Experience implementing Title V at a large utility

Conference · Thu Dec 31 04:00:00 EST 1998

OSTI ID:679345

Toeroek, D ^[1]

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1. Toeroek Associates, Arvada, CO (United States)

Implementation of a Clean Air Act Title V program at a large utility in Colorado involved the following activities: Generation of Operating Permit Applications; Identification of areas of non-compliance and self-reporting to the regulatory agency; Development and implementation of better record-keeping systems; Development and implementation of training programs; and, Development and implementation of a pilot program. This paper discusses in detail eight ``lessons learned`` from the experience gained during a one-year pilot program. (1) The whole process of record-keeping at the plant level had to be improved. Under Title V, regulators will go directly to a facility and ask to see documentation of compliance. Facility personnel must be prepared to show regulators the appropriate documentation. (2) Recordkeeping must be electronic. Trying to comply using manual record-keeping will generate too much paper. (3) By monitoring for a year as if Title V were in effect, deficiencies were identified early and corrected. In this way, the Utility was ready when their permit was issued. (4) One person at each facility was designated as the Title V representative, giving one focal point for the plant and one person responsible for the Title V information. (5) Training was conducted for everyone at the plant, from the receptionist to the manager. This was important for getting cooperation from plant personnel. More specific training was given to Title V representatives from all the plants. (6) A multi-disciplinary implementation team is necessary, consisting of personnel from legal, operations, environmental, etc., to ensure successful implementation. (7) Internal audits were conducted during the pilot program so that plants can self-report to the regulatory agency, thereby gaining regulatory relief from severe fines. (8) A Quality Assurance Manual/User`s Guide was prepared that pulls together all aspects of the program. This ensures consistency in implementation when personnel change.

• OSTI ID: 679345
• Report Number(s): CONF-980632--
• Country of Publication: United States
• Language: English

Related Subjects

29 ENERGY PLANNING, POLICY, AND ECONOMY
54 ENVIRONMENTAL SCIENCES
AIR POLLUTION ABATEMENT
CLEAN AIR ACTS
COLORADO
IMPLEMENTATION
LICENSE APPLICATIONS
QUALITY ASSURANCE
TRAINING