Is There Life After Title V? Real World Experiences (Panel Discussion), 1996 Environmental Conference Proceedings

Topics: Panel members will be asked to reflect on certain key issues Members will be asked to discuss three “optional” key issues that relate to their facility, as well as two “must provide” items. The menu of issues are:

(All provide) Brief overview of facility, including size in production terms, location, age and (approximate) number of sources regulated under the Title V permit.

Is your state program inclusive of “White Paper” suggestions? Has your state required detailed emissions inventories, qualification of pollutants and mill information? How comprehensive was your application? Did you come up with new permit limitations by virtue of information you provided in the application? (e.g., did source capacities get translated into process limits?) Have you had to revise your Title V permit yet? Does your state have different tracks for minor and major new source changes? How difficult will revisions be? How interested was the public in your permit? Did you have a hearing? Any suggestions for the audience? How will your state incorporate new permit requirements into Title V? Will your permit be reopened for MACT or simply reissued with conditions? Did you anticipate this eventuality in your application to minimize reopening potential? How about enhanced monitoring (CAM plan) and 112(r)? Did your state require you to provide detail for either program in the application? How were these provisions incorporated in the permit? Does your facility operate under the “plant-wide emission limit” concept? Is this a good thing? Did your state allow grouping of certain sources into a bubble?

(All provide) What would you do differently? Will you take the same approach when your permit expires?