TM 5-815-1/AFR 19-6
CHAPTER 4
STACK EMISSION REGULATIONS AND THE PERMITTING PROCESS
4-1.
Stack emissions
c. Emission levels. One must file for a New Source
Review application if, after use of air pollution control
The discharge of pollutants from the smokestacks of
equipment, the new boiler or incinerator will result in
stationary boilers and incinerators is regulated by both
increased emissions of any pollutant greater than a
Federal and State Agencies. A permit to construct or
specified limit. Proposed modifications of existing
modify an emission source Will almost certainly be
boilers and incinerators that will cause increases in
required.
pollutant emissions greater than certain threshold levels
a. The emissions must comply with point source reg-
("de minimis" emission rate) require New Source
ulations, dependent upon characteristics of the point
Review.
source, and also with ambient air quality limitations
d. General determinants for steps required for per-
which are affected by physical characteristics of the
mitting. Steps required for a New Source Review
location and the meteorology of the area of the new
depend upon the location of the new source, charac-
source.
teristics of the other sources in the area, and on discus-
b. The permitting procedure requires that estimates
sions with the State Air Pollution Control Agencies,
be made of the effect of the stack emissions on the
possibly the EPA, and how well one is current with the
ambient air quality. Predictive mathematical models
changes in regulations and administrative practices.
are used for arriving at these estimates.
Because of the constantly changing picture, it is usually
c. Due to the time requirements and the complexity
very beneficial to engage an air quality consultant to
of the process and the highly specialized nature of
aid in planning permitting activities.
many of the tasks involved, it is advisable to engage
e. Technical tasks. The principal technical tasks that
consultants who are practiced in the permitting
are required for the permitting effort in most cases may
procedures and requirements. This should be done at
be summarized as follows:
a very early stage of planning for the project.
(1) Engineering studies of expected emission
rates and the control technology that must
4-2.
Air quality standards
be used.
a. Federal Standards -- Environmental Protection
(2) Mathematical modeling to determine the
Agency Regulations on National Primary and Secon-
expected impact of the changed emission
dary Ambient Air Quality Standards (40 CER 50).
source.
b. State standards. Federal installations are also
(3) Collection of air quality monitoring data
subject to State standards.
required to establish actual air quality con-
centrations and to aid in analysis of air
4-3.
Permit acquisition process
quality related values. All technical tasks
a. New Source Review. The state agency with juris-
are open to public questioning and critique
diction over pollution source construction permits
before the permitting process is completed.
should be contacted at the very beginning of the project
f. New Source Review program steps. The steps
planning process because a New Source Review (NSR)
required in a New Source Review vary. However, it is
application will probably have to be filed in addition to
always required that a separate analysis be conducted
any other State requirements. A New Source Review
for each pollutant regulated under the Act. Different
is the process of evaluating an application for a "Permit
pollutants could involve different paths for obtaining a
to Construct" from the Air Quality Regulatory Agency
permit, and may even involve different State and Fed-
having jurisdiction.
eral Agencies.
b. Planning. Consideration of air quality issues very
(1) Attainment or nonattainment areas. A con-
early in the planning process is important because engi-
cern which must be addressed at the
neering, siting, and financial decisions will be affected
beginning of a New Source Review is
by New Source Review. Engineering and construction
whether the location is in a "nonattainment"
schedules should include the New Source Review pro-
or "attainment" area. An area where the
cess which can take from 6 to 42 months to complete
National Ambient Air Quality Standards
and which may require the equivalent of one year of
(NAAQS) are not met is a "nonattainment"
monitoring ambient air quality before the review pro-
area for any particular pollutant exceeding
cess can proceed.
the standards. Areas where the National
Ambient Air Quality Standards (NAAQS)
4-1
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