GENERAL AIR QUALITY OPERATING PERMIT FOR PERCHLOROETHYLENE DRY CLEANERS APPLICATION PACKAGE



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PIMA COUNTY DEPARTMENT OF ENVIRONMENTAL QUALITY Air Program 33 N. Stone Avenue, Suite 700, Tucson, Arizona 85701 Phone: (520) 243-7400 GENERAL AIR QUALITY OPERATING PERMIT FOR PERCHLOROETHYLENE DRY CLEANERS APPLICATION PACKAGE

General Operating Permit for Perchloroethylene Dry Cleaners Application **BEGINNING INSTRUCTIONS** Please read the introduction and disclaimer below. To begin the application process, complete the standard permit application form for your facility. This form is page 2 of the application packet. Once this form has been completed, go to page 3 of the application packet and follow all instructions completely, starting with Step 1. Each step in the packet is accompanied by specific instructions. If the instructions are followed completely, and in the correct order, your application stands a good chance of being complete. Submittal of a complete application the first time around provides for the greatest likelihood that your application processing time will be as short as possible. Submittal of an incomplete application can result in substantial delays in processing time. Thank you for helping PDEQ to provide the most expeditious service possible. INTRODUCTION The Pima County Department of Environmental Quality (PDEQ) has drafted this General Permit to streamline the permitting process for the large number of air pollution sources (perchloroethylene dry cleaners) which would otherwise require substantially similar individual source permits. This action shall reduce PDEQ s workload and afford decreased permitting timeframes while enhancing the capabilities of the Air Quality Program. With the issuance of this General Permit, the Dry Cleaning Facilities General Permit issued by the Arizona Department of Environmental Quality is no longer available through PDEQ. Not all dry cleaning facilities are eligible for coverage under this general permit. However, the most common types found in Pima County will be eligible. You qualify for this general permit if you meet all of the following conditions: Your facility is not collocated in a building with a residence. Your facility does not utilize transfer type dry cleaning machines or any ancillary equipment (including, but not limited to, a separate washer, dryer or reclaimer.) Dry cleaning operations at your facility consume no other solvent than perchloroethylene (PCE). Your facility does not consume/purchase more than 2,100 gallons of PCE in any given consecutive 12 month period. Other than those units to be covered by this General Permit (i.e. PCE dry cleaning machines and associated boilers), there are no emission units, operations or activities co-located at the facility that (1) are subject to a permitting requirement and/or (2) emit significant quantities of any pollutant. DISCLAIMER Completion of this application package does not void the right of the Control Officer under 17.12.165 of the Pima County Code to require the Applicant to provide supplemental information before processing the application and issuing or denying an Authorization to Operate (ATO) under this General Permit. - 1 - May 4, 2010

PIMA COUNTY DEPARTMENT OF ENVIRONMENTAL QUALITY 33 N. Stone Ave, Suite 730 Tucson, AZ 85701 Phone: (520) 740-3340 STANDARD PERMIT APPLICATION FORM FOR CLASS II/III SOURCES (As required by A.R.S. 49-480, and Title 17 of the Pima County Code) 1. Permit to be issued to (Business License Name of Organization): 2. Mailing Address: City: State: ZIP: 3. Name (or names) of Owner or Operator: FAX #: Phone: Email: 4. Name of Owner's Agent: FAX #: Phone: Email: 5. Plant Name (if different than item #1): 6. Proposed Equipment/Plant Location Address: City: State: ZIP: 7. Plant/Site Manager/Contact Person: FAX #: Phone: Email: 8. General Nature of Business: Standard Industrial Classification Code(s): Permit Class: 9. Type of Organization: Corporation Individual Owner Partnership Government Entity Other 10. Permit Application Basis (Check all that apply): New Source General Permit Revision: Renewal of Existing Permit # Portable Source Administrative Minor Significant Date of Commencement of Construction or Modification: Is any of the equipment to be leased to another individual or entity? 11. Typed or Printed Name of Responsible Official (RO): Official Title of RO: RO Fax #: RO Phone #: RO Email: Date: 12. Signature of Responsible Official of Organization: - 2 - May 4, 2010

