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Frequently Asked Questions on Title V

Overview on Policy Issues

The purpose of this appendix is to provide the answers to several questions asked by DAPC staff and the regulated community regarding Title V.

You can download a copy of this file in Word Perfect 6.1 format, the file name is policy.zip (61 K)

Title V

1. For applicability purposes, do you only include potential PM10 emissions or do you consider potential emissions for total suspended particulate (PM or TSP) to establish whether or not your facility is a 100 TPY major source for particulate?

You are to base Title V applicability determination on 10 and 2.5.

2. Does a source operation that meets the definition of a NSPS category or NESHAP category have to include their fugitive emissions for that source operation as required by category if the source is not subject to the NSPS or NESHAP requirement (i.e., was built before the federal rule was in effect)?

After consultation with USEPA, the source operation [emission unit(s)] that is included in a definition of the NSPS or NESHAP categories is required to include fugitive emissions even though the source might not have to comply with the particular NSPS or NESHAP standard because of an applicability date, etc. Remember this includes only those emission units (not the entire facility) for which the NSPS or NESHAP establishes requirements.

3.Does a facility that emits methane or ethane have to report these emissions as organic compounds?

Since methane and ethane can be emitted in large quantities and are not regulated under OAC Chapter 21, DAPC has determined that it will process fee reports at this time which do not include methane and ethane emissions. Our policy may change in the future, if methane or ethane emissions standards are adopted by a future federal or State air pollution control law or regulation.

4.If an emission unit has limitations that go beyond the SIP that result from a BAT determination in a PTI, are these federally enforceable to take advantage when determining the potential to emit?

If the PTI that established a BAT beyond the SIP allowable was issued as a direct final, then the BAT is not federally enforceable through the permit and the emisions unit can only take credit for control up to the SIP requirements. If the PTI was issued as a draft then final, DAPC considers those limiting conditions (operational and/or hourly emissions limits) to be federally enforceable through the permit.

5.Can "bottlenecks" in productions, physical limitations, or seasonal operation be considered when calculating the potential to emit?

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