Optimizing operational flexibility and enforcement liability in Title V permits

Conference · Wed Dec 31 04:00:00 EST 1997

OSTI ID:353591

McCann, G T ^[1]

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1. Rust Environment and Infrastructure Inc., Greenville, SC (United States)

Now that most states have interim or full approval of the portions of their state implementation plans (SIPs) implementing Title V (40 CFR Part 70) of the Clean Air Act Amendments (CAAA), most sources which require a Title V permit have submitted or are well on the way to submitting a Title V operating permit application. Numerous hours have been spent preparing applications to ensure the administrative completeness of the application and operational flexibility for the facility. Although much time and effort has been spent on Title V permit applications, the operating permit itself is the final goal. This paper outlines the major Federal requirements for Title V permits as given in the CAAA at 40 CFR 70.6, Permit Content. These Federal requirements and how they will effect final Title V permits and facilities will be discussed. This paper will provide information concerning the Federal requirements for Title V permits and suggestions on how to negotiate a Title V permit to maximize operational flexibility and minimize enforcement liability.

• OSTI ID: 353591
• Report Number(s): CONF-970677--
• Country of Publication: United States
• Language: English

Related Subjects

29 ENERGY PLANNING, POLICY, AND ECONOMY
54 ENVIRONMENTAL SCIENCES
AIR POLLUTION
CLEAN AIR ACTS
ENFORCEMENT
IMPLEMENTATION
LIABILITIES
LICENSES