1.3 Permitting Process for the Construction of Air Emissions Sources
Please consult COMAR 26.11.02.10 for a list of sources which are exempt from having to obtain Air Quality Permits to Construct and/or Approvals.
When new sources of air pollution are planned for installation at BWI Marshall and Martin State Airports, an Air Quality Permit to Construct must be obtained (if required) from the Maryland Department of the Environment’s Air and Radiation Management Administration (MDE/ARMA) prior to commencing construction. All permit applications shall be submitted to MDE/ARMA in conjunction with and only after approval by MDOT MAA’s Environmental Compliance Section. At project initiation, Consultant must schedule an initial consultation with MDOT MAA’s Environmental Compliance Section to discuss permitting requirements for all new air emissions sources that are planned or proposed. Preparing the applications for such permits is the responsibility of the Consultant. Later integration of new sources with facility air quality operating permits is the responsibility of the Owner (MDOT MAA).
Whenever practicable, Consultant/Owner should consider the incorporation of energy/fuel efficient, lower emission equipment into the design for air emission sources. In addition, when the purchase of a non-environmentally responsible piece of equipment is specified and/or recommended by the Consultant, justification in the form of a best available or economically feasible option will be required.
Whenever fuel burning equipment is added to the MDOT MAA inventory, the Environmental Compliance Section must be notified by the Consultant regarding the addition.
Unless otherwise stated, the general application for equipment capable of emitting air pollution (not including air pollution control devices, incinerators, and boilers) is the Application for Processing or Manufacturing Equipment (Form 5). Sources which have the potential to emit Toxic Air Pollutants (TAPs) and are subject to COMAR 26.11.15, also require a Toxic Air Pollutant (TAP) Emissions Summary and Compliance Demonstration (Form 5T) and an Emission Point Data (Form 5EP). If pollution control equipment is to be installed on the unit, then Application for Permit to Construct Gas Cleaning or Emission Control Equipment (Form 6) is required for any control device associated with the equipment described on Form 5.
All forms can be found on the Maryland Department of the Environment Permits to Construct and Operate Application Forms web page.
The application fee of $500 per piece of equipment will be invoiced once MDE/ARMA receives the permit application. This fee will be paid per the Consultant’s contractual agreement with MDOT MAA. Three (3) copies of the permit application, each signed and dated individually, must be submitted to MDE/ARMA.
1.3.1 Permitting Process
The Consultant shall be responsible for completing the necessary applications for Air Quality Permits to Construct as set forth below. The permit applications shall be submitted to the MDOT MAA Environmental Compliance Section in the Office of Environmental Services. The Owner (MDOT MAA) shall be responsible for signing and submitting the appropriate permit applications to the MDE/ARMA. In addition, the MDOT MAA is responsible for paying all permitting fees as set forth below. If the MDOT MAA is notified that any permit application is deemed incomplete, the Consultant shall take immediate action to rectify the situation and submit the appropriate documents to MDE/ARMA.
After an Application for Processing/Manufacturing Equipment has been approved by MDE/ARMA, but prior to operating the processing/manufacturing equipment, the Environmental Compliance Section, upon notification by the Engineer, will submit an Application for Permit to Operate Process Equipment (Form 26).
Note that BWI Marshall and Martin State Airports each have different environmental regulatory requirements depending on the type and size of equipment to be constructed as the two airports have separate permits. BWI Marshall is a major source (NOx emissions >25 tpy) under Title V (COMAR 26.11.02.17); therefore, the addition of equipment may constitute a major modification and trigger major source permitting. This imposes additional air pollution control requirements and significant delays due to the longer permitting process. An evaluation should be completed for any future projects involving the installation of sources emitting NOx. On the other hand, Martin State is a minor source and therefore; additional equipment would most likely not trigger the need for major modification.
1.3.2 Sources Exempt from Permits to Construct
COMAR 26.11.02.10 lists sources which are exempt from having to obtain Air Quality Permits to Construct and/or Approvals.
For sources not listed in COMAR 26.11.02.10, if the source to be installed meets the following requirements, it may be exempt from an Air Quality Permit to Construct as follows:
· The installation is not subject to any source-specific State or Federal emission standard;
· The expected uncontrolled emissions are less than 1 ton per calendar year of each pollutant for which there is a Federal air quality standard or which is a Class II toxic air pollutant (TAP) as defined in COMAR 26.11.15.01B(5); and
· The emissions contain no more than one (1) pound per day of Class II toxic air pollutant, as defined in COMAR 26.11.15.01B(4).