18425.007
AIR QUALITY
IMPLEMENTATION PLAN
FOR THE
STATE OF ALASKA
VOLUME III: PERMIT SYSTEM
DECEMBER 1971
Prepared for the
STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
TRW
SYSTCMS GROUP
SPACE PARK * REDONDO BEACH. CALIFORNIA S0278
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18425.007
AIR QUALITY
IMPLEMENTATION PLAN
FOR THE
STATE OF ALASKA
VOLUME III: PERMIT SYSTEM
DECEMBER 1971
Prepared for the
STATE OF ALASKA
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
TRW
SYSTEMS GROUP
ONE SPACE PARK • REDONDO BEACH. CALIFORNIA S0278
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The work upon which this publication is based
was performed by TRW Systems Group pursuant
to Contract #68-02-0048 with the Office of Air
Programs, Environmental Protection Agency.
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TABLE OF CONTENTS
Page
1;0 OVERVIEW 1-1
2.0 PERMIT SYSTEM REQUIREMENTS 2-1
2.1 Registration Requirements 2-1
2.2 Permit Requirements 2-1
2.2.1 Permit Requirements - New or Modified Sources . . 2-1
2.2.1.1 Authority to Construct 2-1
2.2.V.2 Permit to Operate . 2-2
2.2.2 Permit Requirements - Existing Source 2-8
2.2.3 Conditional Permit to Operate 2-8
2.3 Exemptions 2-9
3.0 PERMIT UNIT 3-1
4.0 REGISTRATION 4-1
5.0 AUTHORITY TO CONSTRUCT - PERMIT TO OPERATE 5-1
6.0 PROCESSING OF PERMIT APPLICATIONS 6-1
6.1 Review 6-1
6.2 Approvals 6-1
6.3 Rejections 6-2
7.0 HEARINGS 7-1
8.0 SOURCE SURVEILLANCE 8-1
8.1 Inspection of Existing Facilities 8-1
8.2 Inspection of New and Modified Facilities 8-2
8.3 Submission of Data From Operator Installed 8-3
Monitoring Equipment
9.0 AIR QUALITY CONTROL JURISDICTIONS 9-1
9.1 State Agency Responsibilities 9-1
9.2 Local Agency Responsibilities 9-2
10.0 DATA MANAGEMENT 10-1
10.1 Data Types 10-1
10.2 Data Handling 10-1
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TABLE OF CONTENTS (Continued)
Page
10.2.1 Application for Authority to Construct .... 10-2
and Permit to Operate Category
10.2.2 Issued Authority to Construction Category ... 10-4
10.2.3 Issued Permits to Operate Category 10-4
10.3 Automated Information Systems 10-5
11.0 IMPLEMENTATION SCHEDULE 11-1
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1.0 OVERVIEW
The intent of the Alaska Permit System is to provide the mechanisms
and procedures by which the State Department of Environmental Conservation
(DEC) and local Afr Pollution Control Agencies can monitor and control both
new and existing sources of air pollution. To this end, the Permit System
was designated after careful review of the existing and proposed APCA require-
ments; and capabilities and after consideration of the existing and proposed
sources in the State. The Permit System was also designed to fulfill the
general requirements delineated in the Federal Register, August 14, 1971,
Vol. 36, No. 150, Sections 420.18, Review of New Sources, and 420.19,
Source Surveillance.
The features of the Permit System will allow, in accordance with
Alaska Statute 46.03.020, the DEC and the local Air Pollution Control
Agencies to:
a. Establish whether existing sources are in compliance with
the applicable Rules and Regulations or, if not in
compliance, are undertaking action to comply.
b. Determine prior to initiation of construction whether
new or modified sources will comply with applicable
Rules and Regulations and will not interfere with the
attainment or maintenance of a National Ambient Air
Quality Standard (NAAQS).
c. Assure that the appropriate Air Pollution Control
Agencies will be.able to control and maintain air
quality in accordance with NAAQS by limiting, if
necessary, the nature, location, and number of
new emission sources.
d. Provide, through source registration, source emission
and other data from which to estimate air quality
trends and generate emission inventories.
e. Provide the control agencies with the ability to
approve or disapprove the construction, modifica-
tion, and operation of sources based on air quality
considerations.
1-1
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2.0 PERMIT SYSTEM REQUIREMENTS
2.1 REGISTRATION REQUIREMENTS
Each facility, either existing or new, as defined in Appendix A
shall be required to submit a registration form to the appropriate
Air Pollution Control Authority (APCA) if its capacity is equal to
or exceeds values indicated in Column I of Tables 2-1 and/or 2-2.
The values listed correspond to emissions of 5 tons per year of
total uncontrolled air pollutants. The registration requirement
will be waived for facilities required to obtain a Permit to Operate.
