Implications of Title V for Corrugated Container Facilities, 1997 Environmental Conference Proceedings

Title V of the Clean Air Act of 1990 requires major sources of air emissions to apply for and obtain a federally enforceable operating permit. Major sources are defined as any facility with the potential to emit (PTE) greater than 100 TPY of criteria pollutants, 10 TPY of any single hazardous air pollutants (HAPS), or 2.5 TPY of the combination of all HAPS. The PTE for a facility must be based on maximum capacity at 8,760 hr/yr, unless the facility has imposed federally enforceable limits on operating hours, fuels and/or raw materials which limit the PTE. Georgia-Pacific Corporation (G-P) operates approximately 40 box plants located in 22 states throughout the U.S. KBN Engineering and Applied Sciences was contracted to perform emission inventories for each facility, evaluate Title V applicability, and to obtain Title V permits where necessary. Where feasible, a federally enforceable synthetic minor operating permit (FESOP) or classification as a natural minor source was obtained. This paper will review the applicable Title V regulations, and the EPA and state policies on FESOPs and natural minor sources. Differences in regulations and policies between the various states will be discussed. Approaches used in preparing FESOP applications for the various facilities, describing methods of escaping Title V, will be presented. Types of limitations (i.e., fuel usage, hours of operation, raw material usage) proposed by the permittee and permit conditions imposed by the agencies, including monitoring, record keeping and reporting requirements, are summarized. Also, approaches and methodologies used in requesting natural minor status are presented.