Kentucky Air Permitting Issues

The state does have a Title V permit program in place. Sources with the potential to emit more than 100 tons of VOC per year, or 10 tons of one hazardous air pollutant (HAP) or 25 tons a combination of hazardous air pollutants are required to apply for a Title V permit. The state's program does contain provisions for a synthetic minor designation. These sources are referred to as Conditional Major Sources. These sources are facilities that agree to federally enforceable limits that restrict their potential to emit to less than the major source threshold. If the facility potential emissions are less than any of the following thresholds, then no permit is required: 2 tons per year of any one hazardous air pollutant (HAP); 5 tons per year of any combination of hazardous air pollutants; 10 tons per year of any other regulated air pollutant (RAP), including VOCs; and the source is not subject to a NSPS or NESHAP.

Registration is required if a facilitys potential emissions fall within any of the following: If the facilitys potential emissions fall within any of the following categories, then a state origin permit is required:

• > 2 but < 10 tpy of a HAP
• > 5 but < 25 of combined HAPs;
• > 10 but < 25 tpy of a RAP subject to an applicable requirement that does not specify the method of compliance;
• > 10 but < 100 tpy of a RAP subject to an applicable requirement that specifies the method of compliance;
• > 10 but < 100 tpy of a RAP that is not subject to an applicable requirement; or
• If the source is subject to a NSPS or NESHAP.
• < 10 tpy of a HAP;
• < 25 tpy of combined HAPs; and
• > 25 but <100 tpy of a RAP subject to an applicable requirement that does not specify the method of compliance.

Jefferson County does contain its own set of regulations:

• All sources emitting VOCs in quantities equal to or greater than 100 tons per year and all Control Technique Guidance (CTG) sources emitting VOCs in quantities of 25 tons or more per year or some lesser applicability amount as defined in the specific CTG regulation shall maintain daily records and calculations that demonstrate daily compliance with the VOC emission standards defined in the applicable portions of Regulation 6 or 7.