Q. What types of Title V permit revisions can a facility make?

A. Federal regulations specify several different types of permit revisions that facilities might need to make to their Title V permits. Depending on the nature of the proposed permit change, the change will be classified as one of the following types of revisions and will require a facility to submit an application for the permit revision:

Administrative permit amendments

An administrative permit amendment is a permit revision that:

• Corrects typographical errors;
• Identifies a change in the name, address, or phone number of any person identified in the permit or provides a similar minor administrative change at the source;
• Requires more frequent monitoring or reporting by the permittee;
• Allows for a change in ownership or operational control of a source if the permitting authority determines no other change needs to be made to the permit and provided that a written agreement for transfer of permit responsibility has been submitted to the permitting authority;
• Incorporates the requirements from preconstruction review permits authorized under an Environmental Protection Agency (EPA)-approved program; or
• Incorporates any other type of change the EPA has approved.

The facility submitting the request may implement the changes proposed in the request immediately after submitting the request to the permitting authority.

Permit modifications

A permit modification is any revision to a Title V permit that doesn’t qualify as an administrative permit amendment. Permit modifications may be considered either minor or major (significant).

Minor permit modifications are those that:

• Don’t violate any applicable requirement.
• Don’t involve significant changes to existing monitoring, reporting, or recordkeeping requirements in the current permit.
• Don’t require or change a case-by-case determination of an emissions limitation or another standard, a source-specific determination for temporary sources of ambient impacts, or a visibility or increment analysis;
• Don’t seek to establish or change a permit term or condition for which there’s no corresponding underlying applicable requirement and that the facility has used to avoid an applicable requirement that would otherwise apply (such as a federally enforceable emissions cap or an alternative emissions limit).
• Aren’t considered modifications under Title I of the Clean Air Act (CAA).
• Aren’t required by a state program to be processed as a major/significant modification.

A source may make the change proposed in its minor permit modification application immediately after it files the application.

Significant permit modifications are those that don’t qualify as minor modifications or administrative amendments. States must provide criteria for determining whether a proposed permit change is considered significant. At a minimum, every significant change in existing monitoring permit terms or conditions and every relaxation of reporting or recordkeeping terms or conditions will be considered significant.