Off-Permit Changes |
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| Off-Permit changes are those changes which are not addressed or prohibited by the Title V Permit. There are many changes that a source may make that are already allowed by a Title V permit. For example, a Title V permit may allow for the production of "dimensional lumber." If a facility switches from making 2x4's to 1x6's, they are still making dimensional lumber. Another example is a boiler which normally burns 50% natural gas and 50% fuel oil. If the boiler is permitted to burn either natural gas or fuel oil without any limit on either fuel, then the boiler could be switched to burn either fuel, singly or combined in any way without being considered a change under Title V.
If the requested change results in an increase in emissions of a regulated pollutant from a non-regulated source, no notification or record keeping is required for the modification. For example, increasing the VOC emissions from a small process not subject to a VOC rule would not trigger any permit requirements unless it surpassed the VOC threshold for that type of process or the VOC PSD significance level for that facility. Georgia Rule (e) is an applicable requirement for many sources of particulate matter; Rule (n) is an applicable requirement for all sources of fugitive particulate matter; Rule (d) regulates all boilers, and Rule (g) regulates all equipment that burns fuel. These rules have no lower source thresholds. If the change in emissions involves toxics, a review of the change under the toxic guideline should be done, if necessary. The outcome of the toxic guideline review may change the way the permit is processed (i.e. the outcome of the toxic guideline review could determine what type of permit modification is required). Therefore, if it is required, the toxic guideline review should be performed early in the application review process. If the change involves an emission unit or activity which appears on the "Trivial List" contained in the Title V instructions, the company does not need to keep records of the change. If the change involves an emission unit or activity listed on the exemptions list or on the "Insignificant Activities List," 391-3-1-.03(10)(g), the company must keep records describing the change and the emissions resulting from the change. If the change is exempt from permitting under 391-3-1-.03(6), but is NOT on the insignificant activities or trivial list, the company must notify both EPD and EPA of the change. Note that the exemptions list and the insignificant activities list are very similar. The main differences are that "Combustion Equipment" under (6)(b)1, 2, and 3 and the "Cumulative modifications" under (6)(i)3 of the exemptions list are not part of the insignificant activities list. There are also a few other differences between the exemptions list and the insignificant activities list. |
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