4 The record articles

South Carolina Title V Permit Streamlining

Posted: March 8th, 2021

Authors: Jenny B. 

One section in your next Title V permit renewal application could substantially reduce the burden of demonstrating compliance with your permit and save your company thousands of dollars in stack testing costs and hundreds of man hours in compliance demonstrations.   When your five-year Title V permit renewal comes due, careful consideration should be given to including a section for “Requested Permit Streamlining.”

A facility may propose to streamline more than one applicable requirement for the same pollutant at a single emissions unit into a single permit condition.  The overall objective of streamlining is to establish the most stringent permit limit that will assure compliance with all related applicable requirements for an emission unit.  All of the applicable requirements remain in effect but compliance with each of them is assured through compliance with the over-riding Title V permit streamlined condition.  The monitoring, recordkeeping, and reporting requirements associated with the most stringent emissions requirement are presumed appropriate for use with the streamlined emissions limit.  Streamlining does not have to wait for the next Title V renewal and may also be incorporated via the Title V significant modification process.

The United States Environmental Protection Agency (U.S. EPA) and the South Carolina Department of Health and Environmental Control (SC DHEC) provide guidance to assist Title V permit holders with the streamlining process.[1]  In South Carolina, facilities with emissions sources subject to Boiler MACT can choose to request several SC DHEC evaluated and pre-approved streamlining options for South Carolina Regulation 61-62.5, Standard No. 1 including streamlining of:  particulate matter (PM) and opacity limits, PM testing, monitoring, reporting, and recordkeeping requirements.  In lieu of biennial PM testing under SC Regulation 61-62.5 Standard No. 1, PM source testing for Standard No. 1 maybe conducted in accordance with Boiler MACT annual/triennial testing requirements.  This could save in stack test costs alone around $6,500, an average cost for a Method 5 source test.  For emissions units where Part 64 Compliance Assurance Monitoring (CAM) would be applicable for the subsumed requirements the Department has determined the monitoring required by the Boiler MACT is sufficient to show compliance and Part 64 can be subsumed and considered exempt pursuant to 40 CFR 64.2(b)(1).  Streamlining also simplifies your annual compliance certification because you will be performing a line-by-line compliance certification for fewer permit conditions.

DHEC Title V Streamlining Guidance

Streamlining Multiple Applicable Requirements on the same Emissions Unit

Streamlining PM Source Testing for Requirements Contained in Standard No. 1 and 40 CFR 63, Subpart DDDDD

One size doesn’t fit all and streamlining may not be for every Title V permit or every set of requirements (especially when the requirements are expressed in different units or forms).  A violation of a streamlined emissions limit or operating limit would be a presumed violation of both the streamlined requirement and the subsumed emissions or operating limits.  Per U.S. EPA guidance, streamlined permit terms should be requested to be covered by a permit shield, providing certainty that the source will be considered in compliance with all of the applicable requirements subsumed under the streamlined requirement.

If you have any questions or would like to discuss opportunities to streamline the air permitting and compliance burden at your facility, please reach out to Jenny Brown at 1 (678) 293-9432 ext. 212 or jbrown@all4inc.com or Mike Kendall at (843) 460-5378 or mkendall@all4inc.com.

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