Can of worms-THE PERMIT-issues

[Charlie Atherton <charlie@structurex.net>]

The actual permit itself, as it is written, can be a problem for the public and the agencies.

Some thoughts and suggestions about permits.

Permit writers should serve as enforcement officers before they are allowed to write permits.  
Obviously this is so that the permit is written so that it is enforceable.

Permits should include material balances.  
This means that the quantity of chemicals going into the industrial process equals the quantity of chemicals produced by the process.  Pretty simple, and industrial accountants do this, but most permits do not require it.  If material balance monitoring had been in place at a Calcasieu industrial facility, the largest EDC spill in the world, would not have happened.

Permits sometime seem to follow the letter of the law, but not the intent of the law.

Permits should include full time, real time, community monitoring for permit compliance of all media.  
We have two large refineries using high Sulphur crude, but no air monitors for Sulphur compounds.

Permits should be a mechanism to be used to continually improve the quality of our environment and human health.

Permits should include how terrorist's activities will be addressed.  
Since industry convinced congress that the terrorist threat is such a real threat that RMP (worst case) information can not be made available to the general public, then industry must spell out, in detail in their permit, how they are preventing terrorist activities from happening at the permitted facility, and how they will handle terrorist activities if their system fails.

What is your experience with the way permits are written?
Charlie Atherton