The Clean Air Act (CAA) is a comprehensive federal law that regulates air emissions from stationary and mobile sources. The Act calls for states and EPA to solve multiple air pollution problems through programs based on the latest science and technology information. One of these programs are air emission point operating permits. There are generally three (3) different operating permit categories of air pollution sources, such as the following:
- Title V Source
- Synthetic Minor or Federally Enforceable (Limiting) Source
- Minor Source (varies from state to state)
What are the different types of operating permits?
The three most common air operating permits are the Title V Operating Permit (TVOP) for major air emitting sources, Synthetic Minor Operating Permit (SMOP) or Federally Enforceable State Operating Permit (FESOP) for sources that want to limit emissions and avoid Title V status, and the Minor Operating Permits (some states have multiple minor source permits). Types of permits may vary from state to state.
Who is required to obtain an operating permit?
When determining whether a facility needs a permit, potential uncontrolled emissions are typically used. Potential emissions or potential to emit (PTE) are generally calculated based on around the clock operation at maximum capacity with some limited exceptions. Actual emissions are what is actually being emitted, and takes into account lower usages, less operating time, etc. For more details on types of pollutants and pollutant producing equipment, see Air Emission Inventories.
The following emission source thresholds are guidelies for evaluating operating permit options and requirements:
Title V Source: Criteria Pollutants: PTE and Actual Emissions > 100 tons per year (tpy)
Individual Hazardous Air Pollutants (HAPs): PTE and Actual Emissions > 10 tpy
Total HAPs: PTE and Actual Emissions > 25 tpy
SMOP/FESOP: Criteria Pollutants: PTE > 100 tpy and Actual Emissions < 100 tpy
Individual HAPs: PTE > 10 tpy and Actual Emissions < 10 tpy
Total HAPs: PTE > 25 tpy and Actual Emissions < 25 tpy
Minor Source: Criteria Pollutants: PTE < 100 tpy and Actual Emissions < 100 tpy
Individual HAPs: PTE < 10 tpy and Actual Emissions < 10 tpy
Total HAPs: PTE < 25 tpy and Actual Emissions < 25 tpy
If the facility PTE and actual emissions exceed the 100 tpy/10 tpy/25 tpy thresholds, they are required to obtain a Title V Operating Permit. If only the facility PTE emission exceed the above thresholds, and the site can maintain or limit emissions below the thresholds, a SMOP/FESOP is an option. If PTE is less than the thresholds, the state may require a Minor Source Operating Permit. Also, be aware that some states may have additional threshold limits to consider.
What are some requirements of the operating permit?
Requirements set forth by a state issued air operating permit vary depending on the facilities processes, equipment and chemical or materials used, and expected emissions. See the following list for typical requirements of a Title V Operating Permit:
- Opacity limits
- Reporting – Annual, semi-annual, or quarterly reports
- Monitoring – Calculate actual emissions monthly based on usages, inspect pollution control equipment, etc.
- Emission Limits – 249.0 tpy of VOC, 24.9 tpy of total HAPs, etc.
For questions about Air Operating Permits, contact Environmental Compliance & Safety at:
- Phone: (662) 840 5945
- Website: https://envirocomp.net/contact/
