Alaska Air Permit Program

1
Alaska Air Permit Program

• Presented By
• Alaska Department of Environmental Conservation
• Improve and Protect Air Quality In AlaskaA
  Workshop for Environmental Staff in Native
  Villages U.S. Environmental Protection Agency,
  The Institute for Tribal Environmental
  Professionals,and The Alaska Inter-Tribal Council
• November 6 - 8, 2007

2
Air Permits

• The air permitting program provides a process to
  protect air quality from stationary source
  pollution. Air permits are legal documents that
  specify
• what construction is allowed
• Clean Air Act and Air Quality Control
  obligations
• what applicable emission limits must be met
• prohibitions
• monitoring, recordkeeping, and reporting
  requirements.

3
Objectives

• What kinds of sources get permitted?
• What sources typically need a permit in a
  village?
• How can I provide input on permits for local,
  regional, and industrial sources?

4
Source Types Requiring Permits

• Sources requiring permits
• Larger stationary sources
• Different permits required for different
• Source size
• amount and type of fuel burned
• potential to emit
• Sources not requiring permits include
• Home heating
• Vehicles
• Dusty roads

5
Typical Village Permits

• Power generator operations
• Some communities may have within or nearby
• Mines
• Seafood Processors
• Oil Gas
• Permit types include
• Title I (of Clean Air Act) Construction minor
  permits
• Title V (of Clean Air Act) Operating permit
• Owner requested limit
• Pre-approved emission limit
• General permit
• Open burning permit

6
Title I Construction Permits

• Construction Permit needed if there is a
• NEW major stationary source
• major modification
• major modification to a major source with
  pre-approved emission limits, or
• new stationary source or modification

7
Title V Operating Permit

• The permitting process following the construction
  permit process
• Applies to large power generators, examples are
• Bethel
• Nome
• Trident Sand Point
• Red Dog Mine
• Sources that emit
• 100 tons per year for criteria pollutants
• 10 tons per year of any hazardous air pollutant
• 25 tons per year of hazardous air pollutants in
  aggregate
• Department develops individualized operating
  permits for these sources

8
Owner Requested Limit

• Owner or operator of an existing or proposed
  stationary source may request an enforceable
  limit on their ability to emit air pollutants.
• An approved limitation can be used
• to determine allowable emissions for stationary
  sources
• to limit a stationary source's potential to emit
• Usually, an owner suggests an ORL to avoid
  pollutant levels that may trigger stronger
  requirements
• ORLs include
• P/V Arctic Star with Icicle Seafoods in St. Paul
• Kodiak Adventures, LLC, fish processing plant in
  Naknek
• USAF Airport in King Salmon

9
Pre-approved Emission Limit

• PAELs streamline the permitting process for small
  sources with predictable sources and emissions
• Limits for stationary sources with PAELs become
  effective the day after the department receives a
  request containing all the required information.
• Under these "preapproved" emission limits, no
  additional department approval is required.
• The owner and operator must comply with the limit
  while that limit is in effect.
• PAELs exist for diesel engines, including power
  generation
• Alaska Power and Telephone and Alaska Village
  Electric Cooperative have a number of generators
  working under PAELs.

10
General Operating Permits

• Available as a way to permit common sources
  emitting greater than 100 tpy of pollutant by
  using a predictable process
• General Operating Permits available for
• Diesel Electric Generating Plants of a certain
  size and capacity
• Asphalt Plants of a certain size and construction
  date
• Soil Remediation Units of a certain size and
  rated capacity
• General Permits Functioning as Minor Permits are
  available for these sources if not major sources
  (less than 100 tpy of regulated pollutant)
• Examples of facilities operating under general
  permit include
• Unalaska Valley Power
• Unalakleet Power Plant
• TPS Technology Soil Remediation Unit in Cold Bay
• Colaska, Inc. asphalt plant in Bethel

11
Permit Process

• Source must submit a permit application to the
  Alaska DEC
• The DEC reviews permit application
• If all information is provided after DEC
  thoroughly reviews the permit, DEC issues a
  completeness determination.
• Once a completeness determination is determined
• A general operating permit is issued
• Pre-approved emission limits are effective the
  day after the department receives all required
  information
• Title I and V (New Source Review and major
  emitters) permit applications undergo further
  analysis as permit writers craft unique permits
  specific to the facility

12
Opportunities for Input

• All operating, construction, minor, and owner
  requested limit permits have at least 30 days set
  aside for public comment after the draft permit
  is finished
• All comments must be considered and responded to
• EPA also has 45 days to review for approval or
  disapproval, providing another opportunity to
  comment
• Minor permits may be fast-tracked through a 15
  day notice period
• To get on the notice list, sign up at
• http//www.dec.state.ak.us/air/airsurvey/airsurvey
  .asp
• Notices are posted at
• http//www.dec.state.ak.us/air/ap/calendar.htm

13
Opportunities for Input

• Applications for major and minor general permits,
  PAELs, and open burn permits, do not go out for a
  public comment period
• Public comment was available during the
  development of general permits and PAELs
• Major general permits expire allowing for review
• Diesel Electric Generating Plants May 1, 2008
• Fuel Limited Diesel Electric Plants June 6,
  2010
• Asphalt Plants September 12, 2008
• Soil Remediation Units September 12, 2008

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What comments are most effective?

• By public notice deadline
• Specific to air quality
• In writing
• Suggest improvements to the permit