Title V Permit Preparation

Title V Permit Preparation

Developed by staff from Cleveland Division of Air Quality,

Ohio EPA Northeast District Office, and Ohio EPA Central Office

Original January 2006; updated July 2010

Workshop Schedule

Time Activity

9:45 - 10:00 Sign-In and Registration

10:00 – 10:05 Introduction

10:05 – 10:10 Application Receipt

10:10 – 10:15 Preliminary Completeness Review

10:15 – 10:30 Technical Review

10:30 – 10:45 BREAK

10:45 – 11:15 Permit Preparation: Part I – Initial Review

11:15 – 12:00 Permit Preparation: Part II – Develop Terms and Conditions

12:00 – 1:00 LUNCH

1:00 – 1:15 Questions and Answers (Permit Preparation)

1:15 – 1:30 Permit Preparation: Part III – Odds and Ends

1:30 – 1:50 Practical Exercise - SOB

1:50 – 2:20 CDAQ Supervisor Review

2:20 – 2:35 BREAK

2:35 – 3:05 CO Review

3:05 – 3:25 Permit Issuance

3:25 – 3:45 Questions and Answers

3:45 – 4:00 Wrap-Up and Course Evaluation

Content

• Receipt of Application

• Preliminary Completeness Review

• Technical Review

• Permit Preparation

• CDAQ Supervisory Review

• Central Office Review

Content

• Issuance of Draft Permit

• Post-Draft Permit Process

• Changes to Permit After Issuance

• Additional Title V actions

Receipt of Application

• Application received electronically by DAPC Central Office (CO) through the e-Business Center Air Services.

– STARS2 action item created.– Preliminary completeness action listed on

CDAQ Chief of Engineering’s “To Do” list.– CDAQ Chief of Engineering checks

STARS2 "To Do" list daily.


• In Air Services, the “responsible official” must obtain a PIN which serves as their signature when submitting applications and other documents – the hard copy signed receipt is no longer needed.

• In the STARS2 activity log, CDAQ Chief of Engineering assigns permit application to the appropriate CDAQ Permit Writer.


• CDAQ Chief of Engineering determines staff workload.

– In general, Title V permit work is assigned to staff based on Permit Writer's number of major and minor permits as well as their current and projected workload and skill level.

– Facility assignments are made by CDAQ Chief of Engineering (in accordance with protocol (See Appendix A)).


• CDAQ Chief of Engineering updates STARS2 Workflow.

– CDAQ Chief of Engineering assigns tasks to selected staff.

Preliminary Completeness Review

• All fields of the application must be filled in (i.e., complete) in order for the facility to successfully submit the application through Air Services.

• Compare the application to the preliminary completeness checklist (Appendix B).

Preliminary Completeness Review

• Send “Preliminary Completeness” letter or “Preliminary Incompleteness” letter to applicant.

– Use letter templates for preliminary completeness or incompleteness letters (Appendices C and D respectively).

• Letter drafted by Permit Writer and sent within 60 days of application receipt. If more than 60 days has passed, the application automatically becomes preliminarily complete.

• Permit writer updates STARS2 Workflow.

Technical Review

• Application and/or file review– Print hard copy of the application, if

needed, or review in STARS2.– Review the new application, making notes,

listing questions.

Technical Review

• Review existing facility files as well as application materials using checklist (Appendix E).• Gather relevant files.• Review hard copy information.• Check completeness against active and archive

file databases.• Make notes and/or list questions to ask.• Identify missing portions of the application.

Technical Review

Review for control equipment• Review most recent stack test report.• Check continuity of most recent inspection report

with Title V application.• Check PTOs, PTIs, and prior issued Title V permit

(for renewals).• Review facility profile in STARS2 for control

equipment accuracy.

Technical Review

Review non-insignificant and insignificant units• Identify major issues.• Review (most current) PTIs.• Check installation dates.• Check PTIs and related files to PTIs (both

insignificant and non-insignificant).• Request and review emissions calculations and

relevant info for questionable insignificant units.• Review EAC forms.

Technical Review

Update emissions units in STARS2• Confirm that insignificant units are properly identified.• If a unit should be marked insignificant the facility needs

to update their profile.• Ohio EPA does not have the rights to mark a unit

insignificant.

Technical Review

Has all technical information been received?• Determine if missing information can be obtained in

hardcopy or if an application revision via Air Services is needed.

• Request missing information in writing from company or return application if necessary.

