Permitting Guidance for Title V & Title IV Renewal Applications

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Permitting Guidance for Title V & Title IV Renewal Applications

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PERMITTING GUIDANCE

DATE:April 4, 2014

TO:Title V and Title IV Permittees

THROUGH:Ted Schooley, Permit Program Manager

Joseph Kimbrell, Major Source Permit Specialist

FROM:Cember Hardison, Acting Major Source Permit Manager

SUBJECT:Guidelines for Title V Operating and Title IV Acid Rain Renewal Applications

TITLE V SOURCES

Title V Operating Permit Renewal Deadline:

Title V Operating Permits expire every 5 years. Operating Permit Renewal Applications must be submitted by the permittee to the Air Quality Bureau (AQB) twelve (12) months before the date of expiration of the last new Title V operating permit or the last renewal Title V operating permit. Please refer to 20.2.70.300.B.2 NMAC for this regulatory requirement. Title V Significant Modifications or Minor Modifications do not re-start the 5 year renewal clock.

Complete Application:

The renewal permit application must not only be “timely” but must be COMPLETE. Please refer to 20.2.70.300.A, C, and D NMAC to determine the regulatory requirements for complete applications.

A complete renewal application is one that includes:

  • all information required by the Universal Application form unless that section specifically states that it does not apply to 20.2.70 NMAC,
  • all information required by 20.2.70.300.D & E NMAC, and
  • enough information about each source, including regulatory citations of any NSPS or NESHAP emission standards, to allow the AQB to determine all applicable requirements that apply (see 20.2.70.300.D((7) through (9) NMAC).

Internet address to the State of New Mexico Title V regulation 20.2.70 NMAC:

ACID RAIN SOURCES

Acid Rain Permit Renewal Deadline:

Acid rain permit application renewals must also be submitted to the AQB twelve (12) months prior to the date of expiration of the existing Acid Rain Permit, pursuant to 20.2.70.300.B.2 NMAC.

Please note that the expiration dates for the Title V operating permit and the Title IV acid rain permit may not necessarily be the same. The AQB typically tries to sync the operating permit and acid rain permit expiration dates. If they are not synced, the permittee may submit the Acid Rain renewal application earlier than required so that it may be submitted with the Title V operating renewal application. This will cause the expiration dates to be the same for the two new permits.

For the portion of the Acid Rain source subject to the acid rain provisions of Title IV of the Federal Act, the permittee must submit a COMPLETE acid rain permit application renewal (in triplicate) to the Department. Each application must be signed and certified by the company’s DESIGNATED REPRESENTATIVE. Failure to submit a complete acid rain permit application renewal on time is a violation of the Federal Act.

See the Air Quality Bureau Website for the Acid Rain permit application form and instructions.

Permitting Guidance for Title V & Title IV Renewal Applications

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