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3.2.2.1 Air
Most states have been granted the authority by EPA to implement some, if not all, of the
requirements of the Clean Air Act.
a. Permit to Construct (PTC). Applications for a PTC and an Operating Permit for the
proposed facility should be submitted to the state 15 to 18 months prior to commence-
ment of construction. Generally (although this may vary from state to state), the state
will notify the applicant within 30 days whether the application for PTC or operating
permit is complete and within 60 days will issue a proposed approval, proposed con-
ditional approval, or proposed denial, with an opportunity for public comments to
follow.
b. NESHAP Analysis. A NESHAP analysis is generally submitted to the state along with
the PTC application. State review of the PTC application does not occur until the EPA
approves the NESHAP document. Data collection (ambient air and engineering data)
for the analysis typically takes 1 yr, and preparation of the analysis about 6 months.
3.2.2.2 Archaeological Finds
If archaeological resources are determined to be endangered by a project-related activity,
application for a permit from the jurisdictional land manager to remove or excavate an archaeo-
logical site must be submitted. Activities are coordinated with the State Historic Preservation
Office (SHIPO). The DOE must be qualified to do the permitted removal or excavation. Archaeo-
logical resources excavated or removed remain the property of the United States. The remains
and the copies of records and data must be archived by a suitable institution.
3.2.2.3 Other State Requirements
Other state requirements will likely include water quality standards and wastewater treat-
ment requirements, solid and hazardous waste requirements, and special provisions for wildlife.
These vary by state and will have to be developed when specific fusion facility sites are
selected.
3.3 Environmental Compliance Procedures and Scheduling
3.3.1 Environmental Documentation Guidelines
3.3.1.1 NEPA Compliance Plan
Specific environmental mitigation commitments identified in fusion facility NEPA docu-
ments are incorporated into the design and operation of the facility through an approved Mitiga-
tion Action Plan (MAP). The MAP describes how mitigation of adverse environmental conse-
quences will be implemented and monitored to assure effectiveness. The implementation of the
MAP will be the responsibility of the design, construction and operating organizations. The plan
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