Obtaining Appropriate Permit Conditions

A key part of any permitting process is the set of conditions in the permit designed to ensure that the source emissions are consistent with current rules, with the representations in the permit application, and with the control technology determination made as a part of the permit review. Those permit conditions are critical to the source in several ways. The most obvious is that they are legally enforceable and must be met regularly. Also, those limits will influence how often the permit must be amended when subsequent process changes occur. Practical and flexible permit conditions that meet the government's need for accountability are considered to be integral to a successful permitting effort. A few key considerations when negotiating permit conditions are:

• Avoid overly detailed limits, particularly when they have no environmental consequence. For example, a permit specifying a certain raw material may preclude the use of another raw material at a later time.

• Avoid redundant limits. States are inclined to set emissions limits (short- and long-term), as well as limits on process throughput and hours of operation and raw material type.

• Aggregate limits provide more flexibility than separate unit-by-unit limits. For similar operations, it may be easier to meet a single overall limit on a consistent basis than a limit on each unit. This provides flexibility to operate one unit more when other units are out of service or constrained.

• Clarify the basis for demonstrating compliance with a limit. Often, permits set limits with no description of how to show compliance. To the extent there is any ambiguity, it is best to spell out the compliance basis in the permit.

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