Preparing
For Title V 

If
you want to be overwhelmed by regulatory initiatives, the
Clean Air Act Amendments (CAAA) may be for you.
The
CAAA requirements contain a maze of new regulations aimed
at decreasing sources of air pollution in all 50 states.
Specifically, the CAAA contains 11 new and amended
titles, including nonattainment provisions, hazardous air
pollutant standards, expanded monitoring and
recordkeeping requirements, and expanded enforcement
authority.

Preparing A Title V Permit Application
Develop
a Work Plan
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- Review facility records and determine
what documents are available.
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- Determine the application due date.
Develop a work plan and schedule.
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- List tasks that must be completed.
Identify and gather personnel required to
complete the work.
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- Discuss the work plan with CAAA team
members.
Prepare
an Emissions Survey
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- Conduct a plant inspection to locate all
potential emission points, identify point
and fugitive emissions sources, and note
unusually small sources.
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- Beginning with a comprehensive source
list, eliminate sources the state defines
as insignificant.
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- Quantify emissions using one of the many
available techniques. (EPA has published
numerous documents.)
Perform
a Compliance Audit
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- Identify applicable regulations,
including state regulations, permit
conditions and limits, NESHAPs, and
federal new source performance standards
for each emissions point. Review
information obtained during the emissions
inventory to determine compliance.
Identify
Alternative Operating Scenarios
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- Incorporate plans for future operations
by including the plant's operating
scenarios in the initial permit.
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- If alternative scenarios for plant
operations would require significant
changes, determine whether state or
federal preconstruction permits would be
required.
Develop
and Test a Compliance, Recordkeeping, and Monitoring Plan
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- As required under Title V, propose an
ongoing compliance program.
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- Test monitoring and recordkeeping
programs to ensure that they are adequate
before making a commitment to their use
in a permit.
Prepare
the Application
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- Complete the permit application several
months in advance to allow time to
conduct an internal review and obtain
final inhouse approvals.
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- Ensure that staff assigned to prepare the
application are appropriately trained
before work is initiated.
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- Establish mechanism for responding
quickly and thoroughly to the regulatory
personnel during their review of the
permit.
The Regulations
The
cornerstone of the CAAA is the Title V operating permits
program, which will serve as the funnel through which all
of these requirements will be executed. Companies will
incur higher operating costs in routine plant operations
such as maintaining monitoring and control equipment, in
enhancing recordkeeping and reporting to meet
requirements, in paying annual emissions fees, and in
settling noncompliance penalties. Permits in most states
may set limi ts on fuels, raw materials, production
rates, and products in the manufacturing process.
New
construction and plant modifications will take longer to
approve to meet new restrictions and public meeting
requirements. Companies should allow more time in project
planning cycles for the permit application process. Cost
estimates (not including source testing) for preparing
the Title V operating permit application range from
$15,000 to $400,000. An emissions inventory alone may
require several hundred hours to complete.
The
original implementation strategy was for all states to
submit a proposed operating permit program by November
1994. However, fewer than half of the states submitted
their plans on time. Since the U. S. EPA has maintained
November 1995 as the deadline for application submittal,
the timeframe for application preparation has been
effectively reduced. Since preparation time for
applications can approach 6 months, the deadlines will be
difficult to meet.
How to Respond
A
dedicated company team is needed to prepare a Title V
permit application. Everyone whose function might be
affected by the permit should understand its
implications, and participate if possible. EA re commends
that a person be assigned to serve as Title V project
manager, backed up by a response team whose members
include a senior operations representative, process
engineers, and designated environmental staff.
Throughout
the Title V process it is important to recognize that
there may be opportunities in the regulatory
entanglement. Well planned and developed Title V permits
can, in fact, provide a competitive advantage in the
marketplace. Along these lines, EA is helping one of the
largest pulp and paper companies in the U.S. to develop,
perform, and execute a comprehensive Title V permitting
program for mills located nationwide.
The Response Team
In
this case, EA has been a member of the firm's CAAA
Response Team. The client's CAAA project manager works
directly with management to request resources and
funding, and the senior operations manager ensures that
production levels and facility operational flexibility
are not impaired. Process engineers are of critical
importance due to the highly technical nature of input
required. The environmental staff (or outside consultant)
assists with the prepa ration of a solid application.
Engaging plant and corporate management early in the
process helps the company integrate the needs of
compliance and economic factors to protect the bottom
line of the company.
The
client's senior management team and EA are developing a
comprehensive plan with the ultimate goal of attaining
the highest degree of flexibility allowed by the
operating permit program. For each mil l designated, EA
is performing a comprehensive emissions inventory of all
significant emissions units and developing a detailed
regulatory analysis and compliance assessment, an
operational flexibility strategy, a monitoring plan, and
submittal of a compl ete state permit application.
The Response Project
The
project is an 18 month effort for which EA provides
technical, document preparation, and management services
to assist each facility to comply with the operating
permit requirements.
The
primary products of the effort include:
- Inventories of all units emitting pollutants
regulated under the Clean Air Act. Inventories
define the potential of each unit to emit and a
means for estimating actual emissions in order to
determine emissions fees. Insignificant units
were iden tified. Inventories were summarized in
written and spreadsheet format. Physical
characteristics suitable for dispersion modeling
requirements were summarized.
- Facility process diagrams depicting process flow
and emission units.
- A regulatory requirements evaluation, including
CAAA based mandates. The evaluation included an
assessment of emission limits, monitoring
requirements, and the basis of each requirement.
- Monitoring plans were developed that address
enhanced monitoring, other compliance monitoring,
and fee monitoring for each emission unit.
Surrogate monitoring procedures were evaluated.
- An operational flexibility analysis was performed
that evaluated process changes and future
operational needs.
- A compliance certification plan was developed to
identify practical procedures for ensuring
compliance with Title V requirements.
Meeting the Title V Challenge
This
Title V program represented air quality permitting of
unprecedented complexity. The program was designed to
achieve compliance while at the same time providing
flexible operating permits for all mi lls that need them.
Title
V is the most comprehensive and costly environmental
measure to be developed in more than a decade. It
promises to have a significant and lasting impact on
industry, including affecting some compa nies' financial
well being. The program mandates increased capital
expenditures, requiring companies to purchase more
monitoring and control equipment, and to institute
process changes.
If
air quality obligations are facing your company,
preparation will be your best line of defense and
success.
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