Barr prepared an initial Title V permit application for a confidential client's assets associated with a nearby Salt Lake City refinery. Although the client had originally applied for a Title V permit in 1996, the Utah Division of Air Quality hadn’t issued the permit, and a lawsuit against the agency resulted in a requirement for the client to submit an updated version of the application. Our work included:
Conducting a comprehensive regulatory-applicability analysis of federal and state requirements, including those under Utah’s state implementation plans for PM10 and PM2.5
Identifying emission sources, applicable regulations, and individual requirements for each emission source
Preparing a narrative describing operations and preparing an associated block-flow diagram
Calculating the facility's PTE (potential to emit)
Compiling a list of compliance monitoring devices and a description of applicable test methods
Assisting with application submittal, discussions and negotiations with UDAQ, and review of the draft Title V permit prepared by the agency
Following review by the general public, UDAQ, and U.S. EPA, the Title V permit was issued to the client.
