By Timothy P. Fagan, BLR Air Expert
tfagan@blr.com

Determining if a source is a major source will have significant impacts on the work and time needed to complete the permitting process, because major sources will be required to comply with New Source Review (NSR) and Title V, instead of minor source permit requirements.  Adding to the complexity of the major source determination is the fact the definition changes depending on the permitting program.

In Air Permitting Training: Defining a Major Source (Part 1) the major source criteria for nonattainment NSR and PSD was defined.  Today will cover what constitutes a major source for Title V operating permits.

Title V
Title V operating permits are required for major sources in both attainment and nonattainment areas.  In general, a major source under Title V is a source that has the potential to emit (PTE) 100 tons per year (tpy) or more of any pollutant subject to regulation. Sources that are major for VOCs are considered major sources for ozone.

However, the general rule does not apply in all instances. As is the case with nonattainment NSR, ozone, CO, and PM-10 have subcategories that lower the emissions threshold below 100 tpy because of the severity of the nonattainment classification. In addition, greenhouse gases (GHG) are considered “pollutants subject to regulation” but only if a source has the potential to emit at least 100,000 tpy of carbon dioxide equivalents (CO2e) .

Fugitive emissions are not to be included when making a major source determination unless the source is among those specifically listed to include such emissions.

A major source under Title V may also be a source that has the potential to emit 10 tpy of a single hazardous air pollutant or a combination of HAPs equaling or exceeding 25 tpy.  EPA may established regulations requiring Title V permits for sources emitting HAPs in lesser quantities if deemed necessary.

Additional Resources:

• Guidance on Major Source Determination for Certain Hazardous Air Pollutants
• No Change Proposed to GHG Thresholds
• What is Title V?

Feedback: I’d like to do a series of posts on air permit training. Leave a comment or send me an e-mail and tell me what training topics are most important to you.

Timothy P. Fagan is a Legal Editor for BLR’s environmental publications, focusing primarily on air quality related topics. Mr. Fagan has covered environmental developments with BLR since 2000. Before joining BLR, he spent 5 years in environmental consulting and was responsible for air quality permitting and compliance for a broad range of industries in both the private and public sector. He received a Bachelor of Science degree in chemical engineering from Villanova University and a Master’s degree in environmental engineering from the Pennsylvania State University.

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