General Permit to Construct for Concrete Batch Plants
Under the Rules for the Control of Air Pollution in Idaho (IDAPA 58.01.01.201– 228), certain facilities that emit air pollutants are required to obtain an air quality permit to construct. Because most concrete batch plants have similar types of equipment that generate air emissions, DEQ has created a streamlined permitting process where these operations may obtain a general rather than a facility-specific permit to construct.
Steps in the General Permitting Process
1. Applicant contacts DEQ by phone.
Prior to submitting an application for a new or modified concrete batch plant, the applicant is advised to contact Bill Rogers (contact information at right) in DEQ's Air Quality Division to learn about the permitting process and to set up a preapplication meeting.
2. Applicant accesses and reviews permitting documents on DEQ's website.
- Form GI: General Information
- Permit Application Form GCBP: The applicant may fill out this form in part or entirely before the preapplication meeting or complete the form after the meeting. Information provided on the permit application form will be entered into a spreadsheet to develop emission rates specific to the facility. (Spreadsheet is provided for informational purposes only and does not need to be submitted by applicant to DEQ.)
- Permit Template: Content of the facility's permit will be very similar to that of the template; facility specifications will be added.
- Statement of Basis Template: Content of this analysis will be very similar to that of the template; facility specifications will be added.
3. Applicant attends a preapplication meeting with DEQ.
The preapplication meeting may be held in person or via conference call. During this meeting, the applicant will be expected to provide an overview of the proposed project and will have the opportunity to ask questions about the permitting process. DEQ staff will advise the applicant on applicable state and federal regulations and explain the options for conducting air quality impact analyses (called modeling analyses) that are used to determine the required setback distance for the concrete batch plant. (See modeling information below: Step 5.)
4. Applicant completes and submits permit application form and fee.
The general permit fee is $1,500, which includes a $1,000 application fee and $500 processing fee. This is a one-time fee. (Additional fees may apply if the permit is changed in the future.) The fee may be paid by check, credit card/E-check, or bank wire transfer.
Pay by check
Make check payable to the Idaho Department of Environmental Quality, and send completed application and check to the following:
Idaho Department of Environmental Quality
Attn: Fiscal Office - Air Quality Program
1410 N. Hilton
Boise, ID 83706
Pay by credit card/E-check
Send completed application to the following:
Idaho Department of Environmental Quality
Attn: Air Quality Program
1410 N. Hilton
Boise, ID 83706
To pay fees, link to Access Idaho website at https://www.accessidaho.org/ai/payport/online/deq/index.html
(Note: Convenience fee of 3% applies to credit card payments, $5 to E-check payments.)
Pay by bank wire transfer
Send completed application to the following:
Idaho Department of Environmental Quality
Attn: Air Quality Program
1410 N. Hilton
Boise, ID 83706
To pay fees, contact Katie Bennett, DEQ Fiscal Office
katie.bennett@deq.idaho.gov
(208) 373-0446
5. DEQ conducts modeling.
Before an air quality permit may be issued, an air quality impact analysis must be performed to demonstrate compliance with applicable air quality standards. Air quality dispersion modeling is used to estimate concentrations of pollutants resulting from emissions generated by operation of the proposed facility.
Emission rates developed from information provided on the permit application will be used to develop a modeling scenario, which will in turn be used to establish the minimum setback distance for the concrete batch plant.
- A setback distance is defined as the minimum distance from any center of a silo baghouse stack, truck or central mix loading point, weigh batcher transfer point, or other emission point associated with this concrete batch plant to any area outside of the plant's physical boundary where the air quality may be impacted by emissions from the plant.
The applicant may choose from two modeling options based on whether the facility is intended to be portable throughout the state or stationary in a specific site. Setback distance requirements vary based on the modeling option selected.
- If the facility is intended to be portable, modeling will incorporate meteorology data throughout the state. The worst case dataset will be used as representative of the state, and the setback distance will most likely be the greatest distance possible.
- If the facility is intended to be stationary, modeling will incorporate meteorology data at the specific site. No portability will be allowed, but the setback distance may be greatly reduced.
The primary driver when establishing the setback distances is NOx emissions associated with the engines. Some things that may reduce required setback distances are higher stacks on the engines or adding NOx controls.
For modeling protocol questions, contact Kevin Schilling (contact information at right) in DEQ's Air Quality Division.
6. Applicant advises DEQ whether to proceed with permit processing.
After modeling has been conducted, DEQ will advise the applicant on the required setback distance. If the required distance setback is satisfactory to the applicant, DEQ will proceed with developing the general permit. Prior to permit issuance, the permittee will have the opportunity to review the draft to verify equipment descriptions and confirm numerical values; no substantive changes will be made at this point in the permitting process.
If the required distance setback is problematic, the applicant may advise DEQ to proceed regardless or withdraw the application and resubmit at a later date. DEQ will provide suggestions and recommendations on how to improve the modeled setback distance for the next submittal. If the application is resubmitted, the applicant will be required to pay the $1,000 application fee again; the $500 processing fee will not be required a second time.
Related Federal Requirements
If the engine or engines were constructed, modified, or reconstructed after June 11, 2005, they are subject to 40 CFR 60, Subpart IIII. If the engine or engines were both constructed or reconstructed on or prior to July 11, 2005, they are subject to 40 CFR 63, Subpart ZZZZ. It is possible that both subparts may apply. They both would apply if one engine is subject to IIII and the other is subject to ZZZZ, as the general permit allows for the use of up to three engines. For further details, refer to the Statement of Basis Template under "Regulatory Review."