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Permit Application Information and Work Group Exercises

This document outlines essential information for permit applications related to monitoring provisions. Key aspects include background information, monitoring approach descriptions, emission unit specifics, applicable regulations, and control technologies. Additionally, it details measurement methods, monitoring frequencies, and definitions for excursions. Quality assurance and reporting requirements are also addressed, along with a sample permit table for clarity. This comprehensive guide aims to support compliance and enhance understanding of monitoring criteria in environmental permits.

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Permit Application Information and Work Group Exercises

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  1. Permit Application Informationand Work Group Exercises Peter Westlin, EPA, OAQPS

  2. Outline of Permit Submittal re: Monitoring Provisions • Background information • Monitoring approach description and level of detail • Justification and support

  3. Basic Background • Emissions unit (PSEU) • Applicable regulations, emission limits, and monitoring requirements • Control technology (e.g., control device (CAM), compliance fuel or raw material, process controls, operation and maintenance protocols)

  4. Monitoring Approach (CAM) • Measurement method (what and how) • Monitoring frequency and averaging procedures • Excursion or exceedance definition (indicator range for CAM) • Performance criteria – QA/QC procedures

  5. Other Permit Content Factors • Commitment to corrective action • Reporting and recordkeeping • Verification of operational status • QIP Threshold (optional) • Data availability (optional) • Table format (for clarity in permit)

  6. Justification • Brief description of source/control device • Rationale for selecting indicators • Rationale for selecting indicator ranges • Supporting information (e.g., test data, design factors, historical data, margin of compliance)

  7. Monitoring Approach–Title V Permit Table (example) Indicator Combustion T Outlet CO conc. Measurement approach Thermocouple CO CEMS Indicator range Excursion: <1500°F Excursion: >50 ppmv Data representativeness Installed in incinerator PS 4, 40 CFR 60, App. B chamber QA/QC Redundant t-couple and span gas Monitoring frequency Measure continuously Daily zero (+ 30F) Measure continuously (10 sec) Data collection Record continuously Record 1-min averages procedures on chart recorder by DAS (electronic) Averaging period None 1-hr average QIP threshold No more than six No more than 10 excursions excursions 7

  8. Questions?Let’s divide into groups

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