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.
                                    4-1

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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)
                                     5-1

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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.
                                    5-2

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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
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acceptable application is later received and approved by the APC  officer,
the Prohibition Order will  be rescinded.
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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.
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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

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      •  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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