New Hampshire Air Permitting Issues

New Hampshire has a Title V permit program in place. The Title V Operating Permit applies to sources that have completed construction, started operation, and demonstrated compliance with all applicable air regulations. Title V Operating Permits are issued to sources or devices that were required to hold temporary permits and emit or have the potential to emit the following pollutants at the levels specified:

• 10 tons per year (TPY) or more of any one hazardous air pollutant;
• 25 TPY or more of any combination of hazardous air pollutants;
• 100 TPY or more of NOx for sources located in Belknap, Carroll, Cheshire, Coos, Grafton and Sullivan counties;
• 50 TPY or more of NOx for sources located in Hillsborough, Merrimack, Rockingham and Strafford Counties;
• 50 TPY or more of VOCs; or
• 100 TPY or more of any criteria pollutant (e.g., sulfur dioxide).

The State Permit to Operate applies to sources that have completed construction, started operation, and demonstrated compliance with all applicable air regulations. State Permits to Operate are issued to sources or devices that were required to hold temporary permits and: 1) are not subject to the Title V operating permit program, or 2) are choosing to limit their potential emissions to a level below the major source threshold that would trigger a Title V operating permit (called a “synthetic minor source”).

If the source is subject to new source performance standards (NSPS), maximum achievable control technology (MACT), national emissions standards for hazardous air pollutants (NESHAP), or acid rain control, a Title V Operating Permit may be required.