AIR QUALITY REGULATORY ISSUES ASSOCIATED WITH RESOURCE RECOVERY

Transcription

1 AIR QUALITY REGULATORY ISSUES ASSOCIATED WITH RESOURCE RECOVERY DONALD M. POMPELIA Camp D resse r & McKee Inc. Boston, Massach usetts The paper reviews the air quality regulatory issues affecting resource recovery facilities. It addresses current federal and state emission standards along with those emission limitations required in source permitting activities, including Best Available Control Technology and Lowest Achievable Emission Rate. Permitting requirements imposed on facilities by state and federal authorities are also discussed. INTRODUCTION Implementation of an operational resource recovery facility is dependent on meeting air quality regulatory requirements established at the federal, state, and sometimes local, levels. The level of analysis required in the permitting activities is based on several factors, including facility design charagteristics, the quality of the ambient air at the plant site and the area of predicted impact, as well as the extent of the air quality monitoring network in the vicinity of the plant. The basic goal of the air quality permitting process is to promote clean air by ensuring that air quality in areas where ambient pollutant levels meet standards (attainment areas) does not significantly deteriorate while maintaining a margin for future growth, and by providing a means of source growth in areas where existing pollutant levels violate ambient standards (nonattainment areas) by demonstrating progress toward the achievement of these standards. A listing of the National Ambient Air Quality Standards (NAAQS) is contained in Table 1. Air quality in attainment areas is protected by the Prevention of Significant Air Quality Deterioration (PSD) regulations (40 CFR 52.21) which focus on new and modified sources creating large increases in the emission of certain pollutants. Nonattainment areas benefit from New Source Review (NSR) requirements mandated by developments in a specific State Implementation Plan (SIP). A SIP must provide measures to bring ambient pollutant levels into compliance with the standards by certain dates and, once achieved, maintain levels below the standards. This may be accomplished through emission limitations, compliance schedules, transportation controls, and pre construction review of pollutant sources. Because the same area may be classified as attainment for some pollutants and nonattainment for other pollutants, both PSD and NSR may apply. SOURCE EMISSION LIMITATIONS Federal emission limitations have been formulated for certain welldefined sources of air pollution. Likewise, state and local air pollution control agencies have imposed additional limitations for various source categories to meet the specific needs of their geographic areas as provided for in Sec. 116 of the Clean. Air Act (as amended). FEDE RA L EMISSION LIMITATIONS The federal emission limitations mandated by the Clean Air Act (CAA) are the New Source Performance Standards (NSPS) and the National Emission Standards for Hazardous Air Pollutants (NESHAPS). The authority for enforcement of the federal emission limitations, historically held by EPA, is now being turned over to the individual state air pollution control agencies. 320

2 CORRESPONDING FEDERAL STANDARDS Primary Secondary Units ug/m3 (1) All maximum values are values not to be exceeded more than once a year (Ozone std. not to be exceeded during more than one day per year). (2) Gaseous concentrations are corrected to a reference temperature of 25 C and to a reference pressure of 760 millimeters of Mercury. TABLE 1 NATIONAL AMBIENT AIR QUALITY STANDARDS POLLUTANT AVERAGING PERIOD STATISTIc (1) Cone. Units(2) Cone. _ SULFUR DIOXIDE (S0 2 ) 12 Consecutive Mos. A.M. (Arith. Mean of 24 hr. avg. concen.) 24HR. MAX ug/m3 ug/m3 HR MAX. 3 CARBON MONOXIDE 8HR. MAX. 10 mg/m3 10 mg/m3 (CO) IHR. MAX. 40 mg/m J 40 mg/m 3 OZONE Vol tv (PHOTOCHEMICAL OXIDANTS) HYDROEARBONS ( 3 ) (NONMETHANE) IHR. MAX HR MAX. 160 (69 AM) ug/m ug/m3 ug/m3 160 ug/m3 NITROGEN DIOXIDE (N0 2 ) 12 Consecutive Mos. A.M. 100 ug/m3 100 ug/m3 TOTAL SUSPENDED PARTICULATES (TSP) 12 Consecutive Mos. G.M. (Geometric mean of 24 hr. average concentrations) 75 ug/m3 60(4 ) ug/m3 24HR. MAX. 260 ug/m3 150 uglm3 LEAD (Pb) 3 Consecutive Mos. MAX. 1.5 ug/m3 1.5 ug/m3 ( 3 ) T be used as a guide in devising implementation plans to achieve the oxidant standard. (4) As a guide to be used in assessing implementation plans to achieve 24hour standard. Source: 40 CFR 50.

