Title V Permit Preparation

1. Title V Permit Preparation Developed by staff from Cleveland Division of Air Quality, Ohio EPA Northeast District Office, and Ohio EPA Central Office Original January 2006; updated July 2010

2. Workshop Schedule

3. Receipt of Application Preliminary Completeness Review Technical Review Permit Preparation CDAQ Supervisory Review Central Office Review Content

4. Issuance of Draft Permit Post-Draft Permit Process Changes to Permit After Issuance Additional Title V actions Content

5. Application received electronically by DAPC Central Office (CO) through the e-Business Center Air Services. STARS2 action item created. Preliminary completeness action listed on CDAQ Chief of Engineering’s “To Do” list. CDAQ Chief of Engineering checks STARS2 "To Do" list daily. Receipt of Application

6. In Air Services, the “responsible official” must obtain a PIN which serves as their signature when submitting applications and other documents – the hard copy signed receipt is no longer needed. In the STARS2 activity log, CDAQ Chief of Engineering assigns permit application to the appropriate CDAQ Permit Writer. Receipt of Application

7. CDAQ Chief of Engineering determines staff workload. In general, Title V permit work is assigned to staff based on Permit Writer's number of major and minor permits as well as their current and projected workload and skill level. Facility assignments are made by CDAQ Chief of Engineering (in accordance with protocol (See Appendix A)). Receipt of Application

8. CDAQ Chief of Engineering updates STARS2 Workflow. CDAQ Chief of Engineering assigns tasks to selected staff. Receipt of Application

9. All fields of the application must be filled in (i.e., complete) in order for the facility to successfully submit the application through Air Services. Compare the application to the preliminary completeness checklist (Appendix B). Preliminary Completeness Review

10. Send “Preliminary Completeness” letter or “Preliminary Incompleteness” letter to applicant. Use letter templates for preliminary completeness or incompleteness letters (Appendices C and D respectively). Letter drafted by Permit Writer and sent within 60 days of application receipt. If more than 60 days has passed, the application automatically becomes preliminarily complete. Permit writer updates STARS2 Workflow. Preliminary Completeness Review

11. Application and/or file review Print hard copy of the application, if needed, or review in STARS2. Review the new application, making notes, listing questions. Technical Review

12. Review existing facility files as well as application materials using checklist (Appendix E). Gather relevant files. Review hard copy information. Check completeness against active and archive file databases. Make notes and/or list questions to ask. Identify missing portions of the application. Technical Review

13. Review for control equipment Review most recent stack test report. Check continuity of most recent inspection report with Title V application. Check PTOs, PTIs, and prior issued Title V permit (for renewals). Review facility profile in STARS2 for control equipment accuracy. Technical Review

14. Review non-insignificant and insignificant units Identify major issues. Review (most current) PTIs. Check installation dates. Check PTIs and related files to PTIs (both insignificant and non-insignificant). Request and review emissions calculations and relevant info for questionable insignificant units. Review EAC forms. Technical Review

15. Update emissions units in STARS2 Confirm that insignificant units are properly identified. If a unit should be marked insignificant the facility needs to update their profile. Ohio EPA does not have the rights to mark a unit insignificant. Technical Review

16. Has all technical information been received? Determine if missing information can be obtained in hardcopy or if an application revision via Air Services is needed. Request missing information in writing from company or return application if necessary. If application revision is submitted: Check to see if requested information has been added. Check for newly-discovered issues. Reassess if application is adequate once information is received. See Appendix F for technical incompleteness procedures if necessary. Technical Review

17. Site visit During the development of a Title V permit, a site visit must be conducted. Ideally, this site visit takes place after the review of the files and application. If the Permit Writer has visited the entire facility (as part of a previous site visit or facility inspection) a short time before the application receipt, this visit may suffice. Technical Review

18. Site visit (continued) Conduct a site visit via a set appointment and include the following elements: Ask questions and take notes. View emissions units in operation. Check condition and operation of control equipment. Verify control equipment identified in application. Review monitoring and record keeping information. Technical Review

19. Site visit (continued) If possible, invite an Enforcement Specialist along on the site visit. The Enforcement Specialist may be able to bring a different perspective to viewing the current operations and compliance at the facility. Technical Review

20. Review recent “similar” Title Vs for consistency All issued Title V permits are posted on Ohio EPA’s DAPC web site and are also stored in STARS2. A keyword search is available on STARS2 under the permitting tab. Use discretion in reviewing similar permits as things might not be exactly the same for the permit that you are preparing. Technical Review

