions.

A Conditional  Permit  may  allow an article, machine, equipment,
 or other contrivance  to  be  operated in violation of the conditions
 of Rule 9  if  one of the  conditions of the  permit is a definite
 schedule by which  the article, machine, equipment, or contrivance
 may attain  the  conditions  of  Rule 9 and be granted a  Permit  to
Operate.   A Conditional  Permit will be revoked if the applicant
 does  not submit progress  reports to the DAPC according to the
 schedule established  bv  the  Conditional  Permit.  The DAPC may
 further revoke  the Conditional  Permit if the progress reports
 do not  show satisfactory  progress as specified by the terms
 of the Conditional Permit  or if the progress reports are
 found to be inaccurate.

 A Conditional Permit  that allows an article, machine, equipment
 or contrivance  to  operate  in  violation of  the Standards of
 Rule  9  may  not  be  granted  for a  period of  time greater than one
 year, including all renewals.  In addition, no  Conditional
 Permit issued on or after a date one year  after the promulgation
 of the  Implementation Plan  may allow the article, machine,
 equipment or  contrivance  to operate in violation of the Standards
 of Rule 9  for a period of time longer than the greatest of the
 following  two periods:

 1.  60  days
 2.  The period  from the  granting of the permit to a date two
    years  after the promulgation of this Implementation Plan.
     (Thus,  when two years  have passed after the promulgation

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              of the Implementation Plan,  any article, machine,  equipment
              or contrivance will  require  a variance to legally  operate
              in violation of the  Standards of Rule 9 for a period of time
              greater than 60 days.)

Rule  11. TEMPORARY PERMIT TO OPERATE
          Upon application for a Permit to Operate by a new facility, the
          Director shall, within a reasonable period of time,  dispatch
          an inspector to the facility in  question.  If the inspector
          determines that the facility has been constructed according to
          the specifications as set forth  under the Permit to  Construct,
          or else that any changes to the  facility would reduce  or effect
          to an unsubstantial degree the quantity of air contaminants
          emitted by the facility, and if  a reviewing officer  of the
          Division agrees with this conclusion, then the Director shall
          issue a temporary Permit to Operate which will remain  in force
          until an offician inspection of  the facility under actual
          operating conditions can be made and the results reviewed, or
          until the Temporary Permit is suspended or revoked by  the  Director.
          The Director may issue a Temporary Permit to Operate without an
          inspection if the applicant fulfills the following requirements:

          •  The application for a Permit  to Construct is filled out and
             countersigned by a Professional Engineer familiar with  air
             pollution control as  it relates to the equipment  under
             application.
          •  Upon completion of the construction, the Professional Engineer
             noted above submits a letter  to the Director, signed and sealed
             with his professional stamp,  testifying that the  construction
             under application has been completed and is in accordance with
             the specifications as set down in the Permit to Construct.
             The Director is empowered to  reject the testimony of the
             Professional Engineer if the  Director decides that  the
             Professional Engineer's qualifications are insufficient to

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             the equipment in question.   A Professional  Engineer may appeal
             any such judgement to the Commission.

Rule 12.  DENIAL OF APPLICATIONS
         In the event of denial of a Permit to Construct or Permit  to
         Operate, the DAPC shall  notify  the applicant in writing of the
         reasons therefor.  Service of this notification may be  made in
         person or by mail, and such service may be proved by the written
         acknowledgement of the persons  served or affidavit of the  person
         making the service.   The DAPC shall  not accept  a further application
         unless the applicant has complied with the objections specified
         by the DAPC as its reasons for  denial  of the Permit to  Construct
         or the Permit to Operate

Rule 13.  APPEALS
         Within 10 days after notice by  the DAPC of denial  or conditional
         approval of a Permit to  Construct or Permit to  Operate, the
         applicant may petition the Commossion, in  writing,  for  a review.
         The Commission may sustain or reverse the  action of the DAPC;
         such order may be made subject  to specified conditions.

