CAAA Title V Operating Permits--Case Example Illustrating Key Issues Affecting A Kraft Pulp Mill, 1992 Environmental Conference Proceedings

Within the next few years, each pulp and paper mill in the United States will need to obtain an operating permit pursuant to Title V of the Clean Air Act Amendments (CAAA) of 1990. The objective of this paper is to help mill managers identify the challenges facing them in obtaining this major source operating permit and to plan compliance strategies for dealing with the upcoming permit program regulations. Operating permit regulatory requirements are considered for a nominal 1500 ton/day bleached kraft pulp mill to illustrate examples of the issues facing mill managers as they contemplate these upcoming rules. State permit program development guidelines prepared by EPA leave considerable room for interpretation and discretion by the States. These areas of discretion are illustrated to assist mill environmental staffs in resolving issues in advance, planning ahead, and providing useful comment to influence developing State rules. The case example selected addresses the following issues:

. Definition of Source--Are there possible advantages to varying source definition?

. Operating Flexibility--Can process descriptions and enforceable emissions limits be developed without giving up needed operating flexibility?

. Inventory Requirements--How comprehensive will they be?

. Enforceable Limits--How thorough and burdensome are monitoring, recordkeeping and reporting requirements likely to be?

. Permit Fees--How are fees calculated; what are the issues?