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Complex Project Pre-Application Meetings


The DNR requires pre-application meetings for PSD projects and Greenfield Ethanol Plants, and recommends them for any other project that may become complex in nature (SIP, Netting, Major Greenfields, etc.). A pre-application meeting will be required prior to a PSD permit application being reviewed. Preferably the pre-application meeting would occur at the facility and would include a tour of the area and/or processes involved. However, in some circumstances a site visit may not be necessary or possible. In which case an alternate location, possibly at the Air Quality offices, would be arranged. To schedule a pre-application meeting please contact either Dave Phelps at 281-8189 or Gary Smith at 281-4635.

Info needed prior to pre-application meeting

The following information must be submitted to the DNR at least two weeks prior to the meeting (unless otherwise noted).

  • Agenda of items applicant wishes to discuss at the meeting
  • List of people attending (see below).
  • Executive Summary of applicant process/project.
  • Anticipated controls and emission rates
  • Location of the new or modified facility
  • List of nearby facilities that could be considered support facilities or are under common control
  • MACT/NSPS applicability
  • Modeling Protocol (not applicable if modeling is not required)
  • Company’s plans to address pre-construction monitoring

  • (One year of pre-construction monitoring may be required if existing air quality data does not exist or is not representative. Information about air quality monitoring sites in Iowa can be found here.)
  • Whether or not the company wishes for EPA to be involved in the pre-application meeting.
Items that will be discussed at the pre-application meeting
  • Forms required in the application
  • Clarify the permitting process for company and public.
  • Discuss site-specific issues.
  • Discuss control technologies that are anticipated/acceptable.
  • Local air quality concerns (NAAQS, increment, others).
  • Explore pre-construction monitoring and dispersion modeling.
  • Modeling Protocol
  • Additional Impact Analysis
  • Identify similar permitting examples
    • BACT
    • Monitoring, testing, recordkeeping
    • Economic feasibility
  • Establish communication expectations, procedures and responsibilities.
  • Discuss application formatting and number of copies required.
  • Confidentiality
  • Allowable pre-permit activities
  • EPA's role
  • Establish the timeline for the review process.
    (A generalized timeline can be found here).
  • Discuss the DNR's policy for determining the prioritization of the project.

Timing

Pre-application meeting should occur no earlier than three months prior to permit application submittal. The application itself should be nearly complete before attending the pre-application meeting. Having a majority of the application complete before the meeting will provide information needed for the Department to answer more detailed questions.

Meeting Participants

The appropriate people from the DNR will automatically attend based on the information provided prior to the pre-application meeting. The DNR will also coordinate with EPA and the appropriate local agency for their attendance if applicable. However, it is the applicant's responsibility to make sure all other appropriate people attend the meeting.

    Participants that should be included:

  • Construction permit supervisor

  • For scheduling purposes.

  • Two DNR engineers

  • Two engineers should be present to assure understanding of the project scope and facilitate the permit application review.

  • Applicant's environmental representative, project engineer and consultant

  • To describe the process to the DNR and represent the company.

  • Local Agency (if applicable)

  • If the project will be located in Polk or Linn county, a representative from the appropriate group should be included in the meeting.


    Optional participants:

  • DNR Modeler

  • At least one modeler should be present if the project will need to be modeled (required for PSD projects).

  • Compliance

  • A member of the DNR compliance staff should be included if the facility is not in compliance.

  • Legal

  • A member of the DNR legal team should be included if there is a question about confidentiality.

  • Title V

  • If the facility will be major for Title V, a DNR staff member from that section may be included.

  • Other Management

  • Any other management that may play a role in the project may be included.

  • EPA Representative

  • Including EPA in the pre-application meeting can help avoid unanticipated difficulties later in the application process.

  • Representative from DED

  • If DED has been included in the project they should be included in the meeting.



 

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