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Where to find Information About Facilities

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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  1. Where to find Information About Facilities

  2. Overview of Title V Permits

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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)

  8. 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

  9. 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

  10. 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

  11. 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”

  12. How do Title V Permits Help Enforcement? • Reports and certifications alert permitting agency and public • Permit settles what requirements apply

  13. Public Availability of Records • Permit application (except confidential business information) • All reports and certifications • Draft and final permit • Correspondence

  14. 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

  15. 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

  16. 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

  17. 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

  18. Unique Features of Title V Program • Statement of Basis • Permit Shield • Periodic Monitoring • Petition to Object

  19. 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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