Landfill owners/operators must determine if their operation is classified as a major source of air pollutants under the 1990 Clean Air Act Amendments Title V Operating Permits Program. If a landfill operation is determined to be a major source, its owner/ operator will be required to apply for a Title V Air Permit from the state regulatory agency.
Title V is expected to be one of the most broadly applied regulations under the Clean Air Act. While application requirements and schedules for submittals will vary somewhat between states, the Title V Operating Permits Program brings new requirements to owners/operators of municipal solid waste landfill facilities. These air permitting requirements should not be confused with the requirements associated with the New Source Performance Standards and Emissions Guidelines for Municipal Solid Waste Landfills (NSPS).
To determine if their landfill operation is a major source, owners/operators must calculate facility emissions and complete an emissions inventory. The emissions calculations can be based upon actual sampling data or mass balances, or on the use of emission factors approved by the U.S. Environmental Protection Agency. If the calculations reveal that the operation is a major source of air pollutants, the owner/operator must submit a Title V permit application.
A major source is defined in three sections of the Clean Air Act:
States’ requirements to comply with the Title V Operating Permits Program may vary. For further information on air permitting requirements, schedules for submittals, or assistance in preparing emissions inventories, please contact:
Technical Bulletins are prepared by SCS Engineers to alert clients to potential issues which can affect their businesses.
