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Title: Think twice before seeking a synthetic minor permit

Is a synthetic minor permit the solution to onerous Clean Air Act Amendments (CAAA) mandates? Compared with a Title V (Part 70) major source air operating permit, a synthetic minor permit substantially reduces compliance-monitoring and record-keeping requirements, provided pollutants are kept below a certain level. This means that in some instances, the answer is an unqualified yes, a synthetic minor permit is desirable. In others, the answer is maybe. And in many cases, the answer is definitely no--despite apparently compelling reasons to apply for synthetic minor status. The right answer depends on a careful analysis of many factors, and reflects the origin of the term synthetic minor. It was first applied by government officials to facilities designated minor sources of hazardous air pollutants only because they did not operate all full capacity. The facilities actually were major sources masquerading as minor, officials maintained. The term stuck and today is part of the official language. It no longer holds negative connotations, but companies that obtain synthetic minor permits without thinking through the consequences can suffer negative results. Once a source has a synthetic minor permit, it may discover that it cannot expand its operations without a permit modification. If the sourcemore » expands to major source levels, it must obtain a Title V (Part 70) major source permit.« less
Authors:
Publication Date:
OSTI Identifier:
85978
Resource Type:
Journal Article
Resource Relation:
Journal Name: Pollution Engineering; Journal Volume: 27; Journal Issue: 6; Other Information: PBD: Jun 1995
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; HAZARDOUS MATERIALS; POLLUTION SOURCES; PERMITS; AIR POLLUTION; CLEAN AIR ACTS