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Correspondence



Bharat Mathur, Chief
Bureau of Air
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois  62702


Dear Mr. Mathur:

I am pleased to transmit to you the final report of the process review that took place on March 3, 4, and 5, 1998.  Several representatives of the United States Environmental Protection Agency met with Illinois Environmental Protection Agency (IEPA) managers and staff with the goal of increasing knowledge and communication between agencies.  These meetings were also intended to develop the roles that each agency plays, and how these roles can be managed to strengthen our relationship as well as create a conduit for effective permit issuance.

We are very pleased with the commitment that IEPA has made toward a streamlined permit program while still retaining a system of checks and balances to ensure environmental protection.    

I hope you find this exercise as useful as we have.  If you have any questions, please contact Steve Marquardt, of my staff, at (312)353-3214.

Sincerely yours,

/S/

Stephen Rothblatt, Chief
Air Programs Branch

Enclosure

cc: Don Sutton, IEPA
Chris Romaine, IEPA
Jim Ross, IEPA



1998 Illinois Permit Process Review Summary

I. Introduction

On March 3, 4, and 5, 1998, Region 5 initiated the first of a series permit process review of the Region 5 State permitting programs by visiting the Illinois Environmental Protection Agency (IEPA) in Springfield, Illinois. Since IEPA was the first of the six States visited, additional Region 5 personnel were included in the visit for training purposes. The Federal process review team was composed of Ron Van Mersbergen, Keary Cragan, John Kelly, Steve Marquardt, Genevieve Damico, Pallavi Reddy, and Diane Tsenane. The principal State personnel in attendance were Don Sutton, Chris Romaine, Jim Ross, and Hank Naour.

The purpose of a process review was to become knowledgeable and comfortable with three main topics.

Within each of these areas, the USEPA wanted to find the level of quality assurance that all applicable requirements are provided in permits, what factors affect permit issuance rates, and the level of difficulty in using and billing for title v fees. By determining the level of quality assurance of permits, USEPA is able to determine the level of review needed as well as locating areas where USEPA would be able to provide assistance and information. Permit issuance rates continue to be an issue of concern across the country. This process review provided IEPA with an opportunity to educate the USEPA as to the complications involved in permit issuance as well as bring attention to the partnership effort and level of communication needed to streamline the program. Finally, title v fees dicussions served to education the group as to the use of fees raised by permit programs and the difficulties that arise.

The IEPA operated a construction and state operating permit program for over 25 years. Pursuant to the Clean Air Act Amendments of 1990, on March 7, 1995, IEPA obtained interim approval of their title v operating permit program, called the Clean Air Act Permit Program (CAAPP). In order to efficiently implement their existing State construction and operating permit pragram, their non-attainment new source review program, and their Federally Enforceable State Operating Permit (FESOP) Program, in conjunction with their CAAPP program, the IEPA permit section recently underwent a reorganization. This reorganization and added attention to the title v permit program provided a good time for USEPA staff working with Illinois to learn how they can effectively work with IEPA as well as provide an educational experience for the other members of USEPA to take back and use to provide higher quality service and review for all of the Region 5 States.


Through this process review, IEPA demonstrated that they have excellent tools and procedures in place to ensure that all applicable requirements are placed their CAAPP permits. Through their planning and management structure, IEPA has established a balance between training, communication, information transfer and the issuance of permits. Of course there are always areas where IEPA and USEPA can improve to work toward a common goal of a clean environment. All of these qualities and recommendations are discussed further and summarized in the conclusion and recommendation sections.

II. Process Review Highlights

The IEPA staff gave very thorough presentations regarding their workload distribution structure, efficiency of permit issuance, tracking of information, internal review procedures and quality control, processing of title v modifications and the fee structure. These topics are detailed further in the following section along with the summary attachment.

Workload Distribution Structure

Much of the resources are focussed on title v permit issuance as mandated in the Clean Air Act. Additionally, Illinois is implementing an Emission Reduction Market System (ERMS) through their title v program. In order for this program to be fully operational during the 1999 ozone season, IEPA must issue title v permits to the affected sources by May, 1999. The ERMS is a seasonal program designed to reduce VOM emissions from stationary sources in the Chicago area. Using VOC trading units provides flexibility and reduced cost as well as enhance the amount of emission reductions. Deadlines to set up this program have increased the urgency of title v permit issuance because the ERMS program is administered through title v.

