This 13-hour course covers the basics of the title V permit
program from submitting a permit application through issuance
and resolution of challenges to the permit while also providing
a background on the underlying policy and legal foundation for
requirements. Upon completing the training, students will
understand the difference between application and permit
shields; regulated pollutants for purposes of fees vs. for
applicable requirements; inherent vs. non-inherent process
equipment; federally enforceable operating permit programs vs.
title v operating permit programs, and the difference between
periodic, enhanced and compliance assurance monitoring. Students
will gain an understanding of the importance of timely
reporting; handling confidential business information;
determining compliance using the Laxton Method vs. other
approaches to significant digits and considering credible
evidence in compliance certifications; crafting appropriate
“averaging” language; recognizing SIP gaps; addressing
affirmative defenses related to startup, shutdown, and
malfunction emissions; and writing permits to improve
readability and compliance. Relevant judicial and administrative
decisions will be reviewed in each topic area.
to review the brochure.