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IMPACT Guide for Pits & Equipment

Prepared for the Wyoming Contractors Association October 2015

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IntroductionHow IMPACT affects the application process and what is required for all application submissions

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IMPACT Applications

• Applications must be submitted through the IMPACT portal or on IMPACT forms.

• Proper land use planning is still required as part of a complete application.

• An Excel file of all IMPACT forms may be downloaded from: http://deq.wyoming.gov/aqd/new-source-review/resources/guidance-documents/

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Key Application Information

• Cover letter – Should contain a brief project description.

• Cover sheet – IMPACT form that should contain legal description and designate a responsible official.

• Land use planning documentation – Original hard copy letter from local zoning authority which lists the legal land description, what the land is zoned for, and authorization for proposed activities.

• Crushing/Screening/Handling emission unit form (if applicable) – IMPACT form which is required for each individual piece of equipment; transfer/drop points for a system only need to be listed on one of the forms.

• Concrete Batch/Cement Mixer emission unit form (if applicable) – IMPACT form which is required for each individual piece of equipment.

• Hot Mix Asphalt Mixer emission unit form (if applicable) – IMPACT form which is required for each individual piece of equipment.

• Mine/Quarry Form (if applicable) – IMPACT form which is required for mines/quarries; this form contains fields for haul roads and blasting (if applicable).

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Using IMPACTSubmitting applications through the IMPACT portal

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IMPACT Terminology

• Facility Profile Tree: Includes all emission units that are currently constructed as well as all permitted emission units that have a valid authorization to construct, as well as their associated processes, controls, and release points.

• Emission Unit (EU): Equipment related to industrial processes that emit air pollutants at a facility (i.e. crusher, exposed acreage). It should be noted that each emission unit should have at least one process, and may have a control and/or release point assigned

to each process. Each emission unit has its own identifier in IMPACT (i.e. ENG = Engine, CSH = Crushing/Screening/Handling).

• Process (PRC): An industrial activity that categorizes or describes an emission unit and related characteristics; associated with Source Classification Code (SCC). Every emission unit is required to have a valid process associated.

• Control: A device that reduces, prevents, captures, or destroys air pollutants before they are released into the atmosphere. Each control type has its own identifier (i.e. FDS = Fugitive Dust Suppression, typically water or chemical dust suppression).

• Release Point: The point at which a contained pollutant is emitted to the atmosphere. Abbreviated in IMAPCT as VER for a vertical release point or HOR for a horizontal release point (typically found on engines) or AVL for fugitive release points (typically applied to the fugitive dust associated with stockpiling, hauling, crushing/screening, etc.)

• Portal: Website used to access the IMPACT system. Available at https://airimpact.wyoming.gov.

• Responsible Official: Person to whom the air quality permit will be addressed and issued to. The responsible official is responsible for compliance with permit conditions and requirements. This is not intended to be the same as the Title V responsible official.

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Setting up in IMPACT

• First time IMPACT users will need to create a user account.

• All applications will be processed through IMPACT whether submitted through the IMPACT portal or on paper.

• Applications submitted through the portal reduce time spent by the Division entering data.

• For more information on setting up an IMPACT user account: http://deq.wyoming.gov/aqd/impact-system/resources/guidance/

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Portal Application Process

• Update facility profile and create an NSR permit application

• Complete application cover page

• Create the emission units associated with the facility

• Create an emissions process(es) for each emission unit (specify SCC code)

• Create and associate control equipment for each emission process (if applicable)

• Create and associate a release point for each emission process (if applicable)

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Gravel Pits IMPACT Data Entry

• Gravel pits will have up to four fugitive emission units (FUGs)

• Exposed acreage

• Truck loading & stockpiling

• Haul road

• Blasting (omitted if there is not blasting at the site)

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Gravel Pits IMPACT Data Entry• Gravel pits will have up to four fugitive emission units (FUGs)

FDS=fugitive dust suppression as control, AVL=fugitive release point

• Exposed acreage SCC code 30504099 FDS AVL

• Truck loading & stockpiling SCC code 30504020[25] FDS AVL

• Haul road SCC code 30504021 FDS AVL

• Blasting SCC code 30504001 AVL

Emission Unit ID

Process ID

Control ID

Release Point ID

Facility ID

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Gravel Pits – Create EUs

• Create Emissions Unit is available under the “Current Facility Inventory” tab.

• Each fugitive emission unit associated with the pit will be created using this procedure.

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Gravel Pits – Create EUs

• From dropdown menu select Emission Unit Type to be Fugitive. Required fields are indicated with the asterisk (*). (Note the AQD Description field will not be available for editing and will not be required).

• If operating status is selected to be Invalid, Operating, or Shutdown, additional fields may be required.

• Equipment description should reflect the type of fugitive emission unit (truck loading & stockpiling, haul road, etc.).

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Gravel Pits - Process

• The Permitted Emissions table at the bottom of the page will be populated by Air Quality staff.

• Click “Save” when finished.

• Once the emission unit is created, select it in the Facility Tree and click “Create Emissions Process”.

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Gravel Pits - Process

• Input the SCC code listed on slide 11 and click “Save”.

• Note that for the FUG truck loading & stockpiling, there will be two processes (truck loading - 30504020 and stockpiling - 30504025) with separate controls and release points.

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Gravel Pits - Controls• Once the process is saved, select “Create and Associate Control Equipment”.

