On September 23, 2019, the Dallas-Fort Worth (DFW) and Houston-Galveston-Brazoria (HGB) nonattainment areas were reclassified to “serious” nonattainment for the 2008 eight-hour ozone National Ambient Air Quality Standards (NAAQS). Therefore, major source threshold for Nonattainment New Source Review (NNSR) and Title V program are 50 tons per year (tpy) for nitrogen oxides (NOX) and volatile organic compounds (VOCs).
Any site that becomes subject to Title V program as a result of this redesignation must submit an initial Title V permit application by September 23, 2020. Therefore, it is important to assess whether your site is subject to the Title V program. Trinity recommends the following in order to ensure compliance:
- Prepare sitewide emissions summary/potential to emit (PTE) based on all construction permit authorizations (i.e., New Source Review, Standard Permit, and Permit Rule authorizations)
- Confirm permits are representative of the current operations
- Determine NSR permitting actions that need to be completed to confirm major source status prior to submitting the Initial Title V permit application (e.g., permit alteration to void or remove inactive emission sources)
- Determine potentially new applicable requirements as a result of becoming a Title V source
Trinity can assist you with these tasks and also evaluate options available to reduce PTE below Title V major source thresholds, or if your site is major, prepare the initial Title V permit application.