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:
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Conducting a comprehensive regulatory-applicability analysis of federal and state requirements, including those under Utah’s state implementation plans for PM10 and PM2.5
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Identifying emission sources, applicable regulations, and individual requirements for each emission source
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Preparing a narrative describing operations and preparing an associated block-flow diagram
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Calculating the facility's PTE (potential to emit)
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Compiling a list of compliance monitoring devices and a description of applicable test methods
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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.