What is the General Permit Review Process?
Federal Operating Permits - Title V - Permit Revisions and Renewals
After initial permit issuance, changes at a site or changes in applicable requirements may result in the need to revise the Title V permit. Changes at a site may include:
- addition or removal of emission sources;
- operational changes; or
- changes to existing monitoring, reporting, recordkeeping, and testing requirements identified in the permit.
The applicable requirements may need to be changed due to one or more of the following reasons:
- promulgation of new state or federal regulations;
- changes to existing regulations codified in the permit;
- new NSR authorizations; or
- changes (alterations, amendments, modifications, etc.) to existing NSR authorizations.
GOPs
ATO revisions may be required if a site makes a change or if the executive director amends the underlying GOP, which requires individual ATOs to be revised. Additionally, ATOs must be renewed every five years.
Permit holders may operate a change included in a GOP application submitted to the executive director before the ATO is granted.
Please recall that the process for granting an ATO under a GOP is more streamlined than the process for issuing a case-by-case SOP. Likewise, the processing of an ATO revision or renewal is streamlined. Just as in the processing of the initial ATO, revisions and renewals are not subject to individual public notice and hearing requirements, affected state review, or EPA review.
SOPs
The procedures for revising an SOP can vary. There are three different types of SOP revisions:
- Administrative
- Minor
- Significant
In addition to the three types of permit revisions, there are some actions that only require notification. This means that the permit holder can make changes at the site without applying for a permit revision. There are two types of notifications: operational flexibility and off-permit changes.
More detailed information for each revision type, notifications, and other SOP issues (renewals and reopenings) can be found in the tabbed information below.
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