Increases in Permitted Emissions
Many of the Title V Operating Permits include increases in permitted emissions. Some of these are actual increases where the permittee has requested higher levels of production or installed new equipment. In these cases, LRAPA has required the business to address applicable rules prior to granting any increases in emissions. Other emissions increases, as well as decreases, in the operating permit do not represent an actual emission change but are a paperwork increase or decrease. Many of the paperwork increases result from the new permit including equipment that wasn't covered in the previous ACDP permit. The equipment may have always been operating at the site and meeting all applicable requirements; but unlike the new Title V Operating Permits, the ACDP didn't require all of the equipment to be included in the permit.
Paperwork increases also result from the new permit having expanded to include emission limits for all regulated air pollutants emitted by the devices and processes at the facility. The prior permit may not have included emission limits for all regulated air pollutants. Paperwork increases or decreases may also occur when corrections are made to information used to set emission limits in previous ACDP permits. In prior permits, emission limits were often based on estimated emission factors.
Testing & Measuring Emissions
In preparation for the Title V Operating Permit, many ACDP holders extensively tested and measured their actual emissions. This new information almost always leads to an increase or decrease in permitted emission levels. It does not allow an increase or require a decrease in allowable emissions. There is no change in the actual emissions from the business - the paperwork correction improves the accuracy of the permitted emissions.