Air Quality / Air Permitting

Air Permitting

California Air Permitting

Yorke Engineering, LLC (Yorke) staff has prepared over 1,000 air permit applications in the State of California and has 35 air specialists, 14 of whom are Certified Air Permitting Professionals (CPPs or CAPPs). Permitting can get a little complicated; please see the basic steps below the equipment list.

Equipment Yorke Has Prepared Air Permit Applications For (Alphabetically – Partial List)

Abrasive Blasting
Amine Units
Asphalt Operations
Baking Operations
Biomass Power
Boilers
Caning Operations
Chemical Processing
Composting
Digester Gas/Field Gas Engines
Digester Systems
Emergency Generators
Extruders
Food Drying
Forging		 Gasification Units
Geothermal Plants
Glass Manufacturing
Gravel Operations
Grinders
Heaters
Kilns
Laser Cutters
Loading Racks
Mining
Municipal Solid Waste Digesters
Natural Gas Engines
Oil and Gas Separators
Ovens
Pet Food Dryers		 Petroleum Refining Operations
Plastics
Plating Lines
Pyrolysis Systems
Pyrotechnics
Rendering Systems
Roofing Materials Manufacturing
Screens
Sludge Dryers
Spray Booths
Tanks (of All Kinds!)
Turbines
Waste Digesters
Wastewater Treatment

Control Systems

Baghouses
Carbon Monoxide Catalysts
Carbon Systems
Cyclones
HEPA Filters
Regenerative Thermal Oxidizers
Scrubbers
Scrubbers
Selective Catalytic Reduction (SCR) Systems
Thermal Oxidizers – Burn Boxes
____________________________________________________________________

Air permitting in California is delegated from the United States Environmental Protection Agency (U.S. EPA) to the California Air Resources Board (CARB). In 19xx, CARB created the local air district system here in California, which consists of 35 air districts. Permitting is administered at the local air district level. As a result, air permitting is a combination of federal New Source Review requirements, CARB requirements, and local air district requirements. The basic steps to air permitting in California are listed below.

Emission Quantification – Criteria Pollutants

In order to prepare the permit application, emissions must be quantified in a way that is acceptable to the air district. These calculations affect Best Available Control Technology (BACT), toxics, rule compliance, control systems, etc

  • Source-Specific Emissions for Nitrogen Oxides (NOx), Sulfur Oxides (SOx), Lead, Volatile Organic Compounds (VOCs), Particulate Matter (PM), and Sulfur Hexafluoride (SF6)
  • AP-42 Emission Factor Analysis
  • Source Test Emission Factor Development
  • EMFAC for Mobile Sources (Some Districts Require This)
  • Specialized Emissions Tools
    • Emissions Inventory Improvement Program (EIIP) – For Chemical Processes

Emission Quantification – Toxics

Toxic emissions are quantified to meet the air district toxics rules for permitting for source-specific rules and toxic health risk. If toxics are too high, T-BACT may be required to control the toxics. Health risk is calculated to the nearest receptor using the toxics inputs.

BACT – Best Available Control Technology Analysis

BACT is done on a case-by-case basis; however, there are guidelines to follow, and if thresholds are exceeded, control systems will be required. When we prepare the permit application, we will identify BACT early in the process, so the facility can plan for this and minimize cost and schedule delays.

Health Risk Calculations – Dispersion Modeling

  • Toxic Health Risk Assessments (HRAs) for Permitting by Permit Unit
  • Criteria Pollutant Modeling for Larger Projects
  • AERMOD Dispersion Modeling
  • Hotspots Analysis and Reporting Program (HARP) Is Used for Health Risk Calculations
  • Mobile Source Emissions Modeling

Rule Analysis

Permits need to comply with all federal, state, and local rules for categories such as toxics, criteria pollutants, and in some cases, greenhouse gases (GHGs). There are also prohibitory rules and source-specific rules that the equipment must comply with for the air district permit engineer to proceed with issuing a permit. This rule analysis is included in the permit application.

  • Federal Clean Air Act (CAA) Title I – New Source Review (NSR)/Prevention of Significant Deterioration (PSD) and Title V – Operating Permits
  • National Emission Standards for Hazardous Air Pollutants (NESHAPs)/Maximum Achievable Control Technology (MACT)
  • Offset Determinations (Including Federal Requirements)
  • Emission Reduction Credit Generation
  • Local Air District Source-Specific Rules
  • Toxics, Health Risk Assessments
  • California Environmental Quality Act (CEQA) Compliance

Permit Conditions and Air District Negotiations

For larger, complex, or schedule-driven projects, starting the air district negotiations early is a good idea. For simple projects, follow-up after submittal is preferred by most permit engineers.

Permit conditions should be written in a way to minimize the compliance costs to the equipment operator, so Yorke will often suggest permit condition language to the permit engineer since many processes are unique in some way. It is best to ask for the permit conditions in draft form prior to the issuance of an Authority to Construct (ATC) permit.