Page 55 - Wastewater Solids Incineration Systems

24 Wastewater Solids Incineration Systems

3.0 PROJECT IMPLEMENTATION:
PERMIT TO CONSTRUCT

Emission limits for specific source categories are established under the new source
performance standards (NSPS) (CAA Sec. 111, Standards of Performance for New
Stationary Sources) and National Emission Standards for Hazardous Air Pollutant
(NESHAP) regulations (CAA Sec. 112). These limits are minimum requirements. The
prevention of significant deterioration (PSD) provisions (CAA Sec. 165, Preconstruc-
tion Requirements) can result in more stringent limits as a result of the best available
control technology (BACT) review process. The new source review (NSR) (CAA Sec.
173, Permit Requirements) process includes an emission control evaluation that
results in the lowest achievable emission rate (LAER).
To begin the air permit review process, a sufficient amount of information is
needed to define the process requirements so that emission rates can be calculated
and control strategies can be evaluated. However, the permit process is an iterative
process between the applicant and the reviewing authority where emission limits
and performance criteria are evaluated. Thus, it is best to begin the permit process
before final process design decisions have been made. In a traditional design-bid-
build construction process, the 30% design point is a good time to prepare and
submit the air permit application. Enough technical information has been prepared
to define the process and it is early enough in the design process to make modifica-
tion to process equipment or air pollution control devices.

3.1 Permit Application Requirements
The type of review and threshold levels are based on the attainment status of the
region in which the facility is located. Review requirements depend on the total
facility annual potential emission rate or the annual potential emission rate for the
proposed modification. A facility is defined as a contiguous facility, within the same
industrial classification code and under common ownership. It is easy to understand
that the incinerator for processing wastewater residuals would be considered part of
the WWTP. However, adjacent landfills or solid waste processing facilities are also
within the same industrial classification. If the regional authority or municipality also
owns these facilities, the emissions from these facilities may be counted when deter-
mining the review status of a proposed solids thermal treatment facility.
A typical permit application would contain the following elements, although the
format and presentation would vary by the reviewing agency.