Determining Enforceablility of Air Quality Requirements for the Title V Permit, 1997 Environmental Conference Proceedings
The focus of this paper is two-fold:
1. Outline the importance, from the perspective of the regulated source, of the identification of state-only enforceable requirements versus federally enforceable requirements in a Title V permit;
2. Describe how to determine the enforceability of requirements as part of a Title V permitting study, including available tools.
Contained also in this paper is a case study of enforceability determinations of requirements included in the Title V permit for an integrated pulp and paper mill. The case study is presented to provide an impetus for sources to thoroughly review their draft Title V permits to ensure correct determinations of enforceability.