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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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generate tv permit shell in stars2
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
generate tv permit shell in stars21
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
generate tv permit shell in stars22
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

convert stars issued tv permit from html to word format
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
convert stars issued tv permit from html to word format1
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
convert stars issued tv permit from html to word format2
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
drafting title v permit terms and conditions
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
develop facility wide terms and conditions
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
develop facility wide terms and conditions1
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
develop emissions unit specific terms and conditions
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
develop emissions unit specific terms and conditions1
Develop Emissions Unit-Specific Terms and Conditions
  • Develop Appropriate Operational Restrictions and Monitoring, Recordkeeping, and Reporting (M/Rk/Rp) Requirements
develop appropriate operational restrictions and m rk rp requirements
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
develop appropriate operational restrictions and m rk rp requirements1
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
develop appropriate operational restrictions and m rk rp requirements2
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
develop appropriate operational restrictions and m rk rp requirements3
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
develop testing requirements
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
develop miscellaneous requirements
Develop Miscellaneous Requirements
  • Any other requirements, such as a compliance schedule, which do not fit elsewhere, should be specified in this section
gap filling
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
gap filling1
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)
update outdated t cs that have been copied from previously issued permits
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
update outdated t cs that have been copied from previously issued permits1
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
update outdated t cs that have been copied from previously issued permits2
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.
update outdated t cs that have been copied from previously issued permits3
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
drafting title v permit terms and conditions1
Drafting Title V Permit Terms and Conditions
  • Develop CAM Requirements (if needed)

*This topic will be covered later in the training*

drafting title v permit terms and conditions2
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
drafting title v permit terms and conditions3
Drafting Title V Permit Terms and Conditions
  • Identify State-only Enforceable Requirements in Section C.1.a)(1)
drafting title v permit terms and conditions4
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
drafting title v permit terms and conditions5
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
drafting title v permit terms and conditions6
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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