14.EAC - Process Operations - Because it is possible to use hundreds of different paints, solvents, catalysts, etc., for one or more products, it would be very burdensome to identify all raw materials by product. Is all of this information necessary?
The products should be grouped into representative or different product groups (topcoat, primer, stain, etc.). In the table for item 6, the worst case scenario for each group should be given.
15.EAC - Fuel Burning Operations - Annual average fuel consumption may not be available. How should this information be completed? Does this information need to be updated each year? Could a field inspector interpret this number as enforceable limit?
The company will have to make the best estimated possible for the annual average fuel usage information. The data will be used to calculate emissions and may be used as background information to check emission estimates reported by the company; therefore, this information should be for maximum expected fuel usage. For ash and sulfur content, a weighted average should be used. In no case will the information provided in the EAC forms be considered a limit for the emissions unit, unless Ohio EPA actually issues a permit that includes that limit. In general, the fuel usage information will not have be updated each year.
EAC - Solvent Cleaning - Is the information for average and maximum number of parts necessary?
How do we handle the situation of having an agitator in the unit, but not presently in use? We also have the situation where the recovery from cold cleaners is handled in groups. How do we handle this?
Ohio EPA has modified this form and no longer requires the average and maximum number of parts cleaned.
18.Is there a standard way to determine which EAC Form is applicable for a source?
If it is not obvious which EAC Form to use, the facility should contact the appropriate Local or District Office. The EAC Forms were formally known as appendices and have been required for State PTO applications for years, so most facilities should be aware which EAC forms are appropriate for a specific source.
19.Test Methods for Determining Compliance - Test methods for OC do not have ability to differentiate the OCs into specific HAPS. What methods does industry use to determine compliance with limits for HAPs?
Industry will have to estimate HAP emissions as best as possible and describe the method used in the Applicable Methods for Determining Compliance Field at the Facility Level Form - Applicable Requirements Tab.
What is the guidance for reporting throughput for standby equipment/sources?
A facility may not want to use worst case (8,760 hours/yr) to calculate the throughput for a standby source unless the facility feels they need that flexibility. If there are federally enforceable operating limits in a PTI for this equipment, the company should give worst case estimates within the limits of that PTI. If there are no such limits in the PTI, the company may choose to request operating restrictions in the Title V operating permit.