NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

So, you just got a GCP – 5…

What Now?

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

GCP PERMITS

• GCP Application and Compliance Requirements

• What to Expect When the Inspector Arrives

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

• General Construction Permits were developed to create a streamlined permitting process for typical small sources.

• What are the advantages?

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

GCP ADVANTAGES

• Fast – 30 days• Simple – no modeling

• Less expensive - $3400• Predictable – published in advance

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

BUT…• GCP permits contain many restrictions

that may or may not be in a regular construction permit.– Production rates– Hours of operation– Recordkeeping

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

WHY?

• GCP permits are based on a generalized computer model.

• GCP permits emphasize respect for neighbors.

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Do I Want a GCP?

• GCP – typical facility in a low-impact location.

• Regular construction permit – site specific for location, equipment, production.

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

GCP -5 Permits – Who Qualifies?

• Concrete production facilities

• No more than 2400 yards/day

• Conventional equipment

• No slag, asbestos, radionuclides or Hazardous Air Pollutants

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

• Can I have more than one kind of permit?

• Can I co-locate facilities?

• Yes – with restrictions

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

APPLICATION REQUIREMENTS

• Public Notification

• General Information

• SIC Code – 3271, 3272, 3273

• Facility Status and Location

• Operating Schedule

• Production Rate

• Restricted Area

• Disturbed Area

• Storage Piles

• Haul Roads

• Equipment List and Capacities

• Emission Controls

• Drawings and Maps

• Plan of Operations

• Contact Name

• Fees - Yes

• Modeling - No

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Site Restrictions

• Minimum distance from Class 1 Area – 3 miles

• Minimum distance between equipment, piles, roads and fence – 42 feet.

• (Other GCP permits require ¼ mile separation from nearest residence.)

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Emission Restrictions and Conditions1. Dust control on haul roads; stockpiles in bunkers

2. Dust controls on truck loading points:• Washed sand• Control stockpiles during hours of operation• 15% of mix water in truck before dry materials• Inject cement through concentric boot• Install commercial negative pressure canopy over loading

point

3. Filter on silos

4. Filter efficiency 99.9 %

5. Recycle filter fines into a controlled silo

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

More Emission Restrictions6. No visible emissions from filters and silos

7. Zero visible emissions shall cross the plant boundary

8. Silos alarm at 95% of capacity

9. Base course and watering on haul roads (or better)

10. Surfactant, paving, wheel washing required inside ¼ mile of occupied structure

11. Haul roads limited to one mile

12. Maintenance of mixing facilities

13. Filter or baghouse on all silos if production > 1920 tons/day.

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

MONITORING

1. Activity status and filter differential pressure each time a silo is filled or truck is filled;

2. Recorded by CEMS or datalogger;

3. Confirm filter operation within manufacturer’s specifications.

…

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Recordkeeping

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

RECORDKEEPING

• Compliance based on inspections – no periodic reports to the Bureau;

• Maintain records:– Two years

– On site or at local business office

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Records

a. Actual dates/hours of operation

b. Monitoring records

c. Weekly production; monthly rolling average

d. Haul truck records

e. Fuel delivery manifests

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Records

f. Quantity and frequency of water or surfactant on roads;

g. Haul road sweeping;

h. Other haul road measures;

i. Maintenance records;

j. Loading canopy system

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

Wrapping UP…

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

How do we measure success?• New Mexico skies are blue - but they can be bluer.• New Mexico is a great place to live - but it can be better.• New Mexico workers work safely - but they can be safer

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

How does the Air Quality Bureau measure success?

• Voluntary compliance

• Partnership - ask for help

• Satisfied neighbors

NEW MEXICO ENVIRONMENT DEPARTMENT

AIR QUALITY BUREAU

QUESTIONS?