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Clean Air Act Amendments of 1990
Title V – Operating Permits
The Clean Air Act Amendments (CAAA) of 1990 initiated the Federally
Enforceable Operating Permit Programs as Title V of the Act. Facilities
over the threshold limits for NOx, VOC, PM10, CO, and SO2 are designated
as "Major" and must submit a Title V application package
by specified deadlines. After obtaining Title V permit, facilities
are required to submit annual & Semi-Annual Compliance certification
to the EPA and local agency.
The steps required for preparing Title V application packages include
the following:
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Air audit to inventory facility information
and process the data necessary to characterize emissions from
the facility and prepare facility’s Emissions Inventory
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Calculation of the facility’s Potential
to Emit (PTE) for the criteria (NOx, VOC, PM10, SOx, and CO)
and Toxic Pollutants
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Comparison of PTE against the threshold levels
for major source classification under Title V program
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Emission estimation using various techniques
involving maximum process raw-material flow rates entering
each basic process level and using process rate emission factors
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Comparison of the associated emissions with
Title V threshold limits to determine Title V applicability
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Performing compliance assessment of sources
as related to Title V requirements and providing assistance
in correcting compliance deficiencies
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Evaluating future operational considerations
and applicability of Continuous Compliance Monitoring requirements
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Updating existing permit facility information
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Preparing the final Title V Operating Permit
Application or Synthetic Minor Application for submittal to
the regulatory agencies
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This approach, along with AQMS experience with various
industries and regulatory issues, provides facilities with improved
permit conditions, better data management, and cost savings associated
with enhanced engineering processes.
AQMS staff has obtained Title-V permits for many of
industries throughout the states. For more information please contact
us.
Title III – Air Toxics and
MACT requirements
Maximum Achievable Control Technology (MACT) is the term commonly
used to describe the standard mandated by Section 112 of the Clean
Air Act.
EPA is required to list source categories of
major Hazardous Air Pollution (HAP) and develop MACT standards for
the May 15, 2002 was the application deadline for the major sources
of HAPs subject to the requirements of section 112 j, known as MACT
hammer.
If a MACT standard is not published for a specific
source category by May 15, 2002, affected facilities have two options:
- Prepare and submit a new Title-V Permit application
- Modify and submit an amendment to an existing Title-V Permit
If your facility has a source for which a MACT standard
has not been adopted, and your facility is a major source for HAPs,
you will be required to comply with the above requirement. For more
information about applicable MACT standards, please contact us.
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