ENV-95-166 NOBODY KNOWS CHERRY POINT LIKE CHERRY POINT PEOPLE TITLE V OPERATING PERMITS: A TEAM APPROACH

Description:

For too long, many of us have only been able to guess at the effort involved in preparing and negotiating a Title V Air Operating Permit. This regulatory paper will present several realities of Title V permitting and will focus on the team approach taken by ARC0 Product Company’s Cherry Point refinery in Washington State. Instead of hiring an environmental contractor or delegating the permit application task to the refinery environmental department, ARC0 established an integrated team of refinery personnel to draft the permit application. The “Title V Team” was comprised of Process Engineers, Instrumentation Engineers, Maintenance Staff, Environmental Engineers, Senior Management, Legal Counsel, and an Environmental Consultant, This group worked together for nearly two years to craft a permit application that met the Title V requirements at a least cost while working to ensure long term operational flexibility.