Reviewing Title V Operating Permits (CAA)

19 May 2020

The Title V Operating Permit program was mandated as part of the Clean Air Act Amendments (CAAA) of 1990.  The name “Title V” was established because the operating permit program was outlined in the fifth title of the 1990 CAAA.  Congress intended the Title V Operating Permit program to be a means for consolidating all permit requirements under one facility-wide operating permit.  This Title V Operating Permit would include applicable federal rules, state rules that were approved by a State Implementation Plan (SIP), and other conditions that resulted from the air quality permitting process.  This approach provides the facility, the regulatory agency, and the general public with a single resource for reviewing conditions that apply to a facility and for assessing its compliance with those conditions.

Title V Operating Permit program regulations can be found in 40 CFR Parts 70 and 71, where 40 CFR Part 70 is implemented by each individual state via its State Implementation Plan (SIP), and 40 CFR Part 71 is implemented by U.S. EPA.  Title V Operating Permits take time before they are effective and they must be renewed through the submittal of a Title V Operating Permit renewal application.  This application, as well as semiannual deviation reports, annual certification reports, and other submittals, must be certified by the designated Responsible Official as to the truth, accuracy, and completeness.  Title V Operating Permits may be changed through major modifications, minor modifications, and administrative updates.  They may also be revised to a certain extent during the renewal process, which is generally a good opportunity to review and streamline conditions.

Learn the several ways a facility may become subject to the Title V Operating Permit program, including its level of emissions, applicable regulations, and/or construction permitting requirements, and more at ALL4’s Air Quality 101 (AQ101) Training**.

Once subject to the Title V Operating Permit program, 40 CFR Part 64 establishes Compliance Assurance Monitoring (CAM) requirements for Title V facilities, which is intended to ensure that air pollution control devices are properly operated by continuously monitoring parameters.  This requirement has several applicability criteria and exemptions to consider.

By Lindsey Kroos, Technical Manager, ALL4 

**ALL4’s Air Quality 101 (AQ101) Training is a 12-session, webinar-based course covering the Clean Air Act and its various regulatory programs.  Originally designed to educate environmental consultants as they joined the ALL4 team, it was requested by clients to further their understanding of compliance and permitting at their facilities.  ALL4 has trained environmental professionals of the regulated community throughout the country and expanded their knowledge of regulatory programs that impact industrial operations.