PERMIT CONTENT Sample Clauses

PERMIT CONTENT. According to 40 CFR §70.6 (a) (1), each permit issued shall include “Emission limitations and standards, including those operational requirements and limitations that assure compliance with all applicable requirements at the time of permit issuance.” Subparagraph i and ii go on to point out that duplicate requirements and overlapping requirements must be reconciled. Without prejudice, the DAQM permit evades many requirements and does not clearly include the “streamlining” demonstration prescribed in EPA white papers. DAQM and its predecessor agencies have issued permits pursuant to APCR Section 12 since 1987. Section 12 contains regulations that are not federally enforceable, are not SIP approved, and are less stringent than approved SIP requirements. Consequently, all Part 70 permits that were issued by DAQM that are based on the Section 12 since 1987, are misleading to the public, unlawful, and do not comply with the requirement to “assure compliance with all applicable requirements at the time of permit issuance.” Compliance requirements are missing from the permit. The proposed permit allows non- quantifiable means of measurement (emission factors) in place of continuous emission monitors and performance tests that would quantify emissions.
Sample 1
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PERMIT CONTENT. According to 40 CFR §70.6 (a) (1), each permit issued shall include “Emission limitations and standards, including those operational requirements and limitations that assure compliance with all applicable requirements at the time of permit issuance.” Subparagraph i and ii go on to point out that duplicate requirements and overlapping requirements must be reconciled. Without prejudice, the DAQM permit evades many requirements and does not clearly include the “streamlining” demonstration prescribed by EPA. As an example of DAQM’s failure to require LAER, page 10 of the proposed permit lists various emission units and their Emission Control levels. The permit lists the PM-10 limits for the source as 51.37 tpy, thus making the source significant and subject to LAER per Section 15.14 of the SIP. Despite the requirement for LAER, all emission units A01 thru A09 are shown to have 0% emission control for PM-10. DAQM and its predecessor agencies have issued permits pursuant to APCR Section 12 since 1987. Section 12 contains regulations that are not federally enforceable, are not SIP approved, and are less stringent than approved SIP requirements. Consequently, all Part 70 permits that were issued by DAQM that are based on the Section 12 since 1987, are misleading to the public, unlawful, and do not comply with the requirement to “assure compliance with all applicable requirements at the time of permit issuance.” The NEC objects to Condition C-8 of Part III. The requirement of LAER is not met. Rather than test for control efficiency, compliance is determined by at least 90% uptime and less than 10% bypass. No mention of control deficiency and LAER is in the permit. The NEC objects to Condition C-20 regarding a “design” of a boiler. The important criterion is not the design but the actual emissions. The NEC objects to Condition C-24 and there has been no mention of a “nonmetallic mineral processing” plant at the site. The NEC objects to Condition C32 regarding unpaved roads. Condition C-31 has established that LAER requires paved roads. Unpaved roads do not comply with LAER. The NEC objects to Condition D-3 regarding “low sulfur coke.” Low sulfur coke is undefined in the permit. The NEC objects to Condition D-10 of the permit regarding Granite Construction or Chemical Lime. This condition appears to demonstrate the sloppiness of DAQM management and their “quantity over quality” approach to permitting. We request that DAQM define exactly what Chemical Lime and/or Gran...
Sample 1
PERMIT CONTENT. According to 40 CFR §70.6 (a) (1), each permit issued shall include “Emission limitations and standards, including those operational requirements and limitations that assure compliance with all applicable requirements at the time of permit issuance.” Subparagraph i and ii go on to point out that duplicate requirements and overlapping requirements must be reconciled. Without prejudice, the DAQM permit evades many requirements and does not clearly include the “streamlining” demonstration prescribed in EPA white papers. EPA white papers are not statutes or regulations and for that reason, are legally insufficient for any lawful purpose. “Streamlining” is not authorized by law and DAQM has failed to cite any legally sufficient basis for “streamlining.” DAQM and its predecessor agencies have issued permits pursuant to APCR Section 12 since 1987. Section 12 contains regulations that are not federally enforceable, are not SIP approved, and are less stringent than approved SIP requirements. Consequently, all Part 70 permits that were issued by DAQM that are based on the Section 12 since 1987, are misleading to the public, unlawful, and do not comply with the requirement to “assure compliance with all applicable requirements at the time of permit issuance.” Compliance requirements are missing from the permit. The proposed permit allows non- quantifiable means of measurement (emission factors) in place of performance tests that would quantify emissions.
Sample 1

Related to PERMIT CONTENT

  • Client Content Client Content, including all pre-existing Trademarks, shall remain the sole property of Client or its respective suppliers, and Client or its suppliers shall be the sole owner of all rights in connection therewith. Client hereby grants to Designer a nonexclusive, nontransferable license to use, reproduce, modify, display and publish the Client Content solely in connection with Designer’s performance of the Services and limited promotional uses of the Deliverables as authorized in this Agreement.

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