3 The NSPS were established for new and modified sources to reflect the degree of emission reduction achievable applying the best technological control system considering the financial impact of the system. They were to be established for any stationary source which would contribute significantly to air pollution which could endanger public health or welfare. By law, EPA is required to review these standards every four years and, if needed, revise them. A NSPS (40 CFR 60 Subpart E) limiting the emission of particulate matter from incinerators capable of charging more than 45 metric tons (t) per day (50 TPD) of refuse has been established. This pertains to the size of the individual combustion unit and not the aggregate capacity of all installed units at a given location. Since resource recovery facilities burn refuse, they are considered to be in the same source category as municipal incinerators and therefore are subject to that particular NSPS. The NSPS applicable to refuse burning resource recovery facilities states that no facility shall discharge any gases which contain particulate matter in excess of 0.18 gm/dscm (0.08 gr/dscf) corrected to 12 percent CO2 The source owner is also required to record daily charging rates and hours of operation of the facility. Performance tests to verify compliance with the particulate standard for incinerators must be conducted within 60 days after achieving full capacity operation, but not later than 180 days after the initial startup of the facility (40 CFR 60.8). The EPA reference methods (40 CFR 60 Appendix A) to be used in connection with incinerator testing include: EPA Method 5 for the concentration of particulate matter and associated moisture content EPA Method 1 for sample and velocity traverses EPA Method 2 for velocity and volumetric flow rate EPA Method 3 for gas analysis and calculation of excess au A NSPS (40 CFR 60 Subpart 0) has been developed for sewage sludge incinerators which limits the discharge of particulate matter to a maximum rate of 0.65 gm of particulate per kg dry sludge input (1.30 lb/ton). Also, the effluent gases are restricted to a maximum opacity of 20 percent. Refuse and sewage sludge can be cocombusted in varying ratios of quantities. In these cases, the applicability of the NSPS can be determined from Table 2. It should be noted that EPA is considering a modification of the. NSPS for nonfossil fuel fired industrial boilers. "'Personal communication between the au thor and Nick McCamy, USEPA Region I, April """Personal communication between the author and Ben Mykijewycz, USEPA Region III, March It it expected that this will include waste fired systems thereby affecting the NSPS applicable to resource recovery facilities. The NESHAPS were established to control air pollutants for which no ambient air quality standard has been developed and which could be anticipated to result in an increase in mortality or in serious irreversible illness. Four such pollutants have been identified to date, namely vinyl chloride, mercury, beryllium and asbestos. The standards for abestos and vinyl chloride are source specific and do not apply to the incineration of municipal solid waste. There is some controversy concerning the applicability of the beryllium NESHAPS (less than 10 g/day [0.022 lb/day]) for solid waste incineration. According to the regulations, incinerators burning a waste containing beryllium that is generated from a specific process or operation specified in the regulation would be subject to the beryllium NESHAPS. However, interpretation of the regulation by regional EPA officials*'** indicated that incinerators firing municipal solid waste not specifically derived from one of these beryllium process operations are not subject to the beryllium NESHAPS. This opinion was also voiced by the EPA project officertt responsible for revising the operation. It is recommended that a decision on applicability of this regulation be confirmed by the appropriate reviewing authority with regard to any specific permitting requirements, Mercury emissions from incinerators firing sewage sludge are specifically regulated under the NESHAPS (40 CFR 61.5). Therefore mercury emissions from any facility that cofires sewage sludge with refuse would be limited to 3,200 g (7.05 lb) of mercury per 24 hr period. STATE EMISSION LI MITATIONS Every state allowing the combustion pf refuse has a specific emission standard regulating particulate emissions from refuse burning facilitiest. A surveyt of state regulations indicates that 23 states have standards that either reference the NSPS or have exact copies of the NSPS written into their regulations. Nine states have standards less stringent than the NSPS. Three states have more stringent regulations Massachusetts and Illinois, 0.05 grains/dscf (0.11 g/dscm) and Maryland, 0.03 grains/dscf (0.07 g/dscm) at 12 percent CO2 The remaining states have emission standards that are a function of the amount t Helfand, R. M., "A Review of Standards of Performance for New Stationary Sources Incinerators," Office of Air Quality Planning and Standards, U. S. EPA, 450/379 09, Research Triangle Park, N.C., March ttpersonal Communication between the author and John Copeland, U. S. EPA, Research Triangle Park, North Carolina, March