Efficiency of Permit Issuance

There are several issues that affect the permit issuance rate for IEPA. First, approximately 1800 title v sources have been issued Federally Enforceable State Operating Permits (FESOP) to restrict their potential to emit (PTE) under major source thresholds. An additional 642 source are covered under the January 25, 1995 Seitz memorandum (50% potential to emit transitional policy). The remaining approximately 760 title v sources have submitted applications and are being processed. Factors that complicate timely permit issuance include the development of the system, model permits, analyst structure and staff training. Also adding significantly to the time required for permit issuance is the percentage of permit applications that are incomplete or have compliance and implementation issues (~95%) and the amount of confidential business information claimed which requires additional legal review. The IEPA continuously sets goals for permit issuance for the entire system as well as each permit writer. This type of information allows IEPA to locate the labor and time intensive areas of permit issuance and streamline wherever possible. By tracking each analysts performance and output, specific training or advancement can be administered after locating areas of difficulty and areas of expertise.

Tracking Information

IEPA has an electronic permit tracking system (Permit Trax) that includes information on 8500 sources state-wide. Some of the capabilities of the electronic tracking system include the ability to query by location, Standard Industrial Codes, and key words. Each field office in Illinois also has access to the PermitTrax. In addition to the PermitTrax, IEPA has an Local Area Network (LAN) that houses their model title v (CAAPP) permit language, the electronic versions of their rules, guidance, and spreadsheet calculation sheets, all in electronic format for all of the permit analyst to access. This system ensures consistency, accuracy and helps analysts assure that all applicable regulations are included through utilization of the different source-type models.

Title V Modifications

There was a discussion about a letter sent by the USEPA regarding the draft Konstant Products title v permit. The draft CAAPP permit included changed limits from what was established in previous construction permits. It was the USEPA’s view that the title v permit could not be used to establish or significantly modify applicable requirements. IEPA was concerned that using separate minor construction permits for minor modifications would be too cumbersome and unnecessary since minor modifications do not require a public notice period. It was IEPA’s view that such added workload could slow the title v issuance rate. IEPA also demonstrated that their CAAPP program authority is broader that the Federal Part 70 rules, such that IEPA does have the ability to change some existing applicable requirements through the CAAPP program. After a lengthy discussion, both sides agreed on a three tiered approached for changes in applicable requirements in the CAAPP permits.
1) Insignificant changes, mistakes, obsolete rules, etc., could be "cleaned-up" according to the White Paper - without any formal process.

2) Only very minor NSR changes could be "fixed" in the title v permit as long as they are labeled as such in the permit and Public Noticed accordingly.

3.) Any major or synthetic minor or netting NSR or PSD activity must be evaluated and issued in a separate NSR permit through proper procedures (although it may be parallel processed for public/USEPA reviews).

There is still concern as to the tracking of such modifications, concurrent public notices and the level to which the staff feels these combination permits are appropriate.

Fee Structure

The idea behind the fees portion of this review was to educate the USEPA as to the structure in place to quantify the work associated with title v fees and allow the IEPA to explain the positives and/or difficulties with the way the system is designed. IEPA staff provided a brief session of question and answer that allowed the USEPA to feel comfortable in the allocation of funds and the system of checks designed to assure that the dollars are distributed in the correct manner. IEPA handles its title v fees differently then any other State in the region. The title v fees are based on allowable emissions rather then actual emissions. Allowables requested are routinely 60 to 100% higher than current actuals. This allows for less conflict with industry concerning billing. There is some concern that the decrease fee used due to this difference, $13.50/ton compared to almost $33/ton, may cause some difficulties in the future due to the lack of increases for inflation and the difficulties in increasing the fee. The fee must be approved by a board established by the legislature. IEPA is fully aware of the intricacies of their budget system and feels that the current situation is adequate. There is still uncertainty as to how this will all play out in the future.


Conclusions & Recommendations

IEPA has a very strong grasp on the function of its permitting program and the need to satisfy all obstacles in an expedited manner. Each section of the program provides for conduits of information in order to provide consistency and attention to detail. The visit to Springfield, IL provided the USEPA with an educational experience as well as an increased assurance that IEPA is committed to producing quality permits. We will continue to work with them to provide increasing levels of productivity, consistency and quality.

