Printech Archive
Re: Title V permit consultant costs

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Date: Sun Apr 09 2000 - 20:09:12 CDT


The answer to your question is not necessarily an easy one. The cost of
"Title V" compliance can vary, depending upon the type of permit that is
needed. If the printer's potential emissions are close to or have exceeded a
100 TPY threshold, but the actual emissions are much less, then a Title V
permit may not be necessary. The printer may be able to obtain a Federally
Enforceable State Operating Permit (FESOP). These permits go by different
names, but they limit the "potential" emissions by imposing federally
enforceable limits.

At the heart of the issue is how are the potential emissions being
calculated? There is no set methodology approved by EPA. However, EPA did
issued a policy statement that stated if a printer's actual emissions are
less than 50% of the major source threshold (50 TPY in this case), then they
can't emit enough to qualify as a major source. This 50% rule is subject to
state approval and the April 1998 EPA memo is available on the PNEAC web

Regarding pricing, printers have paid from as little as $5,000 to $50,000
depending upon the size of the operation, type of printing equipment, other
activities occurring at the facility, boilers, paper handling equipment etc.
Another factor is the state forms that need to be completed. Some are not as
complex as others. The last factor is the amount of negotiation that is
required with the draft permit. I would plan for at least one site visit.

Please call me if you want to discuss these issues any further.

Gary Jones
Graphic Arts Technical Foundation
200 Deer Run Road
Sewickley, PA 15143
412/741-6860 x608 - Phone
412/741-2311 - Fax

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