1 / 31

How to Actually Write a Title V Permit Renewal

How to Actually Write a Title V Permit Renewal. Generate TV Permit Shell in STARS2. Proper designation of Insignificant Emissions Units (IEUs) in Permit Available Guidance: Answer Place ID 1259 video (don’t follow upload instructions)

cullen-hutchinson
Télécharger la présentation

How to Actually Write a Title V Permit Renewal

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. How to Actually Write a Title V Permit Renewal

  2. Generate TV Permit Shell in STARS2 • Proper designation of Insignificant Emissions Units (IEUs) in Permit • Available Guidance: Answer Place ID 1259 video (don’t follow upload instructions) • Must group IEUs so that they are appropriately incorporated into the permit shell • Make sure all IEUs are added to permit • Create groups of IEUs • IEUs with applicable requirements • IEUs with no applicable requirements • Generate shell document • IEUs will be grouped at the end of the document

  3. Generate TV Permit Shell in STARS2 • Grouping of Similar Emissions Units • Emissions units with identical terms and conditions can be grouped on the Permit Detail Page • Shell will contain one set of terms and Conditions (T&Cs) for the entire group

  4. Generate TV Permit Shell in STARS2 • Basic format of Shell • Same format as PTI/PTIOs • Facility-wide (Section B.) and emissions unit-specific (Section C.) sections • Permit structure numbering • C. Level 1- the section level 1. Level 2 – the emissions unit or grouping level c) Level 3 (1) Level 4 a. Level 5 i. Level 6

  5. Convert STARS-issued TV Permit from HTML to Word Format • Convert HTML document to Word • Available Guidance: Answer Place ID 1232 video and June 27, 2008 IOC from Mike Hopkins • Retrieve HTML version of previously issued permit from STARS2 • Manipulate formatting in Word using Macros • Enable Macros • Run Macros • Removes nested tables, reconstructs emissions unit tables, removes repeated text, and removes paragraph breaks

  6. Convert STARS-issued TV Permit from HTML to Word Format • Copy converted document into Shell • Available Guidance: April 25, 2008 IOC from Mike Hopkins (don’t follow upload instructions) • Cut and Paste terms using Quickstyles • Beware old State-only terms that must be moved! • Format the emissions limitations table

  7. Convert STARS-issued TV Permit from HTML to Word Format • Clean-up • Update internal references (Available Guidance: June 26, 2008 IOC from Mike Hopkins) • Identify state-only enforceable terms

  8. Drafting Title V Permit Terms and Conditions • Available Resources • Previous Title V permit • Issued PTIs (esp. new or modified since last TV) • ORC/OAC rules • Federal regulations • Facility files • State-wide permit terms and conditions library http://www.epa.ohio.gov/dapc/terms/termsintro.aspx • SEDO standard terms and conditions (J:\DAPC\PERMITTING\STCs) • Engineering Guides • Other guidance memos

  9. Develop Facility-wide Terms and Conditions • For requirements that apply to the entire facility • Facility-wide synthetic minor restrictions • MACT blurb • IEUs • Must list which terms are state-only enforceable

  10. Develop Facility-wide Terms and Conditions • List IEUs in Facility-wide Terms and Conditions • Copy or cut and paste the IEUs from the end of the shell document to the appropriate Part B. place • Delete the Part C. T&Cs that were associated with the IEUs • List appropriate rule citations next to each IEU • PTI or PBR number • OAC rule 3745-31-03 for other exemptions • ORC 3704.036 for existing sources that meet IEU definition

  11. Develop Emissions Unit-Specific Terms and Conditions • List applicable rules in Emissions Limitations Table for all Non-Insignificant EUs • List allowable emissions limits in Emissions Limitations Table for all Non-Insignificant EUs • Section generally will contain all the numerical emission limitations • Requirements can spill over into additional T&Cs if needed

  12. Develop Emissions Unit-Specific Terms and Conditions • Develop Appropriate Operational Restrictions and Monitoring, Recordkeeping, and Reporting (M/Rk/Rp) Requirements

  13. Develop Appropriate Operational Restrictions and M/Rk/Rp Requirements • List operational restrictions necessary to ensure ongoing compliance with the applicable requirements • Restrictions may originate from state rule, PTI, self-imposed de-rating, operating conditions that reflect good O&M of the control equipment • May apply to the emissions unit, e.g. hours of operation, coating usage, production rate, type of material used, fuel quality specs • Previously, may have applied to the control equipment, e.g. temperature, pressure drop, scrubber flow rate, pH

  14. Develop Appropriate Operational Restrictions and M/Rk/Rp Requirements • List M/Rk Requirements necessary to ensure ongoing compliance with the applicable requirements • Available Guidance: Engineering Guides 52 and 65 • EG 52 identifies emissions units that are required by federal or state rule to employ CEM, or where a CEM may be justified • EG 65 addresses monitoring and recordkeeping programs • Permittee has to propose compliance approach as part of the TV application