• If application revision is submitted:– Check to see if requested information has been added.– Check for newly-discovered issues.

• Reassess if application is adequate once information is received.

• See Appendix F for technical incompleteness procedures if necessary.

Technical Review

Site visit– During the development of a Title V permit,

a site visit must be conducted.• Ideally, this site visit takes place after the review

of the files and application.• If the Permit Writer has visited the entire facility

(as part of a previous site visit or facility inspection) a short time before the application receipt, this visit may suffice.

Technical Review

Site visit (continued)– Conduct a site visit via a set appointment

and include the following elements:• Ask questions and take notes.• View emissions units in operation.• Check condition and operation of control

equipment.– Verify control equipment identified in

application.• Review monitoring and record keeping

information.

Technical Review

Site visit (continued)– If possible, invite an Enforcement Specialist

along on the site visit.– The Enforcement Specialist may be able to

bring a different perspective to viewing the current operations and compliance at the facility.

Technical Review

• Review recent “similar” Title Vs for consistency– All issued Title V permits are posted on Ohio

EPA’s DAPC web site and are also stored in STARS2.

– A keyword search is available on STARS2 under the permitting tab.

– Use discretion in reviewing similar permits as things might not be exactly the same for the permit that you are preparing.

Technical Review

• Contact CO Reviewer[1]– As needed, contact CO Reviewer via phone or e-

mail prior to the drafting of the permit to inform that work has been started on the Title V permit.

– After initial contact, all parties maintain contact with CO Reviewer, as needed.

– This communication establishes the working relationship that is beneficial to effective and timely permit issuance; discussions include deadlines, guidance, and resource suggestions.

[1] Task can be conducted in one or more sections.

Break

• 15 minute break

Permit Preparation

• Prepare a listing of pollutants

• The following resources can be used:– Facility Information– Internet– Other Sources

Permit Preparation

• Facility information:– Title V application;– Fee reports;– Stack test information;– Previous permits; – Process flow diagrams; and– Raw materials review (e.g., EAC forms)

Permit Preparation

• Internet:

– U.S. EPA Compilation of Air Pollutant Emission Factors (A.K.A AP-42);

• http://www.epa.gov/ttn/chief/ap42/index.html

– OHIO EPA DAPC website• http://www.epa.state.oh.us/Default.aspx?alias=www.epa.state.oh.us/dapc

Permit Preparation

• Other sources:– AWMA Air Pollution Engineering Manual –

a.k.a. AP-40;– RACM manual and E.G. 75;– Experienced colleagues;– Similar issued permits (i.e., permits issued for

different facilities with the same types of emissions units); and

– Similar issued permits (i.e., permits issued for "sister" facilities with the same facility name located in different parts of the State – such as for General Motors Corporation).

Permit Preparation

• Develop a listing of applicable rules for each emissions unit.– The following resources can be used:

• CDAQ applicable rule index (see Appendix K);• Previous permits for the source (i.e., PTOs, PTIs,

Title V, etc.);• Internet; • Similar issued permits; • Permit application; and• Inspection reports.

Permit Preparation

• Applicable Rule resources (continued)

– Review installation/modification dates to determine if PTI is necessary.

• Verify the installation/modification dates in STARS2.

– Applicable federal rules for each pollutant:• NSPS 40 CFR Part 60;• NESHAP 40 CFR Part 61; and• MACT 40 CFR Part 63 (if HAPS are listed as a

pollutant).

Permit Preparation

• Determine Applicable Limits for each State and Federal Rule.

– The following resources can be used:• Issued PTIs, PTOs, and Title V permits;• Ohio Administrative Code (OAC);• Code of Federal Regulations (CFR); and• Ohio EPA Engineering Guides.

Permit Preparation

• Applicable Limit Resources (continued).– Review issued PTIs for the source

• Compare current State/federal regulations to PTI limits and check the current validity of any emission factors relied upon to establish PTI limits.

• In certain cases where a new State regulation is more stringent than a PTI limitation, or when emission factors change, CDAQ may need to process a modification of the PTI concurrently with the processing of the Title V permit.

Permit Preparation

• Applicable Limit Resources (continued).

– Compare all limits for the same pollutant to determine whether the limits are less stringent or equivalent to each other in order to include appropriate "less stringent than" or "equivalent to" wording in the permit.

– An example for a particulate emission source: identify release point(s) - stack or fugitive.