4 TABLE 2 APPLICABILITY OF NSPS FOR COINCINERATION OF REFUSE WITH SEWAGE SLUDGE t Sewage Sludge (percent) Municipal Refuse (percent) Incinerator Charging Rate Applicable Subpart (40 CFR 60) >50 Tons/Day Total Waste Subpart a or Proration of 0 and E >50 Tons/Day Total Waste Subpart E o 100 < 50 Tons/Day Municipal Refuse None 100 o Any rate Subpart <50 Tons/Day Total Wastes, >1.1 Dry Tons/Day Sewage Sludge Subpart <50 Tons/Day Total Wastes, <1.1 Dry Tons/Day Sewage Sludge Subpart <50 Tons/Day Total Wastes <1.1 Dry Tons/Day Sewage Sludge None Note: 50 tons/day = 45 t/day, 1.1 tons/day = 1.0 t/day of waste being incinerated. Based on a 300 1PD (272 tpd) furnace burning refuse with a higher heating value of 4450 Btu/ lb (10,350 l/t), of these remaining states, 11 would have less stringent standards and Delaware, Nevada and North Carolina would have more stringent standardst. Although the District of Columbia has a particulate limitation equal to 0.03 gr/dscf (0.06 gm/dscm) at 12 percent CO2, new incinerators are banned. Also, New Mexico explicitly prohibits incineration. The existing NSPS does not contain any provision which limits the stack effluent's opacity. However, a surveyt of state regulations indicate that Delaware is the only state that has not adopted an opacity standard, and of the remaining states, all but two have opacity standards more stringent than 20 percent (No.1 on the Ringelmann chart). Source: Helford, R.M., "A Review of Standards of Performance for New Stationary Sources Incinerators," Office of Air Quality Planning and Standards, U.S. EPA, 450/379009, Research Triangle Park, North Carolina, March In summary, it appears that the current NSPS is identified by most states as reflecting their most stringent incinerator emission standards. However, the fact that some states have more stringent regulations than the NSPS may indicate a trend toward the tightening of the standard. SOURCE PERMITTING REQUIREMENTS Source permitting has traditionally been carried out at the federal, state, and sometimes local levels. However, as with the NSPS and NESHAPS, EPA is delegating responsibility of PSD review and permit issuance to the state level. New Source Review is also carried out at the state level under requirements mandated by each individual state reflecting that specific area's concern. PSD REVIEW PSD review requirements apply to major sources locating in an area designated as attainment or unclassifiable 323

5 TABLE 3 SIGNIFICANT EMISSION RATES Pollutant EMISSION RATE (tons/year) (t/yr) Carbon monoxide Nitrogen oxides Sulfur dioxide Total suspended particulates Ozone (Volatile Organic Compounds) ( l) Lead Asbestos Beryll i um Mercury Vinyl chloride Fluorides Sulfuric acid mist Total reduced sulfur (incl uding H S) 2 Reduced sulfur (including H S) 2 Hydrogen sulfide (l) The terms ozone and photochemical oxidants are used interchangeably since. ozone is the compound measured in the ambient air which is considered to be representative of ambient concentrations of photochemical oxidants in general. The compounds are formed through several complex photochemical reactions that occur between other precursor air contaminants (primarily nitrogen oxides (NO ) and volatile organic compounds (VOCs)) in the presence of sunlight, Qith possibly a third body needed to stabilize the reaction. Consequently, ozone is a secondary pollutant formed by interactions of primary pollutants, and is not directly emitted in any discernable amount from refuse burning facilities. Therefore from a regulatory standpoint VOCs are the pollutants regulated to reduce ambient ozone concentrations. Source: 40 CFR (b) (23) 324

6 under Section 107 of the CAA for any criteria pollutant. Applicability is determined in two steps: source and pollutant applicability determinations. Source applicability is defined by the size of the facility and the quantity of emissions emitted. The proposed resource recovery facility would be classified as a municipal incinerator according to the Standard Industrial Classification (SIC) Code and is one of the sources specifically referenced by the PSD regulations. Only major sources of air pollution are subject to the PSD regulations. If the resource recovery facility burns over 250 tons of refuse per day (227 tpd) and has the potential to emit greater than 100 tons/year (91 t/yr) of any PSD pollutant, it would be considered a major source and therefore subject to PSD review. If a facility charges less than 250 tons of refuse per day (227 tpd), it would have to