Where to find information about facilities
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Where to find Information About Facilities. Overview of Title V Permits. The Need for Title V . Air quality goals were not met Confusion as to what requirements applied to a facility Existing rules often lacked monitoring Limited public access and comment Weak compliance oversight

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Where to find Information About Facilities

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Where to find information about facilities

Where to find Information About Facilities


Overview of title v permits

Overview of Title V Permits


The need for title v

The Need for Title V

  • Air quality goals were not met

  • Confusion as to what requirements applied to a facility

  • Existing rules often lacked monitoring

  • Limited public access and comment

  • Weak compliance oversight

  • Purpose of Title V permit: accountability, improved compliance and enforcement


Who issues title v permits

Who Issues Title V Permits?

  • State and local agencies

  • EPA in Indian Country

  • Tribes – if they develop a program and get it approved by EPA


Who has to get a title v permit

Who has to Get a Title V Permit?

  • All major sources

  • Plus some non-majors

  • Around 20,000 major sources nation-wide

  • Call your permitting agency to see which sources are getting permits

  • See http://www.epa.gov/airquality/permits/obtain.html


How do permits get issued

How do Permits Get Issued?

  • Sources must apply

  • Permitting agency prepares draft permit

  • Draft permit is reviewed by public

  • Public hearing may be requested

  • EPA reviews some State permits and may veto the permit

  • Final permit is issued


Permit applications

Permit Applications

  • New sources:

    • Due within 12 months of starting to operate

  • Sources that have title V permits:

    • Due at least 6 months before the 5-year renewal date

  • Sources that need their permit updated (modified)


What is included in a title v permit

What is Included in a Title V Permit

  • All applicable requirements including

    • Requirements from federal standards, such as

      • Maximum Achievable Control Technology Standards

      • New Source Performance Standards

    • Terms and conditions from new source review permits

    • Conditions from the State Implementation Plan

  • Origin and authority for each permit term

  • Monitoring, recordkeeping, and reporting


What does a title v permit look like

What does a Title V Permit Look like?

  • Can be quite long (85-100 pages for a medium size permit)

  • Statement of basis

  • States choose the format

  • General conditions

  • Conditions for specific process line or emissions source


What does a title v permit look like1

What does a Title V Permit Look Like?

  • For each process line or emissions source, the permit generally has:

    • Description of process and its pollution control equipment

    • Emission limit or other type of limit

    • Monitoring, recordkeeping and reporting


How do title v permits promote compliance

How do Title V Permits Promote Compliance?

Title V Permits:

  • Roll all applicable requirements into one document

  • Add source-specific monitoring (sometimes)

    • Monitoring means collecting and using data on emissions or other information about the operation of a process or pollution control device

    • Each permit limit or condition needs monitoring “sufficient to assure compliance”


How do title v permits help enforcement

How do Title V Permits Help Enforcement?

  • Reports and certifications alert permitting agency and public

  • Permit settles what requirements apply


Public availability of records

Public Availability of Records

  • Permit application (except confidential business information)

  • All reports and certifications

  • Draft and final permit

  • Correspondence


Minimum requirements for public involvement

Minimum Requirements for Public Involvement

  • Minimum requirements for notice of draft permit:

    • Newspaper notice

    • Creation of mailing list to provide notice

    • Other means necessary to notify affected public

  • 30 day public comment period

  • 30 days notice prior to public hearing (if one is held)

  • Record of commenters, issues raised, must be kept


Opportunities for involvement

Opportunities for Involvement

  • Obtain copy of application

  • Request informal meeting with permitting agency

  • Review file and draft permit; submit comments

  • Request and participate in public hearing

  • Petition EPA to object to the permit if your concerns have not been met


Petitions to epa to object to a permit

Petitions to EPA to Object to a Permit

  • EPA must object to a permit if it is not in compliance with the requirements of title V

  • E.g., does not include all applicable requirements or does not assure compliance with applicable requirements

  • Anyone who commented on the permit can petition EPA to object to a permit

  • If EPA objects to the permit, permit cannot be issued

    • If permitting authority fails to revise the permit, EPA will issue or deny a permit


  • Different views on title v

    Different Views on Title V

    • Increases industry’s costs and risk of discovering (and having to report) violations

    • Some States

      • Welcome the extra monitoring and compliance

      • Think its just a bunch of paperwork

    • Environmentalists love the accountability, extra monitoring, better access to information


    Unique features of title v program

    Unique Features of Title V Program

    • Statement of Basis

    • Permit Shield

    • Periodic Monitoring

    • Petition to Object


    Websites that can be helpful

    Websites that can be helpful

    • Permits

      • Region 6 website on permits and their status

      • http://yosemite.epa.gov/r6/Apermit.nsf/AirLA?OpenView&Start=1&Count=4000&Expand=1#1

      • Louisiana DEQ Public Notice site

      • http://www3.deq.louisiana.gov/news/pubnotice/default.asp

      • http://www.deq.louisiana.gov/portal/ONLINESERVICES/CheckPermitStatus.aspx

    • Regulation

      • http://yosemite.epa.gov/opei/RuleGate.nsf


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