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Title V Permits - FAQs

Who Obtains a Title V Operating Permit?

  • Major sources defined as a source with the potential to emit (PTE):
  • PTE>100 tpy of any criteria pollutant or
  • PTE>10 tpy of any individual hazardous air pollutant (HAP) or
  • PTE>25 tpy of combined HAPs

WHAT IS A TITLE V OPERATING PERMIT?

  • Permits consolidate all air quality regulatory requirements
  • Permits incorporate existing conditions for a facility and establish a compliance demonstration, recordkeeping and reporting requirement for the existing conditions that do not already have an existing compliance demonstration, recordkeeping and reporting requirement
  • Permits take no less than 110 days to become effective
  • Permits are issued draft for a 30 day public comment period
  • Permits are issued proposed for a 45 day EPA review period
  • Permits are issued as Date of Decision for the 30 day appeal period to the Montana Board of Environmental Review
  • Permits are then final and effective in the State of Montana
  • EPA has an appeal period of 60 days beginning at the end of EPA’s 45 day
  • Permits are renewed every five years

WHAT TITLE V OPERATING PERMITS ARE NOT.

  • Permits do not and can not add new emission limitations
  • Permits do not and can not change existing emission limitations
  • Determinations made in the preconstruction permit process are not up for re-approval during the operating permit process
  • National ambient air quality standards (NAAQS) are not considered applicable requirements in the operating permits