emit greater than 250 tons/year (227 t/yr) of any pollutant to be classified as being major. For sources cofiring refuse and sewage sludge, the same criterion would be used to determine whether the source is major regardless of the quantity of sludge fired. Pollutant applicability is determined by comparing the potential emissions with specified significant emission rates. If the proposed source emits pollutants which are designated as attainment or unclassifiable (or any other PSD regulated pollutant that is not subject to an ambient air quality standards), and it emits those pollutants at a rate greater than the significant emission rate, the source is subject to PSD review for those pollutants. A listing of all PSD pollutants and their respective significant emission rates is depicted in Table 3. To determine applicability, prediction of pollutant emission rates must be determined. Emissions from a refuse combustion facility are influenced by several factors. These include facility design and operating features; type and efficiency of air pollution control equipment; and characteristics of the refuse fuel. Information on the first two factors and their influence on pollutant emissions is usually available or can be reasonably developed, but the effects of waste characteristics on pollutant emissions are often more difficult to predict and subject to sometimes wide variations. The emission of some pollutants (such as carbon monoxide, hydrocarbon, and nitrogen oxides) are heavily influenced by the combustion system design and operation, while emissions of other pollutants (such as sulfur dioxide, hydrogen chloride, and heavy metals) are more dependent upon the specific characteristics of the waste that is burned. While relating waste characteristics to emission rates is an ideal way of predicting emissions, its application for most projects of this type has been very limited. This is principally due to the lack of data correlating refuse composition to stack emissions; and to the lack of uniform waste characterization data which could permit detailed analytical prediction of specific pollutants. Because of these limitations, the most feasible approach for predicting emission levels appears to be the use of observed pollutant emission rates from similar operating facilities. The potential emissions used to determine source and pollutant applicability are calculated based on the maximum design capacity of the facility incorporating the anticipated pollution control devices. That is, the potential emissions are based on full system processing capacity at yearround continuous operation. Although a facility operating with a continuous refuse supply may only be anticipated (or guaranteed) to operate at nominal rated availability (typically between 80 to 85 percent of full capacity), emissions are based on 100 percent availability unless the system owner is willing to accept a permit restriction limiting source operation to less than this 100 percent value. It may be possible to exempt the proposed facility from PSD review by reducing the potential emissions (by increasing the air pollution control efficiency or limiting system capacity) below the 100/250 tons/year (91/227 t/year) cutoff level. This decision is dependent upon several factors unique to each individual source, and therefore these concerns must be considered before a decision is made. Once the applicability of the PSD regulations is determined, future permitting activities may be defined. If it is determined that the source is not subject to the PSD regulations, then a letter requesting a nonapplicability determination must be sent to the reviewing authority for an official determination. If, however, it is determined that the source would be subject to a PSD review, further permitting requirements must be defined. The requirements consist of performing a Best Available Control Technology (BACT) analysis, an air quality analysis, and performing pre construction ambient air quality monitoring (if necessary). BACT is a casebycase analysis of alternative air pollution control technologies for each source subject to the PSD regulations. Each pollutant emitted from the facility at a rate greater than the PSD significant emission rate (Table 3) is subject to a BACT review. Since the BACT analysis determines the control strategy for a particular source/pollutant, it will ultimately determine the allow able emissions from a source that cause air quality related impacts. BACT can never be less stringent than an appro priate local, state or federal emission limitation for a source. The BACT analysis provides the rationale for select ing the control strategy to best satisfy the individual constraints of the area surrounding the site when consider ing the impacts on energy, economic and environmental 325

