A Systematic Approach Benefits Manufacturers Implementing Title V Permits
June 15, 2004: Implementing Title V and assuring compliance requires careful planning, attention to detail, and it takes time. By outsourcing the implementation task (or parts of it) to a firm with industry knowledge and experience, you will find that project focus and schedules are maintained, and you will benefit from using solutions proven to work efficiently and cost-effectively.
Dixon Environmental has facilitated Title V implementation at several manufacturing sites, and we have found that following a systematic process is particularly beneficial.
Step 1- Translate permit language and requirements to “plain English”.
Step 2- Determine the optimal compliance method for each requirement.
Step 3- Assess current practices:
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Identify responsible person(s);
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Look at gaps where new procedures are needed;
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Consider opportunities to improve current monitoring and recordkeeping (i.e., eliminate redundancies).
Step 4- Provide new procedures and proper training to responsible persons.
Step 5- Look at work flow practices, particularly data handling and management:
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Where does the data come from?
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Who is responsible for acquiring date? Securing data? And reporting data?
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Where are records kept?
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In what format (paper log, electronically)?
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Do you have document filing and retention procedures in place?
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Do you need to upgrade your data management system?
A wide range of consulting and software tools are available. Make certain you’re getting the right level of compliance assistance for your facility. Contact Dixon Environmental at info@dixonenvironmental.com.
The following case study illustrates the benefits you may receive by choosing Dixon Environmental for your Title V compliance and implementation.
Case Study
Dixon Environmental provided regulatory and batch plant expertise to a batch chemical manufacturer working with their State agency to develop a facility Title V permit. Dixon Environmental employed a novel approach to agency coordination that included presenting all the facility compliance issues upfront in order to streamline the process and eliminate obstacles that might otherwise result in last minute delays. In addition, Dixon Environmental thoroughly researched Federal and State applicable requirements, updated all of the client’s preconstruction permits, and wrote a Title V compliance plan for agency review. The agency initially requested that the compliance plan require calculations for the manufacture of each batch run. Dixon Environmental identified this as an unrealistic requirement requiring additional manpower for no real environmental benefit. Dixon Environmental worked with the agency to incorporate reasonable monitoring and recordkeeping requirements appropriate for batch plants into the Title V permit.
By choosing Dixon Environmental, this client benefits from:
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Unique solutions based on experience with Title V permits for batch facilities,
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A consultant with batch plant experience for realistic monitoring, recordkeeping and reporting requirements, and
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The maximum operating flexibility allowed by regulations.
Read more Title V cases ...
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