Permit Preparation

• Applicable Limit Resources (continued).

– Ohio Administrative Code (OAC rules) - refer to most current version on the Ohio EPA DAPC website.

– Code of Federal Regulations (CFR):• NSPS 40 CFR Part 60;• NESHAP 40 CFR Part 61; and• MACT 40 CFR Part 63.

Permit Preparation

• CDAQ Permit Writer and CDAQ PRM evaluate the need for a “pre-draft” strategy.

– STARS2 now allows for grouping of identical emissions units; therefore, “pre-draft” strategy might not be needed.

– CDAQ Permit Writer and CDAQ PRM determine if enough emissions units to be included in the permit are similar to pursue a pre-draft strategy.

Permit Preparation

• “Pre-Draft” Strategy (continued).– If there are several similar emissions units,

terms and conditions may be prepared for a sample emissions unit and submitted for review under a pre-draft strategy.

– When prepared, the sample terms and conditions under a pre-draft strategy will be sent to DAPC CO Reviewer for review.

Permit Preparation

• Creating the permit “shell”– The T&C document must be generated in STARS2.– Prior to generating the terms and conditions document in

STARS2, make sure the list of active emissions units is accurate, if it is not, facility might need to update the facility profile and resubmit their application.

– Terms and conditions (T&Cs) are developed primarily for non-insignificant emissions units and, if needed, facility-wide terms are also developed.

– T&Cs are prepared in Word and saved to L:\Data\Facilities at the appropriate facility number folder.

– Optional, it’s also okay to begin preparing the SOB at this point, or wait until permit terms are complete.

Permit Preparation

• Review following sources for possible terms:

– Incorporate appropriate PTI(s) T&Cs into Title V permit T&Cs.

– Issued Title V permits from similar sources (use as appropriate)• Can check with CO for up-to-date information on previous permits

prior to writing current Title V permit.

– Check Library of Terms and Conditions (use as appropriate).

– If necessary, develop T&Cs from inspection report and/or site visit.

Permit Preparation

• Review sources (continued)

– Identify any necessary operational restrictions.

– Identify alternative operating scenarios.

– Determine what type of monitoring, record keeping, and reporting program is necessary for the permit.

Permit Preparation

• Review sources (cont.)

– For each allowable emission rate or control requirement, determine if an adequate demonstration of compliance has been included in the testing section.

– Determine the frequency of emission testing (required by PTI, Engineering Guide #16, etc.).

• Review most recent emission testing for each emissions unit.

– Verify compliance with applicable limit(s) and ensure that acceptable test methods were employed.

Permit Preparation

• Review recent fee emissions reports

– Use average ton/hr values and hours of operation to estimate short term emissions rates to determine whether source is likely to be in compliance.

– Where possible, emission estimation methodology in fee emissions report (FER) should match compliance method in permit.

Permit Preparation

• Assemble State/federal T&Cs

– Part B Specific Facility Terms and Conditions

• Provides for placement of requirements that apply to the entire facility or to several emissions units at the facility.

• MACT, NSPS, NESHAP, synthetic minor terms for HAPs, etc., and insignificant emissions unit requirements are usually included in Part B.

Permit Preparation

• Assemble State/federal T&Cs (continued)

– Part C Terms and Conditions for Emissions Units

• Operations, Property, and/or Equipment [section 1.]

– This is imported from the emissions unit description in the facility profile in STARS2, update if necessary.

– It should clearly describe the equipment and processes that comprise the emissions unit and the associated control equipment.

• Section a)(1), identify terms that are State-only enforceable (e.g., air toxics terms, new (not modified) OAC rules that are not part of the federally approved SIP).

Permit Preparation

Assemble State/federal T&Cs (continued)• Part C Terms and Conditions for Emissions Units

– Applicable Emissions Limitations and/or Control Requirements [section b)(1)].

» List Rules/Requirements.

» List Emission Limitations/Control Measures.

Permit Preparation

• Assemble State/federal T&Cs (continued)


• Additional T&Cs [section b)(2)]

– Overflow from section b)(1) (e.g., synthetic minor restrictions).

– Clarification of emission limits/control measures.

– Define control efficiency if applicable.

– Negative declarations and/or rule exemptions.

Permit Preparation

• Assemble State/federal T&Cs (cont.)


• Operational Restrictions [section c)]

– Ensure ongoing compliance with the applicable requirements, emissions limitations, control measures, etc..