2.2 PERMIT REQUIREMENTS
Each facility, either existing or new, as defined in Appendix A
shall be required to obtain a Permit to Operate or, if applicable, an
Authority to Construct if its capacity is equal to or exceeds the
values indicated in Column II of Tables 2-1 and/or 2-2. These values
correspond to 25 tons per year of uncontrolled particulates or SO
A
and 100 tons per year of uncontrolled NO CO, or hydrocarbons. Tables
A
2-1 and 2-2 are intended to be indicative of those sources which will
be required to obtain permits or registration. Sources having a
variety of processes or fuel combustion emissions should.consult with
the APCA if there is any question concerning the requirement to register.
These tables were developed from the emission factors as published by
the EPA and will be revised as newer information becomes available.
2.2.1 Permit Requirements - New or Modified Sources
2.2.1.1 Authority to Construct
In order to build or modify facilities which have the potential to
emit particulate matter, vapor, gas, or any combination thereof, it
will be necessary to obtain an Authority to Construct in accordance with
the requirements of the Administrative Code of the State of Alaska as
proposed in this Implementation Plan (see Regulations Volume). In order
to operate such a facility after it has been built or modified, a
Permit to Operate must be obtained. Both the Authority to Construct
and Permit to Operate requests are submitted at the same time and with
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one complete application. However, the Authority to Construct and Permit
to Operate will be granted in sequence.
An application for Authority to Construct and Permit to Operate
shall be submitted to the appropriate APCA having jurisdiction over
sources in that region of Alaska. The APCA will review the application
and will determine whether or not the proposed facility is designed and
will be operated in accordance with the requirements of the State of
Alaska or its own (local) statutory authority. An affirmative decision
will result in the granting of Authority to Construct, which gives the
applicant the right to build the facility, but only according to
specifications submitted as part of the application. If the application
is rejected, the applicant will be informed as to the reasons for re-
jection and will be prohibited from building or modifying the facility
as designed. The applicant may resubmit the application after necessary
revisions have been made.
2.2.1.2 Permit to Operate
After the construction or modification is completed, the facility
will be inspected by the APCA to verify that the actual construction
is in accordance with the design and operating features included in
the original or an appropriately amended Application. If the facility
passes a non-operational inspection, a Permit to Operate will be
granted. The non-operational inspection will consist of a site visit
by a qualified member of the appropriate APCA. This individual shall
be familiar with general engineering practice and the specific tech-
nologies utilized in minimizing air pollutant emissions.
In addition, the APCA may require the operator of the facility to
substantiate, by the submission of data or conducting tests, whether
the adequacy of his control equipment provides for the source meeting
the requirements of the applicable rule or regulation. These data and
tests will consist of stack sampling and/or continuous monitoring of
emissions.
2-2
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TABLE 2-1. GUIDELINES FOR MINIMUM PERMIT AND REGISTRATION REQUIREMENTS FOR PROCESS EQUIPMENT
Column 1 tabulates process rates which represent total emissions of 5 tons per year for the types of
operations indicated. Process rates in excess of the specified rates require registration.
Column 2 tabulates process rates which represent emissions if uncontrolled in excess of 25 tons per year
of SO/ or particulates or 100 tons per year of NOX, CO or hydrocarbons. Process rates in excess of the
specified rates require permits.
PROCESS DESCRIPTION
(Column 1)
REGISTRATION PROCESS RATE
(Column 2)
PERMIT PROCESS RATE
Dry Cleaning
Petroleum Solvents
Synthetic Solvents
30 tons clothes cleaned/yr
fir n it n M
600 tons clothes cleaned/yr
900 "
rv>
i
CO
Petroleum Storage
Fixed roof tanks storing gasoline
or finished petroleum product
Fixed roof tanks storing crude
oil
Floating roof tanks storing
gasoline or finished petroleum
product
Floating roof tanks storing
crude oil
60,000 gal - total storage
9,000,000 gal/yr - throughput
90,000 gal - total storage
10,000,000 gal/yr - throughput
Registration required for any
single tank greater than 40 ft
diameter
Registration required for any
single tank greater than 45 ft
diameter
1,000,000 gal - total storage
180,000,000 gal/yr - throughput
1,800,000 gal - total storage
250,000,000 gal/yr - throughput
Permit required if greater than
four (4) 100 ft diameter tanks
or equivalent
(Consult APCA)
Permit required if greater than
four (4) 100 ft diameter tanks
or equivalent
(Consult APCA)
Gasoline Marketing
Assumes splash fill system
- if submerged fill or other vapor
return systems are used, these will
be considered as control measures
4,000,000 gal/yr - throughput
8,000,000 gal/yr - throughput
Asphalt Batching Plants
200 tons product/yr
1000 tons product/yr
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TABLE 2-1. GUIDELINES FOR MINIMUM PERMIT AND REGISTRATION REQUIREMENTS FOR PROCESS EQUIPMENT (CONT'D.)
