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Mr. Himanshu Mehta <br />8 May 2025 <br />Page 5 <br />Phase 3— Title V Permit Revision Applications <br />Under this phase, Geosyntec will prepare the FDEP Title V Air Operation Permit revision <br />application for the IRCL facility. Geosyntec will complete FDEP, DARM Form No. 62- <br />210.900(1) titled "Application for Air Permit - Long Form" and address the additional <br />information items required by the form. The following items will be prepared as part of the <br />permit revision application: <br />• Facility plot plan; <br />• Process flow diagram; <br />• Precautions to prevent emissions of unconfined particulate matter; <br />• List of insignificant activities; <br />• Identification of applicable requirements; <br />• Compliance report and plan; <br />• Description of proposed revisions to the current Title V Air Operation Permit; <br />• Fuel analysis or specification; <br />• Detailed description of control equipment; <br />• Procedures for startup and shutdown; <br />• Operation and maintenance plan; <br />• Previously submitted information; and <br />• Identification of applicable requirements. <br />Geosyntec will describe the additional emission unit (i.e., the flare) for the IRCL facility, and <br />calculate the emissions of air pollutants expected to be released into the environment by its <br />operation. Geosyntec will complete the required FDEP Form 62-210.900(1) and prepare a <br />transmittal letter to FDEP that summarizes the permit revision application package. <br />Phase 4 — Response to Regulatory Comments <br />Following submittal of the permit revision application, Geosyntec will meet with the FDEP- <br />DARM Tallahassee office to present and discuss the application package. This meeting will be <br />held via teleconference in order to reduce overall costs of the project. Geosyntec will provide <br />FDEP-DARM with written responses to requests for additional information (RAIs) throughout <br />the course of the permit application review process. For the purpose of the budget estimate, <br />Geosyntec has estimated one response to FDEP-DARM RAI will be required. <br />Geosyntec will also review and provide comments on the draft Title V Revised Permit issued by <br />FDEP to ensure that it is consistent with the facility requirements and does not contain <br />unexpected compliance and monitoring requirements. <br />NCP2323263/JL23037 Title V Air Operation Permit Revision Proposal.doc <br />engineers I scientists I innovators <br />