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ENV-05-184 Title V Certification Issues - A Self-Diagnostic Tool

Kenneth Weiss, ERM

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member, Special/Temporary Member - $0.00
Government, NonMember - $25.00

Description:

Approximately 25,000 facilities in the United States are required to obtain a new Title V Operating Permit that lists all of a facility’s applicable air emissions limitations in a single document For a number of large facilities like petroleum refineries and chemical plants, Title V permits have been in place for many years. These facilities have faced the daunting task of verifying compliance with a tremendous number of applicable requirements. Our experience at three refineries in the Southwest and West is that a typical refinery should expect to have to certify compliance with anywhere from 2,200 to approximately 3,500 actionable and applicable federal and state requirements. Many refineries with EMIS have found that their Title V compliance status has not improved significantly. Huge amounts of time are spent maintaining the databases and responding to uncovered deviations, and the environmental staff cannot seem to find time to eliminate deviation root causes and drive the deviations to zero. Something more than just EMIS is needed. Instead, facilities need to step back and develop the “Management Process” that enables the compliance certification. After presenting the elements of a robust management system to support a Title V Compliance Certification program, this paper presents a simple and straightforward self-diagnostic tool that any refinery can use to assess its existing program and identify areas for future effort.

Product Details:

Product ID: ENV-05-184
Publication Year: 2005