22. How should a facility determine the potential to emit for HAPS?
Generally, this has to be done on a case-by-case basis. In the example of painting operations, HAPs limits would be based on VOC limits assuming all VOC is one or more HAP and assuming the VOC limits are federally enforceable. This would be true unless specific HAPs limits were listed in a permit. USEPA is expected to provide more guidance in this area.
23. Are Emergency Episode Plans (under OAC rule 3745-25) applicable requirements?
Yes. However, Ohio EPA has developed Engineering Guide 64 negating the need to have this plan on file or identify this requirement on your Title V application at this time. USEPA has determined that this Engineering Guide will be acceptable to them.
24. How is the Ohio EPA communicating with its districts in regard to facilitating plants which desire to pursue synthetic minor status, and therefore, have several PTI's (or PTO's) to submit. For example, the federally enforceable limits will be based on the maximum emissions stated when there isn't a SIP provision? Can the EPA and the facility discuss monitoring options prior to the permit issuance?
The Ohio EPA has provided training to the District and Local staff concerning synthetic minors and Title V. It is recommended that facilities desiring synthetic minors talk to their field representative about their situation before applying for the permits. Field representatives can give guidance on the best method of restricting potential emissions to avoid Title V. They can also discuss the monitoring or record keeping that will be needed.
25. If a facility wants to avoid Title V by restricting their potential emissions, should they use the permit to install process or the permit to operate process?
It is recommended that facilities use the permit to operate process. The only time this is not recommended is if the facility discovers emissions units which should have had a permit to install but didn't or they wish to restrict an emission unit which has not been constructed yet. In this case, a permit to install should be processed.
26. Is there going to be a help line to help Ohio industry with the Title V rules?
You will be able to get guidance from the field offices. Also, there is significant information on the DAPC web pages and the Agency "Answer Place", http://ohioepa.custhelp.com that you can review before contacting the appropriate DO/LAA.
27. Does a facility which becomes a synthetic minor need to do any reporting to demonstrate this status? In other words, how will the Ohio EPA know that a given facility is a synthetic minor facility and, therefore, doesn't need to apply for a Title V permit or pay the Title V fees?
Chapter 3745-78 requires the larger non-Title V facilities to report their potential emissions every two years to establish that they are not Title V. We recommend that your company share its potential to emit analysis with the appropriate DO/LAA. This should minimize the risk of an inadvertent mistake.
28. When will my Title V permit application be due?
Ohio obtained full approval from USEPA that will be effective on 10/01/95. Therefore, the schedules provided in OAC rule 3745-77-04 were initiated on this date. Therefore, facilities were required to file their Title V applications within the time frames specified below: