When it comes to Title V Air Permits, writing your permit is often just as difficult and complex as actually complying with it. The language, limits, and conditions all need to be thoughtfully written, otherwise your permit could be rejected by the EPA or make your annual compliance reporting a huge headache.
In order to help site managers out, the EPA has prepared online Title V air permit writing tips; in fact, you can get read them by following this link. While this is a helpful resource, it can be a bit daunting and inaccessible. So we thought we’d simplify things a little bit and highlight some of the bigger stumbling blocks in Title V permit writing. Over the next few weeks, we’ll cover some of these Title V Air permit writing topics in depth.
Today’s topic is streamlining your Title V Air Permit, which is one of the most important ways you’ll write in all the regulations affecting your facility and manage your compliance obligations. It’s all about keeping all those overlapping federal, state, and other regulations in order and making your permit as short and sweet as possible.
When Streamlining Enters the Picture
For most facilities, there is more than one air regulation that affect daily operations. It could be local regulations, or any number of federal regulations that are contained within the U.S. Clean Air Act (CAA). It’s your duty as an owner or operator to stay compliant with all of them. For example, you probably need to comply with acid rain regulations, Prevention of Significant Deterioration (PSD) requirements, and annual TRI reporting.
Sometimes, however, these regulations can overlap. Your facility might have two different emission limits for a particular HAP, or a certain piece of equipment might have two different emission monitoring requirements.
These are the scenarios when streamlining comes into effect, and some judgement will be needed to determine the best way to write your Title V Air permit.
Streamlining For Simplicity
Because your Title V Air permit needs to be written so that it addresses all the air regulations that apply to your facility, its processes, emissions, and equipment, there could be a lot of overlap between regulations and possibly conflicting information.
Not only does this make it difficult for you to pin down exactly what is expected of you, but it could potentially lead to pages and pages of permits that don’t match up.
To streamline all of this data, you are required to write in the most stringent limits that apply to your business. The logic behind this is that by complying with the lowest emission threshold or requirement, it will automatically ensure all the more lenient thresholds are already met.
Of course, you were going to comply with the lower limit anyways, but it’s important that things be stated properly in your Title V Air permit, otherwise it could get rejected. Your Title V Air permit needs to be as streamlined as possible during the application process.
For example, if your NESHAP regulation sets an emission threshold of a certain Hazardous air pollutant (HAP) at 10 TPY (tons per year) and a PSD permit condition says you can only emit 5 TPY, your Title V Air Permit needs to list only the 5 TPY.
This also applies to monitoring conditions. If, for example, you use a boiler that has a MACT weekly emissions monitoring condition and another regulation that calls for daily (or even hourly) emissions monitoring, you will need to provide daily emission records and include the most frequent (and most assuring of compliance) monitoring in your Title V Air permit.
When Streamlining Takes Work
In general, streamlining is a relatively simple concept to grasp and apply to your permit. It won’t change the way you do business, so it’s all about how things get written down.
But that doesn’t mean there isn’t a degree of calculation and thought that goes into streamlining your regulations. In the case when two regulations overlap in the type of emission regulated but not in the same units, you will need to do some unit conversions in order to determine which unit of measurement and limit you should apply.
The EPA gives the example of a facility with limits on particulate matter expressed in both “grains per dry standard cubic meter” and in “per dry standard cubic foot”. In this case you will need to convert one of the regulations so that they can be accurately compared side by side. As with all cases of streamlining, you must then take the more stringent of the two limits.
Just make sure that the math is all correct, otherwise you could be falling out of compliance with two regulations!
When it comes to writing your Title V Air permit in these scenarios, you’ll need to include the conversion factor you used in your Statement of Basis, which is the section which acts as a general overview of your entire permit.
See more examples of permit streamlining from the EPA.
To learn more about simplifying your Title V Air permit, download 'The Title V Air Permit Handbook'...it's free!
November 8, 2012