Goal Setting

The timing structure and goal setting for permit issuance rates sets realistic goals to get quality permits at expedited rates. Also, each permit analyst has a number of permits in his/her name to act on. All of the actions taken on these permits are tracked over time in order to provide feedback as to areas to streamline the process or point out areas of improvement. USEPA representatives were impressed by the accountability associated with the work load of each writer. This system provides a pattern of tasks and performance of those tasks.

Organizational structure & Information transfer

IEPA uses the knowledge of experienced staff to update and train newer staff members. This is done from a combination of weekly meetings, speakers, and E-mail exchanges. Information transfer provides for consistent and quality permits. IEPA spends quality time providing a nurturing environment for permit analysts who are willing to learn and excel.

Internet Access

IEPA feels that not every permit writer should be given Internet access due to the increased length of time it could add to the issuance of permits and performance of daily duties. While the USEPA understands these concerns, we would recommend that Internet access be available on a suitable number of accessible computers for all staff to use. Permit issuance and quality may be improved through access to information and examples from the many State agencies that have their permits available on the Internet and the USEPA website and others have all the guidance documents, regulations, and implementation materials readily available. Providing limited access will provide for higher levels of information exchange while still addressing the need for permit issuance rate as a priority.

Public Comment

There is an important balance between providing the public information and the costs for public notice. The IEPA spends a significant amount of money to notify the public of impending permit actions without much public participation on most projects. This leads to doubts about the value of these efforts, narrowing the focus to projects of obvious public concern. It is the USEPA’s contention that one function of a permitting authority is to allow the public to become involved in decisions affecting their community. In this regard, the IEPA’s goal should be to expand public knowledge of permitting activities. In the past there have been concerns that the newspapers used to public notice certain permit actions are not reaching the affected community, possibly due to the type of newspapers in which the public notice information is provided. It is important in boundary areas between different newspapers, it may be best to do the public notices in multiple papers. While we are sympathetic to the dollars spent to provide the public information, it is an essential part of our responsibilities to the public and therefore IEPA must continue to focus attention on education and involvement.

Memorandum of Agreement

The next step in improving the working relationship between IEPA and USEPA is the implementation of the Memorandum of Agreement which outlines each Agencies role in permit activities. The IEPA has the primary responsibility for the implementation of the Clean Air Act Permitting Program (CAAPP) while the USEPA has the responsibility to provide assistance and oversight of the implementation of the CAAPP. Also included in this agreement are commitments to such topics as general practices for communication, routine reporting, preliminary review, handling of draft, proposed and issued permits, reopening of permits, integrated processing of construction permits, availability of documents, USEPA audit of IEPA CAAPP, handling of confidential information, and dispute resolution. Commitments to these topics will provide for improved program actions. The USEPA will continue to work with IEPA to improve this partnership.

Continued Quality Effort

Overall, the USEPA program reviewers were very impressed with the level of detail and hard work that IEPA has committed to in order to issue quality permits. This challenging program is continuously evolving and in need of continuous upkeep and maintenance in order to maintain high quality permits. The IEPA must balance the State’s economic development goals while protecting public health and the environment. We commend IEPA for the hard work that has been applied to the program and the commitment to carrying these ideals into the future. The USEPA will continue to work toward improved relations and communication with IEPA in order to assist with the common goal of environmental protection.

ATTACHMENTS: The following attachment provides a detailed summary of the information discussed.


GENERAL
1. Organization
How are permits assigned?Individual permit analysts work on both NSR and CAAPP permits. One analyst works on all permits for a company. The companies (and permits) are assigned to the analyst based on interest, experience and ability.
How is enforcement involved in the permit process?There is little interaction between the sections. In preparation of the permit, if there is a potential PSD violation, the engineer sends a memo to enforcement and puts the CAAPP permit on hold until resolved. The compliance assurance section acts as the hub for all communications.
How are staff organized?Within the Permits Group:
CAAPP Permits ---- Electric Utility Permits --- State and FESOPs
/ \ | / \
ERMS nonERMS Work Lead Work Lead Work Lead
| | | | |
work lead work lead Analysts Analysts Analysts
| |
analysts analysts

The above 3 groups report to Don Sutton. Chris Romaine is the technical expert.

