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Non-Title V Operating
Permits
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Information on obtaining
Title V permits |
Who Needs A Non-Title V Operating Permit?
A non-Title V (also referred to as synthetic-minor or minor) Operating Permit is required of companies that have operations involving a non-major air contaminant source. These companies include facilities with the potential to emit less than 10 tons per year (tpy) of any hazardous air pollutant (HAP), or less than 25 tpy of any combination of HAPs, or less than 100 tpy of any regulated air pollutant (TSP, SO2, VOC, CO, NOx, and Pb).
What Information Must I Provide?
All applicants must submit a Non-Title V Operating Permit Application. The following information is needed to complete the application:
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Facility identification information
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Description of processes and products, including process flow
diagrams
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Emissions of regulated air pollutants, including sample emission calculations
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Fuels, fuel use, raw materials, production rates and operating
schedules
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Information on air pollution control systems
Data must be provided for both normal (actual) and projected maximum (potential) operating scenarios.
Application for a non-Title V operating permit must be submitted in accordance with the following schedule:
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Not less than 60 days prior to the expiration date of an existing
operating permit
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Not more than 30 days after the initial startup date of an air
contaminant source for which a construction permit has been issued.
If stack sampling has been required as a condition on the construction
permit, an application must be submitted within the time specified on
the construction permit and include the results of that testing.
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Minor Sources Application Forms |
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Form Description |
Form # |
Application Form |
Form Instructions |
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.pdf |
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.pdf |
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Index of Forms |
APC Index |
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Permit Application - General Information |
APC-2-01 |
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Process or Fuel Burning Source Description |
APC-2-02 |
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Emission Point Description |
APC-2-03 |
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Incinerator Source Description |
APC-2-04 |
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Storage Tank Description |
APC-2-05 |
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Surface Coating (Non-Printing) Description |
APC-2-06 |
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Printing Description |
APC-2-07 |
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Oven/Dryer Description |
APC-2-08 |
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Degreaser Description |
APC-2-09 |
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Asphalt Plant Source Description |
APC-2-10 |
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Rock Crushing Plant Source Description |
APC-2-11 |
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Concrete Batch Plant Source Description |
APC-2-12 |
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Coal Preparation Plant Source Description |
APC-2-13 |
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Perchloroethylene (PERC) Dry Cleaner Description |
APC-2-14 |
N/A |
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Cyclone Description |
APC-2-20 |
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Proposed Schedule of Corrective Action |
APC-2-30 |
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What Fees Are Required?
Application Fees: Permit Renewal: none; Permit Modification: $130.00 to $600.00 per permit
Annual Permit Fees: $65.00 to $200.00 per permit
Annual Emission Fees: Non-Title V sources are required to pay annual emission fees for each ton of regulated air pollutant except carbon monoxide. The fee is based on actual emissions. For the accounting year 2006, emission-based fees were $27.00 per ton of allowable hazardous air pollutants and criteria air pollutants, excluding carbon monoxide.
The fee rate is reviewed annually by the Shelby County Air Pollution Control Board. The Board then makes a recommendation on changes to the County Commission.
Stack Sampling Fees: $130 to $660 when stack testing is required
How Will My Application Be Processed?
The Section generally processes the applications for operating permits in the order in which they are received. During the application evaluation process, the applicant may be requested to submit additional information. In addition, a site inspection may be conducted to assess the compliance status of the emission source prior to the issuance of the operating permit. Depending on the complexity of the emission source, a draft permit may be prepared and sent to the applicant for review before the final operating permit is issued. The normal duration of an operating permit is five (5) years. Depending on the workload, it generally takes 30 to 180 days for the Section to process the application for an operating permit.
What Are My Rights And Responsibilities After The Permit Is Approved?
At least one operating permit must be prominently and conspicuously displayed on the operating premises. The air contaminant source must be operated in accordance with the terms of the permit. An operating permit is not transferable from one owner to another. Any modification to the source requires a construction permit.
Non-Title V permit holders are responsible for record-keeping, monitoring, and reporting as required in the operating permit, and submitting annual actual emission reports.
The non-Title V permit holders have the right to appeal a permit condition by filing a petition for reconsideration of the permit condition. The petition for reconsideration of permit conditions must be delivered to the Pollution Control Section within 30 days after the mailing date of the permit.
What Are The Section's Rights And Responsibilities After The Permit Is Approved?
The Pollution Control Section is responsible for protecting Shelby County's air quality. Requiring a Source (or a business) to obtain an operating permit ensures that any existing, new, modified, replaced or relocated Source complies with all air pollution emission standards and will not have a detrimental impact on human health or the environment.
The Section has the right to conduct routine inspections as deemed necessary. The Section may suspend or revoke any operating permit if the permit holder fails to comply with the provisions, stipulations or compliance schedules specified in the permit. The Memphis Shelby County Air Code provides for civil penalties of up to $25,000 per day for each day of violation.
Who Do I Contact For Applications, Assistance And Other Information?
For air contaminant sources located in Shelby County, the applicant must contact and obtain a permit from the Pollution Control Section.
In addition, applicants may call the following centers for assistance:
(Click on title for more information)
Applicants may refer to the following publications for further information:
- TN Dept. of Economic and Community Development: Air Permitting of Industrial Facilities in Tennessee
- Memphis Shelby County Air Code
- Memphis City Air Code
- 40 CFR §60: Standards of Performance for New Stationary Sources
- 40 CFR §61: National Emission Standards for Hazardous Air Pollutants
- 40 CFR §63: National Emission Standards for Hazardous Air Pollutants for Source Categories
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