– Include restrictions on hours of operation, production, coating usage, etc., as needed.

Permit Preparation



• Monitoring and Record Keeping Requirements [section d)]

– Required for each operational restriction, control measure and emission limit (unless otherwise specified in the T&Cs).

– Data required to be recorded and maintained.

» Must specify frequency of monitoring.

» Specify monitoring devices (e.g., CEMs, see Engineering Guide #52 for CEM systems).

– Include air toxics language if contained in PTI.

Permit Preparation



• Reporting Requirements [section e)]

– Specify the results required to be reported.

– Specify the frequency of reports (e.g., quarterly deviation-based, annual, "after the event," etc.).

– Include requirements to submit reports of deviations from operational restrictions and/or emission limitations.

– Include term regarding submission of reports through Air Services.

Permit Preparation



• Testing Requirements [section f)]

– List each emission limitation from section b)(1) of the permit and provide a method for determining compliance for each.

– Specify the applicable compliance method for each emission limit.

» Cite applicable test methods where needed.» Compliance may be based solely on monitoring, record

keeping and reporting or on emission factor(s) rather than testing.

– If needed, stack testing requirements are inserted in section f)(2) (see Engineering Guide #16 or applicable rules).

Permit Preparation



• Testing Requirements [section f)] (cont.)

– Compliance methods may include one or more of the following:» Emissions tests;» Material balance calculations;» AP-42 emission factor calculations;» Method 24 analyses;» CEM and COM data;» Record keeping program; and/or» VE readings using Method 9.

Permit Preparation



• Miscellaneous [section g)]

– Items that do not fit under any of the above categories.

Break

• Pizza time!

Permit Preparation

• Citation of Rule Authority

– Citation must be present for each term and condition – see issued Title V permits for examples.

• Example: [Authority for term: OAC rule 3745-77-07(C)(1) and PTI #13-88888]

Permit Preparation

• CDAQ Permit writer prepares or updates the Statement of Basis (SOB) document using the Ohio EPA guidance (Appendix M).

• The SOB document must be generated in STARS2 and then saved to L:\Data\Facilities.

Permit Preparation

• For Title V Permit Renewals, the CDAQ Permit Writer shall follow the current Ohio EPA guidance concerning the preparation of Title V permit renewals (Appendix P).

– Upon submittal of the permit renewal recommendation, CDAQ will attach a copy of the completed checklist in STARS2.

– CDAQ Permit Writer and CDAQ PRM shall contact DAPC CO Reviewer to discuss technical issues, progress, schedule, etc. for permit renewals.

Permit Preparation

• A CAM plan is required at facilities where ALL of the following apply:

– Required to obtain a Title V permit;– Have controlled emissions units;– Emit pollutants subject to an applicable

rule; and– Have uncontrolled emissions greater than

major source threshold.

Permit Preparation

• CAM Plan Odds and Ends.– Examples where CAM may apply:

• Combustion sources with dust collectors.• Some VOC sources with incineration controls.

– Most HAP sources are exempted from the CAM requirements if a MACT rule is applicable.

– Most Ohio permits typically require parametric monitoring even though CAM may not apply.

– Additional CAM guidance from U.S. EPA can be found at: http://www.epa.gov/ttn/emc/cam.html

Permit Preparation

• CAM Plan Review– CDAQ Permit Writer determines if a Compliance Assurance

Monitoring (CAM) plan is required using CAM guidance (Appendix L).

– If a CAM plan is required, CDAQ Permit Writer will provide a discussion of the CAM plan as part of the draft Title V permit.

– CDAQ Permit Writer shall contact DAPC CO Reviewer to discuss progress, schedule, technical issues, etc. associated with the review of the submitted CAM plan.

– In cases where a CAM plan is required but has not been submitted, CDAQ Permit Writer shall contact the facility to obtain a CAM plan – facility might need to submit a corrected application.

Permit Preparation

• Quality Indicators for terms and conditions.– Terms and conditions developed for Title V permits should

be:• Accurate and comprehensive (from a regulatory standpoint);• Clearly written and understandable (put yourself in the place of

the facility environmental contact or other reasonably competent technical person -- are compliance obligations clearly spelled out?);

• Enforceable – inspectors must be able to enforce each term;• Grammatically correct; and • Reflect overall level of high quality and appear to be a

professional-looking document.

