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Title V Operating Permits

Just about every facility has a Title V Operating Permit or Renewable Operating Permit (ROP).  Even a facility with a permit exemption often has a letter that explains exemption status on file with the local air management agency.

Since issuance in the late 1990s permit contents have evolved. In a single document, a permit lists all emission sources (major or minor sources) at a given facility, plus any emission limits or standards, operating restrictions, work practice standards, or any other significant requirements.

For each source, the permit lists each pollutant of concern, the pollution control devices installed to control that pollutant, and how the facility can demonstrate that it is following the permit terms and conditions. If a source on site is exempt from using one of the demonstration methods listed below, the permit will still list the source but state that it is exempt.

Methods for Demonstrating Compliance

There are several different methods for demonstrating compliance, including:
  • Continuous Emission Monitoring Systems (CEMS), such as a NOx or opacity monitor,
  • Continuous Parameter Monitoring Systems (CPMS), such as temperature, or water flow, etc.
  • Fuel sampling and analysis,
  • Periodic emissions testing, or
  • Simple record-keeping on existing operating conditions, such as the local weather conditions.
When a permit is issued, it states the day of issuance and the expiration. Approximately every five (5) years, permits need to be renewed and updated. Renewal applications must be submitted no earlier than eighteen (18) months before the expiration date but no later than six (6) months before the expiration date.

New Permits

Review a newly issued permit with care.  Focus on new or revised terms and conditions.  Occasionally, existing conditions are deleted or dropped. In many cases, you may need to incorporate the changes into your existing operating procedures or practices.

Keep Your Quality Assurance Quality Control (QAQC) Plans Updated

It is essential to keep your QA/QC plan up-to-date because it describes the steps and actions the facility must take to follow the conditions of the permit. The plan serves as a the cornerstone for field audits conducted by local air quality agency or the EPA. An auditor will use the plan and verify whether or not employees at your facility know and understand the commitments it contains. 

Keeping the QAQC plan up-to-date is increasingly essential. Many states now include the plan on file with the air permits. The QA/QC plans are open to the public for review and comment. Third parties can access the plan and second guess the plant’s operation.

ESC Spectrum can assist you with a permit or QA/QC plan review, and make sure that your StackVision DAS is in alignment with those plans.

For questions, suggestions, or for a general chat, do not hesitate to contact me.

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Jon Konings

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