Within the Air Division: the Compliance Assurance section acts as a hub. The enforcement, field offices, permits, legal, monitoring, and toxics interact via the compliance assurance section.
How are permits organized?Each title v permit “package” has a public notice sheet, permit timeline, project summary, permit and review notes from the analyst.
2. Interim Approvals
What are the Interim Approval Issues?Issues include acid rain, insignificant activities, administrative amendments, and enhanced NSR.
What issues arise when addressing Interim Approval?The acid rain issue has been resolved thru legislative fix. Some issues may be resolved by interpretations of the white papers and/or the Part 70 revisions. Audit privilege laws may also affect full approval.
3. Memorandum of Agreement
What does the MOA contain currently?The MOA contains the responsibilities and roles that IEPA and USEPA will play in title v issues. Some of these responsibilities include communication, reporting, review, processing, and dispute resolution.
What is necessary to change to make the MOA more efficient?The MOA has been agreed upon by IEPA and USEPA. The MOA was signed by the respective officials on April 9, 1998.
FEES
1. Title V Revenue
What are the fee rates specified?Fee rates are $13.50 per allowable ton of emissions. Any regulated pollutant is charged, except for CO which is exempt under the CAA. HAPs are not double counted as VOC or PM.
Does the Permitting Authority anticipate changes to its fee structure?No. If the cost per ton is to be increased, it must first be approved by a board comprised of industry leaders and then passed in legislature. This would be a very difficult process.
Are appropriate emission records used for $/ton based fees. How are actual emissions determined?The State charges on ALLOWABLE emissions.
Are records kept (and used) for any hourly based fees?There are no hourly fees.
How is the IEPA notifying sources of the fees owed and due dates for payments?There is an automated computer system which generates the bills 45 days before due date. If no entry denoting payment is made in that time, the computer automatically produces another letter.
Discuss recording of incoming payments.The companies send in copies of their bills which have account numbers on them. The accounting department credits the appropriate account.
Are the sources paying the total fees charged each year?Yes. A few sources have discrepancies with the bill and speak directly to IEPA to find a solution.
Are they paying on time?There have been no problems probably due to the billing based on allowables which eliminates most conflict.
If there’s a collection problem, how does the IEPA address it?If there is no response to the notices sent, compliance assurance is notified. An investigator is assigned who may make a site visit. Further notices are then sent. No legal cases have arisen as of now.
Are late fees being assessed? Are they credited to TV accounts?No late fees are assessed.
2. Title V Expenditures
What matrix is the IEPA using to differentiate title v activities from non title v?There is a set list of activities which are attributed to title v. Each manager decides if activities which are in a gray area are considered under title v activities.
How are time sheets used?Each analyst and employee must complete a biweekly time sheet accounting for time. The time is divided into hour increments and accounted to a specific activity under a set project description.
How does the allocation system for title v and non title v travel and equipment costs function?All travel and equipment is charged to the appropriate account from the given list of projects.
How are indirect costs apportioned?The occupancy, utilities etc. costs are divided by a percentage which has been approved through Washington DC.
3. Accounting system
Describe the accounting structure.Incoming fees are credited to a general title v account. Payments are attributed to a specific project number which codes by division, fund source and project.
Does the accounting system have separate categorization for title v and non title v funding and expenses?Funding is clearly differentiated. The expenses are clearly separated out, but there may be overlap of title v and non title v activities which are difficult to attribute.
What are the title v fees collected each year? Approximately $10 million was collected.


