Title V Permit Preparation Experience Panel, 1995 Environmental Conference Proceedings

Panel Moderator - Allan E. Cawrse

Union Camp

Preparation of Title V air permit application is underway at every large U.S. pulp and paper facility. Since this is a brand-new effort, the Air Quality Committee suggested a panel of speakers make a presentation at the 1995 TAPPI Environmental Conference. This panel will consist of individuals who have been directly involved in preparing or reviewing a Title V air permit application. The panel is to share experience and the lessons learned in preparing a Title V air permit. The panel members will relate experiences in organizing for permits, air testing for permits and state interaction and guidance for permit applications. The audience will hear what the panel members considered to be techniques that worked or did not work. The audience will benefit from the collective experience and opinion of the panel members.

Panel members will be asked to specifically reflect on certain key issues, including:

- Brief overview of facility, including size in production terms, numbers of sources and age

- Estimating fugitive emissions: did the facility use test or engineering data? Did the state provide any guidance as to what methods were acceptable; did any limitations show up for fugitives? There is particular interest in emission estimates from chip piles, lagoons, process tanks, and landfills.

- Operating flexibility: did the facility try to make detailed or general process and operating descriptions? How does the facility see the revisions to Title V affecting operating flexibility?

- Enhanced monitoring requirements: how did the facility handle this requirement in the absence of a final rule? Was it necessary to install CEMs or were alternative monitoring methods sufficient? What guidance did you received from your state?

- Other points of interest: panelists may also touch on permit preparation, data management tools, how the SIP was reviewed or other topics of interest.