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Air Permitting Services     EMS and Compliance Audits  
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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:

 

Air audit to inventory facility information and process the data necessary to characterize emissions from the facility and prepare facility’s Emissions Inventory
 

Calculation of the facility’s Potential to Emit (PTE) for the criteria (NOx, VOC, PM10, SOx, and CO) and Toxic Pollutants
 

Comparison of PTE against the threshold levels for major source classification under Title V program
 

Emission estimation using various techniques involving maximum process raw-material flow rates entering each basic process level and using process rate emission factors
 

Comparison of the associated emissions with Title V threshold limits to determine Title V applicability
 

Performing compliance assessment of sources as related to Title V requirements and providing assistance in correcting compliance deficiencies
 

Evaluating future operational considerations and applicability of Continuous Compliance Monitoring requirements
 

Updating existing permit facility information
 

Preparing the final Title V Operating Permit Application or Synthetic Minor Application for submittal to the regulatory agencies
 

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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