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Appendix B Group 11/30/95 thru 03/28/95(1) Appendix C Group 03/29/95 thru 09/29/95(1)

Facilities located in the Appendix A or B groups could request in accordance with the requirements of OAC rule 3745-77-04(B)(4) up to a 90 day extension for submitting their Title V application.

29. What terms and conditions from OEPA issued PTI's are applicable requirements that must be specified on the Title V application?

In Ohio's program, federally enforceable PTI terms and conditions are applicable requirements. Therefore, PTI's that were first issued as a draft and then final will contain federally enforceable terms and condition. SIP-based requirements (e.g., BAT limits) are also considered applicable requirements.

30. Described below are a number of helpful documents associated with Title V or FESOP permitting that you may be interested in obtaining from DAPC's computer :

Engineering Guide #58 issued final on 3/31/95 provides assistance with establishing what constitutes a "facility" which is imperative for assessing Title V applicability.

Engineering Guide #61 provides assistance on calculating potential to emit and whether or not a FESOP or Title V permit will be required.

Engineering Guide #62 identifies "trivial activities" that will not have to be inventoried and considered for Title V applicability nor listed as an insignificant activity on the Title V permit application.

Engineering Guide #63 identifies when a Title V application must be updated and submitted to Ohio EPA. NOTE: Change in a federally required information field. Engineering Guide #63 has been replaced by New Guidance <http://www.epa.state.oh.us/dapc/title v/tvrevguide.pdf> (6/3/03)

FESOP guidance document provides detailed instructions for how to apply for a FESOP permit (which limits a facility's potential to emit with federally enforceable conditions in an OEPA permit to operate in order to avoid Title V permitting).

31. Can facilities that are subject to the MACT be eligible for a FESOP?

USEPA accepted our FESOP SIP with the provision that allows the state to restrict HAPS; however, some of the source categories (i.e., chrome plating and degreasers) USEPA has decided they must be Title V. Ohio's program of electronic submittal for the Title V applications did not anticipate that small emitters would have to file. The small business technical assistance program, supervised by Rick Carleski should be able to assist some facilities. Other MACTcategories remain open as to whether or not they will automatically have to have Title V permits. For more information facilities should contact their District Office or Local Air Agency.

32. What kind of monitoring requirements are going to be required (ex. asphalt plants with baghouses)?

This issue will be addressed in a future Engineering Guide. First, it is the facility that proposes how they will demonstrate compliance with the applicable requirements. By the time they go to file the Title V application, there will be a "library" established where they can find the various options for monitoring for each type of control equipment or source category. For example in the case of a baghouse, it could be as simple as recording the differential pressure, use of triboflows, visible emissions taken by the company, or as complicated as an approved O & M plan (using the 1993 guide) and relying on a continuous opacity monitoring system for demonstrating ongoing compliance. If it is a federally enforceable limit that they are

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