Implementing EPA’s New Clean Air Act Policies Under NSR and Title V

Implementing EPA’s New Clean Air Act Policies Under NSR and Title V
Wednesday, December 2, 1:00 pm – 3:30 pm ET

Over the last several 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 Clean Air Act. Experts in NSR and Title V permitting matters will discuss challenges and implementation issues with regard to the recent policy changes listed below, facing both permitting authorities and the regulated community:

  • Interpretation of “Adjacent” based upon physical proximity between properties 
  • Scoping “Ambient Air” based upon a limited change to the application of the “access” element in the regulatory definition of ambient air
  • Interpreting “Begin Actual Construction” proposed guidance, allowing physical on-site activities prior to obtaining an NSR permit, provided that those activities do not constitute physical construction on an emissions unit
  • Plantwide Applicability Limitation (PAL) permitting issues guidance with respect to permit reopening, expiration, termination, and renewal, and monitoring requirements under PAL
  • In the final rule on major MACT to area source (“MM2A”), EPA provides that a major source can be reclassified to area source status at any time upon reducing its potential to emit of hazardous air pollutants below the major source thresholds of 10/25 tpy
     $200 A&WMA Member; $250 Nonmember
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Eric Cornwell, Manager, Stationary Source Permitting Program, Air Protection Branch, Georgia EPD
Eric Cornwell is the air permitting manager at Georgia EPD. In his over 25 years of experience in air quality permitting, he has managed dozens of NSR reviews, including the last permitted coal-fired power plant and multiple nonattainment major new source review projects. Eric is also a Co-Chair of AAPCA’s Permitting & NSR Committee.

Eric Hiser, 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 authors the blog on NSR developments.

Dave Jordan, 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 17 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.  

Matthew Porter, Meteorologist, Division of Air Quality, Permitting Section, Air Quality Analysis Branch, North Carolina Department of Environmental Quality
Matthew Porter is an air pollution meteorologist with NC DAQ in the Permitting Section. He has been with DAQ for four years performing PSD and air toxics modeling reviews and various air quality studies using a variety of dispersion modeling systems including AERMOD, SCICHEM, and CALPUFF. Before joining DAQ, Mr. Porter was an environmental consultant for nine years. His environmental consulting experience includes air quality permitting, dispersion modeling, air quality monitoring, noise modeling, water quality modeling, spill planning, stormwater planning, discharge permitting, TRI reporting, and overall compliance management for a variety of industrial sectors including wood products, oil and gas, power generation, pulp and paper, petroleum refineries, and mining activities. Mr. Porter has a Bachelor of Science degree in Civil Engineering (2006) and Master of Science degree in Environmental Engineering (2007) from Washington State University.

Booker Pullen, New Source Review Supervisor, Air Permitting Section, DAQ
Booker Pullen received his B.S. in Mechanical Engineering from North Carolina State University in 1980. He previously worked for 11 years as a Field Superintendent for construction at the Anheuser Busch Plant in Newark, New Jersey and the Hoffman LaRoche Facility in Nutley, New Jersey. He has been with the DAQ for over 28 years and is currently serving as the New Source Review Branch Supervisor in the Air Permitting Section. He is also a Certified Public Manager. 
Moderator: ​

Rahul Thaker, P.E., QEP, Environmental Engineer, North Carolina Department of Environmental Quality, Division of Air Quality
Rahul Thaker, P.E., QEP, has 32 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 24 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 Workgroup. Mr. Thaker, as an A&WMA Board Director, assists in various technical programmatic and membership recruitment activities.