Optimizing operational flexibility and enforcement liability in Title V permits
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.
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- Conference: 90. annual meeting and exhibition of the Air and Waste Management Association, Toronto (Canada), 8-13 Jun 1997; Other Information: PBD: 1997; Related Information: Is Part Of 1997 proceedings of the Air and Waste Management Association`s 90. annual meeting and exhibition; PB:  p.
- Air and Waste Management Association, Pittsburgh, PA (United States)
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- United States
- 54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; AIR POLLUTION; CLEAN AIR ACTS; ENFORCEMENT; LIABILITIES; LICENSES; IMPLEMENTATION