PROCESS DESCRIPTION
Portland Cement Manufacture
Dry process
Wet process
Note: one barrel of cement = 376 Ibs
Concrete Batching
Stone Quarrying and Processing
Without tertiary crushing
With tertiary crushing
Incinerators
Municipal
Indus trial /Commercial
Flue Fed
Domestic Single Chamber
Pathological
Ammonia Production
Plants with methanator
Plants with CO absorber and
regeneration system
Nitrate Fertilizers
With Prilling Tower
With Granulator
Copper Smelting
(Column 1 )
REGISTRATION PROCESS RATE
150 barrels product/yr
200 " " "
50,000 cu yards concrete/yr
600 tons raw material /yr
500 tons raw material/yr
250 tons waste/yr
400 tons waste/yr
100 tons waste/yr
20 tons waste/yr
900 tons waste/yr
30 tons ammonia/yr
20 tons ammonia/yr
700 tons product/yr
600 tons product/yr
7 tons concentrated ore/yr
(Column 2)
PERMIT PROCESS RATE
750 barrels product/yr
1000
250,000 cu yards concrete/yr
3000 tons raw material/yr
2500 tons raw material/yr
1600 tons waste/yr
7000 tons waste/yr
1600 tons waste/yr
650 tons waste/yr
6250 tons waste/yr
2000 tons ammonia/yr
600 tons ammonia/yr
3800 tons product/yr
6500 tons product/yr
40 tons concentrated ore/yr
ro
i
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TABLE 2-1, GUIDELINES FOR MINIMUM PERMIT AND REGISTRATION REQUIREMENTS FOR PROCESS EQUIPMENT (CONT'D.)
PROCESS DESCRIPTION
Lead Smelting (Primary
Zinc Smelting
Secondary Lead Smelting
Pot Furnace
Reverberatory Furnace
Blast Furnace
Rotary Reverberatory Furnace
Secondary Magnesium Smelting
Petroleum Refineries
Fluid Catalytic Cracker Units (FCC)
Moving Bed Catalytic Cracking
Units (TCC)
Wood Pulping
Diesel Electric Generators
(Column 1 )
REGISTRATION PROCESS RATE
12 tons concentrated ore/yr
7 tons concentrated ore/yr
12,500 tons processed/yr
40 tons processed/yr
30 tons processed/y
140 tons processed/yr
2500 tons processed/yr
600 barrel! s feed/yr
2500 barrels feed/yr
40 tons air dry unbleached
pulp/yr
TBD*
(Column 2)
PERMIT PROCESS RATE
75 tons concentrated ore/yr
45 tons concentrated ore/yr
62,500 tons processed/yr
360 tons processed/yr
250 tons processed/yr
700 tons processed/yr
12,500 tons processed yr
Permit decisions for all
refineries will be based upon
an analysis of each registered
refinery by the Air Pollution
Control Authority based upon
the registration data submitted
300 tons air dry unbleached
pulp/yr
TBD
IV)
en
*To be determined.
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TABLE 2-2. GUIDELINES FOR MINIMUM PERMIT AND REGISTRATION REQUIREMENTS FOR FUEL BURNING EQUIPMENT
Column 1 tabulates fuel burning rates which represent total emissions of 5 tons per year for the types of
operations indicated. Fuel burning rates in excess of the specified rates require registration.
Column 2 tabulates fuel burning rates which represent emissions if uncontrolled in excess of 25 tons per
year of SOX or particulates of 100 tons per year of NOX» CO or hydrocarbons. Fuel burning rates in excess
of the specified rates require permits.
FUEL BURNING EQUIPMENT
(Column 1)
REGISTRATION FUEL CONSUMPTION
(Column 2)
PERMIT FUEL CONSUMPTION
I
O1
Bituminous Coal Fired Equipment
Utility and large industrial
boilers (greater than 100 x 106
Btu/hr heat input)
Large commercial and general
industrial boilers (10 to 100 x 106
Btu/hr heat input)
Commercial and domestic furnaces
(less than 10 x 106 Btu/hr heat
input)
Handfired units
40 tons coal/yr
50 tons coa'l/yr
140 tons coal/yr
60 tons coal/yr
300 tons coal/yr
350 tons coal/yr
1500 tons coal/yr
1500 tons coal/yr
Residual/Crude Oil Fired Equipment
Power Plants
Industrial and commercial-
Residual oil fired
40,000 gallons oil/yr
5,000 gallons oil/yr
380,000 gallons oil/yr
380,000 gallons oil/yr
Distillate Oil Fired Equipment
Industrial and Commercial -
Distillate Oil Fired
Domestic Equipment
50,000 gallons oil/yr
5,000 gallons oil/yr
400,000 gallons oil/yr
400,000 gallons oil/yr
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TABLE 2-2. GUIDELINES FOR MINIMUM PERMIT AND REGISTRATION REQUIREMENTS FOR FUEL BURNING EQUIPMENT (CONT'D.)
