Permit Application Information

and Work Group Exercises

Peter Westlin, EPA,

OAQPS
Outline of Permit Submittal re:
Monitoring Provisions

 Background information
 Monitoring approach description and
level of detail
 Justification and support
Basic Background

 Emissions unit (PSEU)

 Applicable regulations, emission limits, and
monitoring requirements
 Control technology (e.g., control device
(CAM), compliance fuel or raw material,
process controls, operation and
maintenance protocols)
Monitoring Approach (CAM)

 Measurement method (what and how)

 Monitoring frequency and averaging
procedures
 Excursion or exceedance definition
(indicator range for CAM)
 Performance criteria – QA/QC
procedures
Other Permit Content Factors

 Commitment to corrective action

 Reporting and recordkeeping
 Verification of operational status
 QIP Threshold (optional)
 Data availability (optional)
 Table format (for clarity in permit)
Justification

 Brief description of source/control device

 Rationale for selecting indicators
 Rationale for selecting indicator ranges
 Supporting information (e.g., test data,
design factors, historical data, margin of
compliance)
 Monitoring Approach–
Title V Permit Table (example)

Indicator Combustion T Outlet CO conc.

Measurement approach Thermocouple CO CEMS
Indicator range Excursion: <1500°F Excursion: >50 ppmv
Data representativeness Installed in incinerator PS 4, 40 CFR 60, App. B
chamber
QA/QC Redundant t-couple and span gas
Monitoring frequency Measure continuously Daily zero
(+ 30F) Measure continuously
(10 sec)
Data collection Record continuously Record 1-min averages
procedures on chart recorder by DAS (electronic)
Averaging period None 1-hr average
QIP threshold No more than six No more than 10 7
excursions excursions
Questions?
Let’s divide into groups