Missouri Air Permitting Issues

Written October 17, 2019

All facilities in Missouri are required to obtain an operating permit, either a Basic State Permit, or a Part 70 Title V Permit. 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 of a combination of HAPs are required to apply for a Title V permit. The state's program does contain provisions for a synthetic minor designation. Synthetic minors are those facilities that agree to federally enforceable limits that restrict their potential to emit to less than the major source threshold.

The state's program includes the option of obtaining a general permit. A general permit is a permit issued to a group of similar sources. This permit program replaces the state operating permit program. Facilities with the potential to emit less than 40 tons of VOCs; or 10 tons of one hazardous air pollutant; or 25 tons of a combination of hazardous air pollutants are not required to obtain a permit. This applies to installations of new presses as well. No construction permit is required if potential emissions of the entire installation are less than regulatory de minimis levels or potential emissions of the proposed project are below the insignificance levels.