7 issues. A primary purpose of conducting the BACT analysis is to minimize any further degradation of air quality (psd increments), thereby allowing the opportunity for future economic growth. A BACT analysis and the results it produces provide the majority of the input data for the other two required PSD analyses: the air quality impact analysis, and the determination of preconstruction monitoring. As noted earlier, results of the BACT analysis may reveal to the applicant that application of certain emission controls may exempt the proposed facility from PSD review altogether. Historically, the common air pollution control devices typically considered in the BACT analysis include electrostatic precipitators and fabric filters for particulate control, possibly combined with dry scrubbing units for S02 and acid gas control. Even though solid waste has a relatively low sulfur content (typically <0.1 to 0.5 percent), application of scrubbing units is becoming a more serious concern due to potential impacts of acid gases. Although not widely practiced in the U.S., S02 and acid gas control is being encouraged by some state reviewing agencies. Also, many full service vendors now offer limited guarantees on the operation of dry scrubbing units for acid gas removal. A review of recent BACT Determinations*,** indicates recent BACT decisions for particulates at 0.03 gr/dscf (0.07 g/dscm) to 0.05 gr/dscf (0.11 g/dscm) at 12 percent CO2. BACT determinations for other pollutants have generally reflected combustion controls inherent to system operation and waste characteristics (low sulfur content of refuse). The next step in the PSD analysis is to conduct an ambient air quality analysis. This analysis determines the impact of the proposed facility upon ambient air quality. This analysis insures that the NAAQS will not be violated and that the PSD increments will not be exceeded. PSD increments, established in the CAA to control growth, have been formulated for TSP and S02 and are listed in Table 4. These increments represent the maximum concentration that the total of all major sources permitted in an area are allowed to add to the baseline concentration of the area providing the NAAQS are not exceeded. Calculation of the baseline concentration can be a difficult task as it is dependent on several source contributors in the general vicinity of the proposed facility. *BACT/LAER CLEARINGHOUSE A Compilation of Control Technology Determinations, Office of Air Quality Planning and Standards, USEPA, Research Triangle Park, N.C., May **BACT/LAER CLEARINGHOUSE, Office of Air Quality Planning and Standards, USEPA, Research Triangle Park, N.C., April Generally speaking, the baseline concentration is the adjusted ambient concentration at a given location when the first complete PSD application is submitted. Air quality simulation modeling using EPAapproved modeling techniques would be performed to predict source impacts on air quality. An air quality impact analysis would have to consider variations in load conditions for maximum shortterm pollutant impacts. That is, as the charging rate fluctuates between maximum and minimum loads, the exhaust gas flow rate and therefore stack exit velocity would fluctuate as well. These variations would affect plume rise substantially, as well as the resulting ground level pollutant concentrations. Additionally, the boiler maintenance schedule will also affect pollutant dispersion and must also be considered in the impact analysis. This is due to the fact that a recently overhauled boiler would be subject to maximum heat transfer which would increase steam production while minimizing the heat lost to the exhaust gases. This would lead to a lower plume temperature and therefore reduced buoyancy, decreasing plume rise, and increasing ground level pollutant concentrations. Both of these factors, charging rate fluctuations and boiler maintenance, have the potential for increasing shortterm pollutant concentrations, possibly leading to maximum shortterm pollutant impacts. An additional impact analysis would also be performed to assess the source's impact on Class I areas (pristeen areas) as well as on visibility, soils and vegetation having significant commercial or recreational value. This impact could occur as a result of facility operation or associated commercial, residential and industrial growth. In making compliance determinations with ambient standards and increments, it is necessary to assess existing air quality levels for each applicable air pollutant emitted from the proposed source. Continuous preconstruction ambient air quality monitoring would thus be required to define existing pollutant levels. Existing ambient air quality data determined to be representative of the source location and impact area can often be utilized. However, an applicant may have to conduct such monitoring if existing monitoring data are insufficient. The reviewing agency, however, has the option of requiring an applicant to perform monitoring. In general, if the source's projected impacts are less than the significant monitoring concentrations listed in Table 5, or if the background concentration for any pollutant is below the respective significant monitoring concentration, then the applicant would be exempt from performing preconstruction ambient air monitoring. If these criteria cannot be met, the monitoring requirement may still be waived if the applicant can show that the PSD increments and NAAQS are not exceeded using 326

