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Project: Bulk Loading Terminal - Permit Correction

Overview: Business Objective

A client's bulk loading terminal became subject to the Title V permitting program when a local air district opted in to an "extreme" ozone nonattainment designation, which reduced the major source threshold from 25 tons per year to 10 tons per year. ALG worked with our client to prepare an initial Title V permit application and operating permit that to optimize operating flexibility and to properly document the applicability of federal, state and local requirements. and worked with the local air district to ensure the final permit conditions were appropriate.

Technical Approach

A key part of the initial Title V permit application is the reasonable inquiry necessary to certify compliance with applicable permit conditions and applicable local, state, and federal regulations. ALG staff is expert in air quality regulations; we performed a comprehensive review of air regulations that was documented in a compliance database, allowing for efficient compliance certification. This process revealed gaps in internal monitoring protocols that were quickly modified to ensure all required monitoring was being performed.

Following submittal of the application, ALG worked with our client and the local air district engineering and permitting staff to craft permit shields and streamline applicable monitoring and compliance certifications,saving our client a significant level of effort for ongoing annual compliance certification's.

Results

Title V operating permits are intended to put in one place all of the obligations a facility operator has under federal and state clean air act requirements. While not necessarily a welcome process, a properly crafted Title V permit will remove ambiguities, and provide clear reasoning as to the non-applicability of major federal and state programs. ALG was selected by our client for our expertise in these technical issues, and our solid professional relationship with local district engineering staff that allowed the project to be executed efficiently, and to provide a smooth transition to major source status.

 
 
 

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Oil and Gas Exploration and Production - Operating Permits