They could very well be. Most Title V permits have an open period in which the public can submit questions and objections to the permit.
This is where I used to get crazy with the environmental groups as there was no amount of compliance that was sufficient for them. Even if you met the compliance regulations, they would still object.
Well it sounds to me like the EPA is using the “citizen petition” crap to deny the extension or fast permitting. The PDF just says “two citizen petitions filed with the EPA, dated August 28, 2009, and January 5, 2009.” I haven’t found those petitions on the EPA website and have no idea if they keep them there. What is interesting though is the Green groups bragging about how they are going to stop the refinery with this convoluted process. It is also interesting that the plant in question is owned by Koch which is accused by Greenpeace of climate denial funding. I think this is an intentional and deliberate first strike by Obama’s EPA goons to shut down CO2 via the back door, pretending that there are pollution point sources that pass Texas’ standards (they use facility-wide regulation). In reality they just want to shut it down by using Texas’ own logic that point sources don’t matter to climate change, just the totals.