ENV-04-204 Sunoco Uses Technology to Streamline Title V Certification

Description:

Sunoco’s objectives for Title V compliance is to maximize consistency across the company, minimize the potential for deviations and increase the level of compliance assurance. In order to increase the level of compliance assurance and to minimize potential deviations, Sunoco has initiated a major effort to maximize Title V consistency across the company. Starting with the permitting process, while the applications were typically prepared on an individual basis, it was found that many of the underlying applicable requirements apply to multiple facilities. As a result of this discovery, the final permit language for each site was drafted to be as consistent as possible overall. Once a permit was issued, we further standardized compliance by identifying consistent interpretations of the requirements. While it may sound obvious, getting to know the Title V permit is the foundation for everything that comes later. Very often, we believe we understand a particular permit term or condition, but after further analysis, we realize there is more to the requirement than we initially thought. For instance, the terms opacity and visible emissions are often used interchangeably, but from a Title V certification standpoint, they are two completely different animals. One uses EPA Method 9 for visual inspections while the other relies on Method 22. On the other hand, we generally understand the rigid rules surrounding CEM maintenance and performance. What is not so quickly realized is that many Title V permits contain monitoring provisions that rank thermocouple and DP cell maintenance and performance with traditional CEMS. Lastly, whether the permit regulators used regulatory citations, paraphrased regulations, or cut and pasted the entire regulation to the permit can completely change what we must comply with and how we must certify the compliance.