– Upon completion of the draft permit terms, the CDAQ Permit Writer reviews the draft permit against the listed criteria to ensure that quality terms and conditions have been written.

Permit Preparation

• Whenever possible, CDAQ Permit Writer will allow "breathing space" after the first draft of T&Cs before submitting the permit for review.

– This time, typically from 2 to 7 days, allows a cooling off period before the Permit Writer reviews the entire permit.

– CDAQ Permit Writer prints out hard copy of entire permit.

– CDAQ Permit Writer reviews the entire permit, making corrections or seeking guidance from CDAQ PRM or DAPC CO where appropriate.

Permit Preparation

• CDAQ Permit Writer updates STARS2 Workflow and assigns permit to CDAQ PRM.

Practical Exercise

• Generation of SOB

CDAQ Supervisory Review

• Pre-Draft Strategy Review

– Pre-draft strategy might not be needed. STARS2 now allows for the grouping of identical emissions units.

– The draft terms and conditions for sample emissions units are given to the PRM by the Permit Writer.

• Standard review tasks outlined in this section are used to evaluate pre-draft strategy.

• PRM uploads pre-draft strategy terms for DAPC CO review through STARS2.

• STARS2 Workflow is updated for the submittal of the pre-draft strategy for DAPC CO review.

• PRM sends e-mail to DAPC CO Reviewer noting that the recommendation is a pre-draft strategy.


• PRM receives permit recommendation from Permit Writer

– Package includes:

• Printed copy of permit application (as needed) or leave in STARS2;

• Printed copy of permit terms and conditions;

• SOB;

• Renewal checklist (for renewal permits);

• Main Title V permit facility file; and

• Any pertinent supporting information that went into preparing the permit.


• Initial review of permit hard copy

– Focuses on permit structure including:

• Correct spelling;

• Grammar;

• Punctuation; and

• Format [Ohio EPA Permit Structure Guidance and Ohio EPA Style Manual (Appendix H)].


• Reviews terms and conditions for each emission unit

– PRM ensures the following:

• All emissions units are addressed;

• All pollutants are identified;

• Any recommended PTI modifications are initiated;

• All correct rules are cited; and

• Any emissions units identified as being insignificant units are, in fact, “insignificant”

– Insignificant emissions units that are State/federal enforceable are subject to SIP limits and/or have an issued PTI (the PTI number and issue date should be cited) – facility must submit an EAC form for these insignificant emissions units. Note, recent rule change may affect submittal of the EAC form.

– Insignificant emissions units that are State-only enforceable are either de minimis or not subject to any applicable requirements.


• Review of terms and conditions for each emissions unit

– As needed, the PRM reviews the application for the following:

• emissions unit installation and/or modification dates;

• control equipment which are employed and for which emissions units;

• verifies that control equipment listed in application is included in permit (and vice-versa);

• check emissions unit descriptions in application with permit recommendation; and

• determine if any alternative operating scenarios are possible.

– Reviews list of State and federal rules to determine which apply

• Does the permit make sense for the type of emissions unit (e.g., were SO2 rules cited for a degreaser?)


• Review of terms and conditions for each emissions unit (cont.)

– Checks each pollutant emitted along with applicable emission limits for each pollutant.

– Checks that all PTIs, including modifications, have been issued, as appropriate.



– Checks each allowable emissions limitation or requirement for follow-through in terms and conditions:

• Operational Restrictions;• Monitoring;• Record Keeping;• Reporting; and• Testing (Should emissions testing be required?).

Each section of the permit builds on the previous section.



– Ensures that the correct and most up-to-date terms and conditions are in the permit.

– Identify any PTI "streamlining language" as necessary.

– Ensure proper “authority for term” has been cited.

– Applies technical experience in reviewing each permit.



– Checks each term and condition for consistency (e.g., use same terminology throughout the terms).

– Reviews similar permits that have been issued.

– Identifies any generally applicable facility-wide requirements for inclusion in Part B, Facility Terms and Conditions (e.g., MACT).


• Review of Statement of Basis document (SOB)

– Ensure that all emission limits have been included in the SOB.

– Ensure the proper monitoring, record keeping, reporting and testing have been identified for each emission limit.

– Ensure that current SOB (Appendix M) form has been used (generated from STARS2).


• Draft permit recommendation, SOB, and any supporting information are returned to Permit Writer if any changes are needed.

– After thorough review, deficiencies are marked on hard copy of draft permit recommendation and SOB.

