The Virginia DEQ has recently begun processing Article 6 permits for new and modified “state major” sources (sources with a PTE greater than 100 TPY for any Article 6 regulated pollutant) in a different manner than in years past. Under their new guidance, a state major permit has to be issued for (1) new major stationary sources (for those with post-permit PTE over 100 tpy for any Article 6 regulated pollutant) not subject to Articles 8 or 9 (major NSR) and for (2) major modifications, where the application is for a project at an existing state major source and the project increase is above the significance amounts below, and the project is not subject to permitting under Articles 8 or 9 (major NSR) for that pollutant.
|Carbon Monoxide||100 tons per year (tpy)|
|Nitrogen Oxides||40 tpy|
|Sulfur Dioxide||40 tpy|
|Particulate Matter (PM)||25 tpy|
|Particulate Matter (PM10)||15 tpy|
|Particulate Matter (PM2.5)||10 tpy|
|Volatile organic compounds||40 tpy|
The main implications of this change are that such a project would now have the following requirements that it would not have had under a minor NSR Article 6 permit, followed by subsequent Title V modification (the way DEQ used to process this):
This change will not affect every Title V source, or every project at a Title V source, but will have a very substantial impact on those it does. For more information, please contact Jessica Gunter firstname.lastname@example.org or Chris Lampel email@example.com.