DAQ-2018-002270

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director DAQ-2018-002270
GUIDELINES
TO: Permitting Staff
FROM: Marty Gray, Permitting Branch Manager
DATE: April 30, 2018
SUBJECT: Enhanced Approval Order Process
Purpose
This guideline outlines the steps in the permitting process that must be followed so a
modified Approval Order (AO) for an existing Title V source can be incorporated into a
Title V permit using an enhanced process, thus eliminating the need for the Title V draft
permit to have a separate 30-day public comment period.
Implementation
For the enhanced process to be effective for Title V purposes, the Approval Order must
complete this substantially equivalent process.
• The Engineer Review must incorporate all of the following Title V elements, but
only for the modified equipment/operation: NSPS, NESHAP, CAM, Monitoring,
Recordkeeping, and Reporting.
• The Engineer Review cover letter must be signed by the Title V responsible
official and the box checked to alert reviewers that the enhanced process is being
used. The Engineer Review now becomes the Title V administrative amendment
application.
• The Approval Order must go through the 30 day public comment period.
• The newspaper notice for the ITA must include the statement "This AO is being
processed as an enhanced AO, and the Title V permit will be
administratively amended after the AO is issued."
• The Title V engineer will be required to notify affected states.
After public comment ends and comments addressed, the AO is issued to the source. The
source can begin construction but cannot begin operation of the modification until the
Title V permit amendment is completed.
195 North 1950 West• Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
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Page
• The Title V permit engineer will send the AO to EPA with a letter initiating the
EPA 45 day review period. At completion of the EPA review period (maximum
45 days) the Operating Permit will be administratively amended to include the
new conditions.
Analysis
The approval order must be closely coordinated between the NSR and the Title V
engineers.
The next time the AO is modified, the project engineer will remove the Title V required
elements from the AO. The next time the Title V permit is modified, the Title V engineer
will remove any construction requirements for the construction activities that are
completed.
Should a source desire to begin operation of the equipment/process in the modified AO
directly following the AO issuance, the AO should not follow the enhanced process. The
Title V permit will still need to be modified as a major modification, but may be delayed
in accordance with the Guideline "Title V Operating Permit Application Due Dates".
Authority
Pursuant to R307-415-7e(l)(e),
This Guideline shall be audited every five years by the Permitting Branch Manager
10 determine the current status and relevance of the information.