Developments in Title V CAAPP Permitting

1
Developments in Title V CAAPP Permitting

• Don Sutton
• Bureau of Air, Permit Section Manager
• Illinois Environmental Protection Agency

2
Summary of Developments

• Initial Permits
• Brief Project Summary
• Periodic monitoring was mostly records reports
• Streamlining was automatic
• Non-applicability statements added that were not
  necessarily requested or based on a construction
  date
• Loose language for topics such as shutdown,
  malfunction/breakdown, NSR and Title I conditions

3
Summary of Developments

• Renewals
• Detailed Project Summary
• Periodic monitory will be expanded to include
  more testing, inspections, monitoring, etc.
• Streamlining must be requested and justified
• Non-applicability Statements must be requested
  and justified. Remove those based on
  construction date
• Overall language has been tightened up
  significantly

4
Revising a CAAPP Permit

• Revisions to CAAPP permits
• Administrative
• Minor
• Significant
• Make sure all the necessary information is
  included
• Technical information
• Forms
• Proposed language for the change
• Copy or reference to construction permits
• If the wrong request is made or not all the
  necessary information is present in the
  application, a Notice of Incompleteness letter
  will be issued.

5
Periodic Monitoring

• Required to include as per 40 CFR 70 and 39.5 of
  the Act.
• Make sure you suggest periodic monitoring in the
  application, otherwise the IEPA will be putting
  it in for you.
• This is the result of several petitions filed in
  the State.

6
Permit Streamlining

• Subsumming one applicable requirement into
  another
• This will not be done unless specifically
  requested by the source.
• In order to do this, the source must submit a
  detailed analysis comparing the more stringent
  regulation to the less stringent regulation with
  an explanation as to where and how the
  requirements of one rule are subsummed within
  another and how the source prefers to demonstrate
  compliance.

7
Non-Applicable Statements

• The application must contain a specific request
  for a non-applicable statement to be included in
  the permit.
• These constitute permit shields and must be
  supported with an explanation as to why the rule
  is not applicable.
• Non-applicability statements based on
  construction dates must include a certification
  by the responsible official that the emission
  unit(s) has not been reconstructed or modified.

8
Statement of Basis

• A more comprehensive project summary is being
  written for all permits that require public
  comment.
• The document explains the permit in more detail
  regarding periodic monitoring, prompt reporting,
  streamlining, and non-applicability statements.
• Sometimes includes other information as necessary
  to support certain permit conditions (i.e.,
  compliance history, previous years emissions,
  etc.)