TITLE V
1. Efficiency of Permit Issuance
What are the steps in permit issuance?Jim Ross assigns a working file to a permit analyst containing completeness determination, CAAPP 200 form, compliance certification form, delegation for responsible official and fee form. Analyst obtains the application from the file room. The permit, staff notes, and project summary are written concurrently. A memo is sent to the compliance section if there is a concern with the findings in the application. The compliance section has 10 days to respond. When a compliance schedule is drafted it is also sent to the compliance section for review. Any confidential business information material is reviewed by a paralegal. The prepared draft then goes through management and peer review. The source reviews the permit which is then sent to public notice.
How are permits prioritized?Currently ERMS permits are the priority because they must be issued by May 1, 1999. Permits are generally done by source category. At this point, some of the less complicated source categories have been completed to gain experience and knowledge for the more complicated sources.
What is available for standard language?IEPA has model permits, language, rules and calculations for each source category available on the LAN.
What resources are being used to issue permits?There are approximately 60 people in the permits section including administrative and technical staff. There is an extensive electronic permit tracking program and model permits on the LAN.
Does the permitting authority have a strategy to issue the permits? Are they following it?IEPA is issuing permits to sources subject to ERMS first. Permits will then be issued by source category. IL has a system of goals and target numbers set up to meet permit issuance rates.
2. Processing of Title V modifications
How are reopenings identified and processed?Reopenings are determined on a case by case basis depending on the reason for reopening. These determinations will be discussed between the permit analyst, lead worker, and unit manager. There are procedures in place to process the permits.
How are administrative amendments processed?Final permit action within 60 days of receipt of the application. A copy of the final permit is submitted to USEPA.
Is the permitting authority taking steps to minimize the reopenings? What are the steps?IEPA is continuously striving toward clear, complete and concise permits that contain all applicable requirements as to reach the goal of quality permit issuance. This involves anticipation of difficulties and quality control of exiting permits.
How are the modifications tracked?The ICEMAN computer tracking system is capable of tracking the modifications.
How are permits designed to incorporate modifications?Modifications will be identified in the unit specific sections. NSR modifications are represented with the associated construction permit number that created the modification.
3. Inclusion of all applicable requirements in permits
What process is used to check the applicable requirements?IEPA has source category model permits which would have the general applicable requirements for that industry type. The analyst also reviews past construction permits and the application. The SIP rules are categorized by pollutant so rules are readily identified. The work leader and unit manager review the draft permit. The field offices and compliance section also have the chance to comment on the draft permit.
What process is used to incorporate SIPs? Source specific SIPs? NSR requirements?The analyst can review the SIP for applicable sections by identifying the pollutants. All previously issued NSR permits do not expire and are filed together for reference to facilitate the incorporation of the requirements into the title v permit.
What flexibility options are given to sources wanting to change limits from NSR?Minor changes in NSR requirements can be made by concurrent public notice of the NSR changes and title v permits. It is important to note the NSR changes in the title v permit and provide a mechanism to track these changes as NSR changes. Anything that requires netting or a major NSR permit is processed separately.
How are sources which never received NSR permits handled?These sources are handled concurrently between any enforcement action necessary and proper permitting activity to provide federal enforceability.
What is the protocol for making applicability determinations?The permit writer speaks to the lead worker who speaks to the unit chief. Issues not resolved at this point can be raised to Chris Romaine for NSR issues, Bob Smet for toxic implementation, or other experts. Major applicability determinations are brought to the IEPA Compliance Decision Group that meets bi-weekly. Don Sutton is a member. If issues are still present USEPA is questioned.
How are permits designed to ensure that applicable requirements are addressed?The lead workers draft up a permit for particular source categories which contain the applicable requirements that could apply to that source type. IL’s rules are also sorted according to pollutant which allows for the permit writer to find rules that may apply to a source of a particular pollutant. There is also an internal review for both technical and administrative accuracy. The field offices and compliance section also have an opportunity to review.
What information is provided in a statement of basis? Is it complete?IEPA does not provide a separate document for a statement of basis. This information is provided in a project summary and through more detailed source information in the permit. The types of decisions made in a statement of basis are not always included in this manner due to differences in the information provided by varying permit writers.
What criteria are used in placement for conditions in the Federal/State side of permits?IEPA puts the requirements to limit a pollutant under major source thresholds in the Federal side while placing much of the other requirements in the State side. This was done to allow industry the comfort level to come out of State only permits and into FESOPs and provide federal enforceability to the controlling pollutant.
4. Process of integrating NSR
What modifications are eligible for an integrated NSR permit?Minor changes to limits, but they must be noted as such in the permit and public notice. PSD, netting, synthetic minor, and major NSR are to go through the construction permit program separate from the title v program.
How are the integrated NSR permits processed? Public noticed? Filed?As a result of our process review, the title v permit will be filed in both the title v files and the NSR files. The modifications will be noticed as both a NSR and title v change. The permit will also note the dual function of the permit conditions.