21. Contact CO Reviewer[1] As needed, contact CO Reviewer via phone or e-mail prior to the drafting of the permit to inform that work has been started on the Title V permit. After initial contact, all parties maintain contact with CO Reviewer, as needed. This communication establishes the working relationship that is beneficial to effective and timely permit issuance; discussions include deadlines, guidance, and resource suggestions. [1] Task can be conducted in one or more sections. Technical Review

22. 15 minute break Break

23. Prepare a listing of pollutants The following resources can be used: Facility Information Internet Other Sources Permit Preparation

24. Facility information: Title V application; Fee reports; Stack test information; Previous permits; Process flow diagrams; and Raw materials review (e.g., EAC forms) Permit Preparation

25. Internet: U.S. EPA Compilation of Air Pollutant Emission Factors (A.K.A AP-42); http://www.epa.gov/ttn/chief/ap42/index.html OHIO EPA DAPC website http://www.epa.state.oh.us/Default.aspx?alias=www.epa.state.oh.us/dapc Permit Preparation

26. Other sources: AWMA Air Pollution Engineering Manual – a.k.a. AP-40; RACM manual and E.G. 75; Experienced colleagues; Similar issued permits (i.e., permits issued for different facilities with the same types of emissions units); and Similar issued permits (i.e., permits issued for "sister" facilities with the same facility name located in different parts of the State – such as for General Motors Corporation). Permit Preparation

27. Develop a listing of applicable rules for each emissions unit. The following resources can be used: CDAQ applicable rule index (see Appendix K); Previous permits for the source (i.e., PTOs, PTIs, Title V, etc.); Internet; Similar issued permits; Permit application; and Inspection reports. Permit Preparation

28. Applicable Rule resources (continued) Review installation/modification dates to determine if PTI is necessary. Verify the installation/modification dates in STARS2. Applicable federal rules for each pollutant: NSPS 40 CFR Part 60; NESHAP 40 CFR Part 61; and MACT 40 CFR Part 63 (if HAPS are listed as a pollutant). Permit Preparation

29. Determine Applicable Limits for each State and Federal Rule. The following resources can be used: Issued PTIs, PTOs, and Title V permits; Ohio Administrative Code (OAC); Code of Federal Regulations (CFR); and Ohio EPA Engineering Guides. Permit Preparation

30. Applicable Limit Resources (continued). Review issued PTIs for the source Compare current State/federal regulations to PTI limits and check the current validity of any emission factors relied upon to establish PTI limits. In certain cases where a new State regulation is more stringent than a PTI limitation, or when emission factors change, CDAQ may need to process a modification of the PTI concurrently with the processing of the Title V permit. Permit Preparation

31. Applicable Limit Resources (continued). Compare all limits for the same pollutant to determine whether the limits are less stringent or equivalent to each other in order to include appropriate "less stringent than" or "equivalent to" wording in the permit. An example for a particulate emission source: identify release point(s) - stack or fugitive. Permit Preparation

32. Applicable Limit Resources (continued). Ohio Administrative Code (OAC rules) - refer to most current version on the Ohio EPA DAPC website. Code of Federal Regulations (CFR): NSPS 40 CFR Part 60; NESHAP 40 CFR Part 61; and MACT 40 CFR Part 63. Permit Preparation

33. CDAQ Permit Writer and CDAQ PRM evaluate the need for a “pre-draft” strategy. STARS2 now allows for grouping of identical emissions units; therefore, “pre-draft” strategy might not be needed. CDAQ Permit Writer and CDAQ PRM determine if enough emissions units to be included in the permit are similar to pursue a pre-draft strategy. Permit Preparation

34. “Pre-Draft” Strategy (continued). If there are several similar emissions units, terms and conditions may be prepared for a sample emissions unit and submitted for review under a pre-draft strategy. When prepared, the sample terms and conditions under a pre-draft strategy will be sent to DAPC CO Reviewer for review. Permit Preparation

35. Creating the permit “shell” The T&C document must be generated in STARS2. Prior to generating the terms and conditions document in STARS2, make sure the list of active emissions units is accurate, if it is not, facility might need to update the facility profile and resubmit their application. Terms and conditions (T&Cs) are developed primarily for non-insignificant emissions units and, if needed, facility-wide terms are also developed. T&Cs are prepared in Word and saved to L:\Data\Facilities at the appropriate facility number folder. Optional, it’s also okay to begin preparing the SOB at this point, or wait until permit terms are complete. Permit Preparation

36. Permit Preparation Review following sources for possible terms: Incorporate appropriate PTI(s) T&Cs into Title V permit T&Cs. Issued Title V permits from similar sources (use as appropriate) Can check with CO for up-to-date information on previous permits prior to writing current Title V permit. Check Library of Terms and Conditions (use as appropriate). If necessary, develop T&Cs from inspection report and/or site visit.

