Pollution sources operating permits

Initially, all major sources of air pollution are required to obtain an operating permit. However, any state permitting authority may extend the apphcability of the operating permit to minor sources as... 

Title V requires that all major sources (and certain minor sources) obtain an operating permit. Many pulp and paper mills are required to have a Title V permit, and may be required to submit information about emissions control devices and the general process at the facility in the permit application. Permits may limit pollutant emissions and impose monitoring record keeping and reporting requirements. 

The CAA requires major stationary sources to install pollution control equipment and to meet specific emissions limitations. In addition, the 1990 CAA amendments required major stationary sources to obtain operating permits. Examples of stationary sources include manufacturers, processors, refiners, and utilities. 

One of the provisions of the 1970 Qean Air Act initiated the requirement for air pollution sources to obtain a permit for construction of the source and a permit to operate it. The construction permit apphcation must be completed prior to the initiation of construction of any air pollution source. Failure to do so could result in a 25,000 per day fine. In some states, initiation of construction was interpreted as issuance of a purchase order for a piece of equipment in others, groundbreaking for the new construction. Therefore, to ensure compliance with the air permit requirement, this author suggests that completion of the air permit be given first priority in any project involving air emissions into the atmosphere. The best practice is to have the state-approved permit in hand before beginning construction. Most states have their permit forms on the Internet, and a hard copy can be downloaded. Alternatively, the permit forms can be filled out electronically and submitted. 

Operating permits are legally enforceable documents that permitting authorities issue to air pollution sources after the source has begun to operate. Most large sources and some smaller sources of air pollution are required to obtain a Title V permit which comes from Title V of the Clean Air Act as amended in 1990. Most title V permits are issued by state and local permitting authorities. Permits include pollution-control requirements from... 

The primary benefit to the public is that air permits limit the amount of air pollution allowed at a stationary source. For operating permits (Title V permits), a major source owner/operator is required to compile all applicable air pollution requirements at their source for purposes of obtaining one comprehensive permit (Title V permit). This process also includes public review of the proposed operating permit. Permits... 

The Title V permitting program, or operating permits, clarifies the pollution control requirements a source must meet. The permit program ensures that all of a source s obligations with respect to its pollutants will be contained in one permit document. The permit also spells out a source s monitoring and reporting requirements to the state and EPA. 

Operating permits are issued to all major sources and a limited number of area sources. The permit stipulates how much of and what types of pollutants a source is allowed to emit. As a part of the permit process, a source must prepare a compliance plan and certify compliance. Each permit issued to a facility will be for a fixed term of up to five years and will include a fee to cover reasonable direct and indirect costs of the permitting program. 

When an industrial operation is subject to the permit program as a major source for any one pollutant, all potential emissions of every regulated pollutant at the facility must be addressed in the permit application. The following section outlines the minimum operating permit program elements. 

Does facility have any operation, i.e., air pollution source(s), which requires a permit ... 

Sources Subject to Prevention of Significant Deterioration (PSD) Sources subject to PSD regulations (40 CFR, Sec. 52.21, Aug. 7, 1980) are major stationary sources and major modifications located in attainment areas and unclassified areas. A major stationaiy source was defined as any source hsted in Table 25-4 with the potential to emit 100 tons per year or more of any pollutant regulated under the Clean Air Act (CAA) or any other source with the potential to emit 250 tons per year or more of any CAA pollutant. The potential to emit is defined as the maximum capacity to emit the pollutant under apphcable emission standards and permit conditions (after apphcation of any air pollution control equipment) excluding secondaiy emissions. A major modification is defined as any physical or operational change of a major stationaiy source producing a significant net emissions increase of any CAA pollutant (see Table 25-5). 

Ohmic heating of catalyst is often used as a simple method of igniting the chemical reaction during reactor startup, for instance, in the oxidation of ammonia on platinum-rhodium gauze catalysts. Another application is the prevention of cold-start emissions from automotive catalysts responsible for much of the residual pollution still produced from this source (21). The startup times needed for the catalyst to attain its operating temperature can be cut by a factor of 5 or more by installing an electrically heated catalyst element with a metallic support upstream of the main catalyst unit. Direct electrical catalyst heating permits facile temperature control but requires a well-defined catalyst structure to function effectively. 

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