Environmental Permitting

Pre-Permit Checklist for Title V

It is important to make sure that all regulated air emissions are included in operating permits. If you are applying for a Title V permit use this checklist to make sure you’ve got everything.

Before You Apply (Y/N)

Does your facility fit under any of the categories that are required to obtain operating permits?

  • A major source? ___
  • Subject to New Source Performance Standard? ___
  • A nonmajor “area source” of hazardous air pollutants? ___
  • Regulated under acid rain provision? ___

If the facility does not fit into one of these categories, then you do not have to obtain an operating permit. ___

If the facility does fit into one of these categories, then have you identified the permitting agency—EPA, state, or local agency? ___

Have you received the proper application forms from all applicable agencies? ___

Have you determined when the application is due (e.g., within one year after becoming subject to Title V? ___

Have you formed a permitting “team” for gathering the necessary information for the application? ___

Have you decided who will be the “responsible official” for signing the permit and other certifications? ___

Does this person satisfy the definition of a “responsible official” in the regulation? ___

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For the Application (Y/N)

Have you included the following information in your permit application? (Various state forms may differ slightly.)

  • Company or plant name and address? ___
  • Owner’s name? ___
  • Names and telephone numbers of site managers and other facility contacts? ___
  • Description of pollutant source’s processes, products, and SIC code? ___
  • Description of:
      • All emissions for which the facility is a major source? ___
      • Regulated emissions for which the facility is not a major source? ___
      • All emissions points for regulated pollutants? ___
      • Emissions rate in TPY? ___
      • Fuel; fuel use; raw materials; production rates; operating schedules (only if required)? ___
      • Any air pollution control equipment and monitoring devices? ___
      • Work practice standards for limiting emissions? ___
      • Calculations that you used to determine emissions rates and other data? ___
  • All applicable air pollution control requirements, including reference to any applicable test methods? ___
  • Any regulated emissions for which the facility has been exempted? ___
  • Any “alternative operating scenarios” that you may anticipate? ___
  • Emissions requirements you have already complied with? ___
  • Emissions requirements taking effect during permit term that will be complied with on a “timely basis”? ___
  • How you will comply with existing requirements that you are not yet in compliance with? ___
  • A compliance schedule for meeting standards not yet reached? ___
  • A statement committing company to twice-a-year progress reports on complying with existing requirements not yet complied with? ___
  • Methods (monitoring, testing, inspections, etc.) to be used to determine compliance? ___
  • Schedule for submitting “compliance certifications” at least annually to regulatory agency? ___
  • Has the responsible official signed the following statement at the end of the application? ___

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 “Based on information and belief formed after reasonable inquiry, the statement and information in the document are true, accurate, and complete.”

Have you double-checked to make sure the permit application is complete?
(Contains answers to all required information requests.) ___

Have you made copies of the permit application? ___

Have you made sure to correct any inaccuracies or add “relevant facts” that were inadvertently left out of the permit application, as you are required to do by law? ___

Have you made note of the date the application was submitted? (If EPA or the state has not yet decided whether it is “complete” within 60 days, then it is deemed complete.) ___
Have you made a public notification, in a local newspaper, for example, of your application for a CAA operating permit? ___

After the application is deemed complete, have you responded promptly to any additional questions on it from the regulators?

See tomorrow’s Advisor for a checklist to help you conduct your business with a final operating permit.

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