37. Permit Preparation Review sources (continued) Identify any necessary operational restrictions. Identify alternative operating scenarios. Determine what type of monitoring, record keeping, and reporting program is necessary for the permit.

38. Permit Preparation Review sources (cont.) For each allowable emission rate or control requirement, determine if an adequate demonstration of compliance has been included in the testing section. Determine the frequency of emission testing (required by PTI, Engineering Guide #16, etc.). Review most recent emission testing for each emissions unit. Verify compliance with applicable limit(s) and ensure that acceptable test methods were employed.

39. Permit Preparation Review recent fee emissions reports Use average ton/hr values and hours of operation to estimate short term emissions rates to determine whether source is likely to be in compliance. Where possible, emission estimation methodology in fee emissions report (FER) should match compliance method in permit.

40. Assemble State/federal T&Cs Part B Specific Facility Terms and Conditions Provides for placement of requirements that apply to the entire facility or to several emissions units at the facility. MACT, NSPS, NESHAP, synthetic minor terms for HAPs, etc., and insignificant emissions unit requirements are usually included in Part B. Permit Preparation

41. Assemble State/federal T&Cs (continued) Part C Terms and Conditions for Emissions Units Operations, Property, and/or Equipment [section 1.] This is imported from the emissions unit description in the facility profile in STARS2, update if necessary. It should clearly describe the equipment and processes that comprise the emissions unit and the associated control equipment. Section a)(1), identify terms that are State-only enforceable (e.g., air toxics terms, new (not modified) OAC rules that are not part of the federally approved SIP). Permit Preparation

42. Assemble State/federal T&Cs (continued) Part C Terms and Conditions for Emissions Units Applicable Emissions Limitations and/or Control Requirements [section b)(1)]. List Rules/Requirements. List Emission Limitations/Control Measures. Permit Preparation

43. Assemble State/federal T&Cs (continued) Part C Terms and Conditions for Emissions Units Additional T&Cs [section b)(2)] Overflow from section b)(1) (e.g., synthetic minor restrictions). Clarification of emission limits/control measures. Define control efficiency if applicable. Negative declarations and/or rule exemptions. Permit Preparation

44. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Operational Restrictions [section c)] Ensure ongoing compliance with the applicable requirements, emissions limitations, control measures, etc.. Include restrictions on hours of operation, production, coating usage, etc., as needed. Permit Preparation

45. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Monitoring and Record Keeping Requirements [section d)] Required for each operational restriction, control measure and emission limit (unless otherwise specified in the T&Cs). Data required to be recorded and maintained. Must specify frequency of monitoring. Specify monitoring devices (e.g., CEMs, see Engineering Guide #52 for CEM systems). Include air toxics language if contained in PTI. Permit Preparation

46. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Reporting Requirements [section e)] Specify the results required to be reported. Specify the frequency of reports (e.g., quarterly deviation-based, annual, "after the event," etc.). Include requirements to submit reports of deviations from operational restrictions and/or emission limitations. Include term regarding submission of reports through Air Services. Permit Preparation

47. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Testing Requirements [section f)] List each emission limitation from section b)(1) of the permit and provide a method for determining compliance for each. Specify the applicable compliance method for each emission limit. Cite applicable test methods where needed. Compliance may be based solely on monitoring, record keeping and reporting or on emission factor(s) rather than testing. If needed, stack testing requirements are inserted in section f)(2) (see Engineering Guide #16 or applicable rules). Permit Preparation

48. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Testing Requirements [section f)] (cont.) Compliance methods may include one or more of the following: Emissions tests; Material balance calculations; AP-42 emission factor calculations; Method 24 analyses; CEM and COM data; Record keeping program; and/or VE readings using Method 9. Permit Preparation

49. Assemble State/federal T&Cs (cont.) Part C Terms and Conditions for Emissions Units Miscellaneous [section g)] Items that do not fit under any of the above categories. Permit Preparation

50. Pizza time! Break