FUEL BURNING EQUIPMENT
(Column 1)
REGISTRATION FUEL CONSUMPTION
(Column 2)
PERMIT FUEL CONSUMPTION
ho
I
Natural Gas Fired Equipment
Power Plants
Industrial Process Boilers
Domestic and Commercial Heating Units
Gas Fired Turbines
Gas Fired Engines for Oil and Gas
Production
Gas Fired Engines for Gas Plants
Gas Fired Engines for Refineries
Gas Fired Engines for Pipelines
20 million cu. ft gas/yr
40 " '
-jr n II M ii n
rn n n II n H
10 "
2
2
1
500 million cu. ft gas/yr
1000 "
2500 "
1000 " '
45
45
25
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If the operation of the facility is found to conform to the specifi-
cations of the permit, the Permit to Operate shall continue in effect and the
facility will enter the routine source surveillance phase of the Permit
System.
2.2.2 Permit Requirements - Existing Source
The procedure for including presently operating sources into the
permit system requires the submission of an application for a Permit to
Operate. The APCA may require that the application be accompanied by
stack emission data, to ascertain whether the emission source is in
compliance with the applicable Rules and Regulations of the State of
Alaska. The criteria for determining which existing sources require
permits are provided in Paragraph 2.2. Each existing source will be
subject to routine surveillance as described in paragraph 2.2.1.3.
2.2.,3 Conditional Permit to Operate
This type of Permit is for those existing sources which are not in
compliance with the Rules and Regulations of the State of Alaska (or the
appropriate local jurisdiction) which define the allowable pollutant
emissions. This permit is granted only for a specified period of time
and its issuance is subject to the following conditions:
a. If an existing source is in non-compliance with emission limita-
tions and submits to the APCA a schedule of compliance showing
specific actions to be taken according to a fixed time schedule
which will, when completed, bring the source into compliance.
If the schedule of compliance includes the installation of control
equipment,then an Authority to Construct will also be required.
b. If an existing source exceeds any emission limitations due to
the breakdown or failure of abatement equipment. Under these
conditions, the APCA may issue a conditional permit. If the
emissions are not satisfactorily reduced within a reasonable
time frame, and if an extension in time is not deemed to be
justified, the APCA may order a shutdown of the emission source.
c. A new or modified source which has applied for a Permit to Operate
as described in paragraph 2.2.1.2 and inspection cannot be per-
formed within a reasonable time. When a conditional permit is
granted under these conditions, the APCA will arrange with the
operator a mutually agreeable date for inspection which, if
satisfactory, will culminate in a permanent Permit to Operate.
2-8
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d. If an existing source has no practicable means known or available
for the adequate prevention, abatement or control of air emissions,
Under these conditions a Conditional Permit will be granted only
until such time as such abatement or control technology becomes
available.
In any case, the satisfactory completion of the emission reductions
specified in the terms of the Conditional Permit to Operate will lead to
the granting of a Permit to Operate. The APCA will conduct an inspection
of the source prior to granting the Permit to Operate and may require the
source operator to perform stack emission measurements or such other tests
as may be required to determine pollutant emission levels. The APCA also
has the option to require the installation of continuous in-stack monitor-
ing equipment and periodic reports of the data collected by such instruments.
2.3 EXEMPTIONS
i
Registration, Authority to Construct or Permit to Operate shall not
be required for:
1. Vehicles as defined by the Alaska State Vehicle Code, but not
including any article, machine, equipment or other contrivance
mounted on such vehicle that would otherwise require a permit
under the provisions of these Rules and Regulations.
2. Vehicles used to transport passengers or freight.
3. Internal combustion engines, including gas turbine and jet
engines, which are considered mobile sources.
2-9
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3.0 PERMIT UNIT
A permit unit is defined as comprised of all the sources of atmospheric
pollution emissions, whether from industrial process operations, fuel combus-
tion, or solid waste disposal, located at a single identifiable site or
facility. The owner or operator of the facility is required to submit
an application to the APCA for the appropriate permit or authorization.
This application and the subsequent permit or authorization will cover all
emission sources located at the facility.
The process operations specified in Tables 2-1 and 2-2 are based upon
the operation of only a single process or combustion unit at the facility.
If two or more operations having pollutant emissions exist at the facility,
then the estimated total emissions of all such operations will be used
in determining the necessity of registration or permit application from
the facility. If the source operator has any questions concerning the
application of these definition or guidelines to his facility, he should
contact the appropriate APCA. In all cases, the decision concerning the
permit and the individual processes to be included in the permit will
be made by the cognizant APCA.
3-1
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4.0 REGISTRATION
The intent of Registration is to provide the APCA with information
necessary to establish the nature and quantity of emissions. Specifically,
the information required for registration will include:
a. Facility identification - name, address, ownership
b. Name, address and telephone number of principle contact
c. Nature of the Operation describing the type of combustion and/or
process occurring
d. Operating schedule of the emission source
e. Type of fuel used, amount burned annually, heat content, sulfur
and ash content, if applicable
f. Nature and efficiency of the emission control equipment, if any
g. Signature of responsible party
h. Amount of production rate or process throughput
i. Amount of material disposed of as solid waste and the type of
such disposal
j. Nature and amount of emissions (or sufficient information from
which to calculate emissions)
k. Stack parameters;
height,
diameter,
exit gas temperature,
exit gas velocity.
