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Title V Permits The Ten Commandments of Technical Review

Title V Permits The Ten Commandments of Technical Review. Christina Wieg Ohio EPA, SEDO, DAPC November 2009. I: Thou Shall Read and Refer to the Guidance. Draft Title V Renewal Application Review and Permit Development in STARS2 Memo dated 2/26/09

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Title V Permits The Ten Commandments of Technical Review

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  1. Title V PermitsThe Ten Commandments of Technical Review Christina Wieg Ohio EPA, SEDO, DAPC November 2009

  2. I: Thou Shall Read and Refer to the Guidance • Draft Title V Renewal Application Review and Permit Development in STARS2 Memo dated 2/26/09 • Title V Completeness Checks (marked draft) • Inter-office communication Title V Renewal Application Review and Permit Development dated August 10, 2004 • Other Sources: • The Answer Place • http://www.epa.ohio.gov/dapc/title_v/titlev.aspx#eguides • July 11, 2006 GE Decision IOC • DAPC T&C Library

  3. II: Thou Shall Use the Checklists • The checklists should be included when you turn in your permit for review. • Technical Completeness Checklist & Preliminary Completeness Checklists • Title V Renewal Permit and Permit Development Checklist • Application Review portion • Renewal Permit Development

  4. III: Thou Shall Start with the Application • Review the renewal application • Compare to the old permit • Make notes • List questions

  5. The Parts of the Application • Application Facility Level Summary • Each Non-insignificant Emissions Unit • Each Insignificant Emissions Unit • Attachments • EAC (did they do it for IEU that have requirements too?) • Calculations • Flow Diagrams

  6. Non-Insignificant vs. Insignificant EU • Insignificant EUs include: • All source categories excluded from the requirements to obtain installation permits or operating permits under section 3704.011 of the Revised Code or Chapter 3745-15, 3745-31, or 3745-35 • All source categories specifically exempted under 40 CFR Part 70; or • Any emissions unit withuncontrolledpotential emissions of five tons or less per year of any regulated air pollutant other than a hazardous air pollutant and not more than twenty percent of an applicable major source threshold under the act • Any research and development source that is by itself not a major source

  7. IV: Thou Shall Check the CalculationsWhere did those numbers come from anyways? • Understand where the numbers came from. Just because they were in the past permit doesn’t make them right. • Document where the numbers came from. • Are the EFs reasonable? • If they say they are based on manufacture’s specks, do we have these specs on file? • If AP-42 was used in their calculation, did they use the most recent version for their EF? Update if needed. • Do you get the same results when you work the numbers?

  8. V: Thou Shall Review the Files • Are there outstanding issues that should be addressed in new permit language? • Are their consent orders language that need to be included? • New PTIs that were overlooked? • Has anything changed from their last permit actions (materials on EAC, flow diagrams, etc)?

  9. VI: Thou Shall Conduct a Site Visit • A site visit must be conducting during the development of the Title V renewal • Are all the sources still there? • Does the application match what is there? • Is the control equipment working and in place? • Does anything look modified? • Are they in compliance?

  10. Not Preliminarily complete?What do I do? • OAC rule 3745-77-05(B)(1)- The director shall promptly provide notice to the applicant for a Title V permit of whether the application is complete. Unless the director determines within sixty days after receipt of the application that the application is not complete, and issues a written notice of such determination as provided in paragraph (B)(2) of this rule, the application shall be deemed to be complete. A completeness determination is not required for modifications processed through minor permit modification procedures contained in rule 3745-77-08 of the Administrative Code In other words…..You have 60 days from the time we get the application to determine if it is preliminarily complete otherwise it is deemed to be complete and you must proceed with the stipulations in the next slides.

  11. Not Technically Complete?What do I do? • OAC rule 3745-77-05(B)(2)- If, during the processing of an application before or after it has been determined or deemed to be complete, the director determines that additional information is necessary in order to evaluate or take final action on the application, the director may request that information in writing from the applicant. Any such request shall identify the information requested with reasonable specificity, provide a basis for the request, and shall provide a reasonable time period, not less Than fifteen days, for the applicant's submission of the requested information. In other words……if you find it to be technically incomplete you should request the information in writing (with a formal letter) and you have to request the information to be given to us no less than 15 days……

  12. Not Technically Complete?What do I do? • OAC rule 3745-77-05(B)(3)- If an applicant fails to make a good faith and timely response to a request for additional information under this rule with regard to an application that the director believes to be incomplete, the director shall offer to meet with the applicant within seven days after issuance of a letter for failure to submit the requested information. If the meeting or meeting offer fails to obtain a complete application form the applicant, the director, without prior hearing, shall make a final determination that the application is not complete. Any such determination shall not become effective until twenty days after notice of the determination is sent to the applicant by certified mail. An incompleteness determination by the director may be appealed in accordance with section 3745.04 of the Revised Code, except that if the notice of appeal is timely filed and is accompanied by an application for stay, the stay shall become effective upon filing and shall continue until such time as the environmental board of review rules on the merits of the stay. In other words….. If they don’t give you the requested information, you have to request to meet with them (work this out with your supervisor) within 7 days of sending them a failure to submit the requested information..…and if that doesn’t work…..we can make a determination that the application is not complete. This determination becomes effective 20 days after the facility receives notification via certified mail.

  13. VII: Thou Shall Compile a List of Needed Info & Request it in Writing • Try and take the time to look over the ENTIRE application, and make list of questions….then ask for the information from the facility via a certified, formal agency letter with a requested time frame. • Make sure to “stop the clock” in STARS2

  14. Facility Submits Requested Information • The requested application information should be received in STARS2 via a permit application amendment/revision • Answers to clarifying questions/correspondence should all be kept in a Title V Renewal file and included in packet given to permit reviewer. • Return the STARS2 clock back to you

  15. VIII: Though Shall Review “similar source” Title V Permits • BE CAREFUL HERE…..I recommend looking at these “other” permits after you have drafted your own…Just because it made it into a final permit DOES NOT make it correct. Just review the permits and ask yourself: • What is different between their permit and mine? • Why is it different? • Do we have the same applicable rules? If not, why? (different size, time period, etc) • Is the permit terms written in the same format? If not, why?

  16. IX: Though Shall Prepare a Detailed Permit Write –up Based on the Technical Review • Anything that you found during your review should be included in a permit write up in order to aid the review process • Did you change mistakes in the permit (rules removed because they didn’t apply or added rules that were left out)? • Did something change at the facility that required something to change in the permit? • Did you tighten up record keeping/reporting because you found that there were loop holes in the way the old permit was written?

  17. X: Though Shall Keep an Open Dialogue with Facility and Permit Reviewers As Needed • If you know an issue is going to arise, try to work it out during the writing processes • If you just don’t know how to handle something, speak to your supervisor to determine the best way to handle it .

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