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Effective Title V Permits

This comprehensive guide explores the benefits of incorporating Alternative Operating Scenarios in Title V permits, allowing for seamless operational changes with minimal delays. Learn how to streamline multiple requirements and leverage flexibility for an ideal Title V permit. Requested by the facility, these scenarios offer innovative compliance options and ensure easy adaptation to evolving regulations.

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Effective Title V Permits

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  1. Effective Title V Permits Scott Miller U.S. EPA Region 4 (404) 562-9120 miller.scott@epa.gov

  2. Ideal Title V Permit • Allows for changes to be undertaken with as little delay and paperwork as possible • Little effort and foresight can cut time to implementation of operational changes • Multiple vehicles designed into title V regulations for accommodating changes • Reduce recordkeeping/reporting

  3. One ToolAlternative Operating Scenarios • 40 CFR 70.6(a)(3)(i)(9) • Permit should include all alternative operating scenarios REQUESTED BY THE FACILITY in title V application • If you can dream it and write it, then install it in the title V permit

  4. Alternative Operating Scenarios • Facility may request inclusion of alternative scenario at any time • Alternative operating scenario can be a different means of compliance with an existing standard or an entirely new applicable requirement • Why wait to trigger and applicable requirement if you think one is coming?

  5. Alternative Operating Scenarios • Florida – Chapter 62-213.410(1) • Georgia – 391-3-1-.03(10)(d)(1)(i) • North Carolina – 15A NCAC 2Q.0508(p) • Kentucky – 401 KAR Chapter 52:020, Section 10 • Colorado – 1001 AQC, Regulation 3 • Arkansas – Regulation 26,Chapter 7,Section 26.701(I)

  6. Alternative Operating Scenarios • Virginia – 9 VAC 80-110.J • New Jersey – 7.27-22.16(h) • New York – Chapter III, Subpart 201-6.5(f)(1)

  7. Alternative Operating Scenarios • Examples • HON-affected facility desires multiple compliance options stated to show compliance with MACT standard • Other examples

  8. Alternative Operating Scenario • Does your facility have a five-year plan? • What affected units might be subject to additional air regulations or a change in regulations already in the permit?

  9. Flexible Preconstruction Permits • Couple flexible preconstruction permits with alternative operating scenarios to obtain the most flexibility and move toward the “ideal” title V permit

  10. Streamlining Multiple Requirements • Streamline multiple applicable requirements to which a process unit may be subject into ONE set of requirements • Perform a streamlining analysis per EPA White Paper II

  11. Streamlining • Basis of Streamlining found here: • http://www.epa.gov/ttn/oarpg/t5/memoranda/wtppr-2.pdf

  12. Streamlining • Once again, REQUESTED BY THE FACILITY not an automatic • Imation Example

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