Title V Operating Permit Renewal

Many U.S. manufacturing facilities are in the process of renewing their Title V Operating Permits (as required by the 1990 Clean Air Act). The renewal process is an excellent time to evaluate your current permit and determine what changes to make for the permit renewal. Some things to consider during this process include the following:

• Is the list of air pollution emission sources included in your current permit representative of current operations?

• Do you anticipate any equipment modifications or additions in the near future?

• Are any of the current permit conditions overly restrictive?

• Have you submitted any permit modification applications to the state agency in the recent past?

• Are there any new or proposed state or federal air pollution regulations that apply to your operations?

One significant example of new air pollution regulations are the National Emission Standards for Hazardous Air Pollutants (NESHAP), also known as MACT standards (Maximum Achievable Control Technology). NESHAP regulations have been issued for various industries and may affect your Title V renewal. If you have older operations, there may be minimal impact. However, if you have new sources in operation, or planned, you may have to make some changes in your raw materials, processes, process controls and/or air pollution controls. Among the latest MACT standards are the following:

Environmental and Engineering Solutions, Inc. (EES) has the expertise to help you sort through the requirements of the recent standards, and help keep your company compliant. We offer a wide range of consulting services such as site surveys, emissions inventories, and Title V permitting. We can also help you select the best controls for your operations.

Standard	Effective Date	Compliance Date
Boilers and Process Heaters	September 13, 2004	September 13, 2007
Reciprocating Internal Combustion Engines	June 15, 2004	June 15, 2007
Plastic Parts Coating	April 19, 2004	April 19, 2007
Iron and Steel Foundries	April 22, 2004	April 22, 2007
Surface Coating of Auto and Light Duty Trucks	April 26, 2004	April 26, 2007
Stationary Combustion Turbines	March 5, 2004	March 5, 2007
Organic Liquids Distribution	February 3, 2004	February 3, 2007
Miscellaneous Metal Parts and Products	January 2, 2004	January 2, 2007

Further information on the various MACT standards may be obtained at: http://www.epa.gov/ttn/atw/mactfnlalph.html