Document and Permit Types

Facilities that emit air pollution above certain levels are required to have an air quality permit. Air permits are legally binding documents, written by DEQ, that include enforceable requirements that the owner/operator of the facility must comply with. Permits specify how facilities must operate pollution control equipment, the pollutant limits they must meet, and what records they must keep and submit to DEQ to show they are in compliance. Permit conditions get their authority from federal or state rules that have been adopted by EPA or by the Oregon Environmental Quality Commission.

 

Each permit receives a unique permit number that includes information on what type of permit it is. Title V permits, with the letters “TV” in the permit number, are for the highest emitting and most complex facilities. Standard “ST”, Simple “SI” and Basic “BS” permits are for smaller and less complicated facilities. Construction “CS” permits are for installation of new equipment at a facility. Short-term Activity “SA” permits are sometimes issued for special purposes, for example allowing a facility to use a temporary boiler while the main one is getting emergency repairs. General permits apply to a group of facilities in the same industry, such as gas stations or rock crushers. General permits have no letters in the permit number, and the 7th and 8th digits of the permit number indicate what type of general permit it is.

Most permits expire 5 years after they have been issued. A permit may be administratively extended if the facility applied for renewal on time and DEQ has not yet issued a renewed permit.

 

Some permits have attachments that contain enforceable permit conditions. This is one way to incorporate lengthy federal regulations into a permit.

 

When DEQ staff write a new or renewed air permit, they also write a review report. A review report is a background document describing the reasoning and calculations that went into the writing of the permit.

 

If a review report contains extensive tables of emissions calculations, the permit writer may put them into a separate document called an emissions detail sheet. Not all review reports have a separate emissions detail sheet.

 

If there are changes to the facility or to regulations that apply to a facility between permit renewal cycles, then DEQ may issue a permit modification to update a part of the permit. Complex permit modifications may have their own attachments, review reports or emissions detail sheets. When a renewed permit is issued, any previous permit modifications are incorporated into it.

 

At a facility that has a Title V permit, some types of small permit modifications such as facility ownership or name changes are called administrative amendments.

 

General permits apply to a category of facilities such as gas stations or rock crushers where all permittees are subject to similar requirements. When a new facility in one of these categories applies for a permit, DEQ sends them a letter called a general permit assignment sheet. This letter notifies the facility that the requirements of the general permit now apply to them. General permit assignment sheets are also sent when a facility’s ownership changes, or when the general permit itself is updated.

 

A few facilities in the dry cleaning and motor vehicle surface coating categories have an area source registration rather than a general permit. Facilities on an area source registration have lower annual permit fees but must comply with additional requirements not found in the general permit for their source category.

 

Most permits require that facilities send certain records to DEQ every year in the form of an annual report. For most facilities, annual reports cover operations during a calendar year, and are due in the following February. For example, a 2019 annual report would cover the facility’s operations between Jan. 1 and Dec. 31, 2019, and the facility would send it to DEQ by Feb. 15, 2020.

 

Air Toxics Emissions Inventory (ATEI)

In 2016, DEQ began requiring that facilities with Title V, Standard or Simple air permits report their emissions of 600+ toxic air contaminants. In some cases, additional information was requested to update or refine submissions. DEQ used this emissions information to prepare a facility-wide Air Toxics Emissions Inventory report for each facility. DEQ will continue to require that facilities submit updated air toxic emissions reports on a triennial basis, with the next report due in 2021. The reporting list of toxic air contaminants required by DEQ is available in Table 2 of the Cleaner Air Oregon rules.