ENV-96-168 TRENDS IN REFINERY TITLE V PERMITTING

Description:

It is a safe bet that nearly every petroleum refinery and petrochemical plant in the U.S. is subject, in some fashion, to the Title V operating permit program in Title 40 of the Code of Federal Regulations (CFR), Part 70 (or Part 71). While many facilities have submitted applications and some states are deep into review, very few permits have actually been issued to date. And the timeframe to implement this program has been stretched far beyond its original bounds. Refineries that have not yet submitted permit applications have a chance to learn from those that are further along in the process. In turn, refineries that are negotiating permit conditions may still find opportunities to influence the process to their benefit. In this paper, we hope to provide ideas and information useful to applicants at any stage of the process based in large part on our collective experience with a variety of facilities in about a dozen states, including several petroleum refineries.