When is the NSR portion issued with respect to the title v portion?Concurrently. For minor changes, the NSR and title v permits would be one document. For significant changes there would be two permits which could be public noticed at the same time. Allowing minor changes in NSR through the title v permit allow public comment on these issues which would not occur otherwise.
How are existing NSR limits incorporated into the title v permits?They will be transposed with the addition of periodic monitoring with the exception of those limits that fall under “enhanced NSR”. Limits from NSR permits are identified with the permit application number.
5. Internal review procedures
Describe the internal review process?The permit writer drafts the permit. The lead worker and unit chief review it. The draft is sent to the source and the compliance section which coordinates with the field offices, legal and modeling section. Bob Smet handles implementation of MACT and NESHAP conditions. Betty Ascher reviews for administrative and consistency details.
How is information shared within the Agency?Memos are sent from permitting to enforcement or legal if there are questions of violations or confidential business information. The title v group meets weekly to share information. The model permits on the LAN are also updated with new models and guidance.
How are new USEPA policies incorporated into permits?Chris Romaine and Don Sutton discuss the policies with the staff on how they should be incorporated into the system.
6. Training
How are new permit staff trained?New staff is trained in drafting permits under the FESOP program. Personnel are then shifted around due to need and interest. Jim Ross has prepared "Effective Permit Writing" material and also maintains several training manuals. Training is done on a continual basis through speakers at weekly permit meetings or in house training sessions.
What are the resources available for ongoing training programs?Each year a Bureau of Air seminar is held which showcases all the different programs and issues being worked on . "Guest speakers" also come to weekly permit meetings for training.
How is policy distributed?Through weekly staff meetings and e-mail.
What is the protocol for making applicability determinations?Permit analyst sends the issue to the supervisor with an opinion. If the supervisor can’t answer the question the Compliance Decision Group may be asked applicability questions. Those decisions are put in a book for further reference.
How are the USEPA/staff concerns disseminated/handled?Through weekly staff meetings and e-mail.
What computers/resources are available to permit staff?Each permit writer has a computer connected to the LAN system. ICEMAN tracks the permitting milestones of each facility. These milestones include a listing of the permits issued to the source and where a permit is in the process of being issued through the end of the public comment period. However, very few permit staff have access to the Internet.
7. Electronic permitting
What is the process for storing documents electronically?IL updates the Region 5 Notes server as title v permits are developed in each stage. In the future citizen comments and response to comments will be available in the Notes system.
How is the information available to others in the office? Public?Model permits are available on the LAN for use in the office. The public can view IL’s permits on the Region 5 homepage.
How is the permit process tracked?IL uses an Oracle based program (ICEMAN) to track the permits through the end of the public comment period.
What are the limitations of the permitting system? Tracking system?Staff don’t have access to the permits on the Region 5 homepage because there isn’t widespread staff access to Internet. The State doesn’t use the same tracking and electronic filing system as the Region.
Does the permitting authority have the ability to determine which sources are subject to specific standards and SIPs? How do they track notifications and the need for reopening?Through ICEMAN, IL can search for sources which might be applicable to a standard. The SIC code is a searchable field in the database as are key words. All 8500 sources in the state are in the system.
8. Public Participation
How are public comments handled? Maintained?The company and field offices have approximately 21 days to review the permit prior to the public notice. Public comments are handled by Brad Frost. He is responsible for response to comments. Currently, only those who made comments receive a copy of the response to comments.
What are the timeframes involved in responding to comments?Permits must be issued within 180 days of receipt of the application for NSR permits. Comments must be responded to in order for the permits to be issued.
How are permits public noticed? Hearings?Brad Frost writes up a public notice which is sent to a local paper. For example, the “Skylines” paper is used in the City of Chicago. There is a difficult balance between the dollars the IEPA spends to public notice this information and the type of newspapers that are used.
How does the public obtain information about the permit? Source?The public can look at the Region 5 homepage for title v permits. Otherwise, Brad Frost or other permit analysts are responsible for responding to calls from the public. Permits are sent to the State and local officials. Mailings of notices are also sent to those on the interested parties list maintained in a FoxPro database.
How and when is USEPA notified of permit issuance? Public concern?The NSR permits and title v permits are sent to USEPA via mail either a week before or a week after the notice appears in the paper. USEPA is notified of sources of public concern on each six week conference call between USEPA and IEPA.
Are cultural or language barriers considered in the notices?None are considered.
9. FESOPs, Prohibitory Rules
What is the process for applying for a synthetic minor permit?Same as the existing state operating permit program. Some title v applications are later determined to be a FESOP.
How does the issuance of synthetic minor permits affect title v permit issuance?IEPA had the first FESOP program in the country. Greater than 2000 FESOPs have been issued thus a large amount of time was spent on these sources that would otherwise have been subject to title v.
Are both title v and FESOPs issued to sources?When a FESOP is needed to limit HAP PTE at a unit in advance of a NESHAP/MACT standard becoming applicable to a source.
10. How are permits brought into the system
What resources are used to identify applicable sources?IEPA has had a construction and operating permit program for over 25 years, such that over 8500 sources are in their system.
What is the application process?IEPA has standard procedures and information on their Internet site. Sources can also easily request application packages.