S T U D Y :

  1. Permits

  2. Plant Emisions

  3. Air Quality Permits

  4. Construction Permits

  5. Operating Permits

An ethanol plant or any other type of biofuels plant may also need to obtain an air quality operating permit. There are two types of operating permits: major source (federal program) and minor source (state program). Again, the potential emissions from the plant will determine whether a facility must obtain a major or minor operating permit.

Purpose: The federal operating permit program, known as the Title V program, was created by the Clean Air Act Amendments of 1990 and was designed to create a “one stop” permit. The Title V operating permit compiles all of the applicable state and federal regulatory requirements, existing construction permit provisions, and record keeping, reporting, testing, and monitoring requirements into one permit. The intention behind listing everything in one permit is to assist facilities with maintaining compliance. Often times, a facility will have several construction permits for several pieces of equipment and it is difficult to keep track of all of the requirements in each permit. One permit with all of the facility’s requirements is intended to make it easier to track the requirements.

Public notification is also an important aspect of the operating permit program. The public is notified when an operating permit is proposed and is given the opportunity to comment during the 30-day public notice period.

This gives the public the opportunity to become educated about the impacts that the facility may have on their environment.

Many states have implemented comprehensive operating permit programs for facilities emitting certain air pollutants. Several states have taken the operating permit program one step further than the federal Title V operating permit program. The federal program only regulates larger facilities (or major sources) of air pollution while some state operating permit programs regulate both larger and smaller facilities (or minor sources) of air pollution.

Unlike a construction permit that must typically be obtained prior to construction and is generally valid for the life of the emission unit, an operating permit must usually be applied for within some period, often 2 months, after the facility begins operation. The operating permit may be issued for a specific period of time rather than the life of the operating unit. Project developers should contact state regulatory officials to determine specific permit requirements for the proposed project.

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