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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)

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How to Actually Write a Title V Permit Renewal

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  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

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