Monitoring required for each operational restriction, control measure and emission as needed (unless otherwise specified in the permit T &C's). needs to include sufficient M/Rk/Rp to demonstrate compliance with applicable emissions limits and operating restrictions. A 2008 federal District Court decision upheld right to gap-fill if underlying monitoring is not sufficient to assure compliance Monitoring results are required to be recorded and maintained. Must specify frequency of monitoring. Use Library of Terms appropriate language. Specify monitoring devices (e.g., pressure gauge, temperature monitor, CEMs, etc.). Refer to Engineering Guide #52 for CEM systems. Reporting Section [section e)]. Specify what record keeping results need to be reported. Specify the frequency of reports (e.g., quarterly deviation-based, annual, "after the event," others). As appropriate, include requirements to submit reports of deviations from operational restrictions and/or emission limitations. Testing [section f)]. List each applicable emission limitation from section b)(1) and provide a method for determining compliance for each. Explain how the emission rate is calculated or why no emission testing is required in this section. Use Engineering Guide #16 to determine frequency for stack testing. Review past permits, stack test results, and inspection reports. Review stack tests required by applicable rule(s).
Upon completion of the Draft permit recommendation, the CDAQ Permit Writer reviews the Draft permit recommendation against the listed criteria to ensure that quality Terms and Conditions have been written. If not already done, prepare or update the Statement of Basis (SOB) document using the Ohio EPA guidance (Appendix M), or the most recent/updated guidance. The SOB document must be generated in STARS2 and saved at L:\Data\Facilities. The SOB document can be prepared during the assembly of the permit recommendation. CAM Plan Review. Determine if a Compliance Assurance Monitoring (CAM) plan is required for one or more emissions units at the facility using CAM guidance (Appendix L). If a CAM plan is required, provide a discussion of the CAM plan as part of the Draft Title V permit recommendation. Contact DAPC CO Reviewer to discuss progress, schedule, technical issues, etc. associated with the review of the submitted plan. In cases where a CAM plan is required but has not been submitted, the CDAQ Permit Writer shall contact the facility contact to obtain a CAM plan. This might require the need to resubmit the Title V application. Additional CAM guidance from U.S. EPA can be at: http://www.epa.gov/ttn/emc/cam.html For Title V Permit Renewals, the CDAQ Permit Writer shall follow the current Ohio EPA guidance concerning the preparation of Title V permit renewals (Appendix P). Upon submittal of the permit renewal recommendation to Central Office, CDAQ PRM will attach a copy of the completed checklist in STARS2. The CDAQ Permit Writer and CDAQ PRM shall contact DAPC CO Reviewer to discuss technical issues, progress, schedule, etc. for permit renewals. Note that the old legacy permits were in a different format that contained two sections for the individual emissions units terms: State/Federal and State Only. The new STARS2 format contains only one section for the emissions unit terms. In this section, it will be necessary to include terms that were previously in the State Only section and identify them accordingly in term a)(1).