A sample copy of a Registration Form is presented in Appendix B.
A copy of the Registration Form must be submitted by each operator to the
appropriate APCA for review and filing. The local APCA shall transmit one
copy of the completed registration form to the Department of Environmental
Conservation in Juneau for information purposes.
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5.0 AUTHORITY TO CONSTRUCT - PERMIT TO OPERATE
For a given facility, a single application is required for Authority
to Construct and/or a Permit to Operate. A sample of this form is shown
in Appendix C.
The APCA may, when requested, assist applicants in compiling all
necessary information required for such an application. However, operators
generally will be encouraged to obtain the services of a professional
engineer.
This application will be made by:
a. Existing sources requiring either a Permit to Operate or a
Conditional Permit to Operate
b. New or modified sources requiring an Authority to Construct and
a Permit to Operate.
The function of this application is to establish whether an existing
source is meeting emissions standards at the time of submission of the
application or whether a new or modified source will successfully meet such
standards after the proposed construction is completed. The application
requires the following information:
a. Facility identification - name, address, ownership
b. Nature of the operation - describing the type(s) of combustion
and process source(s) and equipment.
c. Corresponding BTU ratings or process ratings or process rates, as
applicable and the actual or intended usage rate.
d. Operating schedules
e. Type and amount of fuels used, heat content, sulfur content and
ash content, if applicable
f. Type and efficiency of emission abatement equipment, if any
g. Estimate of nature and amount(s) of emissions
h. Stack parameters (height, diameter, exit gas temperature, exit
gas velocity)
i. Process flow diagram, delineating where air pollutant emissions
occur
j. Procedures for emission reduction during emergency episodes.
(This requirement applies to all sources emitting 100 tons/year
or more of any one pollutant)
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The signature on the application will constitute an agreement that
the applicant assumes the responsibility for notifying the APCA of any
alterations, additions or changes in operation he may decide to undertake.
Anapplication for a Conditional Permit must include a compliance
schedule delineating periodic increments of progress which must be met at
specific intervals. No periodic increment of progress may exceed 12 months.
The APCA has the right to waive or to request the Applicant to furnish
any of the above or additional information necessary to evaluate the
facility's effect on the air environment. The additional information will
be requested within 15 days of the receipt of the Permit Application as
stipulate by AS 46.03.160.
The applicant for a permit for new sources may be required to submit
the following additional information:
a. Drawings and flow diagrams defining the layout, nature, and type
equipment arrangement
b. Emission calculations or sufficient detailed information to permit
the calculation of emissions
c. Calculations estimating the effect of emissions on the ambient
air quality in the area of the source
d. Description of and a specification for the proposed emission
abatement equipment
e. Stack emission testing upon start up
f. Stack monitoring and/or air quality monitoring instrumentation
specifications.
With the exception of pollutant emissions data and estimates, all
records and information supplied to the Department of Environmental
Conservation or to the local APCA will be considered confidential in
accordance with AS 46.03.180.
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6.0 PROCESSING OF PERMIT APPLICATIONS
6.1 REVIEW
An Application for Authority to Construct and Permit to Operate will
undergo a review by the APCA. The review process will provide a full
documentation of all findings. Staff members review the applications will
be engineers or personnel having experience in air pollution control.
Each Permit Application will be reviewed:
a. To insure that all basic information as stated in Section 5.0 has
been provided .
b. To estimate emissions using available emission factors and the
stated efficiency of the abatement equipment. If emission
calculations are included with the application, these will be
compared to the estimates.
c. To calculate allowable emissions using the emission limitations
defined in the Rules and Regulations. These results will be
compared to those of item .b. to determine whether the projected
emissions are in excess of those permitted by the Regulations.
d. To estimate the air quality impact of a new facility. An allow-
able emission rate, based on air quality considerations will be
calculated and compared to the results of items a and c.
e. To ascertain that the abatement procedures submitted for Emer-
gency Episode Action provide acceptable degrees of emission
reduction under adverse meteorological conditions.
f. To assure that compliance schedules, if applicable, provide for
expeditious abatement of the air pollution problems with periodic
increments of progress.
In accordance with Alaska schedule AS 46.03.160, the time limitation
on the review process is 30 days.
6.2 APPROVALS
Within 30 days of receipt of the application it will either be
approved, conditionally approved, or disapproved. If minor modifications
are necessary, the applicant will be called in for consultation and changes
may be agreed upon. For existing sources, a Conditional Permit will be
issued if the compliance schedule and the proposed abatement equipment is
found acceptable.
6-1
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In order for a source to be issued an Authority to Construct or a
Permit to Operate, the reviewer(s) must be satisfied that:
1. The source does, or will, conform to all emission standards as
defined in the Administrative Code;
2. The construction and/or operation of the source will not cause
ambient air quality standards to be exceeded;
3. The source has established a satisfactory emission reduction
schedule for emergency episodes (if required).
