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Air Operating Permit Renewal Applications

Part 70 (Title V) Operating Permits, initial Federally Enforceable State Operating Permits (FESOP), and initial Minor Source Operating Permits (MSOP) issued by IDEM’s Office of Air Quality (OAQ) expire five (5) years after the issuance date of the original permit. Even if a permit has been amended or modified, the expiration date remains dependent on the original permit issuance date. FESOP and MSOP renewals may have a permit term of ten (10) years. Sources will have the right to continue to operate after the expiration of a permit if a timely and complete renewal application is submitted as follows:

  • Part 70 (Title V) Operating Permits and Federally Enforceable State Operating Permits (FESOP):
    • According to 326 IAC 2-7-4(a)(1)(D) for Title V and 326 IAC 2-8-3(h) for FESOP, a timely renewal application is one that is submitted nine (9) months prior to the date of expiration of the permit.
  • Minor Source Operating Permits (MSOP):
    • According to 326 IAC 2-6.1-7 (b), a timely renewal application is one that is submitted at least one hundred and twenty (120) calendar days prior to the expiration date of the MSOP.

Failure to Submit a Timely Renewal Application

326 IAC 2-7-10 states that the expiration of a Title V permit terminates the source’s right to operate unless a timely and complete application has been submitted consistent with sections 326 IAC 2-7-3 and 326 IAC 2-7-4(a).

326 IAC 2-8-9 states that the expiration of a FESOP terminates the source’s right to operate unless a timely and complete application has been submitted consistent with sections 326 IAC 2-8-3(h) and 326 IAC 2-8-7.

326 IAC 2-6.1-7 states that the expiration of a MSOP terminates the source’s right to operate unless a timely and complete application has been submitted.

How to Prepare a Renewal Application

In order to prepare a renewal application, applicants must comply with all the application requirements. There is more than one way to do this.

  • Option 1: Some applicants may prefer to fill out a completely new set of application forms. In addition, there is a Compliance Assurance Monitoring (CAM) requirement that may apply to Title V sources.
  • Option 2: Instead of completing a new set of application forms or otherwise compiling all the necessary information, an applicant may submit a streamlined renewal application.

All required forms are available on the IDEM Agency Forms page.

Streamlined Renewal Application

Instead of completing all the permit application forms or otherwise compiling all the necessary information, you may want to consider submitting a streamlined renewal application. To streamline the renewal application process, you may use a letter of intent to renew or other document to reference your current permit documents for the purposes of satisfying most of the application requirements of 326 IAC 2-7-4, 326 IAC 2-8-3, or 326 IAC 2-6.1-4. The application must meet all the rule requirements and be clear enough so that anyone reviewing the application has all the information needed to understand any reference to other documents. Each application should include the new signed application cover sheet, a current form GSD-01, and completed FED-01 form(s), if applicable. The federal Compliance Assurance Monitoring (CAM) rule applies to Part 70 permit renewal applications and may affect emissions units at your source. In order to process your renewal application as expeditiously as possible, IDEM requests that any changes in processes, materials, or emission units that could impact your permit conditions be included in your renewal application. Please include any information you have regarding new rule applicability or rule changes that could affect your permit conditions. A deficient application could result in delays in obtaining your permit. If additional information is required, OAQ will make this request during the permit development process.

The following items are the minimum for submitting a streamlined renewal application:

  1. A list of your current permit numbers,
  2. A new signed application cover sheet and current form GSD-01,
  3. Completed FED-01 form(s), if applicable,
  4. A list of exempt or insignificant activities that have been added to your source,
  5. A list of emission units that have been removed from your source, and
  6. CAM application forms, if applicable (Title V permits only; see the CAM page)

The preceding list assumes that you are not installing new significant units. You will need to provide appropriate information for OAQ to be able to permit those units.

How to Protect Confidential Information

All information submitted to IDEM will be made available to the public unless it is submitted under a claim of confidentiality. To prevent the public disclosure of confidential business information or trade secrets, applicants should mark the information and include a confidentiality claim with the submittal.

How to Submit the Renewal Application - Title V, FESOP, and MSOP

Mail or deliver one (1) signed hard copy of the original application packet to OAQ. Please do not send your application to any other offices or individuals at IDEM, as this will delay receipt and processing of your application.

Your source must also place a copy of the application packet at a public library in the county where your source is located (preferably at the local public library nearest to the source in the county where the source is located) no later than ten (10) days after submitting the application to IDEM. The GSD-01 instructions contain additional, detailed instructions about this requirement.

Please do not submit any payment with the application. OAQ will bill the applicant for any applicable permit fees at Public Notice. Please note that IDEM charges fees for each New Source Performance Standard (NSPS) or National Emission Standard for Hazardous Air Pollutants (NESHAP) that IDEM incorporates into a permit for the first time. The United States Environmental Protection Agency (U.S. EPA) has been issuing many new NSPSs and NESHAPs in recent years. If you are subject to a NSPS or NESHAP and that rule is not currently in your permit, IDEM will add it at renewal and you will be billed accordingly.

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