8 TABLE 4 PSD AIR QUALITY INCREMENTS Class 1 Pollutant Maximum Allowable Increase (micrograms per cubic meter) Particulate Matter: Annual Geometric Twentyfour hour mean maxlmum 5 10 Sulfur Dioxide: Annual arithmetic mean Twentyfour hour maximum Threehour maximum Cl ass II Poll utant Maximum Allowable Increase (micrograms per cubic meter) Particulate Matter: Annual Geometric Twentyfour hour Sulfur dioxide: mean maxlmum Annual arithmetic mean Twentyfour hour maximum Threehour maximum Class III Poll utant Maximum Allowable Increase (micrograms per cubic meter) Particulate matter: Annual geometric Twentyfour hour mean maxlmum Sulfur dioxide:. Annual arithmetic mean Twentyfour hour maximum Threehour maximum

9 TABLE 5 SIGNIFICANT MONITORING CONCENTRATIONS Pollutant Air Quality Concentration (ug/m 3 ) and Averaging Time Carbon monoxide 575 (8hour) Nitrogen dioxide 14 (annual) Sulfur dioxide 13 (24hour) Total suspended particulates 10 (24hour) Ozone (1) Lead 0.1 (3mont h) Asbestos (2) Beryll i um (24hour) Mercury 0.25 (24hour) Vinyl chloride 15 (24hour) Fl uorides 0.25 (24hour) Sulfuric acid mi st (2) Total reduced sul fur (including H 2 S) (3) Reduced sulfur (including H 2 S) (3 ) Hydrogen sul fide 0.2 (1hour) (I) No specific air quality concentration for ozone is prescribed. Exemptions are granted when a source1s VOC emissions are <100 tons/year (91 t/yr). (2) No acceptable monitoring techniques available at this time. Therefore, monitoring is not required until acceptable techniques are available. (3) No acceptable monitoring techniques available at this time. However, techniques are expected to be available shortly. Source: Ambient Monitoring Guidel ines for Prevention of Significant Deterioration (PSD), EPA450/480/012; Revised February 1981, USEPA, Research Triangle Park, N.C. 328

10 actual worst case monitoring data from monitoring stations located outside the general site/impact area. In any event this exemption from pre construction ambient air monitoring is not automatic. Rather, it is up to the discretion of the reviewing authority. Regardless of the source of data, the applicant must provide at a minimum, ambient monitoring data that represent air quality levels in the year preceding the PSD application. There are substantial time requirements associated with conducting an ambient air quality monitoring program. Typically, monitoring will last four to 12 months, plus the time required for implementing the program and processing the data. Therefore, it is important to determine as soon as posssible if ambient air quality monitoring will be required. NEW SOURCE REVIEW The New Source Review requirements are developed by individual states to regulate those pollutants emitted by facilities located in non attainment areas. Conditions incorporated into the NSR regulations generally require that the nonattainment pollutants emitted by the source be controlled to the greatest degree possible, that an emission offset be obtained from an existing source, and that there will be progress made toward achieving the NAAQS without creating any new violation. Sources emitting the nonattainment pollutants below a specified rate (typically 50 or 100 tons/year (45 or 91 t/year), can be exempt from the requirements of NSR (depending on the state). The NSR regulations are implemented to enforce the measures developed in a particular SIP. As part of the SIP, all of the requirements specified in NSR must be approved by EPA (to determine adequacy) and therefore become federally enforceable. Each state was required by EPA to prepare a SIP to bring air quality levels into compliance with the NAAQS by December 31, However, for carbon monoxide and ozone, provisions exist to obtain an extension of the attainment date up to December 31, This SIP therefore is reviewed by EPA to insure it is adequate to provide for attainment of the NAAQS by the dates specified above. If any deficiencies in the SIP submittal are found to exist, EPA will be required to disapprove the plan. Disapproval could trigger a moratorium on the construction and modification of major stationary sources of the nonattainment pollutant. O'Connell, W. L., Stotler, C. G., and Clark, R., "Emissions and Emission Control In Modem Municipal IncineratoIS," presented at 1982 National Waste Processing Conference. pp The provisions of NSR generally include the application of Lowest Achievable