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16. Do "de minimis" emissions units, as described by OAC 3745-15-05, need to be identified in the Title V permit application under "Insignificant Activities"?

Yes. Ohio law was modified under Substitute House Bill number 715 to make this clear and consistent with Federal law.

17. If an emission is a volatile organic compound, but also a HAP, will enhanced monitoring be established only once the MACT is established or will it be required for Title V application?

It is USEPA's intention to include monitoring requirements in each MACT that will be sufficient to meet the enhanced monitoring requirements. Once the MACT has been established and is issued, you will need to include the monitoring requirements in your Title V application. If the MACT has not yet been developed, then you don't need to include enhanced monitoring requirements in with your Title V application.

Note: On April 4, 1995, USEPA again withdrew its proposed enhanced rules. We do not believe that enhance monitoring will need to be considered for the first round of Title V permits. (updated 4/12/95)

18. Where can I find examples of alternate operating scenarios?

An example of alternate operating scenarios would be a metal parts coating line (OAC rule 3745-21-09) that is currently operated but in the future you may want to coat plastic parts also (separate requirements under OAC rule 3745-21-07).

Note: Well written permits should negate the need for detailing alternate operating scenarios in order to allow for reasonable operational flexibility.

19. If a facility has more than one industrial grouping or standard industrial code (SIC) and only one group has enough emissions to be a major, can the other group be exempt from Title V application?

In most cases, the answer would be no. If the two groups are not completely independent then they would be considered one Title V source. In some cases, if they are completely independent operations (automobile manufacturing and furniture manufacturing, for instance), then they would be considered separate for Title V purposes. These questions should be discussed in detail with your Ohio EPA representative. Further, DAPC is currently working on written guidance that should clarify USEPA's past interpretation of these issues as they relate to federal new source permitting [identical facility (major stationary source) definition provided in the Title V legislation]. Engineering Guide #58 (guidance on defining the "facility") has been issued and is incorporated in the STARShip help menu.

20. How should federal applicable requirements be identified in Title V applications in Air Services?

Enough detail of the federally applicable requirement which is necessary to establish the current SIP requirement. Air Services provides a pick list of current state and federal regulations.Title V applicants will be responsible for understanding which federal requirements are applicable to their facility. Past OEPA permits should provide most of those federal requirements.

21. Will there be an expanded list of insignificant emissions units and activities? The costs and effort to quantify emissions from all minor activities would be significant.

Yes. Ohio EPA has developed engineering guide identifying recognized "trivial" activities that are so small (e.g., laser jet printers, aerosol spray paint cans, Xerox machines, white out bottles, etc.) that we do not expect them to be quantified and reported as insignificant activities on a Title V application. Engineering Guide #62 covers trivial activities.

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