If you need information in order to obtain a permit, check out these links for an in-depth understanding of the process.
Notice of Contruction (NOC)
What is an NOC Permit?
An NOC permit is an approval that regulates the amount of air pollution emitted from a new air pollution source, or a modification to an existing source based upon applicable federal, state, and local air pollution regulations.
When is an approved NOC application required?
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In Washington state, all proposed new air pollution sources and modifications to existing sources must obtain an approved NOC permit from the pertinent control authority prior to construction, installation, establishment, or modification to a source.
What equipment triggers the NOC permit process?
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Air Containment Generating Equipment includes:
- Fuel burning equipment such as boilers or heaters.
- Refuse burning equipment such as incinerators or crematories.
- Processing equipment including asphalt plants, blast cleaning units, coffee roasters, concrete plants, degreasers, dry cleaning machines, electro-plating lines, fiberglass operations, gas stations, incinerators, rock crushers, spray booths, and storage tanks.
Air Pollution Control Equipment includes:
- Bag houses
- Cyclones
- Dust Collectors
- Filters
- Precipitators
- Scrubbers
- Absorbers
- Afterburners
What information is needed to complete an NOC application?
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Application forms may be obtained from the state or local air pollution control agency. Along with these forms, the following information should be submitted:
- Detailed schematics of the proposed action along with a project description and operatin conditions.
- A discussion of applicable air quality regulations, and a Demonstration of Compliance to these regulations.
- Demonstration of the proposed use of the Best Available Control Technology (BACT).
- Environmental checklist (or documentation showing that SEPA has been satisfied).
Who Submits the NOC application?
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The corporation, company, individual owner, or governmental agency that will operate the equipment must obtain an approved NOC.
How long will the process take?
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Once the application is turned in, there is a 30-day discovery period during which the appropriate agency can request additional information. Once this 30-day period is completed and all requested information is received, the appropriate air pollution control agency will review the information within 30 days and provide a preliminary determination.
A public commentary period of 30 days may be required after the preliminary determination. Once the public commentary period ends, the agency can make the final determination on the project. This process should take 40 to 60 days (after the receipt of a completed application), depending on the complexity of the application.
Tips on Expediting the NOC Process:
Plan, Plan, Plan
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When your facility is planning to add new equipment, modify a process, or relocate a plant, make all appropriate scheduling notes to assist the NOC process. If the plans are coordinated among all pertinent parties (such as local air pollution agencies, production personnel, etc.), you can ensure that all of your requirements are met so that no unwarranted delays sideline your project.
An initial meeting with all involved agencies allows them to become familiar with your project's requirements from the start, so that they can help you:
- Identify any potential concerns or roadblocks,
- Express scheduling needs,
- Understand the submittal requirements.
Proper identification of all applicable regulatory requirements
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This process may be time intensive, but it is extremely important. Identifying applicable regulatory requirements and demonstrating your facility's compliance plan will form the backbone of your permit's final conditions. Omissions or insufficient demonstration of compliance will only delay the approval process.
Proper emission estimation.
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Air pollution control agencies recommend the use of four methods to calculate emissions:
- EPA AP-42
- Vendor guarantees
- Source tests
- Mass balance
The selection of the proper estimation method hinges on the ability for the chosen method to be used consistently to demonstrate compliance to established permit limits.
Air Operating Permits (AOP)
What is Title V?
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Title V is a section of the Clean Air Act Amendments (CAAA) of 1990, which requires all states to develop an Air Operating Permit program for industrial and commercial sources of air pollution.
The Air Operating Permit program requires each source to submit a permit application which identifies all emission control requirements applicable to that facility. As stipulated in the CAAA, the state of Washington will issue permits that establish the enforceable emission limits and compliance schedule for each applicable facility. This permit allows the facility to operate legally under specific terms and conditions, and is subject to renewal every five years.
Why is an Air Operating Permit application needed?
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Who is affected by the Air Operating Permit program?
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Specifically, Air Operating Permits will be required for the following:
Major Sources of Hazardous Air Pollutant
This source group includes all Air Toxic Sources that have the potential to emit:
- 10 tons per year or more of a single hazardous air pollutant
- 25 tons per year or more of any combination of listed hazardous air pollutants
Major Sources of Criteria Pollutants Based Upon Either Actual or Potential Emissions:
This source group includes all sources of air pollutants in which the actual or potential emissions are 100 tons per year or more of the following criteria pollutants:
- Nitrogen Dioxide
- Carbon Monoxide
- Sulfur Dioxide
- Volatile Organic Compunds
- Particulate Matter
Prevention of Significant Deteriorization Source or New Source Reviews
Sources that have received or are required to have a pre-construction permit under the requirements of the Prevention of Significant Deteriorization (PSD) program or the Non-attainment Area program must obtain a permit.
Minimum Application Requirements
General Information
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The following information must be included in an Air Operating Permit application:
- Company name
- Facility location
- Operational history
- List of responsible compliance representatives
Description of Facility
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The following information must be included in an Air Operating Permit application:
- List of products produced at the facility
- Process means
- Production processes
Emission-Related Information
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The following information must be included in an Air Operating Permit application:
- Description of all significant emission units operated at the facility
- Description of all emission pollutants
- Description of emission rates (in tons per year)
- Identification of all applicable regulatory requirements
Compliance Test Methods
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The following information must be included in an Air Operating Permit application:
- Description of compliance methods for the facility
- Description of compliance procedures for the facility
The compliance methods must be based on the standard test methods specified by the applicable requirements.
Compliance Plan & Schedule
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The following information must be included in an Air Operating Permit application:
- Description of compliance plan for facility's methods of achievement
- Description of compliance plan for facility's methods of maintenance
The compliance plan must describe the facility's current compliance status. If the facility is not in compliance, the plan must include a description and schedule of the facility's compliance acheivement.
Compliance Certification
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The permit application must include a schedule for submitting compliance certification.
Streamlining the Title V Permit Process
Build in operating flexibility
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Present a variety of operating scenarios that cover any changing facility conditions (i.e. seasonal scenarios, etc.). This flexibility will allow the facility to "switch scenarios" without revising the permit.
Minimize record-keeping and monitoring requirements
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By grouping emission units and activities with similar enforcement requirements, a single record keeping procedure can be used for the entire emission unit group.
Paraphrase application requirements and reference existing permit conditions
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The application can be simplified by using regulatory citation numbers along with a summary of the requirements.
Revise new sources review requirements
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Only federally-enforceable permit conditions are required in an Air Operating Permit. Therefore, non-federally-enforceable requirements need not be used for the application's preparation.
Develop a checklist of insignificant emission sources
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A simple checklist of insignificant emission sources is all that is necessary for the permit.
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