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Webinar Series: On the Ground: Implementing EPA’s New Clean Air Act Policies under NSR and Title V



On the Ground: Implementing EPA’s New Clean Air Act Policies under NSR and Title V
Tuesday, November 5 and Tuesday, November 19, 1:00 pm – 3:00 pm ET

Over the past two and a half years, EPA has issued several policy memoranda and rulemakings pertaining to preconstruction permitting requirements under New Source Review (NSR) and operating permit requirements under Title V of the CAA.  This webinar series is intended to explore how to apply these changes at the plant level (i.e. “On the Ground”).
 
The webinar series will examine how to apply the following EPA policy memos / rulemakings:
•          Common Control Determinations for Stationary Sources and Major Sources
•          Interpretation of “Adjacent” for Stationary Sources and Major Sources
•          Permitting Issues for Stationary Sources Located in Serious Ozone Non-Attainment Areas
•          Reclassification of Major Sources as Area Sources Under § 112 of the CAA
•          Defining Project Aggregation Under New Source Review
•          Determining Project Emissions Under New Source Review
 
Experts in NSR and Title V permitting matters will discuss implementation issues and challenges facing both permitting authorities and the regulated community.
     $300 A&WMA Member; $420 Nonmember 
Please log in to the website before registering . If you are not an A&WMA member and do not already have a user account, join now or create an account before registering. 

Part 1:  ​Applying EPA’s New Interpretation of Stationary Source, Determining Title V Applicability in Reclassified Serious Ozone Non-Attainment Areas, and Unwinding the “Once-In-Always-In” Policy
Tuesday, November 5, 1:00 pm - 3:00 pm 
 
This webinar will include presentations on:

  • Common Control Determinations for Stationary Sources and Major Sources (interpretations issued on April 30 and October 16, 2018, and July 12, 2019) 
  • Interpretation of “Adjacent” for Stationary Sources and Major Sources (draft policy issued on September 4, 2018) 
  • Permitting Issues for Stationary Sources Located in Serious (Reclassified from  Moderate) Ozone Non-attainment Areas (final Rule published on August 23, 2019)
  • Reclassification of Major Sources as Area Sources Under §112 of the CAA (proposed rule published on July 26, 2019)
The memorandums on common control provide EPA’s refined, but narrowed, interpretation on common control criterion when determining if two or more stationary sources should be combined for permitting purposes. The draft guidance on adjacency provides EPA’s current interpretation on the term “adjacent” when determining if two or more stationary sources should be combined for permitting purposes.   
 
The final rule on reclassifying moderate non-attainment areas for 2008 ozone NAAQS to serious areas with more stringent requirements create permitting challenges for stationary sources and major sources.The proposed rule on reclassifying major sources as area sources would incorporate the plain language reading of “major source” and “area source” definitions under §112 of the CAA.
    $169 A&WMA Member; $229 Nonmember 
Part 2:  What is a Project, When to Aggregate, and How to Apply the Project Emissions Accounting Rule
Tuesday, November 19, 1:00 pm – 3:00 pm ET 

This webinar will include presentations on: 
  • Defining Project Aggregation Under New Source Review (final rule published on November 15, 2018), which articulates EPA’s “substantially related” test to determine if two or more projects should be combined into a single project under NSR.
  • Determining Project Emissions Under New Source Review (proposed rule published on August 9, 2019), that revises NSR applicability regulations to make it clear that both emissions increases and decreases that result from a given proposed project are to be considered at Step 1 (significant emissions increase test). 
     $169 A&WMA Member; $229 Nonmember 

Presenters: 

John Evans, Senior Environmental Engineer, RTP Environmental Associates

John Evans is senior environmental engineer at RTP Environmental Associates.  John has almost 30 years of experience in the field of air quality permitting.   John worked for 25 years at the North Carolina Department of Environmental Quality where he has served in a variety of roles including Chief Deputy Secretary, General Counsel, and head of major source permitting. Mr. Evans also served several years as an Assistant Attorney General. Mr. Evans has a law degree and a B.S. in Mechanical Engineering from the University of North Carolina at Charlotte.

Eric Hiser, Lead Environmental Partner, Jorden, Hiser & Joy, PLC
Eric Hiser is lead environmental partner at Jorden, Hiser & Joy, PLC.  He helps complex industrial facilities comply with environmental regulation at reasonable cost while maintaining operational flexibility for future product and process innovation.  Experience includes nearly 200 PSD, NNSR and Title V permits; SIP/FIP development; and state/federal appeals and enforcement defense.  He is a co-author of A&WMA’s New Source Review Manual and authors the NSRLaw.com blog on NSR developments.
 
Dave Jordan, P.E., Partner, ERM
Dave Jordan is a partner in the Indianapolis office of ERM.  Mr. Jordan has more than 40 years of experience in the air pollution regulatory field, including seventeen years of experience with the Indianapolis Air Pollution Control Division.  He has directed and participated in numerous air pollution control construction permit projects during his employment with ERM.

Moderator:  Rahul Thaker, P.E., QEP, Environmental Engineer, North Carolina Department of Environmental Quality, Division of Air Quality
Rahul Thaker, P.E., QEP, has 30 years of regulatory and consulting experience in air quality, wastewater, solid and hazardous wastes, and construction project management.   He is a senior environmental engineer, working for the North Carolina Department of Environmental Quality, Division of Air Quality, Raleigh, NC, for more than 23 years.  Currently he focuses on reviewing and drafting New Source Review and Title V permits for various categories of industrial sources, and leads the Division’s Permitting Work group. Mr. Thaker, as an A&WMA Board Director, assists in various technical programmatic and membership recruitment activities.