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How to target your review

How to target your review. Genevieve Damico U.S. EPA (312) 353-4761 damico.genevieve@epa.gov. What should I review in a permit?. Programmatic issues Monitoring Reporting Inclusion of regulatory standards Emission units. Background.

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How to target your review

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  1. How to target your review Genevieve Damico U.S. EPA (312) 353-4761 damico.genevieve@epa.gov

  2. What should I review in a permit? • Programmatic issues • Monitoring • Reporting • Inclusion of regulatory standards • Emission units

  3. Background • Title V requires monitoring, recordkeeping, and reporting (MRR) to assure compliance. • Practically enforceable permit limitations include MRR that reasonably demonstrate compliance. • Note: The ability for Title V to require additional monitoring is the subject of some debate

  4. Evaluation • MRR and testing work together. It is important to evaluate these aspects of the permit holistically. • The frequency of the MRR should be appropriate to measure compliance with the emission limitations and operational restrictions.

  5. Evaluation Chart

  6. Some things to consider • Are emission factors appropriate? • Is the emissions test performed “periodically”? • Is the data collected reliable?

  7. Questions to Ask • Would the permittee, the permitting authority, and I have sufficient information to measure compliance? • Is the frequency of the MRR sufficient to determine compliance? • Do I have access to the results of the MRR and testing? • Does the permit contain all the required MRR and testing requirements from the Federal rules and the SIP?

  8. Best bang for the buck • Units subject to pre – 1990 rules • Units subject to a SIP requirement for which there is no reasonable compliance assurance method specified • Units subject to old NSR permits • Voluntary terms created in the Title V permit

  9. What you need to make comments • List the areas you feel are not sufficient to measure compliance and suggestions for practically enforceable MRR and testing. • List the MRR and testing that you feel are applicable from Federal rules and the SIP and the corresponding rule citation.

  10. Evaluation Chart

  11. Why is it important to develop an enforceable Title V permit? • If an applicable requirement was missing from the Title V permit, the facility may argue that they are not liable for any potential violations • If a condition is written unclearly and ambiguously, the facility may argue that they followed the condition based upon their interpretation

  12. Why is it important to develop an enforceable Title V permit? • The source may not have sufficient monitoring, recordkeeping, or reporting to determine if it is in compliance • There may be conditions in the permit that prevent enforcement by the EPA and state agencies

  13. Items to look for to ensure practical enforceability • Applicable requirements must be properly translated into the permit • Wording changes must not affect the meaning of the requirement • Conditions should be enforceable as a practical matter • Proper averaging times and recordkeeping frequencies are to be specified • Permit shields should be properly applied

  14. Applicable requirements must be properly translated into the permit • Does the permit contain… • An emission limit or work practice standard for each emission point subject to a standard? • Monitoring, recordkeeping and reporting • “General Provision” requirements • All pre-construction permit requirements

  15. Enforceable as a practical matter • If an inspector were to visit a facility, would s/he be able to easily determine if the facility is in compliance

  16. Proper averaging times and recordkeeping frequencies are specified • Make sure an averaging time is specified (ex: 15 ppm over a 24-hr period) • Frequency of recordkeeping corresponds to the averaging time

  17. Permit shields should be properly applied • Title V permit should explicitly state that a condition is not applicable to the facility • Comment on permit shields you believe were given in error

  18. Additional things to look for when reviewing an emission limit • The emission units subject to the limit are specifically identified • The limit is clearly written • The reference diluent concentration is included (ex: 15% O2) • The source is required to comply with the limit at all times unless exceptions are specifically allowed for by the applicable requirement • The reference test method is identified

  19. Which of the following is not practically enforceable? • The permittee must regularly change the filters in the baghouse • Boiler #1 can emit not more than 39 tons per year of NOx • The emission test shall be conducted while the emissions unit is operating at or near maximum capacity

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