THE APPROVAL OF ANY CONSTRUCTION OR MODIFICATIONS SHALL NOT AFFECT THE
RESPONSIBILITY OF THE OPERATOR TO COMPLY HITH ALL APPLICABLE EMISSION
LIMITATIONS OR OTHER AIR QUALITY CONTROL REGULATIONS.
6.3 REJECTIONS
An Authority to Construct or a Permit to Operate will be denied if
the APCA determines that the application is not acceptable and cannot be
negotiated into an acceptable form. The application with be denied in
the following cases:
1. The facility cannot be built in the geographic area indicated
because emissions from the facility, as designed, may degrade
the air quality of the area to a level which exceeds the NAAQS.
2. The emission control systems or equipment designed or specified
are unreliable or inadequate.
3. The emergency episode plan provisions are inadequate.
4. On-site stack sampling equipment, air monitoring equipment (if
applicable) or sampling ports to be provided for inspection are
inadequate for the purpose.
5. The submitted information has been' improperly prepared to a
degree that it cannot easily be corrected without total rewriting.
6. The application indicates that an applicable rule or regulation,
or any portion of the applicable control strategy, may be violated
by the source.
If an Authority to Construct is denied by the APCA, it shall also
issue to the applicant a Prohibition Order against the construction of the
facility, as designed. If a Permit to Operate is denied by the control
agency it shall also issue a Prohibition Order against the operation of the
facility, in accordance with AS 46.03.160(b) of the Laws of Alaska. If an
6-2
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acceptable application is later received and approved by the APC officer,
the Prohibition Order will be rescinded.
6-3
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7.0 HEARINGS
Procedures for the appeal of the decisions of the Department of
Environmental Conservation (DEC) in connection with the granting or denial
of Permits to Operate, Compl-iance, Prohibition or Shutdown orders shall be
in accordance with the Alaska Statutes 46.03.170 and 44.62.320.
7-1
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8.0 SOURCE SURVEILLANCE
8.1 INSPECTION OF EXISTING FACILITIES
The nature and frequency of inspection of existing sources by the
APCA will depend on the following factors:
• History of complaints against the facility
• Nature and amount of emissions from the facility
• Facility size and complexity
• History of violations
• Time required to conduct inspections
• The frequency and method(s) of stack measurements performed by the
operator. The inspection process may include stack testing if
determined necessary by the APCA.
The exact inspection schedule will be defined following the submission
and review of the permit applications and will be submitted in the first
semi-annual progress report. Inspection interval and type of inspection
will be explicitly stated in this listing.
The APCA will maintain a list of facilities which are to be subjected
to annual inspection. For other facilities, the APCA will establish an
inspection schedule based on facility size and impact on the environmental
of the facility. Those sources which have demonstrated that their abate-
ment programs meet the Rules and Regulations with an adequate safety
margin will be by-passed. Inspections responding to specific citizen
complaints will be performed at any time.
The routine source surveillance will include submission of periodic
reports by each source and routine inspections of the source by the APCA.
Reports will be submitted every two years at a minimum, but the APCA may
require annual or semi-annual reporting from major sources. Periodic
reports may range from production reports and notification of unusual
operations, abatement equipment breakdown, etc., to detailed emission
monitoring data from the larger sources but will include, as a minimum,
data on the nature and amounts of emissions.
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If either the periodic reports or inspections indicate non-compliance
with conditions specified by the Permit to Operate, the APCA will issue an
Order to Comply. The APCA may also levy a fine against the facility depend-
ing on the previous record of the facility, the nature of the non-compliance,
and whether it was known or unknown to the' plant operator. This procedure
represents the basic mechanism by which the APCA insures compliance with
the emission limitations defined in the Regulations.
Inspectors, during the normal course of their activities, will observe
any violations of the State or local ordinances regarding visible emissions.
All violations noted will be brought to the attention of the source owner or
operator and will be referred to the APCA for recording and possible
prosecution.
During air pollution episodes, source inspection will be carried out
by the appropriate APCA. These inspections will be principally designed
to insure that pre-agreed emission reduction measures for each episode
stage are being instituted by each major point source. Roving inspectors
will also enforce community-wide restrictions and bans regarding open
burning and incineration.
8.2 INSPECTION OF NEW AND MODIFIED FACILITIES
New and/or modified facilities will be inspected prior to the
issuance of a Permit to Operate. The source's Authority to Construct will
be used as a guide to the conduct of this inspection. A preoperational
inspection will be carried out in all cases. This inspection will focus
on a visual examination of the facilities and the installed abatement
equipment. If the APCA determines that the preoperational inspection
does not conclusively indicate that the source can be operated in compli-
ance with the applicable emission limitations, a further post-operational
test will be required before issuance of a Permit to Operate. These tests
may include stack emission measurements (carried out either by the APCA or
by the operator of the source under APCA direction) and/or any other data
which the APCA deems necessary to properly evaluate the air pollution impact
of the source. After satisfactory completion of the inspection, the new
or modified source will be granted a Permit to Operate and will be inspected
and monitored according to the provisions outlined in the previous section.
