Alternative Compliance Demonstration Plans in Title V Permit Applications, 1996 Environmental Conference Proceedings

The Title V operating permit program requires permit holders to demonstrate compliance with all applicable regulations. Guidance documents for developing compliance demonstration methods are scarce, and generally raise more questions than answers. Acceptability of variation from existing guidance and the substitution of current monitoring practices for suggested schemes is uncertain. Boise Cascade Corporation, with Trinity Consultants Incorporated, has prepared Title V permit applications where proposed compliance demonstration methods utilize existing recordkeeping and monitoring practices. Often, the methods incorporate procedures currently performed by plant personnel and vary significantly from written state guidance. At the Rogue Valley Plywood facility, existing operation/maintenance procedures, stack testing, and continuous control device monitoring procedures were proposed instead of the suggested stack testing and continuous parameter monitoring procedures. Although regulatory agencies retain the right to modify proposed methods, preliminary discussions indicate that alternative methods are acceptable. This paper presents some of the alternative compliance demonstration methods utilized by Boise Cascade at the Rogue Valley Plywood facility.