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Title: Negotiating Title V and non-Title V permits

The Title V Operating Permits program has been extended over many more years than originally anticipated when the 1990 Clean Air Act Amendments were first legislated. In fact, the regulatory program is still being refined even as facilities complete and submit their Title V permit applications. Likewise, it is clear that the agency review of the Title V permit applications will probably take considerably longer than originally anticipated. Finally, when the agency does complete the review, it is equally clear that there will need to be a significant amount of negotiating on the part of the facility to arrive at a simplified permit that is operationally feasible. This paper presents a number of suggestions for what the facility should be doing between the time the permit application is first submitted and the agency responds with a draft permit. The suggestions are designed to help simplify the permit and enhance flexibility. In addition, the paper presents permit negotiating techniques and points out the pitfalls that will be encountered if the facility does not take action prior to receiving the draft Title V permit. This paper suggests that the facility should internally evaluate how the permit application impacts facility operations prior tomore » the agency doing so. It also suggests that the facility should contact the agency early and amend the permit application to take advantage of increasing regulatory flexibility. By taking these steps, and properly negotiating the permit terms and conditions; the facility will achieve a much better permit, and will hopefully be able to avoid the regulatory burdens and delays associated with re-opening the permit during the next 5 to 8 years (from the time of permit application submittal).« less
Authors:
 [1] ;  [2]
  1. Kleinfelder, Inc., Parker, CO (United States)
  2. Kleinfelder, Inc., Pleasanton, CA (United States)
Publication Date:
OSTI Identifier:
679343
Report Number(s):
CONF-980632--
TRN: IM9940%%162
Resource Type:
Conference
Resource Relation:
Conference: 91. annual meeting and exhibition of the Air and Waste Management Association, San Diego, CA (United States), 14-18 Jun 1998; Other Information: PBD: 1998; Related Information: Is Part Of Proceedings of the 91. annual meeting and exhibition. Bridging international boundaries: Clean production for environmental stewardship; PB: [5000] p.
Publisher:
Air and Waste Management Association, Pittsburgh, PA (United States)
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; CLEAN AIR ACTS; LICENSE APPLICATIONS; AIR POLLUTION ABATEMENT; NEGOTIATION