What Are Title V Operating Permits?

If your facility emits enough air pollution to cross federal thresholds, you need a Title V Operating Permit to legally operate. This guide covers who needs one, how the permit process works, and what it takes to stay in compliance once your permit is issued.

Overview of Title V Operating Permits

In 1990, Congress authorized the U.S. EPA to require stationary emission sources to obtain an operating permit under Title V of the Clean Air Act Amendments (CAAA). These permits categorize emission sources as minor or major sources, depending on their annual emissions of key pollutants like NOx, SO2, and CO.

What does this mean for your facility?

• Major sources (100+ tons/year of criteria pollutants) face stricter monitoring and reporting requirements.

• Facilities must renew permits every five years and maintain compliance through continuous emissions tracking.

• If your permit requires hourly or minute-by-minute data, a Continuous Emissions Monitoring System (CEMS) is essential.

Who Must Obtain a Title V Operating Permit?

Several categories of facilities and emission sources are required to obtain a Title V Operating Permit.

Major Sources

Beyond the 100 tons per year threshold for criteria pollutants, a facility also qualifies as a major source if its potential to emit reaches:

• 10 tons per year of any single hazardous air pollutant (HAP)

• 25 tons per year of any combination of HAPs

Thresholds can be lower in areas that fail to meet national ambient air quality standards, known as nonattainment areas. A facility below these thresholds is considered a minor source.

Acid Rain Program "Affected Sources"

The Acid Rain Program (40 CFR Part 75) was created to reduce SO2 and NOx from fossil fuel-fired power plants. Any emission source subject to Acid Rain rules must obtain a Title V permit regardless of size, whether it qualifies as a major source or not.

Solid Waste Incineration Units Under Section 129

Clean Air Act Section 129 sets standards for solid waste incineration units. All units regulated under Section 129 are subject to Title V permitting regardless of size, including:

• Municipal waste combustors (large and small)

• Hospital, medical, and infectious waste incinerators

• Commercial and industrial solid waste incinerators

• Sewage sludge incinerators

• Other solid waste incinerators

Non-Major Sources Subject to NESHAP or NSPS

The National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Parts 61 and 63) and New Source Performance Standards (NSPS, 40 CFR Part 60) regulate air pollutants from stationary sources. Sources subject to these standards generally need a Title V permit even if they fall below major source thresholds, although EPA has exempted some area source categories in specific NESHAP subparts. Check the subpart that applies to your facility.

How Do I Obtain a Title V Permit for My Facility?

If your facility is required to obtain a Title V permit, start with your state or local air pollution control agency. The process generally follows these steps:

1. You submit a permit application, and the permitting authority prepares a draft permit.

2. The draft permit is opened to public comment for 30 days.

3. The permitting authority sends the proposed permit to EPA, which has 45 days to review it and object if it does not meet Clean Air Act requirements.

4. If EPA does not object, the public has 60 days to petition EPA to object.

5. If EPA objects, the permitting authority has 90 days to revise the permit and resubmit.

Once issued, the work shifts from obtaining the permit to demonstrating compliance with it.

How Do You Demonstrate Title V Compliance?

Your permit spells out exactly how your facility must prove it is meeting its emission limits. For most Title V sources, compliance comes down to three things: continuous monitoring, periodic testing, and reporting.

Continuous Emissions Monitoring

A CEMS paired with a Data Acquisition System (DAS) collects, validates, and stores the emissions data your permit requires, and generates the reports your permitting authority expects to see.

Stack Testing

Many Title V permits require periodic performance testing, commonly called stack testing, to demonstrate that emission units meet their permitted limits. Testing follows EPA Reference Methods (40 CFR Part 60, Appendix A) and typically covers pollutants such as particulate matter, NOx, SO2, CO, and volatile organic compounds. Facilities operating CEMS also need Relative Accuracy Test Audits (RATAs) to verify monitor accuracy under Part 60 Appendix F or Part 75. Test protocols, agency notifications, and final test reports all carry deadlines tied to your permit conditions, so scheduling matters.

Reporting and Recordkeeping

Title V facilities must submit monitoring reports at least every six months and an annual compliance certification signed by a responsible official. Any deviations from permit conditions must be reported promptly, and supporting records are typically retained for at least five years.

How Can Alliance Technical Group Help You Comply With Your Title V Permit?

Alliance Technical Group is a full suite provider for Title V compliance, from testing at the stack to the data and reports your permit requires:

• Stack Testing: As the largest stack testing provider in the U.S., Alliance performs the compliance tests, performance tests, and RATAs your permit requires.

• CEMS and DAS: Alliance offers a full suite of CEMS hardware and DAS software, including StackVision and the 8864 Data Controller, plus ongoing maintenance and support.

  
  

  StackVision helps run real-time emissions reports to meet air permit requirements. Managing different permit conditions across multiple sites is complex, but StackVision simplifies compliance by centralizing emissions data and automating reports.

As a full suite provider, Alliance also supports the reporting side of your permit, helping keep semiannual monitoring reports and compliance certifications on schedule.

Contact us today to learn how we can best support your facility.