Proposal:

Technical Guidance Document for Regulation XXX - Title V Permits

Synopsis:

AQMD’s federally mandated Title V Operating Permit Program is expected to receive interim approval from EPA in January 1997. Facilities subject to Title V are required to begin applying for a permit within the first year of program implementation. To assist these facilities during this process, AQMD staff has prepared application forms and a Technical Guidance Document (TGD) that will provide simple instruction and clarification on compliance with Title V. The TGD will be updated as needed to respond to program changes and the needs of regulated facilities.

Committee:

Stationary Source, December 5, 1996, reviewed.

Recommendec Action:

Receive and file the attached TGD.

James M. Lents, Ph.D.
Executive Officer

Background

Title V of the 1990 amendments to the federal Clean Air Act (CAA) requires EPA to establish a national operating permit program. In 1992 EPA published regulations requiring AQMD and other districts to develop an operating permit program that complies with the federal regulations, submit the program to EPA for approval, and upon EPA approval, implement the program. AQMD will begin implementing its Title V program upon receiving EPA interim approval, which is expected in January 1997. Once EPA grants interim approval, AQMD must issue Title V permits to one-third of the affected facilities each year for the three years following interim approval. Facilities subject to Title V must apply for and obtain a Title V permit, and comply with specific Title V procedures to modify their permit in the future. Title V does not include any new requirements for further reduction of emissions, but it includes new permitting, monitoring, reporting, recordkeeping, public review, and EPA review requirements.

To introduce the Title V program and help facility owners and operators understand how to apply for and maintain compliance with Title V, AQMD originally prepared a draft TGD on July 21, 1995. This July 1995 draft version of the TGD was subsequently rewritten and reformatted to reflect changes to the Title V program and to make the TGD more user-friendly in providing Title V facilities with guidance in implementing this new program. Since that time, AQMD staff has completed the following:

• Released a new draft of the TGD for public review on May 24, 1996. The May 1996 draft TGD is now divided into two volumes. Volume I - Implementation Guidance, introduces the Title V program and discusses the program applicability, permitting and public participation processes, and compliance requirements. Volume II - Title V Application Package, contains information to guide Title V facilities in preparing the standard application forms needed to apply for the different Title V application action types as required by Regulation XXX;

• Held two public meetings to highlight the important components in the May 1996 draft TGD. The Title V Working Group and Public Consultation Meetings were held on May 30, 1996 and June 5, 1996, respectively;

• Extended the public comment period to June 28, 1996 from the original June 19, 1996 deadline to allow facility owners and operators time to review the document and thus ensure it met their needs in providing guidance on Title V;

• Received over 100 comments on the May 1996 draft TGD;

• Revised the TGD to address the comments received; and

• Compiled a list of all the comments and provided responses to the comments.

TGD Objective

The final November 1996 TGD will assist facilities in answering the following general questions:

• How does a facility determine if Title V applies?
• What is a Title V permit?
• How does a facility apply for and obtain a Title V permit?
• What forms are needed to apply for and obtain a Title V permit?
• How does a facility revise its Title V permit if there is a change at the facility?
• What does a facility need to do to demonstrate compliance with Title V?

Since the TGD is a "living" document, AQMD will periodically update this document in response to new information or changes in the Title V program. The next scheduled update for the TGD is March 1997 when the TGD will be updated to reflect proposed amendments to Regulation XXX which are scheduled to be considered by the AQMD Governing Board at that time.

Attachments

Technical Guidance Document, Volumes I & II