Issues Regarding NSR and Title V Permit Conditions

摘要

1. Title V permits have upped the stakes on all air permits, including New Source Review (NSR) 1.1 Some Title V permits not only consolidate all other air permit terms, but also add 1.1.1 Monitoring, reporting and record keeping requirements 1.1.2 Other terms the agency thinks are needed 1.1.3 Averaging times where none existed before 1.1.4 Increased testing 1.1.5 Revised terms that the agency considers 'more enforceable' 2. Meanwhile, New Source Review (NSR) permits are including more unauthorized conditions and requirements 3. More chances of violations due to 3.1 Additional conditions 3.1.1 Emission limits 3.1.2 Monitoring requirements 3.1.3 Reporting and record keeping requirements 3.2 More stringent conditions, including shorter averaging times 3.3 More frequent testing.