FACILITY ELIGIBILITY DETERMINTATION (START HERE!) Step 1: Determine what type of facility you operate, and whether or not you are eligible for this general permit. The first step in the application process is to determine if you re facility is eligible for coverage under this general permit. Not all dry cleaning facilities can be covered by this general permit, but the permit has been structured to cover the most common types found within Pima County. Also, certain types of dry cleaning machines cannot be covered under this general permit; however, the most common types can (see Step 2 below for machine eligibility.) To begin, you will answer a series of questions (all are yes or no responses,) and determine if your facility can be covered by this general permit. Then, you will continue on to Step 2 and determine if each machine you operate at your facility can be covered under the permit, as well. Answer the following questions in order, following all instructions exactly, to determine if your facility is eligible for coverage under this General Permit. Begin with question number 1), and circle Yes or No to answer. Proceed as instructed after answering each question. Questions about your facility: 1) Does your facility utilize any solvents other than perchloroethylene (PCE) in your dry cleaning machines? If no, continue to question 2. If yes, your facility is NOT eligible for coverage under this general permit. Please contact PDEQ for further permitting information. 2) Is your facility collocated in a building with a residence 1?... If no, continue to question 3. If yes, your facility is NOT eligible for coverage under this General Permit. Please contact PDEQ for further permitting information. 3) Is your facility s total yearly perchloroethylene (PCE) purchase/consumption less than or equal to 2100 gallons of PCE in any consecutive 12 month period? 2... If yes, continue to Step 2 on page 4. If no, your facility is classified as a Major Source and is NOT eligible for coverage under this general permit. Please contact PDEQ for further permitting information. 1 A residence is defined as any dwelling or housing in which people reside excluding short-term housing that is occupied by the same person for a period of less than 180 days (such as a hotel room.) 2 To determine your total yearly PCE consumption, sum the total volume (in gallons) of all PCE purchased for your facility in the last consecutive 12 month period. - 3 - May 4, 2010

Step 2) Determine if your machines are eligible for coverage under this general permit, and which category each of your machines fits into. In order to be covered under this general permit, ALL of your machines must meet set criteria. If any ONE of your machines DOES NOT meet the necessary criteria, you entire facility CANNOT be covered under this general permit. Answer all of the questions below, and follow all instructions, to determine what category of machine(s) you operate and if your machines are eligible for coverage under this general permit. Repeat Step 2 for each dry cleaning machine operated at your facility. Make as many copies of this page as are necessary to cover all of your machines. Questions about each of your dry cleaning machines: 4) Is this machine a transfer type dry cleaning machine, or any piece of ancillary equipment (including, but not limited to, a separate washer, dryer or reclaimer)?... If no, continue to question 5). If yes, your machines are NOT eligible for coverage under this general permit. Please contact PDEQ for further permitting information. 5) Was installation, relocation or reconstruction of this machine commenced before December 9, 1991?... If yes, continue to question 6. If no, continue to question 8. 6) Is your facility s total yearly perchloroethylene (PCE) purchase/consumption less than 140 gallons of PCE in any (and all) previous, consecutive, 12 month period? 2... If yes, this machine is categorized as a Category 1 Machine (or an Existing Small Area Source Machine.) Please continue to Step 3 on page 5 of this application packet. If no, continue to question 7. 7) Is your facility s total yearly perchloroethylene (PCE) purchase/consumption less than or equal to 2100 gallons of PCE in any (and all) previous, consecutive, 12 month period? 2... If yes, this machine is categorized as a Category 2 Machine (or an Existing Large Area Source Machine.) Please continue to Step 3 on page 5 of this application packet. If no, return to question 3) on page 3. 8) Was installation, relocation or reconstruction of this machine commenced after or on December 9, 1991, and before or on December 21, 2005?... If yes, this machine is categorized as a Category 3 Area Source Machine. Please continue to Step 3 on page 5 of this application packet. If no, continue to question 9). 9) Was installation, relocation or reconstruction of this machine commenced after December 21, 2005?... If yes, this machine is categorized as a Category 4 Area Source Machine. Please continue to Step 3 on page 5 of this application packet. If no, please return to Step 1 on page 3 and start over. All machines should be categorized under these conditions, or exclude your facility from coverage under this general permit. If you need additional assistance, please contact PDEQ for further permitting information. 2 To determine your total yearly PCE consumption, sum the total volume (in gallons) of all PCE purchased for your facility in the last consecutive 12 month period. - 4 - May 4, 2010

PERCHLOROETHYLENE DRY CLEANING MACHINE INFORMATION Step 3) Record required information for each dry cleaning machine, including which category each machine fits into. The next step in the application process is to record required information for each dry cleaning machine operated at your facility. It is necessary for you to provide permanent and unique identifying information for each machine, so that the identity of each machine and the corresponding applicable regulations can be confirmed by PDEQ inspectors during inspection of your facility. Fill in all the information in the following table for each dry cleaning machine you operate at your facility. Include the category each machine fits into; which you should have determined in Step 2. DO NOT omit any information, or your application processing time may significantly be increased. Manufacturer Model Serial # Date of Installation, Reconstruction or Relocation Machine Category (from Step 2) Is the Machine Equipped with a Refrigerated Condenser? Is the Machine Equipped with a Carbon Adsorber? After the table above has been completed, and all information for each of your dry cleaning machines is recorded, proceed to Step 4 on page 6. If you have problems obtaining any piece of information in the table above, please contact PDEQ for permitting assistance. DO NOT submit an incomplete application. General Operating Permit for Dry Cleaners Application - 5 - May 4, 2010

