Transcript Where to find Information About Facilities Overview of Title V Permits.

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
• Purpose of Title V permit: accountability, improved compliance and
enforcement
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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
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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
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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
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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)
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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
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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
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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
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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”
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How do Title V Permits Help Enforcement?
• Reports and certifications alert permitting agency and public
• Permit settles what requirements apply
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Public Availability of Records
• Permit application (except confidential business information)
• All reports and certifications
• Draft and final permit
• Correspondence
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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
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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
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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
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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
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Unique Features of Title V Program
• Statement of Basis
• Permit Shield
• Periodic Monitoring
• Petition to Object
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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=4
000&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.as
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• Regulation
• http://yosemite.epa.gov/opei/RuleGate.nsf