|Air Quality / 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 over 40 air specialists, 17 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)
Air permitting in California is delegated from the United States Environmental Protection Agency (U.S. EPA) to the California Air Resources Board (CARB). In 1947, Governor Earl Warren authorized the creation of 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
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
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.
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.