         The applicant may also petition the Commission  for a variance,
         as prescribed by the Control  Act.  A petition for a variance
         must state the following:

         a.  The name, address and telephone number of the petitioner,
             or other person  authorized  to receive  service of notices.
         b.  Whether the petitioner is an individual, co-partnership,
             corporation or other entity, and names and  address  of  the
             officers, if a corporation, and the names and address  of
             the persons in control, if  other entity.
         c.  The type of business or activity involved in the application
             and the street address at which it is  conducted.

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         d.   A brief description  of the  article, machine,, equipment or
             other contrivance,  if  any,  involved in  the application.
         e.   The signature  of the petitioner,  or that  of some person on
             his behalf,  and, where the  person signing is not the
             petitioner,  the  authority to  sign.
         f.   The requirement, rule, or order complained of.
         g.   The facts  showing why  compliance  with the requirement, rule
             or order would impose  serious  hardship  on the petitioner or
             on any other person  or persons without  equal or greater
             benefits to  the  public.
         h.   The facts  showing why  the emissions occurring or proposed
             do not endanger  or  tend to  endanger human health or safety,
             human comfort, and  aesthetic  values.
         i.   For what period  of  time the variance is sought and why.
         j.   The requirements the petitioner can meet  and the date when
             petitioner can comply  with  such requirements.
         k.   Whether or not any  case involving the same identical equip-
             ment or process  is  pending  in  any court,  civil or criminal.

         All  petitions  shall  be  typewritten, double  spaced, on legal
         or letter size paper, on one side  of  the paper only.

Rule 14. FAILURE TO COMPLY  WITH  RULES
         The  Clerk of the Commission shall  not accept  for filing, any
         petition which does  not comply  with these Rules relating to
         the  form, filing and service of petitions unless the chairman
         or any two members of the  Commission  direct otherwise and confirm
         such direction in  writing.  Such  direction  need not be made at
         a meeting of the Commission.

         The  Chairman or any two members,  without a  meeting, may require
         the  petitioner to  state further facts or reframe a petition so
         as to disclose clearly  the issues  involved.


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Rule 15.
         A person may file a written objection to the grant of a variance
         within 21 days from initial public notice and thus insure that
         a public hearing will be held, according to Section 12d of the
         Control Act.

         An objection to the grant of a variance must state:

         a.  The objector's name, address, and telephone number.
         b.  Whether the objector is an individual, co-partnership
             corporation or other entity, and names and address of the
             partners if a co-partnership, names and address of the
             officer, if a corporation, and the names and address of
             the persons in control, if other entity.
         c.  A specification of which petition for a variance is being
             objected to.
         d.  A statement indicating why the objector believes that the
             variance should not be granted.

         All  objections should be typewritten or carefully printed in
         ink  on legal or letter size paper.

Rule 16. RULES OF EVIDENCE AT A HEARING
      a.- Each party shall have these rights:   to call and examine
         witnesses; to introduce exhibits; to cross-examine opposing
         witnesses on any matter relevant to the issues even though
         that matter was not covered in the direct examination; to
         impeach any witness regardless of which party first called him
         to testify; and to rebut the evidence against him.  If
         respondent does not testify in his own behalf he may be called
         and examined as if under cross-examination.
      b. The hearing need not be conducted according to technical rules
         relating to evidence and witnesses.   Any relevant evidence

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shall be submitted if it is the sort of evidence on which
responsible persons are accustomed to rely in the conduct of
serious affairs, regardless of the existence of any common law
or statutory rule which might make improper the admission of
such evidence over objection in civil actions.   Hearsay
evidence may be used for the purpose of supplementing or
explaining any direct evidence but shall not be sufficient in
itself to support a finding unless it would be  admissible over
objection in civil actions.  The rules of privilege shall be
effective to the same extent that they are now  or hereafter may
be recognized in civil actions, and irrelevant  and unduly
repetitious evidence shall  be excluded.

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