Has Operating Permitting Really Changed with Title V? Reflecting on the Title V Operating Permit Program

摘要

Now that some state regulatory agencies are reviewing Title V permit applications and issuing permits, evaluation of the process can be made in comparison with the original goals of the Title V permitting program. In addition, assessment of the terms and conditions that are being incorporated into permits, the nature of draft permits that are issued to facilities for comment, and the extent and type of negotiation that has been conducted with agencies to develop successful Title V permits, will be helpful for facilities that are currently undergoing application review. In working with a Fortune 500 surface coating company, fourteen Title V permit applications were developed and submitted for plants located in Maryland, Pennsylvania, Ohio. New Jersey, Illinois. Georgia, West Virginia, Wisconsin, Indiana and southern California. Draft permits have been issued for several of the plants, and differences in the terms and conditions, testing requirements, and permit format and structure have been noted between states. One of the issued permits required modification, and the process was one of the first for this stale agency. This paper will provide a review of the application review process, draft permit negotiation, and permit modifications required for this company's facilities to provide insight into the Title V permitting process. Specific emphasis will be provided on hazardous air pollutant issues, visible emission provisions, compliance monitoring, and permit structure that will provide insight into the Title V program in several states for both regulated sources and permitting agencies.