ENV-05-185 Title V Permits - Where Air Rules and Emissions Estimates Collide

Description:

Now that life with a Title V Operating Permit has become everyday reality for petroleum refineries, facilities are finding that the permit does more than serve as a checklist for the regulatory obligations of the facility – it also imposes obligations (both intended and unintended) that were never part of any of the underlying air rules. One of these is the requirement to annually report all emissions from the facility. Most facilities have operations for which they never had to estimate emissions. In fact, established methodologies for estimating emissions don't exist for certain operations, and are of dubious accuracy for others. Even for those operations for which emission factors are available, the emission factors generally are applicable only to routine operations. There may be ambiguity, at best, with respect to the obligations for estimating and reporting emissions from non-routine events (such as start ups, shut downs, or malfunctions). As facilities endeavor to meet these new obligations, they sometimes find that their task is further complicated by entries that were made on their permit applications. In the absence of data concerning a given parameter, for example, a best guess at a representative value may have been entered. While this may have been thought to be of little consequence at the time, the authority having jurisdiction may now be construing that value as a permit limit. Questions such as, "What were the excess emissions that resulted from Tank 106 having failed a rim seal inspection?", "How can the vapor pressure of lube oil be shown to be below the value that the summer intern put on the permit?", or "What are the emissions from the cooling tower?" never had to be answered to comply with the rules – but they have become significant issues in the new world of Title V permit compliance.