Develop an effective Title V operating permit
Under Title V of the 1990 Clean Air Act Amendments (CAAA), thousands of industrial and government facilities are required to apply for a comprehensive operating permit that addresses all the emission sources at a site and the CAA regulations that apply to them. The new permitting requirements apply to major sources only--although there are several definitions of a major source under the Amended Act. Because Title V applicability is based on potential to emit (PTE) rather than actual emissions, even small and medium sources may initially be subject to this program. Unlike other regulations, Title V puts the burden of demonstrating continuous compliance on source owners and operators. Careful attention to detail is necessary during the application process because the Title V permit is inherently an enforcement fool for the EPA and the general public. Noncompliance can lead to citizen suits and fines up to $25,000 per day. Therefore, it is critical to negotiate an operating permit that does not adversely impact current operations yet provides flexibility for future modifications. Each state and local agency has its own application forms and regulatory interpretations. Areas of complexity include the classification of emission units, the approach for the PTE calculation, the separation of federal and state-enforceable requirements, and the relationship between Title V and other CAAA titles. This article summarizes some lessons learned based upon experiences in various states. (It does not attempt to resolve program uncertainties among jurisdictions.) The practical strategies presented can be used for developing (or modifying) Title V applications as well as during permit negotiations.
- OSTI ID:
- 438875
- Journal Information:
- Chemical Engineering Progress, Vol. 93, Issue 1; Other Information: PBD: Jan 1997
- Country of Publication:
- United States
- Language:
- English
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