On May 11, 2012, MassDEP proposed to amend 310 CMR 7.00: Appendix C to add a GHG applicability threshold to the Title V Operating Permit program.  The amendment conforms to the EPA’s Tailoring Rule and establishes a GHG applicability threshold of 100,000 tons per year of CO2e and 100 tons per year of GHG mass basis.  Facilities that have current Title V Operating Permits and already exceed the GHG applicability threshold will not be required to revise their existing permits.  However, an estimate of the facility’s GHG emissions will be required with the submittal of the next Title V Operating Permit renewal application.  If a facility not currently subject to Title V exceeds the GHG emissions threshold, the owner must apply for an Operating Permit one year from the effective date of the regulation or one year from triggering the GHG applicability threshold. 

If you have questions about how this may affect your facility, please contact Wendy Merz, Managing Consultant at (610) 648-3858 or wmerz@trinityconsultants.com.