– Corrections are clearly marked in red pen (or other distinguishing color) and the permit is returned to the Permit Writer for changes, alternatively Track Changes in Word can also be used.


• Draft permit recommendation, SOB, and any supporting information are returned to Permit Writer if any changes are needed (cont.)

– The Permit Writer makes the revisions and highlights each change on the marked up copy to ensure that all the changes have been made.

• The permit is returned to PRM for further

review.

• If needed, CDAQ PRM makes additional changes and returns to the Permit Writer.


• If there are no further changes, the permit recommendation can be shared with the facility. Any requested changes from the facility should be discussed with the CDAQ PRM.

• After changes from the facility have been addressed, the permit recommendation is submitted to Ohio EPA Central Office.

– The permit recommendation, SOB, and renewal checklist (if applicable) are uploaded to STARS2 along with any other supporting information.

– An e-mail is sent to the Central Office review contact to notify him/her that the permit recommendation is ready for review and to identify any special circumstances involved with the permit recommendation.

• STARS2 Workflow is updated to reflect submittal of the official draft recommendation to Central Office for review.

Break

• 15 minute break

Central Office Review

• Technical review prior to permit review.– CO Reviewer prints hard copy of the Title V

application from STARS2 or review "on screen" (electronically)

– Review of PTI file(s).• CO Reviewer checks PTI files for recently issued PTIs for

the Title V facility under review.– Review of Title V application.

• Review non-insignificant and insignificant units• CO Reviewer checks for major issues: emissions unit

status (insignificant vs. non-insignificant, as identified by the permittee); "insignificant emissions units" that based on available information do not qualify as insignificant, etc....


• Optional Site Visit– At any time the CO Reviewer may contact

CDAQ to schedule a site visit, as part of the technical review/permit review; this is especially useful where complex permitting issues have been identified.


• CO Review of Title V Permit Terms and Conditions.

– Review insignificant emissions unit lists in Part B, Facility Terms and Conditions

• Perform cursory check of facility profile in STARS2 for installation dates of insignificant emissions units.

• PTI number(s) and issuance date should be listed for post-1974 insignificant emissions unit(s).


• CO Review of Title V Permit Terms and Conditions (continued).

– Identify any generally applicable facility-wide requirements for inclusion in Part B, Facility Terms and Conditions.

• These include standard terms and conditions for: – MACT, NESHAP, NSPS, GACT

– Emergency Action Plans (EAPs);

– Asbestos;

– Part 82 (stratospheric ozone);

• Check Title V application for facility-wide applicable requirements identified by the permittee.



– Review the terms and conditions for each non-insignificant emissions unit in Part C, Terms and Conditions

• Identify pollutants for each emissions unit in the permit, creating list, if needed

– Check Title V application for pollutant(s) identified by the permittee;

• Review applicable rules cited in permit



– Review the terms and conditions for each non-insignificant emissions unit in Part C, Terms and Conditions.

• Review each Applicable Emission Limitation/Control Requirement

– Check for correct limit and/or proper application of the rule.– Perform cursory check of facility profile in STARS2 for installation

dates to determine which emissions units should have PTI requirements specified in the terms and conditions.

– Compare the Title V terms and conditions, including limits, versus the PTI terms and conditions and limits.

– Use "PTI Streamlining Language" in permit, as appropriate by noting where substantive changes have occurred in the permit between the Title V T&Cs and the PTI T&Cs and applying the “PTI Streamlining Language” to that section(s) of the permit T&Cs.




• Review each Applicable Emission Limitation/Control Requirement

– If the facility is major for HAPs, check for applicable MACT(s).

– Verify maximum capacity of the emissions unit and compare to emission limits, as needed.

– Check process weight rate (PWR) for OAC rule 3745-17-11 determination and verify that the limit is based on the more stringent of Table 1 or Figure II.

– Review negative declarations and rule exemptions specified for the specific emissions unit.


• CO Review of Title V Permit Terms and Conditions (continued).– Review the terms and conditions for each non-insignificant

emissions unit in Part C, Terms and Conditions.

• Review each Operational Restriction– Check that the Operational Restriction(s) will ensure ongoing

compliance with the applicable requirements/control measures and/or satisfy OAC Chapter 3745-77 "gap-filling" requirements.

– Review wording of T&C to ensure that the Operational Restriction is clearly worded and not vague.


• CO Review of Title V Permit Terms and Conditions (continued).– Review the terms and conditions for each non-insignificant emissions

unit in Part C, Terms and Conditions.

