Veteran Owned Small Business
Q:What is the Major Source under the Title V program?
A:A Major Source is defined as any stationary facility or source of air pollutants which directly emits, or has the potential to emit, 100 tons per year (TPY) or more of any pollutant, including any major emitting facility or source of fugitive emissions, as determined by rule by the administrator. Notably, consideration of fugitive emissions is essential in Major Source determination.
Q:What is meant by contiguous property and how does it apply to permitting?
A:In order to determine if a Major Source exists, commonly owned or controlled pollutant-emitting activities on contiguous or adjacent properties that are within the same two-digit Standard Industrial Classification (SIC) code must be aggregated. The EPA defines contiguous as: “The definition of contiguous has the same meaning and application as under the PSD regulations and, in general, means properties that are touching or have a common edge or boundary.”
Q:What is “potential to emit”?
A:Is a source considered a “Major Source” if it does not actually emit air pollutants in quantities above the Major Source thresholds but has the potential to emit above those levels?

Yes. “The 1990 amendments to the Clear Air Act (CAA), including the Title V Operating Permit’s program, have made source status as a ‘major’ stationary source of considerably greater relevance to air quality programs. The lower Major Source thresholds now included in the Act has made an unprecedented number of sources ‘Major’.” Many of these sources are actually emitting air pollutants in amounts less than the major thresholds but are major on the basis of their potential to emit. Certain categories of these sources are comprised of sources that are in fact rather small and, in some cases, are not addressed in detail by state air quality programs. Examples include: auto body shops, dry cleaners, printers, and surface coaters.

Q:In determining whether a source is a Major Source, facilities need to determine their “potential to emit.” Is a source’s potential to emit determined with or without consideration of control equipment?
A:Only control equipment and limits on operations, hours, fuel usage, etc., that is federally enforceable limits and/or requirements may be considered in determining a source’s potential to emit.
Q:Can a source voluntarily restrict its potential to emit levels below the Major Source threshold in order to avoid Title V permitting requirements?
A:Assuming the permitting authority exempts non-Major Sources, the requirement for a Title V permit would not apply to a source with federally enforceable restrictions that limit its potential to emit to below the levels of a Major Source. However, a source that restricts its potential to emit in a Title V permit is still subject to Title V. The permitted facility is then known as a Synthetic Minor Source.



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