HomeMy WebLinkAbout08.a.4) Title V Permit Renewal Applicationg
Central Contra Costa Sanitary District
June 9, 2011
TO: HONORABLE BOARD OF DIRECTORS
VIA: JAMES M. KELLY, P.E., GENERAL MANAGER
FROM: MARGARET P. ORR, P.E., DIRECTOR OF PLANT OPERATIONS
SUBJECT: TITLE V PERMIT RENEWAL APPLICATION
Prior to the1990 Clean Air Act Amendments (CAAA), the air quality in many areas of the
country was declining because there were very few agencies to enforce the existing
national air quality regulations. In California, both the Bay Area Air Quality Management
District ( BAAQMD) and the South Coast Air Quality Management District (SCAQMD) had
the delegated authority to enforce existing national air regulation and regional air
regulations via their own individual air permit programs since the 1970's. To fill this
enforcement void in other areas of the country, Title V of the 1990 CAAA required the
United States Environmental Protection Agency ( USEPA) to design and implement a
uniform, nationwide air permit program. Even though BAAQMD had an existing air
permitting program, some areas needed modification for USEPA to approve the
permitting program as Title V compliant. Modifications to the BAAQMD program that
incorporated Title V elements were adopted and approved by USEPA in late 1993.
In 1994, BAAQMD required any permitted facility with the potential to emit 100 tons per
year of oxides of nitrogen, carbon monoxide, sulfur dioxide, and particulate matter to
apply for Title V Air Permit. CCCSD had the potential to emit 100 tons per year of oxides
of nitrogen and submitted a Title V Permit application in late 1994. The Title V
application included a list of all the applicable requirements and compliance summaries.
BAAQMD issued the District a Title V Permit in May of 1995. The Title V Permit is issued
for five years, but BAAQMD continues to issue Permits -to- Operate on an annual basis,
which is a fall back to their original 1970's program and also a source of income.
Air regulations and Title V Permit requirements continued to change with time. The major
change for the District from the May 17, 2000, Title V Permit to the December 11, 2006,
Title V Permit was the requirement to include additional methods for showing continuous
compliance with the regulations. This was done by adding either a pollutant specific
Continuous Emission Monitoring Systems and /or a Parametric Monitoring Systems.
CCCSD currently operates approximately 50 continuous emission or parametric
monitoring systems. This increased the demands on the plant instrument shop and
process control staff.
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Honorable Board of Directors
June 9, 2011
Page 2
The next Title V Permit Renewal Application will be submitted to BAAQMD by June 14,
2011, which is 180 days prior to December 11, 2011, expiration date of the current Title V
Permit. This Title V Permit Renewal Application is like the previous application with minor
clean -up of source descriptions, permit conditions, the addition of new sources like the
sludge loading facility, and clarification on some monitoring requirements. The major
expected changes are the addition of State greenhouse gas regulations (AB32) and the
Federal 129 requirements for sewage sludge incinerators (SSI). The District anticipates
numerous new requirements to meet the 129 regulations that became effective on March
21, 2011.
Federal 129 SSI Update
As you are aware, during the development of the 129 regulations CCCSD and National
Association of Clean Water Agencies ( NACWA) commented on the proposed 129 SSI
regulations. USEPA issued the rules on March 21, 2011. NACWA filed a petition on May
24, 2011, with USEPA requesting reconsideration. Furthermore, NACWA filed a legal
petition for review of the final SSI Rule on May 6, 2011, with the U.S. Court of Appeals for
the District of Columbia Circuit. Taken together, NACWA's petition for reconsideration to
USEPA and legal challenge to the SSI Rule in the D.C. Circuit marks the start of
NACWA's advocacy efforts to ensure USEPA addresses fundamental flaws in the SSI
Rule. The two efforts will proceed on parallel tracks; CCCSD is participating in NACWA
efforts.
Recently, the Section 129 requirements have been proposed as part of a Title V Permit in
New York. It is unclear if this was at the direction of the USEPA or New York. In any
case, how the BAAQMD incorporates Section 129 in our Title V permit will be one of the
key issues of the re- permitting process.
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