How to actually write a title v permit renewal
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How to Actually Write a Title V Permit Renewal PowerPoint PPT Presentation


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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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How to Actually Write a Title V Permit Renewal

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How to actually write a title v permit renewal

How to Actually Write a Title V Permit Renewal


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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