  15. Develop Appropriate Operational Restrictions and M/Rk/Rp Requirements • Develop Rp Requirements necessary to demonstrate ongoing compliance • General deviation reporting requirements contained in the Standard T&Cs • Quarterly reports of deviations from emissions limitations, operational restrictions, or control device operating parameters • Semi-annual reports of any deviations from monitoring, recordkeeping, and reporting requirements • Compliance certification • Scheduled maintenance/malfunction reporting • Fee reporting

  16. Develop Appropriate Operational Restrictions and M/Rk/Rp Requirements • Individualized reports for specific EUs • When more frequent than quarterly is desired • Other ongoing reports needed that are not excursion-based

  17. Develop Testing Requirements • Establish compliance methodologies • Compliance methodologies should be established for each emissions limitation listed in the table • Make sure correct format is being used • Establish testing frequency • Available Guidance: Engineering Guide 16 • For Title V facilities, typically either annual, every 2.5 years, or every 5 years

  18. Develop Miscellaneous Requirements • Any other requirements, such as a compliance schedule, which do not fit elsewhere, should be specified in this section

  19. Gap-filling • Supplementing inadequate M/Rk/Rp to ensure compliance with applicable requirements • Permit needs to include sufficient M/Rk/Rp to demonstrate compliance with applicable emissions limits and op restrictions • Experience, appeals, and court decisions have influenced what is sufficient over time • 2008 federal District Court decision upheld right to gap-fill if underlying monitoring is not sufficient to assure compliance

  20. Gap-filling • Applicant is required to identify all requirements and how they will comply as part of TV application • Applicant may submit differing compliance strategy than DAPCs standard terms prescribe • Review applicant’s strategy to determine if as stringent as DAPCs suggested approach • If as stringent, OK to include applicant’s strategy (may need slight tweaking)

  21. Update outdated T&Cs that have been copied from previously issued permits • Add authority citations • Needed for all state-federal enforceable terms and conditions in Parts B and C of the Title V permit. • Revise previous operational restrictions in accordance with GE decision • Available Guidance: July 11, 2006 IOC from Hopkins, Orlemann, Hall, Ahern

  22. Update outdated T&Cs that have been copied from previously issued permits • Revise MACT/NSPS/NESHAP T&Cs in accordance with Engineering Guide 76 • Round 1 Title V permits may have parts of these rules included, or entire rule included, either in terms or as attachment • Now using “detailed citation” approach per EG 76

  23. Update outdated T&Cs that have been copied from previously issued permits • Revise existing superseding language to approved streamlining language • Early Title V permits had “superseding” language to revise the M/Rk/Rp established in older PTI’s. • Any change in M/Rk/Rp requirements needs to be equivalent or more stringent than requirements established in an underlying PTI • If this is not the case, then the PTI will need to be modified and you will not be able to “streamline” the different M/Rk/Rp requirements in the renewed permit.

  24. Update outdated T&Cs that have been copied from previously issued permits • Update other T&Cs consistent with most recent standards • Many of the standard T&Cs we use have evolved since Round 1. e.g. VE check, testing STCs. • Note: do not change air toxics language where toxics analysis was done prior to the SB265 toxics rule changes

  25. Drafting Title V Permit Terms and Conditions • Develop CAM Requirements (if needed) *This topic will be covered later in the training*

  26. Drafting Title V Permit Terms and Conditions • If renewal is also addressing previous modification applications or supplemental updates to current renewal, confirm that all modification issues and supplemental info have been incorporated appropriately into T&Cs • Off permit changes, minor mod, sig mod may have previous applications (should be dead-ended) • Renewal application should have incorporated all previous mod issues • Permitter should confirm this during technical review • Make sure that all supplemental applications to current renewal have been associated with the permit in STARS2

  27. Drafting Title V Permit Terms and Conditions • Identify State-only Enforceable Requirements in Section C.1.a)(1)

  28. Drafting Title V Permit Terms and Conditions • Include Section 112(r) Risk Management Plan Requirements (if needed) • Central Office permit review staff must continue to identify Title V facilities that are required to file a 112(r) risk management plan. • Notify Central Office contact when a facility is subject to 112(r) requirements so that the permit language can be properly reflected in Part B of the permit. (CHECK FLAG IN STARS2) • Available Guidance: October 16, 2001 e-mail guidance from Tom Rigo

  29. Drafting Title V Permit Terms and Conditions • Include Acid Rain Requirements (if needed) • Central Office permit review staff must continue to identify Title V facilities that subject to 40CFR Part 72 (acid rain requirements) • Notify Central Office contact when a facility is subject to acid rain requirements so that the permit language can be properly reflected in Part B of the permit. (CHECK FLAG IN STARS2) • Available Guidance: October 16, 2001 e-mail guidance from Tom Rigo

  30. Drafting Title V Permit Terms and Conditions • General Considerations for T&Cs • Should be accurate and comprehensive (from a regulatory standpoint) • Should be clearly written (understandable) • Should be enforceable • Should be grammatically correct • Should be defendable upon appeal • Overall, they should be a high quality, professional looking product

More Related