Yorke Engineering, LLC staff have prepared over 1,000 air permit applications in the State of California and include over 40 air specialists, 22 of whom are Certified Air Permitting Professionals (CPPs or CAPPs). Air permitting can be complicated; we can help with any kind of equipment you have.
Yorke Has Prepared Air Permit Applications For (Alphabetical – Partial List):
Digester Gas/Field Gas Engines
Municipal Solid Waste Digesters
Natural Gas Engines
Oil and Gas Separators
Pet Food Dryers
|Petroleum Refining Operations
Roofing Materials Manufacturing
Tanks (of All Kinds!)
Carbon Monoxide Catalysts
Regenerative Thermal Oxidizers
Selective Catalytic Reduction (SCR) Systems
Thermal Oxidizers – Burn Boxes
Air permitting in California is delegated from the U. S. Environmental Protection Agency (EPA) to the California Air Resources Board (CARB). In 1947, Governor Earl Warren authorized the creation of the local Air District system throughout the State, which consists of 35 air districts. Permitting is administered at the local Air District level. As a result, air permitting covers a combination of federal New Source Review requirements, CARB requirements, and local Air District requirements. We have broken down the basic steps to air permitting in California as follows.
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;
- Emission Factors (EMFAC) for Mobile Sources (Some Districts Require This); and
- Specialized Emissions Tools:
- Emissions Inventory Improvement Program (EIIP) – For Chemical Processes.
Emissions Quantification – Toxics
Toxic emissions are quantified to meet the Air District toxics rules for permitting, which are based on 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 at the nearest receptor using the toxics inputs.
BACT – Best Available Control Technology Analysis
BACT is evaluated 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 a permit application, we 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, version 2 (HARP2) Is Used for Health Risk Calculations; and
- Mobile Source Emissions 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 our permit application process.
- 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 (NESHAP)/Maximum Achievable Control Technology (MACT);
- Offset Determinations (Including Federal Requirements)
- Emission Reduction Credit (ERC) Generation;
- Local Air District Source-Specific Rules;
- Toxics HRAs; and
- 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. Yorke will often suggest permit condition language to the permit engineer, since many processes are unique and are best understood by the operator. It is best to ask for the permit conditions in draft form prior to the issuance of an Authority to Construct (ATC) permit.