Emission Rate (LAER) control technology. LAER is defined as the most stringent emission limitation adopted by any state or the most stringent emission limitation which is achieved in practice, whichever is lower. Although the most stringent particular limitation contained in any state's SIP is currently 0.03 gr/dscf (0.07 gj dscm) at 12 percent CO2 (Maryland and the District of Columbia), it is believed that a lower particulate emission rate is achievable based on source testing of similar operating facilities (Nashville and other ). Consequently, recent LAER determinations on resource recovery facilities have reflected these data establishing a LAER for particulates at gr/dscf (0.06 gjdscm) at 12 percent CO2 (Tampa, Florida; DER Permit/Certification No. AC ). It should be noted that LAER is constantly being revised, especially for TSP emissions. Before a major source can operate in a non attainment area, the permit applicant must obtain an emission offset by reducing emissions of the nonattainment pollutants from other existing sources. The emissions from the new source, in conjunction with the emission reductions from existing sources, must decrease overall emissions and show progress toward complying with the NAAQS. All offsetting emission reductions are legally binding and enforceable. Emission offsets must be of the same pollutants and obtained in accordance with the specific state's requirements. Some states allow a postponement in obtaining offsets. If the proposed facility is a resource recovery facility which utilizes solid waste to provide more than 50 percent of the heat input necessary to operate the facility, it may be exempt from having to obtain offsets prior to the issuance of the operating permit. This exemption is only granted if the applicant for the proposed source demonstrates that best efforts were made to obtain the offsets and that these efforts were unsuccessful, that the application has secured all available offsets, and that the applicant will continue to seek offsets and apply them when they become available. PERMIT SCHEDULE The total time required to prepare a complete PSD permit application would be about three to six months, excluding an ambient monitoring program. The inclusion of such a program could extend preparation time another 4 to 12 months (including monitoring time). Regulatory review of the permit could take up to one full year based on requirements developed by EPA as part of the Consolidated Permit Regulations (40 CFR ). This, however, is the maximum time allotted and the review period can often be shortened. In addition, states delegated PSD authority may shorten review time schedules 329

11 depending on their individual permitting programs. This is typically the case in the state's review of an NSR application. It should be noted that EPA may propose a set of changes to streamline the permitting procedures described in the Consolidated Permit Regulations (48 FR 14147). PERMIT CONDITIONS Many features of the permit application (equipment specifications, proposed pollutant emission rates, operating procedure, etc.) become conditions of the permit. These limit operation of the source in a manner prescribed by the applicant in the permit package. Record keeping and formal reporting procedures describing facility opera. tion and testing results are also listed as permit conditions. In addition to compliance testing for particulates under the NSPS described earlier, additional pollutant stack monitoring may be required (both compliance testing and possibly continuous monitoring). Also, the reviewing agency has the option of requiring postconstruction ambient air monitoring to determine the effect the source has on ambient air quality. This option is usually only exercised when the potential for compliance problems exists. CONCLUSIONS Many largescale resource recovery projects would be. subject to a rigorous review under PSD and NSR procedures. This review includes many casebycase regulatory determinations that can seriously impact the economical and technical feasibility of the project. Because all appropriate permits must be obtained before facility construction can begin, and in some cases prior to financing, it is imperative to develop a successful permitting approach. Thus, a complete understanding of the permitting process is essential. A substantial lead time for obtaining the air quality permits is usually required because of the complexity and length of the review procedure involved. Preconstruction ambient air monitoring could extend the lead time another four to 12 months. While it is true that guidance on the permitting process may be obtained from similar permitting efforts for other facilities, no two approaches are identical, and a good working relationship with the reviewing agency is necessary. Key Words: Air. Combustion. Environment Institutional Pollution. Refuse. Regulations 330