Page 59 - Wastewater Solids Incineration Systems

28 Wastewater Solids Incineration Systems

plume. Because of the negative response from the public that may result from the for-
mation of a visible yellow plume, mitigation of the visual impact from the plume
may be necessary.

4.0 CONSTRUCT: COMMENCE CONSTRUCTION
To accelerate the time it takes to bring a project from concept to operation and save
money, a design-build approach has been proposed as an alternative to the tradi-
tional design-bid-build approach. Although there is nothing in the CAA that would
preclude a design-build approach, some cautions are warranted. The design-build
approach seeks to streamline the design and procurement process so that the pro-
posed facility can be constructed sooner. As noted in previous sections, construction
cannot commence until the air permit has been issued. To commence construction
means that no person may construct a new source or alter an existing source; certain
site preparation work may begin, but no permanent facilities may be constructed.
The restriction on construction may also extend to binding agreements or obliga-
tions that make commitments to process equipment or construction services that can
not be canceled or modified without substantial loss to the owner or operator. The air
permit process may result in more stringent emission limitations that could affect
process equipment or control technology selection. Thus, it is incumbent on both the
facility owner/operator and provider of design-build services to share the risks asso-
ciated with delays in receiving an air permit or facility design changes due to
increased emissions.

4.1 Facility Operation: Permit to Operate

Once the proposed facility is constructed, a process of performance testing begins.
The pollutant emissions to be tested are defined in the permit to construct. Testing
procedures are defined in 40 CFR 60 Appendix A or methods agreed to by the
reviewing authority. A testing protocol is developed that describes how the testing
will be conducted and the emissions reported. If the measured emission rates are
greater than emission limits established in the permit to construct, then immediate
mitigation measures are implemented. Measures may include modifications to air
pollution control equipment or re-permitting of the facility.

4.2 Federal Title V Operating Permit Program
Shortly after the facility begins operation, the operating permit program assures
continued compliance and reporting of actual emissions from the major facilities.