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Gravel Pits - Controls

• Select Control Equipment Type to be Fugitive Dust Supression. (Note the AQD Description field will not be available for editing and will not be required).

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Gravel Pits - Controls

• Complete Control Equipment Type Specific Information and add Pollutants Controlled to the table.

• Note that at least one pollutant must be added.

• Click “Save” when finished.

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Gravel Pits– Release Point

• Select the desired process from the Facility Tree and select “Create and Associate Release Point”.

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Gravel Pits– Release Point

• Select Release Point Type to be Fugitive (Area, Volume, Line). (Note the AQD Description field will not be available for editing and will not be required).

• Note that for Release Height a value of 0.99 is always entered. This is only true for fugitive release points associated with gravel pits and crushing/screening/handling equipment.

• Click “Save” when done.

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Crushing/Screening/Handling (CSH)

• IMPACT has EUs for crushers, screens, conveyor/drop points and engines

• Crusher SCC code 30504030[31] FDS AVL

• Screen SCC code 30504034 FDS AVL

• Conveyor/drop point SCC code 30504021 FDS AVL

• Engine SCC code 20200102 (diesel engine)

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CSH IMPACT Data Entry – Create EUs

• Create Emissions Unit is available under the “Current Facility Inventory” tab.

• Each fugitive emission unit associated with the pit will be created using this procedure.

• Note the Facility Name: Portable Crushing/Screening Equipment

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CSH IMPACT Data Entry – Create EUs

• From dropdown menu select Emission Unit Type to be Crushing/Screening/Handling. Required fields are indicated with the asterisk (*). (Note the AQD Description field will not be available for editing and will not be required).

• If operating status is selected to be Invalid, Operating, or Shutdown, additional fields may be required.

• Equipment description should reflect the type of equipment (crusher, screen, etc.).

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CSH IMPACT Data Entry – Create EUs

• Fill in the required Emission Unit Type Specific Information.

• The Permitted Emissions table at the bottom of the page will be populated by Air Quality staff.

• Click “Save” when finished.

• Once the emission unit is created, select it in the Facility Tree and click “Create Emissions Process”.

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CSH IMPACT Data Entry - Process

• Once the emission unit is created, select it in the Facility Tree and click “Create Emissions Process”.

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CSH IMPACT Data Entry - Process

• Input the SCC code listed on slide 21 and click “Save”.

• Note that for crushers, an SCC code ending in 30 represents a primary crusher and an SCC code of 31 represents a secondary crusher.

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CSH IMPACT Data Entry – Controls• Once the process is saved, select “Create and Associate Control Equipment”.

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CSH IMPACT Data Entry - Controls

• Select Control Equipment Type to be Fugitive Dust Supression. (Note the AQD Description field will not be available for editing and will not be required).

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CSH IMPACT Data Entry – Controls

• Complete Control Equipment Type Specific Information and add Pollutants Controlled to the table.

• Note that at least one pollutant must be added.

• Click “Save” when finished.

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CSH IMPACT Data Entry – Release Point• Select the desired process from the Facility Tree and select “Create and

Associate Release Point”.

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CSH IMPACT Data Entry – Release Point

• Select Release Point Type to be Fugitive (Area, Volume, Line). (Note the AQD Description field will not be available for editing and will not be required).

• Note that for Release Height a value of 0.99 is always entered. This is only true for fugitive release points associated with gravel pits and crushing/screening/handling equipment.

• Click “Save” when done.

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Benefits of IMPACTHow IMPACT user portal submissions improve application processing

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Benefits of Portal Submissions

• Reduces time spent by Division staff entering data, thereby reducing engineer review time.

• Validation through the IMPACT system helps reduce requests for additional information.

• Paperless application submission.

• Transfer EU feature allows for easy replication of EUs and their associated elements within a facility as well as across facilities, saving time spent re-entering same/similar data.

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Benefits of IMPACT

• Allows users to update the location of portable equipment without submitting forms to the Division.

• Allows users to update like-kind replacement information without submitting forms to the Division.

• Allows the user to create compliance reports (EU startup/shutdown notification, commencement of construction, etc.).

• Allows the user to view facility profiles as well as application, permit and compliance history.

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IMPACT TipsHow to maximize the benefits of IMPACT

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Process Delays

• There are a few common issues that prevent application completeness and cause process delays:

• Missing land use planning documentation

• Applications submitted on outdated forms

• Incomplete equipment information

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IMPACT Tips

• For each emission unit in the facility profile, one entry must be added to the Serial Number Tracking Table.

• For each control device in the facility profile, one entry must be added to the Pollutants Controlled Table.

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IMPACT Tips

• Release Height (ft) will be 0.99 for fugitive release points

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Application Tips

• For each emission unit in the facility profile, one entry must be added to the Serial Number Tracking Table.

• For each control device in the facility profile, one entry must be added to the Pollutants Controlled Table.

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ResourcesWhere to access information regarding IMPACT

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Resources

In addition to this presentation, the following resources are available at: http://deq.wyoming.gov/aqd/new-source-review/resources/guidance-documents/

• IMPACT User Guide – Gravel Pits and Equipment• A guide with similar information to this presentation, presented in a more

concise format for users with some IMPACT experience.• Air Quality Permitting of Mining and Mine/Quarry Operations – Non Coal• A quick reference document with an explanation of the permitting process and

associated processing times as well as a chart showing which forms are required for certain activities.