Generally, a facility can not consider these types of limitations unless they establish federally enforceable conditions in a State permit. However, potential to emit under certain circumstances can be bizarre. A strict interpretation can have extremely small air emitting facilities subject to the program. Therefore, common sense needs to be used. If a company actually emits very small quantities of emissions (less than 20 tons for any regulated non-HAP pollutant or less than a 2 tons for any HAP, or less than 5 tons for all HAP's collectively), then Ohio EPA considers the facility a minor that does not require a Title V permit or a PTO with federally enforceable conditions (synthetic minor).
See Engineering Guide #61.
6. What is the appropriate method for calculating potential emissions for VOC's and/or OC's from a coating line employing equipment such as spray guns. Since theoretically it is possible to continuously spray coating, should this be how "potential to emit" for these operations be determined?
"Potential to emit" for the purpose of determining Title V applicability for coating operations should be quantified in accordance with methods and procedures described in Engineering Guide #45 (PDF).
7. The Ohio EPA has launched "Air Services" online as of June 30, 2008. Will the Title V software allow the printing of a copy of the Title V application?
Yes. The software does have this capability to print all aspects of the Title V application including the emission category forms. The system will also print the fee emission report forms and the emission statement forms.
8. How should trace quantities of Hazardous Air Pollutants (HAP) be identified and quantified? For instance trace quantities (<0.1%) of HAPs are present in coating manufacturer's raw material but are not listed on any material safety data sheets (MSDS). With analytical capabilities at the ppb level, trace quantities of many HAP solvents will be in industrial grade solvents.
You should make a worse case estimate of the amount of HAPs in your coatings or material. If this estimate shows that the maximum amount of these HAPs is negligible compared to the HAPs threshold levels (10 tons/year for each HAP and 25 tons per year for combined HAPs), then that is all you have to do. Upon request by Ohio EPA, you need to provide the data to support your conclusion that you do not trigger the HAPs threshold.
If your evaluation of emissions shows that it is possible to exceed the threshold levels, then you should either get more information on the composition of the coatings from the supplier or you should do your own testing on the components of the coatings.
If you are a Title V facility and you have emission units with trace quantities of HAP's, these emission units would be considered insignificant for HAP's if the total potential HAP's for the emission unit is less than one ton.
9.Will maximum available control technology (MACT) early reduction commitments be applicable requirements?
Yes. These requirements are commitments made by companies to give them more time to comply with a proposed MACT standard.
10. How many tons per year can we put on a grandfathered (pre 1974 construction) reasonable available control technology (RACT) emissions unit?