Server: Microsoft-IIS/3.0 Date: Mon, 29 Dec 1997 20:16:27 GMT Content-Type: text/html Accept-Ranges: bytes Last-Modified: Fri, 29 Aug 1997 16:28:18 GMT Content-Length: 15891 EA Engineering: Preparing For Title V

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

  • Review facility records and determine what documents are available.
  • Determine the application due date. Develop a work plan and schedule.
  • List tasks that must be completed. Identify and gather personnel required to complete the work.
  • Discuss the work plan with CAAA team members.
  • Prepare an Emissions Survey

  • Conduct a plant inspection to locate all potential emission points, identify point and fugitive emissions sources, and note unusually small sources.
  • Beginning with a comprehensive source list, eliminate sources the state defines as insignificant.
  • Quantify emissions using one of the many available techniques. (EPA has published numerous documents.)
  • Perform a Compliance Audit

  • 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

  • Incorporate plans for future operations by including the plant's operating scenarios in the initial permit.
  • 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

  • As required under Title V, propose an ongoing compliance program.
  • Test monitoring and recordkeeping programs to ensure that they are adequate before making a commitment to their use in a permit.
  • Prepare the Application

  • Complete the permit application several months in advance to allow time to conduct an internal review and obtain final inhouse approvals.
  • Ensure that staff assigned to prepare the application are appropriately trained before work is initiated.
  • 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.

    EA Engineering, Science and Technology, Inc.
    11019 McCormick Road
    Hunt Valley, MD 21031
    Telephone: 410-584-7000
    Fax: 410-771-1625
    E-mail: info@eaest.com
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