22. Product at Standard Conditions - Information for the product at standard conditions (68 degrees F and std pressure) is requested. However, for molten metal, should we define the physical state at standard conditions or the conditions it is produced?
There are certain rules where applicability is based on the state of materials at standard conditions. The field for "State at Standard Conditions" should be completed for standard conditions, not operating conditions.
23. Most of the information on the EAC forms is State-only required. The EAC forms should be identified as "state only".
This issue is addressed in detail in Engineering Guide #59.
If data for control equipment such as operating control efficiency and installation dates is requested
but not available, how should the requested be addressed?
The company should have a reasonable idea of what the control efficiency is for specific equipment. If not, the company may use the design control efficiency. For any installation date before 1974, the company should give a best estimate. The Help will make it clear that for any date prior to 1974, only an estimate is required. The comment "installation date is estimate" can be made in the comment field if this is the case.
26.Two options should be added to the picklist - Marble and Rod Bed Scrubbers. What if there is no water-to-air ratio for these scrubbers? What should be the pH be for these scrubbers?
These two options will be added to the picklist. N/A should be entered into the pH field and the water-to- air ratio field should be left blank in this case.
27. Why does Ohio EPA ask for information not required by chapter 77? For example, in the EAC form for storage piles, Ohio EPA requests the trade name of chemical suppressants and the EAC form for roadways requests information on oil characteristics (PCB, Hazardous Waste).
Some of this information is considered State-Only required information. Draft Engineering Guide #59 specifies which information is State only. Ohio EPA will continue to look at information in EAC forms to determine if it is needed.
28. Can several separate emitting operations be grouped as an emission unit? For example, at a steel mill, can the emissions from the combustion stoves and iron tapping be grouped together as a blast furnace emission unit?
The same criteria used to define a source currently, would be used to define emission unit. See Engineering Guide #25 for Assistance.
Ohio EPA should clearly state what forms are required to be submitted by facilities and what fields
within all forms are required for each form. This should be addressed in the users manual.
The online help and QA checks at validation identify which fields are required for the different type of submissions. On some of the fields in the EAC forms, the operation determines whether the field is required or not required. It will not be possible to specify all of these situations. The applicant should contact their local or district office for clarification in those situations.