Title V Operating Permits

Title V of the 1990 Federal Clean Air Act requires each state to develop a comprehensive operating permit program for major industrial sources of air pollution. The program clarifies the environmental obligations of a business by organizing, in 1 document, all of a business' air pollution control requirements.

The Title V Operating Permit Program does not require any tighter emissions standards; it does, however, place a greater responsibility on the business for monitoring, reporting and certifying compliance with the conditions of the permit.

Air Emissions Sources

As defined in the program, a major source of air emissions has the potential to emit 100 tons of any criteria pollutant. Or, for emitters of hazardous air pollutants, a major source has the potential to emit 10 tons of any single hazardous air pollutant or 25 tons of any combination of hazardous air pollutants. A major source can choose to limit its potential to emit through federally enforceable physical or operational restrictions on the facility and can remain in the ACDP program as what is known as a synthetic minor source. Approximately 18 sources are currently permitted under the LRAPA Title V Operating Permit Program.

What Is In a Title V Operating Permit?

The Title V Operating Permit organizes in a single document all the air requirements which apply to the permit holder. The operating permit follows the same structure and format as the current ACDP but contains greater detail. The operating permit begins with a list of permitted activities and describes all emission units and pollution control devices at the facility. Then the permit lists all of the emission limits and standards which apply to the facility. The next section of the permit describes methods of monitoring and record keeping to be used by the business to determine compliance with all applicable requirements.

Finally, the permit describes the methods to be used by the business for reporting and certifying compliance to LRAPA. In contrast, LRAPA’s ACDPs contain less detail in the identification of emission units. The ACDPs also typically do not list all applicable requirements, require less monitoring, and have less detailed record keeping and reporting requirements.

Additional Title V Operating Permit Resources