Frequently Asked Questions
Rule 201- Permits Required
* means that the question is taken out of Section
8 of the NSR Staff Report.
For more information or assistance, call the Engineering Division at (805)
961-8800, or e-mail us at
engr@sbcapcd.org.
Q: Under what conditions can a permit be canceled?
A: A Permit to Operate can be canceled upon request, or an ATC can be
canceled for lack of use, however revocation or suspension can occur only for
non-compliance with permit conditions or non-payment of fees.
Q: What is the filing fee for a combined ATC/PTO application? What is
the permit issuance fee for a combined ATC/PTO permit?
A: A combined ATC/PTO permit is assessed a single application filing fee and
a single permit evaluation fee.
Q: A source wishes to install a degreaser and a solvent work station.
Are these emission units subject to ATC permit?
A: These operations are classified as equipment which have the potential to
emit reactive organic compounds. An ATC permit is required based on the
definition of "Erect". This definition helps clarify that setting up, installing
or assembling equipment such as degreasers or solvent work station requires an
ATC permit to ensure that applicable rules and regulations are evaluated.
Without the underlying equipment, the solvent emissions would not be emitted.
Q: Does the APCD have the authority to regulate "nonroad"engines that
are subject to regulation by USEPA of the federal Clean Air Act Amendments?
A: Rule text (201.D.2.) specifically requires permits for dredges, pile
drivers, pipe laying and derrick barges. The APCD has the authority to permit
such sources pursuant to the federal nonroad engine legislation at 40 CFR 89. In
the preamble to this legislation (IV. Definition of nonroad engine), EPA states
"...Nothing in section 209 of the CAA prohibits local pollution control
districts from regulating the operation of nonroad engines, such as the hours of
usage, sulfur limits in fuel (state fuel restriction may in some cases be
precluded under section 211), daily mass emission limits, and Title 1 operating
permits. In addition, local districts can impose a permitting fee consistent
with the costs incurred for various operational expenditures, such as monitoring
usage and administrative functions. EPA believes that utilization of this option
will assist local districts in achieving their targeted emission levels."
Language has been included to clarify that BACT is not required if preempted by
federal law.
In response to a request from industry, the APCD reviewed an ATC for one of the
newer oil and gas processing facilities that included installation of platforms
and pipelines. Based on potential as well as actual emissions, derrick barges
and pipe-laying vessels are extremely large emitters of air contaminants. The
potential emissions associated with this one project from pipe-laying and
derrick barges totaled more than 500 tons of NOx. The APCD concludes that all
permit requirements not preempted by state or federal law, are appropriate for
emissions of this magnitude.
Examples of activities that would require a permit under 201.D.2 include:
- Non-emergency dredging of Santa Barbara Harbor with diesel equipment on a
barge.
- Pipeline laid between OCS or state platforms.
- Pipeline laid between unpermitted sources in state or federal waters
- Installing or extending piers in Santa Barbara County.
- Pile driving sheet piles for beach restoration or erosion prevention
projects.
- Any abandonment activity (platform, wells, pipeline).
Q: Why does the rule text indicate that the APCO may require
disclosures to be certified by a registered engineer?
A: The APCD has encountered situations involving, for example, ventilation
systems which were improperly designed and failed to function in compliance with
permit conditions. The delay and subsequent added expenses for the applicants
could have been avoided by engaging an engineer properly qualified to design and
review such systems.
For more information or assistance, call the Engineering Division at (805)
961-8800, or e-mail us at
engr@sbcapcd.org.
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