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8.3 SUBMISSION OF DATA FROM OPERATOR INSTALLED MONITORING EQUIPMENT
Any source which is required to maintain and operate emission
measurement instrumentation and/or air quality measurement instruments as
part of their requirement to obtain a Permit to Operate will submit the
measured data to the Department of Environmental Conservation (DEC) on a
semi-annual basis. The operator of each source will be obligated to report
immediately and correct all emissions which were measured to be excessive.
The operator's air quality measurement instrumentation will become part of
the statewide air surveillance network and will be operated in accordance
with the sampling methods and schedule of the statewide system. All data
received from such instrumentation must be made available to the DEC on a
periodic basis ,subject to negotiation. However, the operator must notify
the DEC immediately of any degradation of air quality as determined by the
operator's instrumentation.
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9.0 AIR QUALITY CONTROL JURISDICTIONS
9.1 STATE AGENCY RESPONSIBILITIES
The Department of Environmental Conservation (DEC) will assume
primary responsibility for all emission sources located outside the
jurisdiction of any local agency. This responsibility will include the
administration of the permit and registration system and the conduct of
source surveillance and inspection procedures.
The DEC will also assume responsibility for the permiting and control
of State or Federal facilities located within local jurisdictions , should the
local APCA request such assistance. In the case of Federal facilities, the
DEC will call upon the appropriate area of the Environmental Protection
Agency,if a satisfactory cooperative relationship cannot be developed at
the State level.
The DEC has the responsibility to review and monitor the operation
of local agencies. The nature of the review arid the depth of the review
process will vary with each situation and will depend on:
1. The type of source and the nature and amount of pollutants ;
2. The meteorological, topographic and air quality characteristics
of the location in which the existing source is operating or
for which the new source is planned.
The DEC will assume primary responsibility for the administration of
the permit system within the jurisdiction of a local agency should it be-
come necessary. This authority is granted to the DEC in AS 46.03.220
of the Laws of Alaska in cases where:
1. The local air pollution control program is determined by public
hearing to be inadequate;
2. The control of a particular class of air contaminant source is
determined to be beyond the capabilities of the local agency
because of the complexity or magnitude of the source.
In addition, the DEC when necessary will assist the local agencies
in all practical and reasonable ways in administering the permit system.
This assistance will most likely be technical in nature and may include
the following:
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1. Source inspection and test assistance;
2. Consultation or evaluation of new sources/.
9.2 LOCAL AGENCY RESPONSIBILITIES
In accordance with Alaska Statute AS 46.03.210, areas with a popu-
lation in excess of 1,000 and organized as boroughs may establish pollu-
tion control programs.
All local agencies have the following primary responsibilities with
regard to the Permit System. For all sources in their jurisdiction, they
will:
1. Register all sources requiring registration by the State of
Alaska ;
2. Process, review, and approve applications for Authority to
Construct and Permit to Operate ;
3. Inspect sources ;
4. Process and monitor Conditional Permits to Operate •
A local agency may deviate from any of the features of the Permit
System defined by the State of Alaska,herein,if such deviation is fully
negotiated with the Department of Environmental Conservation and formally
agreed to by both parties. The local agency is, however, obligated to
transmit to the DEC copies of all data submitted to it as part of the
implementation of its Permit System.
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10.0 DATA MANAGEMENT
10.1 DATA TYPES
Data types within the Permit System can be classified as Primary or
Secondary. The Primary Data consist of Registration Forms, Applications
for Authority to Construct and Permit to Operate and portions of supple-
mental data in support of the Application. These supplemental data may
consist of:
• Facility Description and Layout
t Emission Calculations
t Air Quality Calculations
• Stack Measurement Data
• Compliance Schedules
• Stack Parameter Values
• Descriptions of Provisions for Stack Sampling
• Descriptions of Stack Monitoring Equipment
• Descriptions of Air Quality Monitoring Equipment
• Design Specifications for Abatement Equipment
• Abatement Procedures for Emergency Episodes.
10.2 DATA HANDLING
To assure adequate control and access to all available data, a central
depository needs to be established for all primary and secondary data.
This depository shall be established at the offices of the Department of
Environmental Conservation in Juneau, Alaska. Local agencies shall
routinely contribute to this data bank by transmitting copies of all re-
gistration and permit applications. A manaul system can accommodate the
initial requirement of storing a copy of the application and maintaining
a simplified system of tracking the application and its related documents
through the permit-granting process.
Data generated by a Permit will be used in future state-wide emission
inventories, air quality control and projections. Thus, it is desirable
that Permit System data be readily accessible and in a usable form as a
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possible data input in modeling studies, comparative analyses, and as a
source for specific control procedures during emergency episodes.
The intent of the data handling procedures set forth in this descrip-
tion is to describe a method of manual operations, yet allow the basic
structural and procedural flexibility for a possible transition to com-
puterized phases of operation.
