Problems and Solutions to Title V Emission Inventories, 1995 Environmental Conference Proceedings

Under Title V of the Clean Air Act Amendments of 1990 (CAAA), most pulp and paper mills throughout the U.S. are required to submit comprehensive permit applications covering most emission sources within each mill. The final due date of this operating permit application varies considerably from state to state. Some states, like Minnesota, called for permit applications last fall. Most deadlines will come within the next year. Lessons learned from the first set of application submittals will save mills considerable time and effort in preparing their own applications. The backbone of a Title V permit application is a comprehensive air emission inventory that comprises all regulated pollutants for all emission sources. Based on our experience, many problems may arise in preparing the Title V emission inventory because many formerly unpermitted emission units must be included. This paper will identify and provide recommendations for the following issues: determination of insignificant activities that can be excluded from the inventory; location of emission factor resources; development of emission calculations in light of monitoring requirements and operational flexibility; and determination of calculation methods for non-conventional sources.