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Title V Operating Permits, U.S. Clean Air Act Amendments

Last updated by ess-home on 9/16/2008

U.S. Environmental Protection Agency (EPA) - United States

Title V is a program of the United States Clean Air Act Amendments (CAAA) that makes regulators and operators assimilate in one document all of the requirements to which a facility is subject, known as an Operating Permit. Although Title V was supposed to be a "wrapper" program that did not introduce more requirements, many permit holders have expressed that there is a substantial additional compliance burden, since the program places the burden on the owner/operator and companies to have records proving compliance.

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Management System & Data Management Implications

Title V Operating Permit compliance can have significant implications for large industrial facilities. A single facility can have anywhere from 1000 to 100,000 requirements applicable to its various processing units and emission sources.

To effectively demonstrate compliance with these requirements, a data management system can be useful:

  • Data from existing plant software systems can be used to demonstrate compliance with numeric (including calculated) limits
  • Tasks can be assigned and tracked to completion, including those issued thru an existing computerized maintenance management system (CMMS)
  • Compliance with multiple requirements can be documented by completing a single task. For example, there are many regulations requiring that tank inspections be done, yet those could be satisfied by a single inspection

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Fast Facts

Jurisdiction United States plus territories
Applicability All facilities that qualify as being "major" sources of emissions.
Regulatory Driver Title V of the Clean Air Act, as amended in 1990
Promulgating Entity U.S. EPA
Enforcing Entity Most title V permits are issued by State and local permitting authorities.
Entity Summary http://www.epa.gov/oar/oaqps/permits/
Regulatory Text http://www.epa.gov/air/caa/title5.html
Regulatory Submissions Required Facilities are required to annually certify compliance with all applicable requirements and report any compliance deviations every six months. Specific formats vary with Enforcing Authority.

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More Information

For details about how the IHS solutions can help your organization comply with Title V, call 800.289.6116 or email us.

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