We expect that most sources will need to follow the significant permit revision procedures to modify their Title 5 permits to include their initial Notification of Compliance (NOC). You can find these procedures in 40 CFR §70.7(e)(4) and 71.7(e)(3). Any change in monitoring terms and conditions that is considered to be significant must be incorporated into your Title 5 permit through the significant permit revision procedures. Since the initial NOC contains the emission standards, operating parameter limits and monitoring requirements that demonstrate your continued ability to comply with the Phase 1 HWC NESHAP, we consider incorporation of the NOC as a significant change. Applying the significant permit revision procedures also allows for a level of public involvement similar to that which would have been required under RCRA had we continued to regulate combustion emissions under that program. You should note that we plan to amend the permit revision procedures of part 70 and 71 in the future. Therefore, before submitting your request for a revision to your permitting authority, we recommend that you confirm that you are following the correct procedure.
For more information regarding modification of your Title 5 permit to incorporate the NOC parameter limits, see the NOC/Title 5 Interface Fact Sheet (PDF, 324 KB).
What type of modification process should I use to incorporate my initial NOC into my CAA Title 5 permit?
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