• Review each Monitoring/Record Keeping requirement.– In most cases, a Monitoring/Record Keeping requirement is necessary

for each Emission Limitation/Control Requirement and Operational Restriction.

– Check specific rules to see whether the required Monitoring/Record Keeping approach is prescribed by rule or another approach can be used.

– Check for parametric monitoring for control equipment.– Review wording of terms and conditions to ensure that the monitoring

method enables the agency to enforce the respective Emission Limitation/Control Requirement or Operational Restriction; check that the monitoring frequency is appropriate; check that the correct monitoring is specified (e.g., CEMS, if required by rule).


• CO Review of Title V Permit Terms and Conditions (continued).– Review the terms and conditions for each non-insignificant emissions

unit in Part C, Terms and Conditions.

• Review each Monitoring/Record Keeping requirement (continued).– Review air toxic modeling, if applicable.

» Verify that terms and conditions are identified as State-only enforceable in section a)(1) of the terms.

» Ensure current air toxics language has been used.» Perform cursory check of modeled emission rate vs. MAGLC.



emissions unit in Part C, Terms and Conditions.

• Review each Reporting requirement.– In most cases, a Reporting requirement is necessary for each

Emission Limitation/Control Requirement and Operational Restriction.

– Check specific rules to see whether the required Reporting approach is prescribed by rule or whether another approach can be used.

– Review wording of T&C to ensure that the reporting method satisfies "prompt reporting" per OAC Chapter 77 requirements; check that the appropriate frequency of reporting (rule-based, policy, etc…) has been specified.

– Verify that the electronic reporting requirement has been included.



emissions unit in Part C, Terms and Conditions.• Review each Testing (Compliance Method) requirement.

– In most cases, a Testing (Compliance Method) is necessary for each Emission Limitation/Control Requirement and Operational Restriction.

– Check specific rules to see whether the required Testing (Compliance Method) approach is prescribed or another approach can be used.

– Review wording of T&C to ensure that the Testing (Compliance Method) enables the agency to enforce the respective Emission Limitation/Control Requirement or Operational Restriction.

– Ensure that emission rate calculation is accurate and concise or in cases where "no emission testing is required" an explanation should be provided (e.g., cite past emission test that demonstrated the tested emission rate was well below the permit allowable emission rate, etc…).

– Check that terms and conditions include appropriate frequency for emission testing.

– Ensure that Testing (Compliance Method) and/or Test Method(s) are consistent with regulatory requirements.




• Review each Miscellaneous requirement.– This section is typically used for clarification statements such as

rationale for why certain terms and conditions are specified in the permit; also used to include Compliance Plans and Schedules in a Title V permit to address noncompliance issues including the requirement to obtain a PTI.




• Review rule citations for non-SIP approved rules.– New (not modified) non-SIP approved rules should be identified as

State-only in section a)(1) of the terms.

• Ensure “authority for term” for all terms has been cited.• Check for CAM Plan.

– A CAM plan must be incorporated in the terms and conditions, if applicable, using the most recent Ohio EPA or U.S. EPA guidance.

– Check SOB (see below) for whether CDAQ evaluated CAM applicability for each Pollutant Specific Emissions Unit (PSEU) - SOB should indicate "yes" or "N/A" for CAM for each emissions unit.




• Apply the following Quality Indicators for Permit Terms and Conditions:

– Terms and conditions should:» Be accurate and comprehensive (from a regulatory standpoint); » Be clearly written and understandable;» Contain "follow through“;» Be grammatically correct; » Be in a consistent format throughout entire Title V permit;» Be an overall high-quality, professional-looking product.


• Review the Statement of Basis (SOB)– A complete SOB is required at the draft

Title V issuance stage;


• Title V permit corrections & questions– Prepare a marked up Title V permit, using Track Changes in

Word, noting all corrections/questions to send to CDAQ;– If only minor corrections exist the CO Reviewer may elect to

make the changes to the permit instead of sending the corrections to CDAQ;


• Contact CDAQ Permit Writer/CDAQ PRM.

– Discuss progress, schedule, technical issues, etc. through e-mail, phone calls or meetings.

– The permit can be in both “shops” at the same time.


• Once permit has been assigned to CO, if any changes need to be made by CDAQ, including the issuance of any PTIs that affect the recommendation, CDAQ PRM should request that the recommendation be looped back to CDAQ in STARS2 for further changes. If changes are made, the new version must be uploaded into STARS2 when ready for CO review. The previous version can be deleted.


