From: William Bertele, P.E. (firstname.lastname@example.org)
Date: Tue Apr 04 2000 - 20:07:43 CDT
----- Original Message -----
From: Henry Boyter <email@example.com>
Sent: Tuesday, April 04, 2000 7:28 PM
Subject: Re: Title V
Historically, I have seen most of the Title V fees run in the area of
$10,000 to $15,000 for the relatively simple applications, i.e., two sources
and one or two operating scenarios. However, most of these were also judged
inadequate, troublesome and subjected the client to extensive compliance
requirements, i.e. testing & reporting & monitoring requirements. The Title
V Operating Permit applications market is a very competitive one and as such
it appears that you can get a variety of low bids, which also means low
priority and little effort on the compliance requirements.
Depending on the facility requirements and number & variety of processes, I
believe that most of the Title V Operating Permits should cost in the
$15,000 to $25,000 range for a consultant who will really work hard to
obtain minimum compliance requirements and maximum operating flexibililties.
Many expect that you should prepare and submit an application and that it is
it. Just wait for approval. However, this approach may not give you the
best permit terms & conditions.
Actutally the permitting process should be a series of environmental agency
negotiations such that you push the agency to the limit on the least
restrictions on operations and provide the maximum flexibility on operations
and emissions. At the same time, the negotiations should be for the minimum
monitoring & reporting requirements. This will require multiple revisions
to and re-submissions of the application and meeting with the enviornmental
agency. This usually does not happen under a fixed price, low bid contract.
I advise you to look for a consultant that will get deeply involved with
your mode of operations and will provide the revision and negotiations
efforts. This can be done on an intial cost basis with hourly fee basis for
additional effort. Note that in your cost estimate of the preparation of
the application by a consultant, you should also add your own internal costs
for your participation in the process, which should be extensive. Do not
expect the consultant to walk thourgh your faciilty one day and some time
later return with a completed application. You must be an active and almost
equally sharing partner in the data collection requirements for the
preparation of the input data for the application.
If you and your omcpany lean toward low bidder, then caveat emptor. You
have to be as smart as the bidder to understand what you are getting.
In choosing, look for a consultant who has experience in your specific field
and whom you feel that you can trust.
William Bertele, P.E., DEE
New Hope, PA
> What should a printer who is going to break the 100 ton VOC limit for
> potential emissions expect to pay a consultant to bring him into Title V
> compliance? HAPs and other criteria pollutants are a non issue.
> Rob Harrison
> Moore and Associates, Inc.
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