Preparing A Permit Application
Aaron Matijow
Application Processing Timeline for
Minor Sources (Non-Title V)
Refer to MCAPCO Regulation 1.5215 –
“Application Processing Schedule”
• MCAQ will review the air permit application for
completeness within 45 days of receipt.
• Permit will be issued within 90 days* of receipt
of complete application.
*This time includes the mandatory 15-day public comment period
Public Notice
• Required by MCAPCO Regulation 1.5213 – “Action of
Application; Issuance of Permit”
• Public Notice is provided by advertising permit approvals on
the Air Quality Commission (AQC) agenda.
• The AQC meets on the 4th Monday of each month.
• Public comment is received during the meeting and 15 days
afterward.
A 15 day public comment period is not required for changes in
insignificant activities, ownership/name changes, permit reissuance
due to new/modified regulation or modificaitons that do not result in
an increase in emissions.
Application Processing Fees
See MCAPCO 1.5231
For a new facility or a facility
expanding their footprint…
Zoning Consistency Determination
• Submit a written request for a Zoning Determination
letter for your facility to the appropriate Planning /
Zoning Department.
• Include the following information with the request letter:
▫ A “Zoning Consistency Determination Form” and,
▫ A copy of the completed “General Information” air permit
application form (ie. Form S1 for gasoline dispensing
facilities, Form T1 for parking facilities, or Form A1 for all
other air pollution facilities).
• Submit the original, signed copy of the Zoning
Determination to MCAQ or a copy of the request letter
submitted to the Zoning Department
Application Forms
Zoning Consistency Determination
Application Forms Overview
• Where do I get them?
• Which forms do I need?
• Helpful appendices and instructions
Application Forms
Where do I get them?
• Through the mail
• Via email
• From the internet
http://airquality.charmeck.org
Application Forms
Application Forms
Web Page View
Application Forms
What Forms do I need?
• Start with the Application Forms Matrix located
in the General Instructions:
REQUIRED AIR PERMIT APPLICATION FORMS MATRIX
NON-TITLE V APPLICATIONS
A1
A2
NEW FACILITY
X
ADMINISTRATIVE
AMENDMENT
X
MODIFICATION
X
LIKE-FOR-LIKE
REPLACEMENT
X
X
CHANGE OF
OWNERSHIP
X
X
A3
A4
A5
A6
SECTION
B
SECTION
C
SECTION
D
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
E1
E2
E3
E4
Application Forms by Sections
•
•
•
•
•
•
•
•
Section A (facility information)
Section B (process equipment)
Section C (control equipment)
Section D (emission estimations)
Section E (Title V facilities)
Section M (air dispersion modeling)
Section S (stage I/II)
Section T (transportation sources)
Application Forms
Helpful Items – General Instructions
Application Forms
Helpful Items – Completeness Checklist
Application Forms
Helpful Items – Regulated Pollutant List
Permit Application Common
Errors/Omissions
• No application processing fee
• Little or no supporting documentation
▫ Emission Calculations
▫ Manufacturer’s Specs for Equipment
▫ Control Efficiency
• Inaccurate emission summaries
• Rule applicability errors
• Zoning verification form omission
Application Forms
Common Errors/Omissions
• A-1 form not signed
• No recycle reduction form (A-6)
• All required forms are not completed and
submitted
• Complete modeling demonstration
Example of a Permit Application
• A new facility that has:
▫ 20 MMBtu/hr boiler fueled by natural gas or No. 2
fuel oil
▫ Widget Manufacturing Process
 Widget Maker controlled by a baghouse
 Parts Cleaner
▫ Two (2) Oil Storage Tanks
 One 12, 000 gallon No. 2 fuel oil UST
 One 275 gallon waste oil tank
Example Permit Applications (cont.)
A1
A2
NEW FACILITY
X
ADMINISTRATIVE
AMENDMENT
X
MODIFICATION
X
LIKE-FOR-LIKE
REPLACEMENT
X
X
CHANGE OF
OWNERSHIP
X
X
A3
A4
A5
A6
SECTION
B
SECTION
C
SECTION
D
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
E1
E2
E3
X
Use form matrix located in the Air Permit Application General
Instructions to determined what forms are needed:
• A1, A4, A5, A6
• Section B
• Section C
• Section D
Further analysis needed to determine which from Section B, C and D
E4
Example Permit Applications (cont.)
Section B – Emission Sources
B – Emission Source (Required for All Sources)
B-1 – Emission Source (General)
B-2 – Emission Source (Fuel Combustion)
B-2g – Emission Source (Internal Combustion Engines)
B-3 – Emission Source (Incinerator)
B-4 – Emission Source (Coating/Finishing/Printing)
B-5 – Emission Source (Manufacture of Chemicals/Coatings/Inks)
B-6 – Emission Source (Storage Silos/Bins)
B-7 – Emission Source (Liquid Storage Tank)
Section C – Control Devices
C-1 – Control Device (General)
C-2 – Control Device (Fabric Filter)
C-3 – Control Device (Electrostatic Precipitator)
C-4– Control Device (Thermal or Catalytic Incinerator)
C-5– Control Device (Cyclone/Multicyclone)
C-6 – Control Device (Adsorber)
C-7– Control Device (Scrubber)
C-8 – Control Device (Condenser)
Example Permit Applications (cont.)
Section D – Emission Calculations
D-1-1 – Master List of Materials
D-1-3 – Determination of Pounds VOC per Gallon Solids (MCAPCO 2.0900)
D-1-4 – Total VOC Emissions Calculations (Mass Balance Method)
D-1-5 – Toxic and Hazardous Air Pollutant Emission Calculations (Mass Balance Method)
D-2-1 – Emission Calculations By Methods Other Than Mass Balance as Calculated on Forms D1-4
D-2-2 – Summary of Emissions form the D2-1 Forms (Methods Other Than Mass Balance)
D-3-1 – Facility-Wide Summary of Criteria Pollutant, TAP and HAP Emissions
Example Permit Applications (cont.)
• It’s important to notice that two “B” forms are
required for each process
▫ Boiler – B (required for all sources) and B-2 (fuel
combustion source)
▫ Widget Manufacturing – B (required for all
sources) and B-1 (general)
• The B1, B2, etc. compiles process specific
information, emissions information and
documents rule applicability
B Form
Form B-1 (General) Form
Form B-2 (Fuel Combustion)
Form B-7 (Liquid Storage Tanks)
Form C-2 (Fabric Filter)
Form D-3-1 (Facility-Wide Emission
Summary)
Example Permit Applications (cont.)
• Boiler emissions are calculated by using the
natural gas and fuel combustion spreadsheet
• Parts cleaner VOC emissions are determined by
the material balance method, which based upon
product usage and MSDS information
• Widget making PM emissions are based upon
process specific knowledge, manufacturer
specifications and/or performance testing of a
similar unit.
Don’t worry, emission calculation spreadsheets
will be covered later!!
Things to Remember
• Read and use the instruction and appendices for
assistance
• Use of the completeness checklist (Appendix A) will
minimize the risk of your application review being
delayed
• Use emission estimation tools from the MCAQ
website and EPA as needed
• Be mindful of the application processing timelines
and plan proactively
• Contact your MCAQ representative for assistance
▫ Firstname.lastname@mecklenburgcountync.gov
▫ 704-336-5430
Questions??