CAA Title V for Pulp & Paper Industry Facilities: The Reality vs. the Perception, 1997 Environmental Conference Proceedings
Since the Title V Operating Permit Program was mandated by the Clean Air Act Amendments in 1970, much has happened to affect the form and content of the required applications. USEPA has revised or proposed revisions to Part 70 and draft Part 75 regulations and has issued two key “White Papers” to clarify requirements for key program elements. Many states are still attempting to finalize their programs and obtain approval from USEPA.
This paper examines key aspects of the Title V permit application process relative to original expectations. It considers the nature and extent of information in applications and the resulting draft permits. The paper also suggests strategies for maximizing operating flexibility while minimizing noncompliance and enforcement exposure. It is hoped that this information will be helpful to facilities still in the process of negotiating their final Operating Permits.