DAQ-2018-003527

Department of
Environmental Quality
Alan Matheson
Executive Director
DAQ-2018-003527
GARY R. HERBERT
Governor
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
SPENCERJ. COX
lieutenant Governor
TO:
FROM:
GUIDELINES
Permitting Staff
Marty Gray, Permitting Branch Manager
DATE: April 30, 2018
SUBJECT: Title V Operating Permit Application Due Dates
Purpose
• This guideline clarifies that a source may begin construction and operation of a modification
following issuance of the NSR Approval Order (construction permit), and then have one year
from commencing operation ( or one year of the issuance date of the approval order for
modifications not requiring a physical change) to submit their Title V permit application for a
modification.
•
Implementation
The following scenarios explain the due dates for Title V Operating Permit applications:
#1 -New Greenfield Major Source:
Application due within one year of commencing operation.
#2 -Existing Minor Source Adding a New Emission Unit (which results in the source
exceeding a Title V applicability threshold):
Application due within one year of commencing operation of the new emission unit.
#3 -Existing Minor Source Modifying Existing Emission Unit (which results in the source
exceeding a Title V applicability threshold):
#3a -Source modifies an existing emission unit that does not require a physical
change:
Application due within one year of the issuance date of the modified approval order.
#3b -Source modifies an existing emission unit requiring a physical change:
195 North 1950 West• Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
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Application due within one year of commencing operation of the modified emission unit.
#4-Source Has an Existing Operating Permit (adds a new emission unit by approval order
issuance):
Application due within one year of commencing operation of the new emission unit.
#5 -Source Has an Existing Operating Permit (modifies an emission unit by approval order
issuance):
#Sa -Source modifies an existing emission unit that does not require a physical
change:
Application due within one year of the issuance date of the modified approval order.
#Sb -Source modifies an existing emission unit requiring a physical change:
Application due within one year of commencing operation of the modified emission unit.
Analysis and Authority
Applicability to the Title V Program, as written in R307-415-4, generally states that sources of air
pollution that emit greater than 100 tons per year of any criteria pollutant, 10 tons per year of any
single Hazardous Air Pollutant, 25 tons per year of combined Hazardous Air Pollutants, sources
subject to 111 of the Act (Standards of Performance for New Stationary Sources), or sources
subject to 112 of the Act (Hazardous Air Pollutants), are subject to the permitting requirements of
R307-415 and are required to submit an application for an operating permit.
As defined in R307-415-3, a source becomes subject to the Title V permitting program when the
sources potential to emit (PTE) exceeds the tons per year applicability threshold, and operation
commences or is capable of commencing at the major PTE levels.
As per R307-415-5a(l)(b), a source who modifies an approval order to increase a limit on an
existing piece of equipment, and that limit is currently included in their Title V permit, that source
would be required to modify their Title V permit prior to exceeding the current permitted limit.
This Guideline shall be audited once every five years by the Operating Permit section
manager to determine the current status and relevance of the information .