• When CO Reviewer is satisfied that the permit is approvable, he or she assigns the permit to CO PRM in STARS2.

– Based on CO PRM review, additional revisions may be made to the permit by either the CO Reviewer or the permit may be reassigned to CDAQ PRM or CDAQ Permit Writer.

• In instances where CO recommends permit revisions, CO will contact CDAQ PRM and CDAQ Permit Writer to discuss revisions prior to incorporation into the permit.

Issuance of Draft Permit

• Permit is issued by CO Permit Issuance and Data Management (PIDM) Section.

• Public notice is registered in STARS2 by CO PIDM.

• PPP action is assigned to Permit Writer.

Post-Draft Permit Process

• After the draft permit has been issued.– Public hearing held if requested, 30-day notice required.

• Any public hearing will be coordinated through Ohio EPA PIC.– At close of comment period, CDAQ Chief of Engineering shall

remind PRM and Permit Writer of permit time lines.– A "Response to Comments" document is generated in STARS2.

This is prepared by the Permit Writer and includes any comments on the published draft permit and, if applicable, comments from the public hearing. This document is reviewed and discussed with the PRM before making changes to the permit (see Appendix N). Note, this document must be prepared even if there are no comments received.

– Comments received from the permittee or from U.S. EPA (Region V) also require the preparation of a response to comments. If there are no comments, simply enter “no comments received.”

• Our response may be that we disagree with the commenter (with justification), but that must be documented in the file should the issued permit be appealed.


• After the draft permit has been issued (continued).– CDAQ PRM and Permit Writer will discuss significant changes with DAPC

CO Reviewer.– Within a week of the close of the comment period, CDAQ will assess how to

proceed with the next stage of the permit.– If the changes are agreed to, the Permit Writer makes changes in the

Preliminary Proposed Permit recommendation using Track Changes in Word, and adjusts the SOB, then submits the PPP permit recommendation to PRM with the changes highlighted.

– PRM reviews changes and has the Permit Writer make any additional changes necessary.

– Terms are shared with the company to determine if any additional adjustments are needed.

– Once the changes are made, the highlighted copy of the permit along with the “Response to Comments” document are sent to CO for ease of review.

– CO Reviewer reviews and approves changes or recommends additional adjustments.

– STARS2 Workflow should be updated accordingly at each step.


• After the PPP is issued.– A PPP meeting or conference call may be

scheduled upon request by the permittee within 14 days after issuance of the PPP permit.

• PPP meetings are scheduled with the permittee, CO, and CDAQ.

• PPP meetings may take place in person (typically in Columbus) or via conference call.

• If changes are agreed to, the Permit Writer makes the changes in the Proposed Permit recommendation using Track Changes and submits the PP to PRM. After changes are approved, share terms with company.

• After any additional changes are worked out with the company, CDAQ PRM submits the PP recommendation to CO Reviewer through STARS2 and updates Workflow.


• After PP is issued.– If U.S. EPA requests any additional changes within

45 days of PP issuance, these are handled either by CO or the Permit Writer before issuing the final permit.

– CO coordinates response to U.S. EPA comments.• Recently, comments from U.S. EPA have not been

received for most permits and permits are typically issued Final after U.S. EPA grants its approval.

• Lack of comments by U.S. EPA has been a result of early participation and comment from U.S. EPA (typically at the draft permit stage).

Changes to Permit After Issuance

– Changes at the facility or changes in regulations or policy may require changes to a Title V permit after it is issued but before it expires.

– Guidance prepared by Ohio EPA provides various scenarios and the permitting approaches that are required to address the need for these changes (see Appendix O).

– The types of modifications that might occur are: Operational Flexibility; Off-Permit; Administrative Permit Amendment; Minor Permit Modification; Significant Permit Modification; Reopening for Cause; and Monitoring, Records, Reports Changes.

– Of the above types of modification, the Significant Mod is the only one that needs to be issued Draft, PPP, PP, Final. The Significant Mod must also be issued before the company can operate under the mod. It might be necessary to process a Draft PTI simultaneously with a Significant Mod. Therefore, if the company requests a modification, check for this type of modification first and if it can be ruled out, all of the other types of modification are simpler to process.

Date post:	12-Jan-2016
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Title V Permit Preparation

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