Special Permitting Issues, 1998 Cluster Rule Symposium Proceedings

Implementing the Cluster rule requires evaluation of a wide range of factors and technical choices which must be integrated into a viable operating and compliance plan before the permitting process can be initiated. Many of the factors are site specific, implying the need for skilled assistance at each facility location for optimum results. It will be vitally important to achieve and maintain close cooperation and understanding with the appropriate regulatory agencies throughout the complex implementation program.

The factors involved are reviewed and examples of the effects on existing types of operations are discussed. Particular attention is given to MACT issues where understanding and agreement with regulators is vital. These include:

Process not subject to rule

Burning condensed stripper vent gases in 3rd party furnaces

Bleach plant Continuous Emission

Monitors (CEM)

Compliance Monitoring (CMS)

Startup, Shutdown, Malfunction Plan (SSM Plan)

Clean Condensate Alternative

NSR/PSD Implications

Timing and Incentives Program.