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Title 5 Permitting and Enforcement Workshop
Hosted by U.S. EPA - Region 10

Target Audience:
REGULATORS ONLY - Title 5 enforcement and permitting staff at the local and state agencies and EP

Workshop Overview:
The Title 5 Workshop will be a candid discussion of how local, state, and EPA offices are addressing current air operating permit issues - sharing what works and what doesn’t. EPA will provide a legal and policy update to bring everyone up to date and summarize the current administration’s priorities.

Proposed Workshop Agenda:

  • Introduction and brief overview of workshop goals
  • CAAAC Title 5 Task Force Recommendations - What is EPA going to do with them?
  •  AOP Fee Topics
    • Declining AOP Revenues?
    • Closed/Mothballed facilities not paying Title 5 Fees - what happens?
    • Focus on Idaho’s registration and registration fees process
  • AOP Renewal Status - Plans for issuing late renewals
  • Greenhouse Gases
    • New Major Sources for GHG only - Who are they? How will they be handled?
    • Synthetic Minors - Example permit terms and how are they working
    • Example GHG AOP/SOB Language
  • Incorporation of PSD Permits into Title 5 Permits
  • Incorporation of Consent Decree requirements into Title 5 Permits
  • MACTs
    • Fluctuating MACTs Status Update
    • What about the "once in always in" policy?
    • Legitimacy criteria for non-hazardous solid waste materials (i.e., by-products from wood products facilities)
    • Permit conditions for biofilters under PCWP MACT
  • Area Source Rules - How are these being incorporated?
  • Compliance and Enforcement
    • Status of Federally Reportable Violation
    • AOP Compliance Tools
  • Specialty Need-to-Knows
    • New EPA Method 202
    • Cure HAPs and Material Balance Calculations
    • VOC Concentrator - a way to get more out of an existing RTO?
  • Good Permit Practices - Highlights from the 2011 Washington State Title 5 Review

 

For general information contact Lynnette Haller, WA Dept. of Ecology by telephone at 509-457-7126 or via e-mail at LHUL461@ecy.wa.gov

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