Data documentation will fall into four types of data packages dealing
wi th:
1. Registration;
2. Applications for Authority to Construct and Permit to Operate;
3. Issued Authorities to Construct (pending review for Permit
to Operate);
4. Issued Permits to Operate (Routine Permit System Operation).
The files associated with each category are shown in Figure 10-1. A
description of each file follows. Registration forms will be placed in a
Master File arranged in alphabetical order and by Air Quality Control
Region.
10.2.1 Application for Authority to Construct and Permit to Operate
Category
• Application Master File
This file contains a copy of each original application and associ-
ated Primary Data. All actions, until issuance of an Authority to
Construct, or a Permit to Operate, are recorded in this file to
maintain a current status of the application. Each application
is filed alphabetically-chronologically by the name of the com-
pany and date of application. Any action through the permit-
granting process is updated in this master file. After issuance
of Authority to Construct, or Permit to Operate, the application
is transferred to the "Issued Authority to Construct", or "Issued
Permit to Operate" category. An Application Master File will be
maintained by each APCA.
• Review and Approval File
This file is primarily a control device to assist the engineering
personnel in shceduling applications for review. It contains only
the name of the applicant, date of application, and date of the
scheduled review. After approval or disapproval, the information
is purged from the file.
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Figure 10-1. PERMIT SYSTEM DATA FILES
APPLICATION FOR AUTHORITY TO CONSTRUCT
AND PERMIT TO OPERATE FILES
ISSUED AUTHORITY TO CONSTRUCT
FILES
ISSUED PERMIT TO OPERATE FILES
o
CO
Application
Master File
Review and
Approval
File
Modify-Reject
File
Application
Master File
Review and
Approval
File
Modify-Reject
File
Permitted Sources
Master File
Conditional Permits
File
Test/Inspection
File
Legal Action
File
-------
• 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, date of the APCA
conclusions, and the word "modify" or "reject" need appear. De-
tails of the review can be obtained from the Application Master
File since all actions affecting an application update this file.
The Modify-Reject File should assist in ready access of infor-
mation when special tests and/or inspections are required and,
in addition, in any legal action processes. The file may be
purged after an applicant has resubmitted an application and
received approval.
10.2.2 Issued Authority to.Construction Category
• Application Master File
When the Authority to Construct is granted, the application is
sent to the Application Master File in the "Issued Authority to
Construct" category, where a copy is maintained. 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 pro-
cess 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 "Issued Permit to Operator."
category.
• Review and Approval File
This file operates in exactly the same manner as the Review and
Approval File described in paragraph 10.2.1.
• Modify-Reject File
This file operates in exactly the same manner as the Modify-Reject
File described in paragraph 10.2.1.
10.2.3 Issued Permits to Operate Category
• Permitted Sources Master File
This file is created by the transfer of applications, and all
Secondary data, from the Application Master File in the "Issued
Authority to Construct" Category upon issuance of a Permit to
Operate. The data is filed alphabetically by company name;
indicating site location, Standard Industrial Classification (SIC)
number, and process type. The Master File becomes the permanent
record of all sources operating with permits. It contains periodic
test results, inspection reports and evaluations which may lead to
legal actions due to non-compliance with regulations. Purging
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of this file would occur when a need for a new permit arises,
e.g., change of ownership or expiration of the old permit.
• Conditional Permit File
Conditional Permits to Operate are contained in this file during
the period in which they are in force. The same information is
contained in this file as in the Permited Sources File with the
addition of a compliance schedule which must be submitted before
this Permit is issued. As Conditional Permits to Operate expire
and compliance with the regulations is achieved, sources will be
removed from this file and placed in the Permited Sources Master
File.
• Test/1nspection Fi1e
This file contains the name of the company due for emissions
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 in field operations and contains all appropriate
Secondary data. The APCA may develop inspection schedules
based on the date of permit issuance. The registrant would be
purged from the file only if his permit was revoked.
• Legal Action File
This file contains only the name of the registrant and a few
words describing pending legal action. (Examples of these
words would be: "Fine "."Shutdown", or "Order to Reduce
Emissions".) Details of the legal action can then be obtained
from the Registrant Master File.
10.3 AUTOMATED INFORMATION SYSTEMS
The Alaska Air Pollution Permit System will be run, at least initially,
on a manual basis. However, depending on the extent of future development,
it may eventually be advisable to convert to a computerized information
sy s tern.
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11.0 IMPLEMENTATION SCHEDULE
The Permit System will be put into effect a month after EPA
approval of the Implementation Plan. All major sources will be contacted
by mail with an enclosed Permit Application and a copy of the Rules and
Regulations. The Permit Applications will be reviewed and as required
Conditional Permits to Operate will be granted to sources not in compli-
ance with the emission requirements. Compliance schedules will begin on
January 1, 1972 and will continue at a maximum, through the end of 1974.
A typical compliance schedule, requiring the installation of abatement
equipment, will include several significant milestones by which the APCA
may measure progress toward completion.
The point source registration program will begin in the fall of 1973
and is expected to take about four months.
Full compliance of all point sources with the Rules and Regulations
of the State will occur by Spring of 1975.
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