Effective Title V Permits.ppt

Effective Title V Permits Scott Miller U.S. EPA Region 4 (404) 562-9120 miller.scott@ Ideal Title V Permit Allows for changes to be undertaken with as little delay and paperwork as possible Little effort and foresight can cut time to implementation of operational changes Multiple vehicles designed into title V regulations for accommodating changes Reduce recordkeeping/reporting One ToolAlternative Operating Scenarios 40 CFR 70.6(a)(3)(i)(9) Permit should include all alternative operating scenarios REQUESTED BY THE FACILITY in title V application If you can dream it and write it, then install it in the title V permit Alternative Operating Scenarios Facility may request inclusion of alternative scenario at any time Alternative operating scenario can be a different means of compliance with an existing standard or an entirely new applicable requirement Why wait to trigger and applicable requirement if you think one is coming? Alternative Operating Scenarios Florida – Chapter 62-213.410(1) Georgia – 391-3-1-.03(10)(d)(1)(i) North Carolina – 15A NCAC 2Q.0508(p) Kentucky – 401 KAR Chapter 52:020, Section 10 Colorado – 1001 AQC, Regulation 3 Arkansas – Regulation 26,Chapter 7,Section 26.701(I) Alternative Operating Scenarios Virginia – 9 VAC 80-110.J New Jersey – 7.27-22.16(h) New York – Chapter III, Subpart 201-6.5(f)(1) Alternative Operating Scenarios Examples HON-affected facility desires multiple compliance options stated to show compliance with MACT standard Other examples Alternative Operating Scenario Does your facility have a five-year plan? What affected units might be subject to additional air regulations or a change in regulations already in the permit? Flexible Preconstruction Permits Couple flexible preconstruction permits with alternative operating scenarios to obtain the most flexibility and move toward the “ideal” title V permit Streamlining Multiple Requirements Streamline multiple applicable requirements to which a process unit may be subject int