1 title v review dj law us epa region 8. 2 overview know your process permit isn’t always the most...
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Title V Review
DJ LawUS EPA Region 8
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OverviewKnow your process
Permit isn’t always the most important document
Permit size shouldn’t be scary
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The Process – Why is it important?No two permitting agencies will
use the same permit style◦US EPA◦State of Colorado
All techniques used apply to any kind of permit review
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My Review Process – Permit isn’t most importantGoal of reviewing permit is to
understand what is in it and why
Permit itself can be confusing
Statement of Basis – Narrative form◦Much better for
Who/What/Where/When/Why
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Example – US EPA Permit
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Same Thing - SoB
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Starting PointRead Statement of Basis FIRST!
◦It should Give clearest description of source and its permitting history
◦Give reasons why permit is being issued◦Discuss why a particular regulation is
included, or not included, in the permit
Every item discussed in SoB should have corresponding section in permit
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The Permit – What To Look ForPermits can be hefty documents
◦CDPHE Permit – 81 pages, 12 Emission Units
◦EPA Permit – 35 pages, 4 Emission Units
Proposed CDPHE Suncor Refinery Permit – 230 pages not counting Appendices◦That is only for Plants 1 and 3. It
doesn’t include the Title V permit for Plant 2, at 196 pages
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The Approach – Making it Bite-SizedThe key is “Specific” – this is
what makes the permit unique
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EPA Permit -Table of Contents
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CDPHE - Table of Contents
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Permit Is Now ManageableTerms and conditions specific to units at facility
◦ EPA Permit – 7 pages out of 35 pages◦ CDPHE Permit – 20 pages out of 81pages
This is where you should find limitations, testing, monitoring, and reporting required for emission units at facility, as described in SoB◦ State rules for that equipment◦ NSPS requirements◦ MACT requirements◦ Requirements from other construction permits
(BACT)
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What about the rest?Boilerplate – Regulations that apply to every
facility that obtains a Title V permit◦ Should be identical for all sources within permitting
authority’s jurisdiction
Non-site-specific regulations◦ Acid Rain◦ Alternative Operating Requirements◦ Permit Shield◦ Administrative Requirements◦ State-Specific Regulations
It’s all still important but isn’t “specific” to this facility
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Does A + B = C? What is discussed in SoB should show
up somewhere in Permit Specific requirements◦“Boilerplate” typically isn’t discussed in SoB
If it doesn’t, or isn’t clear, worth commenting about◦Public is generally the least knowledgeable
about environmental regulation. If public is confused about requirements or conditions, typically permitting authority can rewrite permit to make it clearer
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Should A + B = C?Requires working knowledge of
environmental regulation and working knowledge of source operations
Best place to start is Permit Application◦Typically not found as part of an “online” record.
Must formally request, or visit location of physical permit record
Other resources include inspection reports, AP-42 process descriptions, NSPS and MACT background documents, etc.
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Final PointsDevelop your own personal
system for permit reviewDon’t be discouraged by size of
documents. Break permit into manageable parts
Don’t expect to know everything at once
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Last RuleWhen you are still confused
about a condition…CALL!Every permit public notice should
have a contact name/number for engineer who wrote permit ◦Best source to determine intent of
section that is troubling you