BOILER EQUIPMENT DECLARATION AND INFORMATION Step 4) Declare any boilers or water heating equipment operated at your facility. It is common for dry cleaning facilities to own boilers and water heaters, and operate such fossil fuel fired equipment at the same facility where dry cleaning machines are also operated. Due to this common situation, this general permit has been written to accommodate such circumstances. Please answer the following question and then follow the instructions that follow. 10) Do you operate any fossil fuel fired boilers or water heaters at your facility in addition to your dry cleaning machines?... If yes, please fill out the following table in its entirety, providing the necessary information about each of your boilers/water heaters. If no, please continue to Step 5 on page 7. Manufacturer Model Serial # Maximum Heat Input Capacity (MMBtu/hr 1 ) Date of Installation, Relocation or Reconstruction Fuel(s) Used (include all if fired in any combination) After the table above has been completed, and all information for each of your boilers/water heaters is recorded, proceed to Step 5 on page 7. If you have problems obtaining any piece of information in the table above, please contact PDEQ for permitting assistance. DO NOT submit an incomplete application. General Operating Permit for Dry Cleaners Application - 6 - May 4, 2010

INSIGNIFICANT ACITIVITY DECLARATION Step 5) Declare any insignificant activities at your facility. All applications submitted to PDEQ must include information about activities engaged in on the premises that are not permitted by PDEQ, but that have a potential to impact air quality. Providing PDEQ with information about these activities will help to prevent complications with future inspections and permitting actions. Review the definition of insignificant activity below, and then fill out the appropriate information in following table. 17.04.340.A of Title 17 of the Pima County Code defines an insignificant activity as one: that is not otherwise subject to any applicable requirement and which belongs to one of the following categories: a. Landscaping, building maintenance, or janitorial activities. b. Gasoline storage tanks with capacity of ten thousand gallons or less. c. Diesel and fuel oil storage tanks with capacity of forty thousand gallons or less. d. Batch mixers with rated capacity of five cubic feet or less. e. Wet sand and gravel production facilities that obtain material from subterranean and subaqueous beds, whose production rate is two hundred tons/hour or less, and whose permanent in-plant roads are paved and cleaned to control dust. This does not include activities in emissions units which are used to crush or grind any nonmetallic minerals. f. Hand-held or manually operated equipment used for buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, or turning of ceramic art work, precision parts, leather, metals, plastics, fiberboard, masonry, carbon, glass, or wood. g. Powder coating operations. h. Internal combustion (IC) driven compressor, IC engine-driven electrical generator sets, and IC enginedriven water pumps used only for emergency replacement or standby service. i. Lab equipment used exclusively for chemical and physical analyses. j. Any other activity which the control officer determines is not necessary, because of its emissions due to size or production rate, to be included in an application in order to determine all applicable requirements and to calculate any fee under this title. If you would like to claim an activity as insignificant that is not listed above, attach a brief explanation including, if necessary, potential emissions with calculations. Activity Description Category of Activity For Official Use Only (a through j above). Reviewer Date (Duplicate as necessary) After the table above has been completed, please continue to Step 6 on page 8. - 7 - May 4, 2010

CERTIFICATION BY RESPONSIBLE OFFICIAL Step 6) Legally binding signatures of the Responsible Official for your facility. Every application submitted to PDEQ must be accompanied by two statements certified by the Responsible Official for the facility to be permitted. These statements are necessary to establish the legally binding relationship between your facility and PDEQ. The responsible official is defined as a person who is in charge of principal business functions or who performs policy or decision making functions for the business. This may also include an authorized representative for such persons. For a complete definition, see Pima County Air Quality Control, Title 17, Section 17.04.340(A)(199). Make sure the Responsible Official (AND ONLY the Responsible Official) for your organization reads and understands the following two statements, and provides his/her signature for BOTH. Applications without these signed statements will be deemed incomplete. 1) Statement of Compliance with all Applicable Requirements Permit Number (If existing source) I certify that I have knowledge of the facts herein set forth, that the same are true, accurate and complete to the best of my knowledge and belief, and that all information not identified by me as confidential in nature shall be treated by the Pima County Department of Environmental Quality (PDEQ) as public record. I also attest that I am in compliance with the applicable requirements and will continue to comply with such requirements and any future requirements that become effective during the life of my permit. I further state that I will assume responsibility for the construction, modification, or operation of the source in accordance with the requirements of Title 17 of the Pima County Code and any permit issued thereof. Name (Print/Type): Title: Signature: Date: 2) Certification of Truth, Accuracy, and Completeness 17.12.165(H) - Certification of Truth, Accuracy, and Completeness. Any application form, report, or compliance certification submitted pursuant to this Chapter shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the documents are true, accurate, and complete. By my signature I,(Name), hereby certify that based on information and belief formed after reasonable inquiry, the statements and information in this document are true, accurate, and complete. (Signature): Title: Date: - 8 - May 4, 2010