The collision of Title III and Title V: A potential permitting and enforcement nightmare
The Clean Air Act of 1990 (CAA) mandated that all facilities classified as major were to obtain a Federal Title V operating permit. In addition, any facility, either major or minor, which emits certain chemicals or compounds above a specific single quantity limit or a total aggregate limit are subject to Title III requirements and are required to obtain a Title V permit as well. The problem with obtaining a Title V permit for Title III substances is there is limited data, at least for the utilities sources, on emission factors and emission rates for many of the Title III listed chemical compounds. In addition, the emission data that exists is very conservative, and if used, would show the facilities to be significant emitters of hazardous air emissions, while actual emissions are significantly less. This could lead a facility to applying for a Title V permit unnecessarily, a time consuming process at best. In Iowa, facilities submitted the first Title V permit applications in 1994. The Iowa Department of Natural Resources is currently in the process of reviewing the submittals prior to issuing operating permits. Title III has not been addressed at all in the submittals and therefore will not be included in this round of finished permits that are to be issued. The outcome of this is that the Title V permits will have to be opened and amended to include the applicable Title III operating conditions and constraints. This paper will examine the areas where Title III and Title V collide and the potential permitting and enforcement issues that will have to be faced by the facilities that operate under these permits. This paper is based on the opinions of two of the three responsible parties (facilities and consultants) that are dealing with the potential permitting and enforcement wreckage before the collision occurs.
- OSTI ID:
- 679348
- Report Number(s):
- CONF-980632-; TRN: IM9940%%167
- Resource Relation:
- Conference: 91. annual meeting and exhibition of the Air and Waste Management Association, San Diego, CA (United States), 14-18 Jun 1998; Other Information: PBD: 1998; Related Information: Is Part Of Proceedings of the 91. annual meeting and exhibition. Bridging international boundaries: Clean production for environmental stewardship; PB: [5000] p.
- Country of Publication:
- United States
- Language:
- English
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