experience of the forest products industry in obtaining air quality permits for new and modified sources

A detailed study of the air quality permitting process for 65 different forest products industry projects requiring preconstruction permit approvals from EPA, state, and local air pollution control agencies was conducted. The projects included a wide array of sources including kraft recovery furnaces, lime kilns, fossil fuel and wood residue fired boilers, solid wood products manufacturing facilities, paper coaters, and printing presses. Information concerning the time involved in the permitting process, costs associated with obtaining the permits, use of air quality models and ambient monitoring data, emission control technology determinations, problem areas encountered during the permitting process, perceived benefits and drawbacks of the permitting process, and the effect of permitting requirements on project planning was obtained.

The results indicate that certain permitting requirements such as Best Available Control Technology (BACT) determinations, dispersion modeling results, and use of ambient air quality monitoring data seldom influence the emission limitations ultimately imposed in the final approved permit, with 87% of the final emission limits equivalent to the applicable New Source Performance Standard (NSPS). The 65 permitting case histories also show that obtaining permits for projects subject to Prevention of Significant Deterioration (PSD) requirements takes approximately twice as long and costs twice as much as obtaining permits for projects not subject to PSD requirements.