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Practically Enforceable Permit Conditions

Practically Enforceable Permit Conditions. Ray Vogel U.S. EPA/OAQPS. Practical Enforceability. Purpose is to make sure permit limits are Clear as to who limit applies to Clear as to when compliance is required Short-term, so that compliance can be determined relatively quickly

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Practically Enforceable Permit Conditions

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  1. Practically Enforceable Permit Conditions Ray Vogel U.S. EPA/OAQPS

  2. Practical Enforceability • Purpose is to make sure permit limits are • Clear as to who limit applies to • Clear as to when compliance is required • Short-term, so that compliance can be determined relatively quickly • Clear as to what standard a source must meet • Clear as to how compliance is to be determined

  3. Practical Enforceability:Example 1 • “The operator shall maintain adequate records, as determined by the Director.” • Not practically enforceable • No standard on “adequate?” • Director, not EPA or citizens, has sole discretion to determine if records are adequate

  4. Practical Enforceability: Example 2 • “The operator shall take corrective action if parameters are significantly out of range.” • Problem: vague and subjective • How is “significantly out of range” determined? By whom? • What kind of corrective action?

  5. Limits on Potential to Emit (PTE) • PTE limits must be practically enforceable • Short-term (monthly or rolled monthly) • Limit operation or production, if source has capacity to emit at major source levels • Recordkeeping to verify compliance

  6. Unenforceable PTE Limits: Example 1 • Plant capable of emitting 300 tpy of CO has only a 249 tpy emission limitation • Problems: annual limit, no limit on operation or production, no recordkeeping • Step 1: Impose a monthly limit on hours of operation or production which, when multiplied by CO emission rate, = 249 tpy • Step 2: Require recordkeeping to verify compliance with operation/production limit

  7. Unenforceable PTE Limits: Example 2 • Plant with rock crusher, permit limits: 0.05 gr PM/dscf; fabric filter must be used and operated at 99% efficiency • Problem: does not specify means of determining % efficiency • Correction: periodic testing and monitoring of fabric filter to ensure 99% efficiency is achieved

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