Back to EEI's Home PageTitle V Emission Studies / Permitting
The passage of the Clean Air Act Amendments of 1990 (CAAA 1990) has brought the need for detailed studies of annual air emissions. Title V is the permitting portion of these Amendments. Air emissions under Title V are not limited strictly to permitted sources but to any process that produces an air pollutant. These new regulations monitor the actual and potential emissions of the 189 listed Hazardous Air Pollutants (HAPs) (under Title III) and the six priority pollutants, which include:
Any facility that exceeds a potential to emit of 100 tons per year (tpy) of any priority pollutant, 10 tpy of any single hazardous air pollutant, or 25 tpy of any combination of hazardous air pollutant, is subject to Title V. Fugitive emission sources are also part of the facility-wide emissions. A facility which chooses to operate under Title V will "pay to pollute" through a Title V Operating Permit, meaning for every ton of pollutant actually emitted, a dollar fee will be assessed. As a major source, enhanced monitoring and additional record-keeping will also be required. Conversely, a Synthetic Minor Permit can be devised to lower potentials to emit by setting self imposed operating restrictions to eliminate major source status.
Facilities are required by EPA to report potential and actual emissions for the last half of 1993, the full year of 1994, and then every two years. Failure to do so could result with enforcement actions.
To assist in Title V compliance, Envisage Environmental, Inc. will provide the following:
There are few exceptions when an air pollution source does not require a Permit to Install (PTI) and a Permit to Operate (PTO). If your facility has an air pollution source, then it should at least be on registration status with the local regulatory authority. Also, if your facility is going to install a new operation that will act as an air pollution source, a PTI needs to be filed by the local regulatory agency prior to construction/installation. Once this is complete, a PTO will be issued describing terms and conditions for the operation of this air pollutant source. Also, having up-to-date permits is an important component to being in compliance with Title V.
Envisage Environmental, Inc. has over 25 years of experience in air compliance issues, from stack testing to air pollution modeling. If you have an air pollution source that could require permitting, contact us at envisage-env@envisage-env.com or call us at 1-800-878-0990 for professional assistance.