Emissions units installed before 1974 are not required to obtain permits to install (unless they are modified). As such, they typically don't have ton per year limits established. Instead, they typically have a short term limit established through existing Ohio rules (RACT). The annual emissions from these emissions units are only limited by the maximum capacity of the emissions unit. This can result in very large federally enforceable potential emissions.
If your actual emissions for your facility is under the Title V thresholds, then you can avoid Title V requirements by requesting restrictions on your potential emissions. This is done by requesting the issuance of a permit which restricts your operations and thereby restricts your potential emissions. This process is called a synthetic minor permit. Instructions on how to do this are contained in separate guidance from the Ohio EPA.
11. Are best available technology (BAT) requirements from Ohio EPA permits to install federally enforceable for emissions units which would otherwise be exempt under Ohio's new permits rule (e.g. throughput limits, operating hour limits, record-keeping requirements)?
The Ohio permit rules and Ohio law were modified in late-1993 and early-1994 to add many small emissions unit exemptions and de minimis exemptions. Under these exemptions, no permit to install or permit to operate is required today. However, in the past, these emissions units needed permits. BAT limits established under these permits are considered "applicable requirements" pursuant to Title V requirements and are also separately, federally enforceable through the permit if the permit to install was issued as a draft permit. If this is true, then these limits are federally enforceable.
Note: Under these exemptions provided by Ohio law, these small emission units emissions must be counted towards Title V applicability. Also, if you are a Title V facility, these exempt emission units must be identified as insignificant activities on your Title V application.
12.Would Ohio EPA oppose legislative action which would revoke permits for small emissions units now exempt from Ohio permit rules?
Yes. Ohio EPA sees no advantage in this kind of legislation. Most of these emissions units are on registration status which requires no action by facilities to maintain. For those on permit status (for which a BAT has not been established that limits the emission unit to under the 10 lbs/day cutoff), facilities do not need to renew the permits. Instead, when the permit comes up for renewal, they must notify the Ohio EPA that their emissions unit qualifies for the exemption. At that time, the Ohio EPA will revoke the permit.
13. Do we need to make a roof drawing of all our vents and stacks?
You are not required to submit a roof drawing with your Title V application. All that will be necessary is for you to provide process flow diagrams for each emissions unit. You will have several different software options to prepare the process flow diagrams. (See STARShip question # 43)
14. Do we calculate particulate matter less than 10 microns (PM10) or total particulate matter (PM)?
This depends on the regulations which apply to your emissions unit. In most cases, you will need to do PM. But in some cases you will need to include the fraction which is PM10 and/or PM2.5.
15. If your emissions unit is an new source performance standard (NSPS) type emissions unit, but is not NSPS because of the date it was built or because it is lower than the thresholds listed in the NSPS, do you count fugitive emissions when determining if you are a major source?
Yes. If the emissions unit is a NSPS type emissions unit, then you must count fugitives.