Title V Air Program Support

Under the Clean Air Act, a facility that has the potential to emit more than specified thresholds of hazardous air pollutants is defined as a major source of air emissions and is required to obtain a Title V operating permit. A federal agency needed help with evaluating the regulatory requirements for its numerous air emissions sources (including emergency generators, boilers, and paint booths) and, subsequently, with applying for and complying with a Title V permit.

ERG has provided ongoing environmental compliance support to this federal agency since 2010. Through this work, our support team has gained a thorough understanding of the agency’s facilities, operations, and regulatory requirements. As one of the first tasks, our team conducted an inventory and analysis of the facility’s air emissions sources to determine whether and where Title V permitting requirements applied. We subsequently prepared the permit application and facilitated the permitting process with the regulatory authority, resulting in issuance of a Title V permit to the agency.

Since then, our team has provided recordkeeping and reporting support, including the submission of semiannual and annual compliance reports, as well as technical assistance to facilitate full compliance with Title V permit conditions. This work has included generating lists of equipment and processes subject to applicable air quality regulations and documenting necessary recordkeeping, reporting, and operational procedures to comply with Title V requirements. In parallel, our team has worked closely with the agency to identify and address any compliance issues, thereby minimizing compliance risk. We have also developed electronic compliance assistance tools for emissions sources and supported the integration of recordkeeping requirements with the agency’s facility management systems.